Beyond The Horizon
The USVI And Their Request For A Summary Judgement Against JP Morgan (Part 3) (6/29/24)
A memorandum of law in support of a summary judgment is a legal document filed by a party in a lawsuit to persuade the court to grant a summary judgment in their favor. Summary judgment is a legal process where the court decides a case without a full trial because there are no disputed material facts requiring a jury or judge to resolve. Here’s a detailed breakdown of what this memorandum typically includes:
- Introduction and Statement of Facts:
- The memorandum begins with a brief introduction, outlining the purpose of the document and a statement of undisputed facts. These facts are often supported by evidence such as affidavits, depositions, and other documents.
- Legal Arguments:
- This section presents the legal basis for the motion, citing relevant laws, statutes, and case precedents. The goal is to demonstrate that, based on the undisputed facts, the moving party is entitled to judgment as a matter of law.
- Standard of Review:
- The memorandum will often include a discussion of the standard of review for summary judgment, explaining that the court must view the evidence in the light most favorable to the non-moving party and determine if there is no genuine issue of material fact.
- Analysis:
- A detailed analysis follows, where the party applying for summary judgment argues how the law applies to the undisputed facts. This section aims to show that the opposing party cannot prove an essential element of their case or that there is no evidence to support their claims.
- Conclusion:
- The memorandum concludes with a summary of the arguments and a request for the court to grant summary judgment, thereby dismissing the case or certain claims within the case without the need for a trial.
- Supporting Documentation:
- The memorandum is usually accompanied by supporting documentation, such as exhibits, affidavits, and a statement of undisputed material facts, to substantiate the arguments made.
(commercial at 9:09)
to contact me:
bobbycapucci@protonmail.com
source:
Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (bwbx.io)
- Duration:
- 13m
- Broadcast on:
- 29 Jun 2024
- Audio Format:
- mp3
Hey there, it is Ryan Seacrest with you. You wanna make this summer unforgettable? Join me at Chumba Casino. It's this summer's hottest online destination. They are rolling out the red carpet with an amazing welcome offer just for you. So don't wait, dive in now and play hundreds of social casino games for free. Your chance to redeem real prizes is just a spin away. Here to join me. - Sponsored by Chumba Casino, no purchase necessary. VGW Group, void were prohibited by law. 18 plus terms and conditions apply. - What's up everyone? And welcome back to the Epstein Chronicles. In this episode, we're getting right back to the USVI and their request for a summary judgment against JP Morgan. Part four, JP Morgan knew of reports that Epstein settled dozens of civil lawsuits alleging child sex trafficking. Then came the reports of the lawsuits, another category of information that was supposed to be part of JP Morgan's due diligence. In 2007, Epstein was bracing for a slew of lawsuits from his many as 40 young women. By early 2008, air dose and Lisa Waters, then a managing director, AWM, among others new of multiple news outlets reporting, the first lawsuit against Jeffrey Epstein, sexual abuse of a minor, et cetera, et cetera. Then the next, the teen, says 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 them by teenagers who say that 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 alleged that young girls from South America, Europe and the former Soviet republics were recruited for Epstein's sexual pleasure. Five, JP Morgan knew Epstein's 2008 conviction covered sex trafficking conduct. On June 30th, 2008, Epstein pleaded 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, redacted. In 2011, William Langford, then global head of compliance, communicated to Steve Cutler, then general counsel, concerned about retaining Epstein as a client, Cutler testified, those concerns are heightened, if you will, by the human trafficking initiative that we're doing, given that he was convicted of these crimes. Six, 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 block 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 assembled evidence that Epstein had made at least tens of thousands of dollars of payments to redacted and was reported to refer to her as his Yugoslavan sex slave. JP Morgan also knew 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, redacted. 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, one additional news stories connected Epstein to human trafficking. AML compliance was concerned about continuing a bank, a human trafficker, while trumpeting the bank's efforts to reign in human trafficking through the bank. My fear is will all of our touting of goodwill on human trafficking work, if anyone should ever say, yet we bank Epstein, a known child's sleaze. 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 his account could be problematic in several ways. AML compliance requested the bank, re-sponsor his client in light of the new allegations of human trafficking, which the firm has been actively assisting law enforcement in uncovering others engaged in the 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, then CEO, AWM, decided otherwise. Seven, 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 believe could be evidence of sex trafficking. In 2008 JP Morgan acquired Bear Stearns where it knew Epstein conducted his brokerage business. Around the time of Epstein's guilty plea, Arthur, Middle Miss, formerly a compliance officer at Bear Stearns, assumed a similar role at JP Morgan and worked on Epstein's investigations. This whole section here is redacted. Eight, JP Morgan employees had personal knowledge of Epstein's sex trafficking. Many emails over JP Morgan email between Staley and Epstein demonstrate that Staley had personal knowledge of Epstein's sex trafficking. Staley met Epstein co-conspirators at Epstein's townhouse. JP Morgan handled more than $210,000 in payments to redacted from Epstein. JP Morgan admits 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 CEO of AWM wrote, " Erdos comparing a client's house to Epstein's. "Remined in me of JE's house, "except it was more tasteful and fewer nymphettes." C, JP Morgan participated in Epstein's trafficking venture. Even if participation requires active engagement order at 24, there is 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, provide 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. Order at 25 and 26. The New York State Department of Financial Services entered into a consent order and issued $150 million penalty to Deutsche Bank for its inexcusable failure to detect and prevent millions of dollars of suspicious transactions related to Epstein, including payments to publicly alleged co-conspirators, settlement payments to 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 red expenses, and to numerous women with Eastern European surnames, and periodic suspicious cash withdrawals totalling more than $800,000 over four years. Redacted and payments to co-conspirators redacted and redacted. From August 2006 through 2013, J.P. Morgan handled $678,741.57 and $607,804.30 in payments, respectively from Epstein's J.P. Morgan accounts to redacted and redacted. Epstein's co-conspirators, recruiters, and door victims. Even after it decided to terminate Epstein's accounts in July of 2013, J.P. Morgan still handled the payment of $15,000 from Epstein's J.P. Morgan account to redacted. Redacted and redacted. In addition to payments from Epstein, J.P. Morgan also opened credit cards for redacted and redacted through NESLLC, CO-Jeffrey Epstein. Only months after Epstein was indicted. NESLLC is an Epstein entity for which J.P. Morgan had not conducted the required due diligence and redacted and redacted. Payments to co-conspirator, Glaine Maxwell. After August 2006, J.P. Morgan continued to handle payments to Maxwell, who by July 2006, it had a reason to suspect was involved with Epstein and the alleged sex crimes. See Superapart 1B, INB. J.P. 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. This is all redacted here. Then it goes into J.P. Morgan sends several of the payments by foreign wire to girls or women to locations in Eastern Europe, including Belarus, Lithuania, and Russia. J.P. Morgan has also handled payments to women for school tuition and rent expenses. Next section, completely redacted, moving into the next part. $1,000 in smaller payments to girls or women and $100,000 payments. As explained above, J.P. Morgan knew from the federal prosecutor subpoena to Bear Stearns that law enforcement considered these payments suspicious and evidence of Epstein's federal sex crimes. - It is Ryan Seacrest here. Everybody needs some variety in life. That's what I love about Chumba Casino. They know how to keep things fresh and exciting. All their games are free to play. Like spin slots, bingo and solitaire. You can claim free daily login bonuses too, and they release new games every week. So spice things up with Chumba Casino.com now for your chance to redeem some serious prizes. Sponsored by Chumba Casino. No purchase necessary. VGW Group, void where prohibited by law. 18 plus terms and conditions apply. - MC2 Modeling Agency SBLC. As described above, from 2005 to March 2011, J.P. 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 was engaged in sexual abuse of minors through MC2. Yet J.P. Morgan continued to extend the SBLC. Who it knew was covering up Epstein's involvement with MC2, C-super apart IB and three. Payments to high-powered lawyers covering up Epstein's sex crimes. Following Epstein's arrest for felony sex crimes and confession to Staley and prior to the NPA, this whole thing has redacted. Then after the NPA through 2013, redacted. Excessive and unusual cash withdrawals. The NYS DFS found inexcusable Deutsche Bank failure to monitor suspicious cash withdrawals of more than $800,000 over four years. Between September 2003 and November 2013, or approximately 10 years, J.P. 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, J.P. Morgan facilitated nearly two and a half million in cash withdrawals for Epstein. Even though it was widely publicized at Epstein, paid for sexual encounters with minors in cash and redacted. J.P. Morgan did not seek an explanation for Epstein's excessive cash withdrawals until 2011, again in violation of its own policy. Next section, completely redacted. J.P. 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 a criminal transaction. And the bank has a substantial basis for identifying a possible suspect. 12 CFR, section 21.11 CN2. J.P. Morgan must file a SARS, no later than 30 calendar days after the date of the initial detection of facts that may constitute a basis for filing a SARS. 12 CFR, section 21.11 D. From 2011 to 2013, J.P. 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 felony charges of soliciting underage prostitutes, J.P. Morgan, explicitly noted that cash withdrawals made an amounts of 40,000 to 80,000 several times a month. C. Supra part IBIDN2. All right, we're gonna wrap up right here. And in the next episode, we're gonna pick up with D. J.P. 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. - Hey there, it is Ryan Seacrest with you. You wanna make this summer unforgettable? Join me at Chumba Casino. It's this summer's hottest online destination. They are rolling out the red carpet with an amazing welcome offer just for you. So don't wait, dive in now and play hundreds of social casino games for free. Your chance to redeem real prizes is just a spin away. Here to join me. - Sponsored by Chumba Casino, no purchase necessary. VGW Group, void where prohibited by law. 18 plus, terms and conditions apply.