The Moscow Murders and More

The USVI And Ther Motion For A Partial Summary Judgement Against JP Morgan (Parts 1-3) (12/30/24)

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.

to contact me:

bobbycapucci@protonmail.com

source:

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

At Arizona State University, we're bringing world-class education from our globally-acclaimed faculty to you, ranked number one in innovation for 10 consecutive years, and number two among public universities for employability. ASU isn't just ahead of the curve, it's creating new paths to success. Earn your degree from the nation's most innovative university. Online, that's a degree better. Explore more than 300 undergraduate graduate and certificate programs at asuonline.asu.edu. What's up, everyone, and welcome back to the Epstein Chronicles. In this episode, we're going to dive right back into the court documents, and we're going to start taking a look at the USVI and their memorandum of law and support of motion for a partial summary judgment. Case number 122-CV-10904-JSR The government of the United States Virgin Islands, memorandum of law and support of motion for a partial summary judgment. In July of 2006, after his arrest for felony sex crimes and extensive news coverage detailing unlawful sex acts with underage girls, Jeffrey Epstein, admitted to James, Jess Daly, then asset and wealth management, AWM, who reported it to Mary Erdos, then CEO of Global Bank, that he engaged in sex acts with multiple young women for money, only denying the girl's ages. At that time, J.P. Morgan could have immediately exited Epstein but the bank knew from Douglas Sandy Warner when he was head of J.P. Morgan, Epstein is one of the most connected people I know in New York. In 2003, Epstein was, by double, the top revenue generator in the private bank and the source of Google co-founder, Sergey Brin, one of the largest relationships in the private bank of four plus billion dollars. Glenn Dubin, billionaire founder of Hybridge, and many other ultra wealthy clients and connections, which would come to include Bill Gates, Leon Black, Larry Summers, the Sultan of Dubai, Prince Andrew, Ehud Barak, Thomas Prischer, Lord Peter Mandelson, and Prime Minister Netanyahu. In 2004, Epstein, together with Jamie Dimon, then CEO and waiting, was an integral part of J.P. Morgan's game-changing acquisition of Hybridge. The next year, redacted, Epstein was too big to fail. So, J.P. Morgan did not exit Epstein in 2006 or 2007 or 2008 or 2009 or 2010 or 2011 or 2012 or the first half of 2013, redacted. And even after his exit right up until his arrests in 2019, J.P. Morgan continued to work with Epstein. Only months before his arrest in July of 2019, redacted and redacted. Rather than exit Epstein in 2006, J.P. Morgan handled millions of dollars in payments to Epstein's other rockstar lawyers, who the bank knew were working to discredit Epstein's victims and help Epstein avoid federal sex trafficking charges. redacted. J.P. Morgan banked all the girls and women publicly alleged in 2006 to be recruiters, accomplices, or victims, including redacted, redacted, redacted, and Golan Maxwell. J.P. Morgan knew that redacted, who Epstein was reported to have referred to as his Yugoslavia in sex slave. In fact, came from Yugoslavia as a teenager in 2004, supposedly worked as a model and was sponsored by Epstein. For years, J.P. Morgan handled Epstein's business with MC2 model management, knowing Epstein was accused of using the supposed modeling agency to traffic and abuse underage girls. At the same time, and for the next seven years, J.P. Morgan self-described as Epstein's number one bank, and at the time, continued to participate in Epstein's sex trafficking venture. It really never stopped handling his excessive cash withdrawals despite tying them to his felony sex crimes. Did not question his cash for fuel to travel the foreign country's explanation, even when he was in jail, and on house arrest, made millions of dollars, more in payments to co-conspirators, including Maxwell, recruiters, and victims, including many girls and women with Eastern European surnames, or located in Eastern Europe, from where J.P. Morgan knew Epstein was reported to have traffic girls, and continued to extend the loan to MC2, which, for all it knew, was a payment for services as a procure. Even when J.P. Morgan knew that federal prosecutors had subpoenaed bare-stearns, which it acquired in 2008, for account specific transaction information tied to Epstein, J.P. Morgan redacted, and went right on handling many more. The entire time the cynical jokes within the company also never stopped, from redacted asking if Epstein was at a party with Miley Cyrus to David Bridgestock, then CFO, comparing another client's house to Epstein's, reminded me of J.E.'s house, except it was more tasteful, and fewer nymphettes. Only in August of 2019, after Epstein's arrest and death, and when there was no more referrals or other benefits to be had, redacted, even though it had all the information in real time, not hindsight, as Diamond misrepresented on CNN. Accordingly, the government is entitled to judgment as a matter of law for J.P. Morgan's participation in Epstein's ex-trafficking venture, and obstruction of federal prosecutors' enforcement of the Law and Violation of the Trafficking Victims Protection Act, US Code 18, Section 1591, A2, and D. The government is also entitled to judgment as a matter of law on J.P. Morgan's equitable and false-shifting affirmative defenses, defenses five to eight, the legal deficiencies that left the court skeptical that the defenses would survive summary judgment persists, and no facts have been developed during discovery that would revive these deficient defenses. The legal standard. Summary judgment is appropriate if the pleadings, the discovery, and the disclosure materials on file, any affidavit show that there is no genuine issue as to any material fact, and that the movement is entitled to judgment as a matter of law, Fedarsiv P-56C, where the moving party has documented particular facts in the record, the burden, shifts to the opposing party to induce contrary record evidence sufficient to create a genuine dispute of material fact. To do so, the opposing party cannot merely make inclusion reassertions to the contrary. The argument, 1. J.P. Morgan's participated in Epstein's sex-trafficking venture in violation of the TVPA, U.S. Code 18, Section 1591, A&2. A. Epstein engaged in a sex-trafficking venture. J.P. Morgan does not dispute Epstein was engaged in a sex-trafficking venture. Epstein was engaged in a horrendous criminal activity, including sex-trafficking. That's not something being contested at all by J.P. Morgan. Epstein's behavior was monstrous. The survivors suffered unimaginable abuse at the hands of this man, who committed heinous crimes. J.P. Morgan acknowledged, redacted, in its own due diligence, respectively, that Epstein redacted and ran a sex-trafficking ring. Epstein was arrested on July 6, 2019, on federal charges of sex trafficking of minors. On August 10, 2019, he died in prison. Glenn Maxwell was convicted in 2022 for conspiring with Epstein to engage in sex trafficking. In 2008, Epstein was convicted for solicitation of an underage girl for prostitution, a covered act under the TVPA, U.S. Code, Section 18, 1591, A&1. In upholding his Level 3 sex-offender status imposed with a conviction, a New York appeals court found clear and convincing evidence Epstein had committed multiple offenses against a series of underage girls. Over the years, many victims have come forward and described being sex trafficked by Epstein, including in the U.S. Virgin Islands, redacted and redacted. J.P. Morgan has also handled millions of dollars in payments from Epstein to known co-conspirators, recruiters, victims, girls, and women until 2019, including payments to women in years that coincided with their trips to the U.S. V.I. B. J.P. Morgan knew or recklessly disregarded that Epstein ran a sex trafficking venture. J.P. Morgan had knowledge of Epstein's sex trafficking venture, either directly or by recklessly disregarding what was plainly to be seen. The government uses new or knowledge herein to mean direct knowledge or a reckless disregard. One. In 2006, J.P. Morgan knew Epstein was engaged in sex trafficking. In July 2006, Epstein was indicted for felony solicitation of prostitution and arrested. Numerous, J.P. Morgan's senior executives, including Staley, Erdos, Katherine Keating, then CEO, U.S., knew of Epstein's arrest and related news coverage, including a Palm Beach post article which stated, Epstein paid to have underage girls and young women brought to his home where he received massages and sometimes sex. And police thought that there was probable cause to charge Epstein with unlawful sex acts with the minor and lewd and lascivious molestation. J.P. Morgan's own due diligence process required that it monitor news, reports about customers, and the Palm Beach post article detailed evidence from police documents including a college student gave Epstein a naked massage and then brought him six girls ages 14 to 16 for massage and sex tinge sessions at Epstein's home. Police obtained statements from five alleged victims and 17 witnesses. Police contend Epstein had sex with girls on three occasions. Redacted met Epstein at age 17 and was recruited to massage him. Epstein told her that he would pay her to bring her more girls the younger the better. She stated that once she brought a 23 year old woman to him and Epstein said that she was too old. She brought six girls to Epstein and said the girls were paid $200 for each session. Redacted told police I'm like a Heidi Fleiss. A 27 year old Epstein employee redacted would arrange the sessions and prepare the massage table. One 14 year old victim recounted the details of her encounter in February of 2005, including being paid $300 for a massage in her bra and panties for bringing this child to Epstein redacted received $200. Police scoured the trash from Epstein's house and found notes with names and phone numbers, sex toys, and female hygiene products. Notes stated that one girl could not come over at 7 p.m. because of soccer. Another said a girl had work on Sunday, Monday after school. Another girl said she leaves school at 1130 and would come over the next day. Another July 2006 news report said police submitted arrest warrants request for redacted and redacted. The same report stated a girl told police she was paid by Epstein to have sex with redacted as Epstein watched and Epstein bragged he brought redacted into the United States to be his Yugoslavian sex slave. JP Morgan knew from its own work on human trafficking that sexual slavery means the coercion of the unwilling into various sexual practices. News around the time of Epstein's arrest also reported that two of Epstein's former employees told investigators that young looking girls showed up to perform massages two or three times a day when Epstein was in town. The news explained that Epstein paid 200 or 300 in cash for the girls and 200 in cash to redacted for recruiting the girls. A. Epstein admitted the conduct but not the ages to Staley. On July 25th 2006, Staley met with Epstein in person and Epstein admitted to the alleged conduct of engaging in sex for money with young women only denying the ages. Staley communicated the exchange to air dose the next day. I went and saw him last night. I've never seen him so shaken. He also adamantly denies the ages solicitation of a minor for prostitution is covered under the TVPA and Epstein had a reasonable opportunity to observe the victim. So it need not be proved. The defendant knew or recklessly disregarded the fact that the person had not attained the age of 18 years. US Code 18, Section 1591, A and 1 NC. Staley also spoke to Diamond about the very public indictment of the bank's client Epstein. B. JP Morgan's own due diligence gave it reason to suspect Epstein and Glenn Maxwell early on. By 2006, JP Morgan already had reason to suspect Epstein's sex trafficking and Maxwell's involvement. In 2003 as part of the bank's due diligence for an Epstein account, JP Morgan reviewed the Vanity Fair profile "The Talented Mr. Epstein" which reported Epstein's penchant for young foreign model types and his best friend Maxwell summoning a young woman for him and throwing a party attended by Prince Andrew and filled with young Russian models. In 2003, JP Morgan also knew that Maxwell was involved with Epstein in structuring cash withdrawals, a red flag for trafficking. Yet the private bank opened an account for Maxwell in 2003 on Epstein's referral noting Maxwell was a companion long-time friend of Jeffrey Epstein. By Epstein's arrest, JP Morgan knew it had made over 25 million in payments to Maxwell from Epstein. News reports related to Epstein's 2006 arrest again described Epstein's relationship with Maxwell. JP Morgan continued to handle payments from Epstein to Maxwell, including 7 million for the purchase of a helicopter, and later reports a Ganaledge Maxwell solicited young girls for Epstein identified as a human rights issue by JP Morgan. C. JP Morgan had corroborating information on redacted and redacted. JP Morgan had significant corroborating evidence of Epstein's sex crimes by July 2006 and knowledge of ongoing conduct after July 2006. JP Morgan knew that alleged accomplice redacted worked for Epstein and had just months prior to his arrest redacted. Redacted was also a customer of the bank. JP Morgan in 2005 made two separate $25,000 payments from Epstein's accounts to redacted. After police reports identified her as a recruiter in 2006, JP Morgan continued to handle payments to redacted, totaling over $675,000 from Epstein's accounts. JP Morgan also had information related to trafficking victim and accomplice redacted, also a customer of the bank. In 2004, sponsored by Epstein, JP Morgan opened accounts and credit cards for two teenagers, redacted, another victim, and redacted. Models and NYC and friends of Jeffrey Epstein. JP Morgan's due diligence report on redacted was approved by the private bank even though the report had no birth date, confirmed SSN or a passport or driver's license number. Epstein's banker at the time, Mary Rice Casey, never met redacted as JP Morgan's process contemplated, even after news reports that Epstein referred to her as his Yugoslavia in sex slave. JP Morgan knew that Epstein and redacted came to the U.S. from Yugoslavia and lived at a building owned by Epstein's brother. Further, JP Morgan knew it had made more than 36,000, 67,000, and 82,000 in payments from Epstein's account to redacted in 2004, 2005, and 2006. Respectively, even though Epstein represented her net worth, was 100,000 from supposed modeling assignments. JP Morgan also knew, redacted's debit transactions at the time, which AML compliance only reviewed more than four years later, were enlightening as compared to the countless stories related to Epstein's escapades. Lots of salon, lingerie shops, drugstores, NY Palm Beach, and in St. Thomas, his place of residence. Plus, lots of video like Girls Gone Wild and some other shops not fit for my good Catholic upbringing. JP Morgan's own human trafficking white paper discussed upscale sex trafficking operations, incurring expenses such as jewelry, lingerie, cosmetics, and sex toys. Even after she was identified in 2006, JP Morgan continued to handle payments to redacted, totaling over $600,000 from Epstein's JP Morgan accounts. JP Morgan redacted and redacted. JP Morgan also knew that Epstein sponsored credit cards for redacted and redacted for travel through Paris, Europe, and the U.S. Virgin Islands, and the U.S. monthly. D. JP Morgan had information about Epstein's cash withdrawals. On October 17, 2006, in light of the derogatory information related to Epstein's felony charges of soliciting underage prostitutes, JP Morgan's private bank held a rapid response meeting, which were escalations of derogatory information to management. Private bank identified Epstein's frequent cash withdrawals as worthy of note and conjunction with his felony charges of soliciting underage prostitutes. Cash withdrawals are routinely made in amounts for $40,000 to $80,000 several times a month, which total over $750,000 year to date. JP Morgan compliance staff acknowledged Epstein was known to pay cash for his massages, and minors are the issue. Three massages a day with girls pay $200 to $300 in cash, and recruiters pay $200 in cash, as JP Morgan knew was reported is about $40,000 cash per month. JP Morgan knew that in the time period of the incidents investigated by the Palm Beach police, and prior to Epstein's plea, it had handled nearly $1.75 million in cash withdrawals from Epstein. The large cash withdrawals really never stopped, and were ultimately the claim reason for JP Morgan parting with Epstein in 2013, when combined with his personal history. Epstein's 2011 explanation that the cash was for jet fuel for his foreign travel was redacted, and not supported by any receipts or other documentation. And redacted. Further, JP Morgan knew Epstein was in jail, and on house arrest from July 2008 through July of 2010, and thus not traveling overseas. In any event, JP Morgan's diligence cited reports that Epstein traveled to foreign countries to traffic young women, so whether to pay for that travel or to pay victims and recruiters or both, JP Morgan knew the cash was connected to Epstein's sex trafficking. Two, after July 2006, JP Morgan learned more information that fed its knowledge of Epstein's sex trafficking, including the Epstein high-powered lawyers helped them avoid federal sex trafficking charges. JP Morgan also knew that Epstein's wealth and high-powered lawyers allowed him to escape more serious charges, including federal sex trafficking charges. In 2006, JP Morgan and their due diligence included multiple news reports that Epstein assembled a team of star lawyers, including Alan Dershowitz, Gerald Leftcourt, Roy Black, and Jack Goldberg, to undermine the credibility of the 14- to 17-year-old girls and challenge the distorted view of the case presented by the Palm Beach police. Reports said Epstein used Black to hire private investigators to pose as police officers, and to review with witnesses what to say to actual police officers. In 2006 and 2007, JP Morgan reviewed reports that federal prosecutors were looking to bring child sex trafficking charges against Epstein, and that his lawyers were negotiating a deal to avoid those charges. The FBI, considering investigating, Epstein for child sex crimes at 50. JP Morgan later acknowledged reports that Epstein supposedly bought his way to a lesser sentencing and paid a whole series of girls to stay quiet. JP Morgan was handling millions of dollars in payments to those lawyers at the time, including numerous $100,000 payments, and continued to handle tens of millions in payments to lawyers at 127. On September 24, 2007, Epstein agreed to plead guilty to two prostitution charges in state court, including the solicitation of a minor to engage in prostitution in exchange for federal non-prosecution agreement, providing him with immunity from federal child sex trafficking charges. Under the NPA, Epstein also waived his right to contest liability and damages in civil lawsuits by minor girls, identified by the NPA. The NPA identified redacted, redacted, and Leslie Groff as Epstein's co-conspirators in soliciting underage girls for commercial sex, and JP Morgan knew of the reports of the plea deal beginning in 2007. The NPA later became public, and JP Morgan was aware of it. In October 2007, Ann Verdon, then General Counsel of Palm Beach, received requested information about Epstein, his transactions, and his news coverage. This research connected the dots between Epstein's financial transactions at the bank, his large, frequent cash withdrawals, credit cards for redacted and redacted, and transfers to redacted, and is a legal conduct. The diligence showed redacted who had talked to the police, unlike a Heidi Fleiss, had a revoked credit card while redacted who did not talk to the police, still had an active credit card under Epstein. JP Morgan continued with business as usual. 3. JP Morgan knew Epstein was connected to MC Squared, modeling agency he was accused of using to traffic and abuse underage models. A news report surfaced in 2007 of industry speculation that massage maven Jeffrey Epstein is a secret financial backer of the agency being run by scandal scarred John Luke Brunel, who was once accused of taking advantage of underage models. Epstein reportedly gave millions to start MC2, which opened in October of 2005. Epstein is a desperate old man that fantasizes and takes advantage of young girls. Epstein's rep, Howard Rubenstein, said he has no business relationship with Brunel and MC Squared, but JP Morgan knew at the time the report that Rubenstein was covering up for Epstein. In 2005, JP Morgan had extended a million dollars standby letter of credit for Epstein to backstop alone to MC Squared. Only two weeks after the news about Epstein's ties to Brunel and MC Squared, Casey among others discussed the MC2 SBLC, which the bank renewed through March of 2011. Even though Epstein was set to plead guilty to felony sex crimes, JP Morgan did not determine, and as of late 2011 still do not know if the $1 million was a payment for services as a pro-cure. JP Morgan would review multiple reports about child sex trafficking by Epstein, Brunel, and MC2, Brunel owner of MC2, and Jeffrey Epstein engaged in racketeering that involved learning in minor children for sexual play for money, all the while continuing to extend the $1 million SBLC. Redacted who JP Morgan was supposed to but did not meet with. Redacted part four, JP Morgan knew of reports that Epstein settled dozens of civil lawsuits alleging child sex trafficking, then came the reports of the civil lawsuits, another category of information that was supposed to be part of the JP Morgan due diligence. In 2007, Epstein was bracing for a slew of lawsuits from as many as 40 young women. By early 2008, Erdos and Lisa Waters, then a managing director, AWM, among others, knew of multiple news outlets reporting the first lawsuit against JE, sexual abuse of minor, etc., etc. Then the next, the teen says that she was lured to Epstein's Palm Beach mansion, and then sexually assaulted in his massage room. In 2010, JP Morgan knew of reports that Epstein had settled more than two dozen lawsuits and claims against him by teenagers who say they were lured to his Palm Beach mansion to give him sexually charged massages and/or sex in exchange for money. These same civil complaints allege that young girls from South America, Europe, and the former Soviet republics were recruited for Epstein's sexual pleasure. 5. JP Morgan knew Epstein's 2008 conviction covered sex trafficking conduct. On June 30, 2008, Epstein pled guilty to felony solicitation of prostitution and pro-curement of a 14-year-old minor to engage in prostitution and was sentenced to 18 months in jail and required to register as a sex offender, redacted as described above. In 2011, William Langford, then global head of compliance, communicated to Steve Cutler, then general counsel concern about retaining Epstein as a client. Cutler testified that those concerns are heightened, if you will, by the human trafficking initiative that we're doing given that he was convicted of these crimes. 6. Based on its own human trafficking work, JP Morgan knew Epstein was engaged in human trafficking. Around the time of Epstein's conviction in 2008, JP Morgan's AML anti-money laundering compliance group Under Langford created a human trafficking overview. The overview reported that nearly two-thirds of the women trafficked for prostitution worldwide come from Eastern Europe. And former Eastern Black countries such as Albania, Moldova, Romania, Bulgaria, Russia, Belarus, and Ukraine have been identified as major trafficking source countries for women and children. JP Morgan knew and had even assembled evidence that Epstein had made at least tens of thousands of dollars in payments to redacted and was reported to refer to her as his Yugoslavian sex slave. JP Morgan knew that it had made more than $1.2 million in payments to girls or women, many with Eastern European surnames from Epstein's accounts from 2003 to 2008. Beginning in 2008, several payments were sent to high-risk locations such as Belarus, Lithuania, and Russia. AML compliance JP Morgan's in-house human trafficking experts wanted Epstein gone from the bank in 2010. When additional news stories connected Epstein to human trafficking, AML compliance was concerned about continuing to bank a human trafficker while trumpeting the bank's efforts to rein in human trafficking through the bank. My fear is that all our touting of goodwill on the human trafficking work if anyone should ever say "yet we bank Epstein," a known child flees. I sent you an email yesterday on that scum Epstein, I reminded McCleary, then head of PB Risk Management, that he listened to two days of human trafficking at the forum and this account could be problematic in several ways. AML compliance requested the bank, re-sponsor this client in light of the new allegations of human trafficking, which the firm has been actively assisting law enforcement in uncovering others engaged in this practice. Langford, the public face of JP Morgan's human trafficking initiative and the global head of compliance believe JP Morgan should exit Jeffrey Epstein as a client, but business, including Erdos, decided otherwise. 7. In 2008, JP Morgan knew the feds were connecting certain transactions to Epstein's sex trafficking. JP Morgan also knew that it made many payments from Epstein's accounts that federal prosecutors believed could be evidence of sex trafficking. In 2008, JP Morgan acquired Barris Stearns, where it knew Epstein conducted his brokerage business. Around the time of Epstein's guilty plea, Arthur Middlemiss, formerly a compliance officer at Barris Stearns, assumed a similar role at JP Morgan and worked on Epstein's investigations. The last portion of this section completely redacted. 8. JP Morgan employees had personal knowledge of Epstein's sex trafficking. Many emails over JP Morgan's email between Staley and Epstein demonstrate that Staley had personal knowledge of Epstein's sex trafficking. Staley met Epstein's co-conspirators at Epstein's townhouse redacted. JP Morgan handled more than $210,000 in payments to redacted from Epstein. JP Morgan admits that Jess Staley was the senior person at JP Morgan with a business relationship with Epstein. Thus, Staley's knowledge is imputed to JP Morgan. Order at 29. Brigstock CFO of AWM wrote air dose comparing a client's house to Epstein's, reminded me of JE's house, except it was more tasteful, and, you know, fewer nymphettes. C. JP Morgan participated in Epstein's sex trafficking venture. Even if participation requires active engagement, order at 24, there's no genuine dispute that JP Morgan actively participated in Epstein's sex trafficking venture from 2006 until 2019. The court found allegations that the bank allowed Epstein to use its accounts to send dozens of payments to then known co-conspirators redacted, provided excessive and unusual amounts of cash to Epstein, and structured cash withdrawals so that those withdrawals would not appear suspicious, went well beyond merely providing their usual banking services to Jeffrey Epstein and his affiliated entities, and were sufficient to allege active engagement. The New York State Department of Financial Services entered into a consent order and issued a $150 million penalty to Deutsche Bank for its inexcusable failure to detect or prevent millions of dollars of suspicious transactions related to Epstein, including payments to publicly allege co-conspirators, settlement payments and dozens of payments to law firms for legal expenses of Epstein and co-conspirators, payments to Russian models, including for school tuition, and hotel and rent expenses, and to numerous women with Eastern European surnames, and periodic suspicious cash withdrawals totaling more than 800 grand over four years, redacted and redacted. Payments to co-conspirators redacted and redacted. From August 2006 through 2013, JP Morgan handled $678,741.51 and $607,804.30 in payments, respectively, from Epstein's JP Morgan accounts to redacted and redacted, Epstein's co-conspirators, recruiters, and/or victims. Even after it decided to terminate Epstein's account in July 2013, JP Morgan still handled the payment of $15,000 from Epstein's JP Morgan accounts to redacted. Redacted and redacted. In addition to payments from Epstein, JP Morgan also opened credit cards for redacted and redacted through NES LLC, Kara of Jeffrey Epstein, only months after Epstein was indicted. NES LLC is an Epstein entity for which JP Morgan had not conducted the required due diligence and redacted. Payments to co-conspirator, Elaine Maxwell. After August 2006, JP Morgan continued to handle payments to Maxwell who, by July 2006, had reason to suspect was involved with Epstein in the alleged sex crimes. JP Morgan's payments to Maxwell included more than $7 million to purchase a helicopter. Millions of dollars in payments to girls and women, many with Eastern European surnames and/or located in Eastern Europe, the whole section redacted. JP Morgan sent several of the payments by foreign wire to girls or women to locations in Eastern Europe, including Belarus, Lithuania, and Russia. JP Morgan also handled payments to women for school tuition and rent expenses. Next section redacted. $1,000 in smaller payments to girls and women and $100,000 payments. As explained above, JP Morgan knew from the federal prosecutor, subpoena, to bear asterns that law enforcement considered these payments suspicious and evidence of Epstein's federal sex crimes. MC2, modeling agency SBLC. As described above, from 2005 to March 2011, JP Morgan extended an SBLC to Brunel and MC2, despite reports that supported payment for services as a procure. By 2007, there were reports that Epstein had engaged in sexual abuse reminders through MC2, yet JP Morgan continued to extend the SBLC. Next part redacted. Who it knew was covering of Epstein's involvement with MC2. Payments to high-powered lawyers covering up Epstein's crimes. Following Epstein's arrest for felony sex crimes and confession to Staley and prior to the NPA, redacted, after the NPA through 2013, redacted. Excessive and unusual cash withdrawals. The NYS DFS found inexcusable Deutsche Bank failures to monitors suspicious cash withdrawals of more than $800,000 over four years. Between September 2003 and November of 2013, approximately 10 years, JP Morgan handled more than $5 million in outgoing cash transactions for Epstein, ignoring its own policy, discouraging large cash withdrawals. From August 2006 to 2013, JP Morgan facilitated nearly 2.5 million in cash withdrawals for Epstein, even though it was widely publicized that Epstein paid for sexual encounters with minors in cash. Next part redacted. JP Morgan did not seek an explanation for Epstein's excessive cash withdrawals until 2011, again in violation of its own policy. Next part redacted. JP Morgan must file SARS to report suspicious financial transactions whenever the national bank detects a transaction or transactions conducted through the bank and involving or aggregating $5,000 or more in funds or other assets where the bank believes that it was used to facilitate criminal transaction and the bank was a substantial basis for identifying a possible suspect. JP Morgan must file a SARS no later than 30 calendar days after the date of the initial detection of facts that make constitute a basis for filing a SARS. From 2003 to 2013, JP Morgan helped Epstein withdraw over $5 million in cash, make millions of dollars in payments to co-conspirators and accomplices, send more than 3 million in wires to women and girls and redacted. At the 2006 rapid response meeting following Epstein's indictment on the felony charges of soliciting underage prostitutes, JP Morgan explicitly noted cash withdrawals made an amount of $40,000 to $80,000 several times a month. Next part redacted. So we're going to end here and in the next section when we pick back up, we're going to pick up with D, JP Morgan benefited from participation in Epstein's sex trafficking venture. All of the information that goes with this episode can be found in the description box.

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.