UNITE-4.1 ES STRICT COURT SOUTHERN DIST-3.6 CT OF YORK GOVE-5.4 RNM-7 ENT OF THE UNITED STATES VIRGIN ISLANDS Plaintiff JPMORGAN CHASE BANK N.A Defendant/Third-Party Plaintiff Case No JSR JPMORGAN CHASE BANK N.A Third-Party Plaintiff JAMES EDWARD STALEY Third-Party Defendant JPMORGAN CHASE BANK A 2S LOCAL CIVIL RULE RESPONSE TO STATEMENT OF MATERIAL ACTS AS TO WHICH GOVERNMENT OF THE UNITE-3.9 ES VIRGIN ANDS CONTE NDS ERE IS NO GENUINE DISPUT-3.5 Pursuant to Fed Civ and Local Ci vil Rule Defendant/Third-Party Plaintiff JPMorgan Chase Bank N.A 223JPMC or 223JPMorgan hereby re sponds to the Statement of Material Facts as to which Government of the Unite States Virgin Islands Contends There is No Genuine Dispute 223USVI SUMF filed by the Government the United States Virgin Islands 223USVI See Dkt To avoid repetition JPMC incorporates by reference herein JPMorgan Chase Bank N.A 2s Local Rule Statement of Undisputed Material Facts in Support of Case Document Filed Page of U?vO?OP?F3O 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10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 Case Document Filed Page of Defendants Motion for Partial Summa,y Judgment SUMF Dk and JPMorgan Chase Bank NA Local Civil Rule Counterstatement of Additional Material Facts CSMF and ppo rtin xh ib i ts cited th ein MC fm inco rp rat es i to i ts es ses i ts ob ectio th at USVIs cited ater i a ca nn ot be prese ted at ri a in a fo a wo ul admissible as evide ce and as sta ed fm er specific objectio be ow A ll a ll egatio co ta in ed in eadings hi a ppo 1i ed by a citatio to ad mi ssib ev i de ce a eby fail to co i th ocal les a a so i sputed fo th easo set fo rth in acco mp a ying respo ses pa ra grap tein Engaged in a Sex-Trafficking Venture JPM Re pon Thi i a eade to hi ch no respo se i waffanted Disp ut ed in sofa as SVI co ten hat th sta ents and doc um ts cited be ow estab li hi fact as a atte of law or a MC knew or rec kl essly i srega ded a stein gaged in a sex tra fic kin ve ur as a atte of aw I In the May class certification hearing counsel for JPMorgan stated I think the way the Court could use those grand jury findings would be to ascertain something not contested which is Mr Ep in wa ngag in horr ndou crimina acti vi in cl uding sex traffi kin Thats not something being contested at all by JPMorgan Tr Class Certification Hr at Doe JPMorgan Chase Bank NA No cv Ma see also id at Your colleague has just acknowledged as indeed JPMorgan has repeatedly that they do not dispute ou do not is put that Mr Ep in a ag in a lon tim traffi kin ve ntur that involved enumerable young women and that required money to make it work mphasis added Un ess he1wise specified all cita ions in JPMC Resp USVI SUMP and JPMC CSMF to JPMC Ex efer to exhibi fi ed by JPMC in support of i motion for summa1y judgment and in opposition to USVIs mo ion for summary judgment Citations herein USVI Ex refer to exhibits submitted by USVI in support of its motion for summary judgment Case Document Filed Page of JPMC Response ndi sputed that the qu ed langu age is fr the it transcript Disputed in sofa as USVI co nt ds that the cited sta tement estab li es that Ep ste in was engaged in a sex rn ffi ck in ve ntur as a at ter fl aw or that JPMC kne or recklessly disregarded that Epstein engaged in a sex rn ffi ck in ve ntur as a at ter aw See CS MF i,i Furth co nt nded that the ited mat ri a cannot presented at trial in a dmi ssib le fo 1m In statements to the press following JPMorgan settlement with Doe JPMorgan stated We all now understand that Epsteins behavior was monstrous and we believe this settlement is in the best interest of all parties especially the survivors who suffered unimaginable abuse at the hands of this man Any association with him was a mistake and we regret it We would never have continued to do business with him if we believed he was using our bank in any way to help commit heinous crimes Ex JPMC Response ndi spute that JPMC ade th qu ed state ment Disputed in sofa as USVI conte ds that the ci ed sta tement establishes th at Ep ste in was engaged in a sex traffi ck in ve nture as a at ter fl aw or that JPMC kn ew or recklessly disregarded that Epstein engaged in a sex traffi ck in ve nture as a at ter aw See CS MF i,i Ex at Case Document Filed Page of Disputed in so far as USVI co nt ds at he cited documen establishes th at Epstein was engaged in a sex trnfficking ve nture as a at ter fl aw or that JPMC kn ew or reckle ss di regarded that Ep tein engaged in a sex trnfficking ve ntur a a at ter aw See CSMF i,i Ex at Disputed in so far as USVI conte ds at he ci ed documen establishes that Ep in was engaged in a sex trnfficking ve nture as a at ter aw or that JPMC kn ew or reckle ss di regarded that Ep tein engaged in a sex trnfficking ve nture as a a tter aw See CSMF i,i at JPMC Response Case Document Filed Page of Disputed in sofa as USVI co nt ds at he cited documen establishes tha Epstein was engaged in a sex rnffick in ve ntur as a at ter oflaw or that JPMC kne or recklessly disregarded that Epstein engaged in a sex rnffick in ve ntur as a at ter law See CSMF i,i In a grand jury found that Epstei exuall exploited and abused doze of mi or girls at hi homes in Manhattan New York and Palm Beach Florida among other location Sealed Indictment at I United States Epstein cr SD NY Jul ECF No I JPMC Response Undispu ed that in Jul a randjm arged at Ep ein sex uall explo i ed and abused doze of min gi rl at hi es in Manhattan New rk and a lm Be ac Florida among ot locations Disputed in sofa as USVI conte ds at he ci ed documen establishes th at Epstein was engaged in a sex rnffick in ve ntme as a a ter oflaw or that JPMC kn ew or recklessly disregarded that Epstein engaged in a sex rnffick in ve ntme as a a ter law See CSMF i,i Ex at The article tated that federal pro ecutors had charged Epstein with sex trafficking in Ju ly Epstein was arre ted on Jul and Epstein died on August JO Ex a New or Tunes arbc it Je Epstein Dead in ui id at Jail Sp unin Inquiries hi sta ed at federal prosecu ors had arged Ep ein i sex raffick in in July Epstein was anested July a nd Ep ein died A Disputed in sofa as USVI co nt ds at he ci ted documen establishes th a Epstein was engaged in a sex raffick in ve ntur as a at ter oflaw or that JPMC knew or recklessly disregarded that Epstein engaged in a sex raffick in ve ntur as a at ter law See CSMF i,i Case Document Filed Page of Ghislaine Maxwell was indicted and arrested in by the United States Attorney ffice for the Southern istrict of New ork/or conspiracy to entice minors to travel to engage in illegal acts enticement of a minor to travel to engage in illegal sex acts conspiracy to trans ort minors with intent to engage in criminal sexual acti ity and trans ortation of a min with intent engage in criminal sexual activity Sealed I ndictment United States axwell cr June CF No Maxwell was convicted on June JPMC Response Undi pu ed th ex th a Maxwe ll was indict in th Unit a es A tto rne ys Offi ce fo he So uthern Di tri ew rk for co pira cy en i ce min rs tr ave gag in ill ega a en i ce men a min rav el a in ill ega a pira cy tran 1t min i int nt gag in rimin a sex a a cti ity a nd tran 1t a i a min ith inten en a in rimin a sex a ac ti i ty Di put in so far as SV I co nt ds at he it oc umen a bli he th at Ep in a en a ed in a sex traffi kin ve ntur a a at ter fl aw that JP MC kne ec kle ss di re arded that Ep in en a ed in a sex traffi kin ve ntur a a at ter aw See CS MF i,i Fmth co nt ed that th i ed mat ri a cann pre ent a tri a in a dmi ss ible fo 1m rgan admits that Epstein ied guilty to felon solicitati of pr stituti and rocurement min rs engage in rostitution was sentenced months in jail and was required register as a sex offender ef Morgan Chase ank NA A nswer to 2d Am Comp and Statement A ffirmative efenses i ECF No JPMC Response Undi pu ed that th qu ted langu age i fr JP MCs An sw er A Co mpl and a em nt A ffnmati ve fen Di put in so far as SV I co nt ds at he it oc umen a bli he th at Ep in a en a ed in a sex traffi kin ve ntur a a at ter fl aw that JP MC kne ec kle ss di re arded that Ep in en a ed in a sex traffi kin ve ntur a a at ter aw See CS MF i,i IO A el sex offender is the highest risk le el and poses a high risk of repeat offense and threat to ublic safety JPMC Response Undi pu ed that in rk a a Le el sex ffender i he hi es ri le ve a nd os a hi ri rep ea ff se and thr ea publi afe ty Case Document Filed Page of Disputed in sofa as USVI co nten ds that the cited document establishes th at Epstein was engaged in a sex trnffi ck in ve nture as a at ter oflaw or that JPMC kne or recklessly disregarded that Epstein engaged in a sex rnffick in ve ntur as a atter aw CSM i,i In November I Epsteins Level sex offender status was unanimously affirmed by the New York Supreme Court Appellate Division The court found that lear and convincing evidence supported the assessment of points for risk factors sufficient for a level three sex offender adjudication The evidence before the Sex Offender Registration Act hearing court established that defendant committed multiple offenses against a series of underage girls The girls were brought to defendant home to provide massages that led to very serious sex crimes These facts were established by Florida law enforcement authorities after their investigation The probable cause affidavit was extreme detailed It set forth the sworn tape recorded statements of the victims The victims detailed accounts of defendants crimes corroborated each other and were also corroborated by other evidence including declarations against penal interest made by defendant accomplice JPMC Response Undisputed as to the contents of the ited decision Di sp ut ed to the extent USVI suggests that Epstein was cla ss ified as a Le vel sex ff ender in all juri sdictio See CSMF i,i Disputed in sofa as USVI co nten ds that the cited document establishes th at Epstein was engaged in a sex trnffi ck in ve nture as a at ter fl aw or that JPMC kne or recklessly disregarded that Epstein engaged in a sex trnffi ck in ve ntur as a at ter aw See CSMF i,i Ex at Case Document Filed Page of Disputed in sofa as USVI conte ds hat he cited documen establishes th at Epstein was engaged in a sex rnffick in ve ntur as a at ter oflaw or that JPMC knew or recklessly disregar ed that Epstein engaged in a sex rnffick in ve ntur as a at ter law See CSM i,i At Ghislaine Maxwells criminal trial a ictim testified under oath using the pseudonym Kate Kate testified that starting when she was years old Maxwell and Epstein flew her to Palm Beach to New York and to the island and Kate gave Epstei sexualized massages in each of those locations Tria Tr at United States Maxwell No cr NY Dec ECF No JPMC Response Undispu ed as to he contents of the ci ed documen Disputed in sofa as USVI conte ds hat he ci ed documen establishes th at Epstein was engaged in a sex rnffick in ve ntur as a at ter oflaw or that JPMC knew or recklessly disregar ed that Epstein engaged in a sex rnffick in ve ntur as a at ter law See CSM i,i Furth er co nt ed that the i ed mat rial cannot presente at trial in admissible fo 1m Bridgette Carr an expert in human trafficking for the US Virgin Is lands Ex at Case Document Filed Page of Di puted in so far a SV I ont ds hat he cit cumen a bli he th at Ep in a en a ed in a sex rn ffi kin ve ntur a a at ter fl aw or that JP MC kne ckle ss di re ar ed that Ep in en a ed in a sex rn ffi kin ve ntur a a at ter aw See CS MF i,i Furth co nt ed that th i ed mat rial cann pre ent ed at tri a in a dmi ss ible fo 1m US istrict Judge Marra stated i an pinion i Februa,y rom about and effrey Epstein sexual abused more than minor girls i ncluding etitioners at his mansion in alm each lorida and elsewhere in the United States and overseas ecause Epste i and i nspirat rs know i ngly traveled in i nterstate and international mmerce sexually abuse Jane Do ane Do and thers they mm i tted violations not only i da law but als federal law I addition his own sexual abuse of the victims pstein directed ther pers ns abuse the girls sexually pstein used paid empl yees find and bring i girls to i Ep stein rked in concert with others obtain min rs not on i wn sexual gratification ut als the sexual gratification of thers Jane Do Jane Do United States Supp 3d Fla internal citati ns i tted JPMC Response Undi pu ed as he nt nt he cited cumen Di puted in so far a SV I co nt ds hat he cited cumen a bli he th a Ep tein was en a ed in a sex traffi kin ve ntur a a at ter fl aw that JP MC kne ckle ss di re arded that Ep in en a ed in a sex traffi kin ve ntur a a at ter aw See CS MF i,i Furth co nt nded that th i ed mat ri a cann pre ent a ri a in a dmi ss ible fo 1m After Ep ste i death Judge erman held a hearing at which several of psteins victims gave statements Victim testified my third orfourth time meeting pstein and Maxwell they br ught me effreys island for the first time and the first i ght there came tapping on my or late at night inform me Jeffrey was ready for an ther Case Document Filed Page of massage JI That night Epstein sexuall assaulted her Tr at United States Epstein No cr SD.NY Aug ECF No JPM Re pon Un dis pu ted th at th qu oted lang age is fr ea rin ran sc ipt in i ted case Disp ut ed in sofa as USV I co te ds at ci ed doc um es ablis es th a Eps in was gaged in a sex rnffick in ve ntur as a at oflaw or at MC knew or rec kl essly i srega ded a stein gaged in a sex rnffick in ve ntur as a at law See CSMF i,i Fu rt co te de at i te ate ia cannot ese ted at ial in admissible fo At the same August hearing Jane Doe No testified I when I was years old I flew on Jeffrey Epstein plane to Zorro Ranch where I was sexual sic molested by him/or man hours JI Id at JPM Re pon dis pu ted th at th uoted lang age is fr ea rin ran sc ipt in i ted case Disp ut ed in sofa as USV I conte ds at ci ed doc um es ablis es hat Eps in was gaged in a sex raffick in ve nt ure as a a oflaw or at MC knew or recklessly i srega ded at stein gaged in a sex raffick in ve nt ure as a a law See CSMF i,i Fu rt co te de at i te mate ia cannot ese ted at ial in admissible fo Ex JO at Id at Id at JPM Re pon Case Document Filed Page of at Disputed in sofa as USVI co nt ds at he cited document establishes th at Epstein was engaged in a sex rn ffi ck in ve nture as a at ter fl aw or that JPMC kn ew or recklessly disregarded that Epstein engaged in a sex rn ffi ck in ve ntur as a at ter aw See CSMF i,i Furth er co nt de that the i te mat ri a cannot presented at trial in admissible fo 1m Ex Ex at Id JPMC Response Disputed in sofa as USVI co nt ds at ci ted document establishes th at Epstein was engaged in a sex ra ffi ck in ve ntur as a at ter law or that JPMC knew or recklessly disregarded that Epstein engaged in a sex ra ffi ck in ve ntur as a at ter fl aw See CSMF i,i Furth er co nt de that the i te mat ri a cannot presented at trial in admissib le fo 1m Ex at Id JPMC Response Disputed in sofa as USVI co nt ds at he ci ted document establishes th at Epstein was engaged in a sex ra ffi ck in ve ntur as a at ter fl aw or that JPMC knew or recklessly disregarded that Epstein engaged in a sex ra ffi ck in ve ntur as a at ter aw See CSMF i,i Furth er co nt de that the i te mat ri a cannot presented at trial in admissib le fo 1m Ex at Case Document Filed Page of JPM Re pon Disp ut ed in sofa as USV I conte ds at ci ed doc um es ablis es hat Eps in was gaged in a sex rnffick in ve ntur as a at of law or at MC knew or rec kl ess i srega ded a stein gaged in a sex rnffick in ve ntur as a at fl aw See CSM i,i Fu rt er co te de at i te ate ia ann ot prese ted at trial in admissib fo 1m filed a creditor claim in the Epstein estate probate proceeding alleging that Epstein sexually abused her in New York and the US Virgin Islands eginning in and continuing/or years thereafter Ex i JPM Re pon Disp ut ed in sofa as USV I conte ds at ci ed doc um es ablis es hat Eps in was gaged in a sex ra fick in ve ntur as a at of law or at MC kn ew or reckless i srega ded a ste in gaged in a sex ra fick in ve ntur as a at er fl aw See CS MF i,i Fu rt co te de at i te ate ia ann ot ese ted at ial in admissible fo 1m filed a creditor claim in the Epstein estate probate proceeding alleging that Epstein sexually abused her in New York New Mexico and the US Virgin Islands from to Ex I I JPM Re pon Disp ut ed in sofa as USV I co te ds at ci ed doc um es ablis es th at Eps in was gaged in a sex raffick in ve ntur as a at of law or at MC kn ew or rec kl ess i srega ded a ste in gaged in a sex raffick in ve ntur as a at fl aw See CS MF i,i Fu rt co te de at i te ate ia ann ot ese ted at ial in a dmi ssib fo 1m ozens of Epsteins victims filed private civil suits against him and his coconspirators including but not limited to a Jane oe No who alleged that in or when she was years old Epstein sexually assaulted her during a massage in Epsteins Palm each residence Ex i Case Document Filed Page of JPMC Response Undisputed that a pl a in tiff proceeding under the eudonym Jane Doe No filed the cited private civil uit and made these a lle gatio in cited private civil ui Disputed in sofa as USVI conte ds at he ci ed document establishes th at Epstein was engaged in a sex rnffick in ve ntur as a at ter oflaw or that JPMC knew or reckle ss di regarded that Ep tein engaged in a sex rn ffi ck in ve nture as a at ter aw See CSM i,i Furth co nt de that the i te mat ri a cannot presented at trial in admissible fo 1m wh alleged that in when was years old Epstein sexually assaulted her more than times during massages in his Palm each residence Ex at i i Epstein paid each time Id at i JPMC Response Undispu ed that a pl a in iff proceeding und th se ud nym made these a lle ga ions in the i ed private civil uit Disputed in sofa as USVI co nt ds at he cited documen establishes th a Epstein was engaged in a sex raffick in ve ntur as a at ter fl aw or that JPMC kne or recklessly disregarded that Epstein engaged in a sex raffick in ve ntur as a at ter aw See CSMF i,i Furth co nt nded that the i ed mat ri a cannot presented at ri al in a dmi ssib le fo 1m Jane Doe No who alleged that Epste in abused her for four years starting in when she was years old She traveled with Epste in to locations including New York City Santa Fe Los Angeles San Francisco St Louis Europe the Caribbean and Africa and in each location Epste in abused her to serve his every sexual whim i i JPMC Response Undispu ed that a pl a in iff proceeding under the se ud Jane Doe No ade the se allegations in th cited private civi ui Disputed in sofa as USVI conte ds at he ci ed documen establishes th at Epstein was engaged in a sex raffick in ve ntur as a at ter fl aw or that JPMC kne or recklessly disregarded that Epstein engaged in a sex ra ffi ck in ve nture as a a ter aw See CSM i,i Furth co nt de that the i ed mat ri a cannot presented at trial in admissible fo 1m Case Document Filed Page of Jane Doe who alleged that she was recruited into Epsteins sex trafficking scheme beginning in October and continuing through April Ex i i Epstein and his recruiters told Doe that Epstein would secure her admission to fashion school in New York City Doe was coerced into engaging in sexual acts with Epstein both in New York and in the US Virgin Islands Id i While in the US Virgin Islands Epstein maintained control of Doe passport and once conducted a search party to find Doe after she attempted to escape the island Id i JPM Re pon dis pu ted a a la in tiff proceed in un der se do Ja Doe No ade th ese a ll egatio in th cited ivate civ il su i Disp ut ed in sofa as USV I conte ds at ci ed doc um es ablis es hat Eps in was gaged in a sex rnffick in ve ntur as a at oflaw or at MC knew or recklessly i srega ded a stein gaged in a sex rnffick in ve ntu re as a at er law See CSM i,i Fu rt er co te de at i te ate ia cannot prese ted at trial in admissible fo JPM Re pon ated in fo 1m atio Ex at Disp ut ed in sofa as USV I conte ds at ci ed doc um es ablis es hat Eps in was gaged in a sex raffick in ve ntur as a at of law or at MC knew or recklessly i srega ded at stein gaged in a sex raffick in ve ntur as a at er fl aw See CSM i,i Ex at Case Document Filed Page of Id at Id at Id at Disputed in sofa as USVI conte ds at he ci ed documen establishes th at Epstein was engaged in a sex rnffick in ve ntur as a at ter oflaw or that JPMC knew or recklessly disregarded that Epstein engaged in a sex rnffick in ve ntur as a at ter law See CSM i,i Ex at Id at Id at JPMC Response Disputed in sofa as USVI co nt ds hat he ci ted documen establishes th a Epstein was engaged in a sex rnffick in ve ntur as a at ter oflaw or that JPMC knew or recklessly disregarded that Epstein engaged in a sex rnffick in ve ntur as a at ter law See CSMF i,i Ex at Id at Case Document Filed Page of Id at Ex at JPMC Response Disputed in sofa as USVI conte ds at he ci ed documen establishes a Epstein was engaged in a sex rn ffi ck in ve nture as a a ter aw or that JPMC kn ew or recklessly disregarded that Epstein engaged in a sex rn ffi ck in ve nture as a a tter aw See CSMF i,i Ex at Ex at Id at JPMC Response Disputed in sofa as USVI co nt ds at he ci ted documen establishes that Epstein was engaged in a sex rn ffi ck in ve ntur as a at ter aw or that JPMC knew or recklessly disregarded that Epstein engaged in a sex rn ffi ck in ve ntur as a a tter aw See CSMF i,i Ex at Id at Case Document Filed Page of Id at Ex at Disputed in sofa as USVI conte ds at he ci ed documen establishes th at Epstein was engaged in a sex rnffick in ve ntur as a at ter oflaw or that JPMC knew or recklessly disregarded that Epstein engaged in a sex rnffick in ve nture as a a ter law See CSM i,i at Id at Id at Disputed in sofa as USVI co nt ds at he ci ted documen establishes that Epstein was engaged in a sex rnffick in ve ntur as a at ter law or that JPMC knew or recklessly disregarded that Epstein engaged in a sex rnffick in ve ntur as a a tter law See CSMF i,i JPMorgan processed wire payments from Epstein to women in years that coincided with the women tr;ps to the US Virgin Islands with Epstein a Ex at Case Document Filed Page of I Di sp ut ed in so far as USVI conte ds at he ci ed documen establishes th at Epstein was engaged in a sex rn ffi ck in ve ntur as a at ter fl aw or that JPMC knew or recklessly disregarded that Epstein engaged in a sex rn ffi ck in ve nture as a at ter aw See CSM i,i at Id Disputed in sofa as USVI co nt ds at he ci ted documen establishes th at Epstein was engaged in a sex rn ffi ck in ve nture as a at ter fl aw or that JPMC kn ew or recklessly disregarded that Epstein engaged in a sex rnffick in ve ntur as a at ter aw See CSMF i,i Ex at Disputed in sofa as USVI conte ds ha he ci ed documen establishes th at Epstein was engaged in a sex rnffick in ve ntur as a at ter oflaw or that JPMC knew or recklessly disregarded that Epstein engaged in a sex rnffick in ve ntur as a at ter aw See CSM i,i Case Document Filed Page of Ex at Disputed in sofa as USVI conte ds at he ci ed documen establishes th at Epstein was engaged in a sex rnffick in ve ntur a a at ter oflaw or that JPMC knew or recklessly disregarded that Epstein engaged in a sex trnfficking ve nture as a at ter law See CSM i,i Ex at Disputed in so far as USVI conte ds at he ci ed documen establishes that Epstein was engaged in a sex trnfficking ve ntur a a at ter law or that JPMC knew or reckle ss ly di regarded that Ep tein engaged in a sex trnfficking ve ntur as a a tter law See CSM i,i Ex at Disputed in so far as USVI co nt ds at he ci ted documen establishes that Ep tein was engaged in a sex trnfficking ve ntur a a at ter law or that JPMC knew or reckle ss ly di regarded that Ep tein engaged in a sex trnfficking ve ntur as a atte law See CSMF i,i Case Document Filed Page of Ex at Disputed in sofa as USVI co nt ds at he ci ted documen establishes th a Epstein was engaged in a sex rnffick in ve nture as a a ter oflaw or that JPMC kn ew or recklessly disregarded that Epstein engaged in a sex rnffick in ve ntur as a at ter law See CSMF i,i JPMorgan Knew or Recklessly Disregarded that Epstein Ran a Sex-Trafficking Venture JPMC Response Thi i a eade hi response i wairn ed Disputed in sofa as USVI co ends th a the sta tement a nd documen cited below establish that JPMorgan knew or recklessly disregarded that Ep ein ran a sex traffi kin ve ntur as a matt la JPMorgan admits Mary Erdoes Catherine Keating a Mary Casey were aware in that Epstein wa arrested for solicitatio of prostitution Ex at Resps JPMC Response Undispu ed that Erdoes Keatin and Casey were awai of Ep steins aiTes for solici atio of prosti uti Disputed in sofa as USVI co nt ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Ep ein ran a sex traffi kin ve ntur as a matt la See CSMF i,i An internal JPMorgan do ument defines Know Your Client KYC a a due diligence process that en ures we know the clients deal with a understand how and they our products and services Wit out KYC we become vulnerab Unknowing to our client cou easil use PCS as a vehicle to pe1petrate illega activitie Ex at JPMC Response Di pu ed to he ex ent USVI mi ss ates he ci ted documen The doc umen defines KYC as Kn ow ur mer USVI Ex at he1 wise undi sputed th at th cited docume nt co a in the qu oted tex Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga knew or recklessly disregarded that Ep ein ran a sex traffi kin ve ntur as a matt la See CSMF r,r Ex at the i ed document co nt a in he quoted te xt Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPMorgan knew or recklessly disregarded Epstein ran a sex traffi ck in ve ntur as a matt aw See CSMF r,r Red Dot information is any derogat01y information identified by Global Security Services which warrants the attention of the banker Ex at JPMC Response Undispu ed that the i ed doc umen co nt a in he quoted te xt Disputed in sofa as USVI co nt ds at hi fac upp i an inference at JPMorgan knew or recklessly disregarded that Ep ein ran a sex traffi kin ve ntur as a matt er la See CSMF r,r JPMorgan due diligence process required that it research and review news publications about clients or clients businesses Ex at JPMC Response Undispu ed that Casey estified that the re i ew ews epo rt publications wi th respect to he clien th li nt business we paii er du diligence review USVI Ex A Di spute to the ex ent USVI asse1 i that this tes im about Casey ow ue diligence wo rk establishes a fact about JPM Cs overa ll due diligence pro cess and policies Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPMorgan knew or recklessly disregarded that Ep ein ran a sex traffi kin ve ntur as a matt er la See CSMF r,r Negative news media was one of the main categories of information reviewed as part of JPMorgan ongoing due diligence monitoring Ex at Ex at Case Document Filed Page of JPMorgan Global Security Services searched databases for negative media regarding clients to escalate to bankers and risk management Ex at JPMorgan Private Bank conducted negative media reviews as part of its approach to determine whether a clients acti ity was suspicious Ex at JPMC Response Di pu ed to he ex ent hi paragraph co sis of SVIs UIIllnai Pea.in heridan McCleerey an Ryans te sti Disputed at cite USVI Ex upp 1t the prop os i ion that egative ne ws medi a was ne of he main catego rie fi JPM dT I SVI Ex at Disputed at JPM ga Glo al Sec urity Serv i ces sea hed da a ases for ne ga ti ve medi a regarding clien Undispu ed that JPMorgan Pri va a nk co cted ne ga ive media re i ews as pa.i of i approach dete nnin heth a clien activity was pi i Disputed in sof ai as USVI conte ds at hi fac upp an inference at JPM ga knew or recklessly disregai 267ded that Ep ein ran a sex traffi kin ve ntur as a matt la See CSM i,i A JPMorgan Due Diligence Report for Epsteins entity YHS LLC includes a section/or news publications Ex at JPMC Response Undispu ed that the i ed Due Diligence Repo1t fo YH LL include a sec ti itled Pu li ca ions SVI Ex at Disputed in sof ai as USVI conte ds at hi fac upp an inference at JPM ga knew or recklessly disregai 267ded that Ep ein ran a sex traffi kin ve ntur as a matt la See CSMF i,i Another JPMorgan Due Diligence Report for Epstein includes a section for news publications Ex at JPMC Response Undispu ed that the i ed Due Dili ge ce epo rt for Jeffrey Epstein include a sec ti in the able of Co nt nt titled Publi catio USVI Ex a Disputed the ex ten th a the cited pages were provided wi th Ex Disputed in sof ai as USVI conte ds at hi fac upp an inference at JPM ga knew or recklessly disregai 267ded that Ep ein ran a sex traffi kin ve ntur as a matt la See CSMF i,i Case Document Filed Page of Morgan admits certain JPMo rgan em yees received re iewed or read articles vering psteins arrest in i da at es JPMC Response Undi pu ed that rt a in JPM an emplo es ece i ed re ie ed or read aicl es ov erin Ep in a es in Fl ri da Di puted in so far as SV I ont ds a hi fac upp i an infer a JPM an kne or ckle ss di re arded that Ep in ran a traffi kin entur as a matt of la See CS MF i,i rgan admits certain rgan employees received re iewed or read a alm each ost article stating that Ep stein was indicted one unt of felony solicitation of rostitution Ex at esp JPMC Response Undi pu ed that 1i a in JPM an emplo es re ei ed re ie ed or read a a lm Be a ch os a1iicle tatin a Ep ein was indi ne un fel so li it at ion of pro ti uti Di put in so far as SV I ont ds at hi fa upp i an infer ce at JPM an kne or ckle ss di re arded that Ep in ran a traffi kin entur as a matt la See CS MF i,i The alm each ost article states alm each billionaire Jeffrey stein a i to have underage girls and young women brought to i home where he recei ed massages and somet i mes sex and police thought there was probable cause to charge pstein with unlawful sex acts with a min and lewd and lascivious molestation at The article lays out in detail i dence fr the alm each Po lice epartment robable Cause Affidavit including a A college student gave Ep stein a naked massage and then brought him six girls ages massage and sex tinged sessi ns at Ep stein home I at A year old stein employee re are the massage table I at would arrange the sessi ns and Po lice btained statements from five alleged victims and witnesses olice ntend pstein had sex with the girls on three occasi ns I at Case Document Filed Page of met Epstein at age and was recrnited to massage him Epstein told her he would pay her to bring him more girls the younger the better She stated she once brought a 23-year old woman to him and Epstein said she was too old She brought six girls to Epstein and said the girls were paid for each session told police Im like a Heidi Fleiss Id at One year old victim recounted the details of her encounter in February including being paid for a massage in her bra and panties For bringing this child to Epstein received Id at Police scoured the trash from Epsteins house and found notes with names and phone numbers sex toys and female hygiene products Notes stated that one female could not come over at p.m because of soccer Another said a girl had to work Sunday Monday after school And still another note contained the work hours of a girl saying she leaves school at a.m and would come over the next day at a Id at JPM Re pon dis pu ted a lm eac ost aicle co ta in i ted in fo nn atio is pu ted as to SVIs chai 267acte izat i at th a rti cle ays in detai evide ce a lm eac li ce robable Ca se A ffi davit Disp ut ed in sofa as USV I co te ds at is fact upp i a in fe ce at JP Mo ga knew or rec kl essly i sreg ai ded a pste in ran a sex raffi kin ve ur as a atte aw See CSMF i,i urth co nt ded hat th cited ater i al ca nn ot ese ted at i al in ad mi ssib fo The Palm Beach Post article also states Palm each police often conducted surveillance at Palm Beach International Ailport to see if his private jet was there Ex at JPM Re pon dis pu ted i ted a lm eac ost a 1ii cle co nt a in quoted tex Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r Further co ntend ed th at th cited ater ial ca nn be pr ese nt ed at ri al in admissible fo1m The Palm Beach Post article said that Epstein paid or cash to the girls and cash to for recruiting the girls Ex at JPMC Response Undispu ed the i ed a lm Be ac ost article co nt a in he ci ed in fo 1m atio The cited docle nt speaks for i self Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga knew or recklessly disregarded that Epstein engaged in a sex ra ffi ck in ve ntur as a matt of law See CSMF r,r Fm i her co ended a th cited a erial ca nn be presen ed at trial in admissible fo1m JPMorgan admits the Palm Beach Post article mentioned Ex at Resp JPMC Response Undispu ed that the Palm eac os ai i icle nti ed Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r Fmiher co ntend ed th a the cited a erial ca nn be pr ese nted at trial in admissible fo1m The Palm Beach Police Department Probable Cause Affidavit discussed in the Palm Beach Post article was filed May Ex at JPMC Response Undispu ed that the i ed Prob ab Ca se Affidavi from he a lm Bea ch li ce Depai i men was dated May Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r Fmiher co ntend ed th a the cited a erial ca nn be pr ese nted at trial in admissible fo1m JPMorgan admits certain of its employees received reviewed or read one or more articles that reference JPMorgan otherwise refers to those articles for their contents Ex at Resp Case Document Filed Page of JPM Re pon dis pu ted a ce 1t a in of JP MCs oyees eceived eviewed read or aiti cl es at fe re ce Disp ut ed in sofa as USV I conte ds at is fact upp ts a infe ce at JP Mo ga knew or rec kl essly i srega ded a ste in ran a sex tra ffi kin ve ur See CSMF r,r A Ju ABC News article Warrants Were Prepared to Arrest Others in Millionaire Sex Scandal states Palm Beach police were planning to arrest two women in connection with their investigation into Jeffrey Epstein Epstein assistant who police say was paid by Epstein to bring over young and underage girls to his house to massage Epstein Another woman involved in the scandal was Epstein girlfriend Though the documents do not mention that any charges were being sought against one girl who began massaging Epstein when she was ears old told police that she was paid by Epstein to have sex with as he watched The girl also told police that Epstein bragged he brought her into the United States to be his Yugoslavian sex slave according to the documents The article also states that the police submitted arrest warrant requests for and According to the report was to be arrested on four counts of unlawful sexual activity with certain minors and on one count of lewd and lascivious molestation warrant was.for lewd and lascivious acts on a victim under years of age Ex at JPM Re pon dis pu ed a i ed doc um ent co nt a in quoted ext Disp ut ed in sofa as USV I conte ds at is fac upp a infe ce at JP Mo ga knew or rec kl ess i srega ded a ste in ra a sex raffi kin ve ur See CSMF r,r mth co nt ded th a th cited a er i a ca nn be pr ese nt ed at trial in admissible fo1 On August Doreen Hewitt emailed Maria Hornak Mary Casey and other JPMorgan employees subject Re Article of Epstein Arrest with the link Case Document Filed Page of http nypost com news regionalnews myste1y moguls teen sex secret bared in _yrobe egionalnews dan mangan.htm Ex at The article states a According to one girl Epstein asked for her real age and she stated she was Epstein advised her not to tell anyone her real age the records say The girl alleged Epstein paid her to have sex with his girlfriend Epstein would then watch the women have sex and take photos of their trysts to display at home the records claim The teen told cops she always refused to have intercourse with Epstein But one time Epstein allegedly grabbed her and forced himself on her When the girl became upset and screamed Nol Epstein apologized and he later paid her for the visit the records allege Palm each cops prepared an arrest warrant request proposing that Epstein be charged with unlawful sexual activity with certain minors and with lewd and lascivious molestation I nstead in a rare move prosecutors brought the evidence to a grand jury which indicted Epstein only on the prostitution charge The frustrated police now have given their evidence to the FBIs Miami division which is considering whether to investigate Epstein for possible federal crimes involving underage girls said Special Agent Judy rihuela The article also states that Epstein assistant helped arrange the sessions and that everal girls allege that led them to Epstein master bedroom where she would set up a massage table and give them oils to rub on Epstein Cops wanted to charge and for their roles in procuring the girls Ex at JPM Re pon dis pu ted a ewitt se nt an ail dated A co ta inin th ink to ci ed a 1ti cle a th at th a 1ti cle co nt a in quoted ext Case Document Filed Page of Disputed in sofa as USVI co nten ds at hi fac upp i an inferen ce at JPM ga knew or recklessly disregarded that Epstein ran a sex traffickin ve nture See CSMF r,r Further contended th at th cited ater ial ca nn be pr ese nt ed at ri al in admissible fo1m In AML Operations Human Trafficking Overview A Reference Document on human trafficking prepared by JPMorgan C01porate AML Compliance dated August JPMorgan states Sexual Slavery means the coercion of the unwilling into various sexual practices Ex at JPMC Response Di pu ed to ex ten USVI mi ss ates th documen hi i desc ribed as a Refe ce oc len hlan trafficking prepared by JPMC Corpora AML Co mplian ce USVI at Und i sputed th at th i ed ocle nt ates Sexual Slave is a tenn that describes any coe cio of he un wi llin in var i sexual practices Id a Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r Ex at Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPMorgan knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r On July Staley met with Epstein in person at Epstein home In that visit Epstein admitted to the alleged conduct of engaging in sex for money with young women only denying the ages to Staley Ex at Case Document Filed Page of JPM Re pon dis pu ted a aley testi fi ed as uoted text Di sputed as un de rl in fact exte nt i equ ir es a credibi li ty deten nin atio Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga knew or rec kl essly i srega ded a stein ran a sex raffi kin ve ur See CSMF r,r On July Staley wrote Erdoes I went and saw him last night Ive never seen him so shaken He also adamantly denies the ages Ex at JPM Re pon dis pu ted a ci ed doc um conta in qu ed text Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga knew or rec kl ess i srega ded a ste in ra a sex raf fic kin ve ur See CSMF r,r Staley admits that in Jamie Dimon communicated with him regarding Epstein arrest on charges of procuring a minor for prostitution and solicitation of a prostitute Ex at Resp Staley also testified that on or about July he spoke to Dimon about Epstein indictment because Dimon was his boss and the indictment of Epstein a client of the bank was a ve1y public event Ex at JPM Re pon is pu ted im clea rl and epeated tes ti fied a did speak to Staley abo ut ste in ind i tm nt in Did you spea i Jes Sta ey abo ut fact th at Epste in a bee in dicted A I i ot Did yo rece i ve a re i fr Jes Sta ey hat had visi ed i pste in day or so afte th in dict A I i ot Did Sta ey in fo1 yo at Eps in said wi th es ect th in dic tm ent hi ad bee et urn ed a day two before A ope Did yo speak i Staley a all in yea about pste in Case Document Filed Page of A I don ecall eve av in a conversation wit him a ut Jeff Ep tein JPMC Ex at see also JP MC Ex at No den in that Dim was awa re in that Epstein ad been a ested for pro st ituti an d/o sex a mi sco duct Di puted in so far as USV I conte ds at is fact upp is an inference at JPM an kne or reckle ss ly di re arded that Epstein ran a sex trafficking venture See CSMF r,r JPMorgan admits that certain of its employees received reviewed or read the Vanity Fair article The Talented Mr Epstein and refers to the article for its content Ex at Resp JPM Re pon se Undisputed that JPMC a dmit that ce rt a in its employees eceived re iewed or read the Vanity Fa ir article The Talented Mr Ep ste in Di puted in so far as USV I conte ds at is fact upp is an inference at JPM an kne or re kle ss ly di re arded that Epstein ran a sex trafficking venture See CSMF r,r I May Casey then Rieth sent the Vanity Fair article along with the ue Di ligence eport DR for Epstein Financial Trust Company I nc to JPMorgan employee Paul Lahiff so he would get eve1ything at once Ex at JPM Re pon se Di puted The i ted ema il does ppo rt the conte nti at Casey hen Rieth se nt the Va ity a ir aii i cle along i th the Due Dili ge nce Rep i to Paul Lahiff The cited email ates Ju st go the DDR back thi rnin wi ll ave it a ppro ved the aftern oo I was wa i ting to pull eve1yth in together before se ndin dow Va ity a ir aicle so yo ll get eve yt hin at ce USV I at Neither the Va ity a ir aii i cle the cited DDR ai attac ed to the ema il fr Rieth to Lahiff nor does the emai establish that Casey in fact se nt ese materi a to a hiff Disp ut ed in so far as USV I conte ds at hi fact upp is an inference at JPM an kne or re kle ss ly di re arded that Epstein ran a sex trafficking venture See CSMF r,r The Talented Mr Epstein states Epstein is known about town as a man who loves women lots of them mostly young Model types have been heard saying they are full of gratitude to Epstein for flying them around and he is afamiliarface to many of the Victoria Secret girls ne young woman recalls being summoned by Ghislaine Maxwell to a concert at Epstein town Case Document Filed Page of house where the women seemed to outnumber the men by far These were not women youd see at Upper East Side dinners the woman recalls Many seemed foreign and dressed a little bizarrely This same guest also attended a cocktail party thrown by Maxwell that Prince Andrew attended which was filled she says with young Russian models Some of the guests were horrified the woman says Ex at JPM Re pon dis pu ted a i ted doc um ent co nt a in quoted ext Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga knew or rec kl essly i srega ded a stein ran a sex tra fic kin ve ur See CSMF r,r urt he co nt ded hat he cited mater i al ca nn be pr ese nt ed at trial in admissible fo1m The Talented Mr Epstein states There are many women in his life mostly young but there is no one of them to whom he has been able to commit He describes his most public companion of the last decade Ghislaine Maxwell the daughter of the late disgraced media baron Robert Maxwell as simply his best friend Ex at JPM Re pon dis pu ted a i ted doc um ent co nt a in quoted ext Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga knew or rec kl ess i srega ded a stein ra a sex tra fic kin ve ur See CSMF r,r mi he co nt ded th at he cited ater i a ca nn be pr ese nt ed at trial in admissible fo1m Id at Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r Ex at Id at Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPMorgan knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r Ex at Id at Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r A JPMorgan training document What is Human Trafficking identified structured transactions as a Key Indicator Red Flag of potential Human Trafficking activity Ex at Ex at JPMC Response Undispu ed that a JPM documen ti led Hlan Trafficking ates tru tur ed tlan sac ions paicularly those co cted via MS ai Key indica ors/Re fla gs of ential Hlan Trafficking activity Di pu ed as to ate ri ality The ci ed doclent was ea in May and JPM termina Epstein as a client in Case Document Filed Page of See SUM JPM policies and rn inin gs evolved in line wit in st:Iy andards wit es ect AML and hum a t:Iafficking see JPM at but post-exit ti inin ate ri als are imm ater ial to JPM co ndu related Epstein and cannot sed to es ab li he prevailing andards at JPM th in t:I urin the rel evant time ri od Disputed in sofa as USVI co nt ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex ti afficking ve ntur See CSMF r,r The JPMorgan training document also states Previous AML history while not necessaril HT-related ma be associated with an investigation related to suspicious activity such as interstate e.xcessive or structured cash activity Ex at JPMC Response Undispu ed that the qu ed rti of the i ed de os i ion in hi th questioner pmpo1is to be re ad in fr a JPM t:Iaining document co a in the qu ted lan age Di sputed the extent that tes im es a li es hat the doc um nt in fact says as USVI as provided a ci th documen and ass umin USVI is efeIT in her ein to he doc umen ubmitt ed as USVI Ex disputed for the re aso disc ssed in response to Disputed in sofa as USVI co nt ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex ti afficking ve ntur See CSMF r,r Ex at Disputed in sofa as USVI co nt ds at hi fac upp i an inference at JPMorgan knew or recklessly disregarded that Epstein ran a sex ti afficking ve ntur See CSMF r,r Case Document Filed Page of Ex at Disputed in sofa as USVI co nt ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex ra ffi kin ve ntur See CSMF r,r From October through Jul JPMorgan handled in pa ments from Epstein JPMorgan accounts to Ghislaine Maxwell Ex at and Figure JPMC Response Di pu ed to he ex ent USVI mi ss ates he ci ed Fi ur Figure ows transactions aling the amount ci ed by SVI occ unin between October and Jul Othe1wise un disp ut ed at he ci ed Fi ur hi ch i a ummai of transactions pr epai by USVIs proff ere expe1i Jorge A ado ows he ci ed transactions Di sputed th a thi in fo nn atio was availa JPMorgan in thi fonnat during he time Ep ein was a li nt of JPMorgan Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex ra ffi kin ve ntur See CSMF r,r Ex at Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex ra ffi kin ve ntur See CSMF r,r Case Document Filed Page of was a customer of JPMorgan Ex at Re JPMC Response Undispu ed that was a sto mer of JPMorgan Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r had a credit card with the Retail Bank Ex at JPMC Response Undispu ed that had a credi ca wi th the Retail Banl Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r In JPMorgan made two eparate pa ments from Epstein JPMorgan accounts to at a i gure JPMC Response Undispu ed that the i ed Figure hi is a umrna1 of transactions pr by USVIs proff red expert Jo ge A ado ows two transactions Di pu that this infonn ation was available JPM ga in this fo1mat during he time Ep ein was a li nt of JPMorgan Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r From August through August JPMorgan hand ed in pa ments from Epstein JPMorgan accou to Ex at and Figure JPMC Response Undispu ed that the i ed Figure hi is a ummai of transactions pr epared by USVIs proff red expert Jo ge A ado ows ran sactio to to a lin fr Januaiy hrou A st Di spute th a thi in fo 1m atio was availa le JPM ga in hi fo1mat during he time Ep ein was a client of JPMorgan Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregai ed that Epstein ran a sex traffi kin ve ntur See CSMF r,r as a customer of JPMorga at Resp JPMC Response Un isputed th at was a of JPM ga Case Document Filed Page of Disputed in so far as USVI co nt ds at hi fact upp is an infer ce at JPM ga knew or reckle ss di regarded that Ep tein ra a sex traffi kin ve ntur See CSMF r,r In sponsored by Epstein JPMorgan ope ned accounts and credit cards for two teenagers and models in NYC and friends of Jeffrey Ep stein at at at JPMC Riis onse Undi ted that in JPM ga ope ed DD A account and credi ca ds fo and a nd at st ein was the a rant or Disputed a to SVIs a ra cte rizati at and we ee agers at thi time See SVI Ex in dica tin at and were yea of age Undi pu te that SVI Ex co nt a in he quoted te xt Disputed in so far as USVI conte ds at hi fact upp is an inference at JPM ga knew or reckle ss di regarded that Ep tein ra a sex traffi kin ve ntur See CSMF r,r The DDRfor was originally a pproved in Feb ruary Ex at Disputed in so far as USVI conte ds at hi fact upp is an inference at JPM ga knew or reckle ss ly di regarded that Ep tein ran a sex traffi kin ve ntur See CSMF r,r The DDRfo was appr ov ed by the Pr ivate Ba nk even though there was no birthdate passport number drivers license number or nfirmed social security number The rivate Ba nker Casey never met as JPMorgan process contemplated Ex at JPMC Res ted Additio a documentation co mplet ed in co nn ectio wi th the ope nin JPM account included her birth date hi in dica ed at acco unt wa ened years ld See JPMC Ex at That document also ows that app li catio was ver ified by two fo1m identification er pa ss port an a a driver licen se Id at Additional docume nt atio also co nfinn th at JPM personnel did ee in so See JPMC Ex Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r The DDR stated that is a Slovakian citizen who has come to the US for modelling work Jeffrey Epstein knows the model personally and Jeffrey Epstein often provides support to emerging models In this case has arrived from the Slovak Republic and Epstein has asked us the favor of opening a checking account for her and he will guarantee her credit card application Ex at JPMC Response Undisputed that the i ted doc umen contains he quoted te xt Disputed in sofa as USVI conte ds at hi fact upp is an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r The DDR represented net worth as earned from modeling assignments Ex at JPMC Re ted to he extent USVI mi sstates he document The document ates th at earned her wea lth through odell in assignments USVI at Othe1wise undi sputed Disputed in sofa as USVI conte ds at hi fact upp is an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r The DDR listed address as Ex at Ex at that the i ted DDR Case Document Filed Page of Di puted in so far as SV I onten ds a hi fac upp i an inferen a JPM an kne or re kle ss di re arded that Ep tein ran a traffickin enture See CS MF r,r I and Morgan handled and respectively in payments from Ep steins Morgan accounts Ex at and igure JPMC Response Undi pu ed that th i ed Fi ur hi i a unai tran a ti prep a red SV I proff red 1i Jo Am a ows tran sac i ith he cited am unt in and Di pu ed that thi a a va il a bl JPM an in thi fo1mat durin he tim Ep ein was a li nt JP Mo an Di put in so fai as SV I co nt ds at hi fa upp i an infer ce at JPM an kne re kle ss di re arded that Ep in ran a traffi kin entur See CS MF r,r January I yan AM liance emails eLuca AM Compl i ance pying i ddlemiss AML Compl i ance I also spent a good deal i me oo king at his assistant or young lady he brought ov er fr raque sic or me lace i ke that acc unt She was invol ed in some of the detailed esca ades She pened accounts in PB spons red him my were her debit transactions enlighting sic as ared to countless st ries related to his escapades ots of salon lingerie sh ps drug st res ny palm beach and in st th mas his places residence lus lots video like girls ne wild and some other sho not fit for my oo cath lic upbringing The transactions are old esides frequent spa like charges it has died wn Sur rised she was never sub oenaed at _R JPMC Response Di pu ed he ent US VI mi ss a es he cument Th as tw ent th qu ted langu age a Be id es fr quent frequent pa lik a ges it as di ow urpri se was ne ve ubp oe ned i SV I a Othe1 i se undi pu ed that th it cumen co nt a in th qu ed lan age Di put in so fai as SV I co nt ds at hi fa upp i an infer ce at JPM an kne re kle ss di re arded that Ep in ran a traffi kin entur See CS MF r,r Case Document Filed Page of JPMorgan own Human Trafficking white paper Human Trafficking Finance Nature Scope and Control Project discussed upscale sex trafficking operations incurring expenses such as jeweby lingerie cosmetics and sex toys Ex at JPMC Response Undispu ed that the i ed document dated Nove mber a ed that a so ur ce pro vided background for th initia tive ated up scale eratio in mTe expenses as jewehy lingerie cos tic sex oys as we ll as airlines tel casinos gro und transpo1 i atio se vices spo1i in even and conce1is USVI at Disputed in sofa as USVI conte ds at hi fac upp i an infer ce at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r From August through January JPMorgan handled in payments from Epstein JPMorgan accounts to Ex at and Figure JPMC Response Di ex ent USVI mi ss ates he ci ed Fi ur Figure ows transactions ota lin occ mTin fr Sep tember through Januai he1 wise undi sputed th at th cited Figure hi is a umrna1 of ra sac ti pr epa red SVIs proffered expe1 i Jorge Amador ows the ci ted transac ions Di pu ed that this infonn a ion was avai able to JP Morga in this fo1mat during he time Ep ein was a li nt of JPMorgan Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregai 267ded that Epstein ran a sex traffi kin ve ntur See CSMF r,r Ex at Case Document Filed Page of I at Di put in so far as SV I nt ds at hi fa upp i an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r The article cited Meet Star irl of the aunchiest art of stein Scandal first ublished on July referred to as star girl of Epstein scandal and an unkn wn Czech sex pp et steins Ex at JPMC Response Di pu he ent US VI gg that a yo a JPM ec ei re ie rea th it ed aicl i a fir ubli Jul as un rt he it at i Di put in so far as SV I co nt ds at hi fa upp i an infer ce at JPM an kne re kle ss di re arded that Ep in ra a traffi kin entur See CS MF r,r Fmiher co ntend ed th a the it ed a erial ann pr ese nted at ri a in a dmi ss ible fo1m March Mar i a Ho rnak rwards an email fr ich ahn Epstein accountant Mary Casey subject New Chase Credit Cards with the attachment Chase Credit Cards xis at The attachment lists Jeffrey stein Chase Credit Cards for and through NES LL c/o Jeffrey stein Expected charges on the credit cards were for travel through aris uro and US Vi rgin I slands and US monthly I at JPMC Response Undi pu ed that rn ac fo wa rd ed the a il Casey Mar a nd a he a ac hmen li a nd as Ca rdh er throu NES Case Document Filed Page of LLC Di pu ed to he ex ent USVI arac teri zes tr ave through a ri Eur ope a nd US Virg in I lan ds an US hl as expec ted arges the credi ca ds as un upp i ed by the i ed document The quote language i includ ed in a co lumn titled Notes and provides in dica ti at he se a th expec ed a ges USVI Ex a Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r The attachment also lists credit cards for Lany Visoski and David Rodgers through Jege LLC Ex at Ex at JPMC Response Di pu ed to he ex ent USVI mi ss ates he document The ci ted document includ es odge and Visoski as Car dh ld but the li sted Epstein entity i JEGE In not Jege LLC SVI Ex at Othe1wise undi pu ed Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r On June Bonnie Perry in Private Bank Risk Management emailed Epstein then banker Paul Morris entities within the relationship do not currentl ha DDRs East th St LLCl NES LLCl and Zorro Trust Ex at JPMC Response Undispu ed that Pen emailed Monis June and the i ed document co nt a in he quoted te Disputed in sofa as USVI co nt ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r Ex at Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregar ed that Epstein ran a sex traffi kin ve ntur See CSMF r,r On ctober JPMorgan held a Rapid Response Team meeting Ex at Case Document Filed Page of JPM Re pon dis pu ted a doc um in dicates th at JP MC a Rap i espo se eam eeting Octobe Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga knew or rec kl essly i srega ded a stein ran a sex raffi kin ve ur See CSMF r,r Rapid Response meetings were escalations of derogatory information to management who would review it and make a determination on how they want to proceed JI Ex at JPM Re pon is pu ted to ex th at USV I mi ss ates th ote a age testi fi ed hat a ra id espo se ee tin is an escalatio of in fo nn atio hat was ro ht to derogato info1 a ti ere i seems so et hin hat ld be escalated up to a age ent a th ey st we give fac th ey eview i and mak a dete1 min atio ow ey want to proceed SVI at Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga knew or rec kl essly i srega ded a stein ran a sex raffi kin ve ur See CSMF r,r The Rapid Response meeting memo notes Derogatory Information reported by Security Services Several newspaper articles were found that detail the indictment of Jeffrey Epstein in Florida on felony charges of soliciting underage prostitutes JI Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext Disp ut ed in sofa as USV I co te ds at is fact upp i a in fe ce at JP Mo ga knew or rec kl essly i srega ded a stein ran a sex raffi kin ve ur See CSMF r,r The memo from the Rapid Response meeting stated that Epstein had accounts with balances totaling approximatel million JI The Rapid Response memo also noted Cash withdrawals are routinely made in amounts for to several times a month which total over year to date JI Ex at JPM Re pon dis pu ted a i ted doc um ent co nt a in quoted ext Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r Ex at Disputed in sofa as USVI conte ds at hi fact upp is an inference at JPMorgan knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r In and JPMorgan recorded cash withdrawals from Epstein JPMorgan accounts totaling Ex at and Figure JPMC Response Undisputed that the i ted repo1i fU SVIs proff red expe1i Jo ge A ado includ es a hai i th at asse 1i th at the CTRs ge ne rated by JPMC relating Epstein in and we re and es ective and th at together th ose a unt equal Di sp ut ed as to USVIs ai riz atio th at JP MC ecor ed cas i drawa at hi info1mation was ava ilabl JP Morgan in hi fonnat during he time Ep ste in was a client of JP Morga Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fac upp is an infer ce at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r Ex at emphasis added Ex at Disputed in sofa as USVI co nt ds at hi fac upp is an infer ce at JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r Id Disputed in sofa as USVI conte ds at hi fac upp is an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r Case Document Filed Page of July yan AM compliance emailed uca AM compliance subject Epstein more info found and states Issue is he reall never stopped the large cash withdrawals Ex at uca res onds Sh uldn the business have been telling us this I at JPMC Response Undi pu a an email DeLu ca Jul and th a the it a il co ntain th qu langu age Di put in so far as SV I co nt ds at hi fa upp i an infer ce at JPM an kne ec kle ss di re arded that Ep in ran a traffi kin entur See MF r,r Jul Jo hn Duffy then CE US rivate ank emails rdoes then CE A WM subject JE talking ints and asks what rd es thinks of three talking oints for Epsteins exit conversation The repetitive nature of your cash transactions is a blem us and our relationship with you The regulatory standards in the banking i ndustry ntinue olve with a ery lerance cash activity when mb i ned with your ers nal history So given the intersect io these circumstances we are i a uniquel challenged situation emediati is required and we need ask you in an orderly manner to find an ther bank ur needs Ex at rdoes replies I think that i fine I JPMC Response Di pu ed he en US VI mi ss a es he doc ument th ub ct th i ed em a il i JE talkin See US VI at Di put as th prop os iti th at th draft thr talkin int we re in fa se for Ep in ex i ve ati as upp 1ied he cited cumen he1 i undi pu ed Di puted in so far as SV I co nt ds a hi fac upp i an infer a JPM an kne ckle ss di re arded that Ep in ran a traffi kin entur See MF r,r The a pi esp nse eam mem states Conclus io from foll up apid es onse urther meetings held with es Staley discuss OB decision for reapproval anker aul Morris sp ke with Mr Ep stein with regard large cash withdrawals Mr ste i withdraws anywhere from i cash ay forfuel expenses when he travels to fore i gn countries Case Document Filed Page of Banker Paul Morris was instructed by the Committee to update the entity KYC which holds the operating account for Mr Epsteins personal ailplane Hyperion to document the purpose of the cash withdrawals Further Paul Morris informed Mr Epstein that the SBLC Stand Letter of Credit to MC2 would not be renewed Mr Epstein will continue to be a banking onl client Ex at JPM Re pon i sputed th at th cited docume nt co ta in qu ed text Disp ut ed in sofa as USV I co te ds at is fact upp is a infe ce at JP Mo ga knew or rec kl essly i srega ded a stein ran a sex raf fic kin ve ur See CSMF r,r Ex at Id at Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at Mo ga knew or rec kl ess i srega ded at stein ran a sex raf fic kin ve ur See CSMF r,r Case Document Filed Page of Ex at Disp ut ed in sofa as USV I co te ds at is fact upp is a infe ce at JP Mo ga knew or rec kl essly i srega ded at stein ran a sex-tra fic kin ve ur See CSMF r,r Case Document Filed Page of I Ex at Id at Disp ut ed in sofa as USV I co te ds at is fact upp i a infe ce at Mo ga knew or recklessly i srega ded at stein ra a sex tra fic kin ve ur See CSMF r,r Ex at Disp ut ed in sofa as USV I conte ds at is fact upp i a infe ce at Mo ga knew or recklessly i srega ded at stein ra a sex tra fic kin ve ur See CSMF r,r Case Document Filed Page of The Rapid ponse memo state Duri the period of March to ecember there were eight large cash withdrawals totaling where Currenc Transacti Rep rts were filed Ex at JPMC Response ndi sp ted th at th i te oc um nt co ta in qu xt Di put in so far as SV I co nt ds at hi fa ct upp is an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r Epstein was in jail fr June to Jul months and on house arrestfrom Jul Ju at at JPMC Response Di put ed th nt that th i ed i i th oc um ts ot pro id the exact da es pst ein in ca ce rati an a ne VI at at Undi pute th at Ep in was in a il fr June Jul and se ane fr Jul to Jul Di put in so far as SV I co nt ds at hi fa ct upp is an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r The ap i esponse memo includes exce1ptsfr the press and quotes a alm each ost article dated August According to the news website The ail east the feds are also checking whether a modeling agency run by a friend of the Wall Street investor pstein fed i a pp etite for underage foreign girls Epstein was known to fl oung women from Eastern Euro alm each where theyd massage him among other services ecause of double jeo ard rules Epstein now a registered sex offender can never be secuted again cr i mes vered by the state charges pleaded guilty to felon solicitati of prostitution and procuring a person under pro titution also a felon Child trafficking wever would ffer tw advantages federal ro ecut rs The charge uld be covered double je pard and there no statute of limitations at JPMC Response ndi put ed th at the it ed oc um nt co ta in th qu ted Case Document Filed Page of Disputed in sofa as USVI co nten ds that this fact upp 1i an inferen ce that JPM ga knew or recklessly disregarded that Epstein ran a sex traffickin ve nture See CSMF r,r In JPMorgan due diligence included multip news reports that Epstein assembled a team of star lawyers including Alan Dershowitz Jack Goldberger Roy Black and Gerald Le/court to look into the backgrounds of his oung accusers and to undermine the credibility of the to year old girls Ex at The same set of reports explain that another of Epstein lawyers Jack Goldberger said Epstein would never knowingly break the law I at Gerald e/court one of Epstein high powered lawyers says his client is innocent Id at Epstein camp was ready to get their story out They did that Monday via Goldberger and attorney Roy Black who also has represented Epstein in the case We just think there has been a distorted view of this case in the media presented by the Palm each Police Id at JPMC Response Und i sputed th at JPM Cs Du Dili ge nce Rep 1i for YHS LLC co nt a in ed cop i es of ew aicles co ncernin Jeffe1 Epstein that includ ed the qu oted lan age Disputed in sofa as USVI co nt ds that this fact upp 1i an infer ce that JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r On July Philip Schlakman emailed Casey then Epstein banker subject epstein press and states it gets worse with a link to a Palm Beach Post Article that notes the Palm Beach police spent months monitoring the Palm Beach International Ailport to keep tabs on Epsteinsprivatejet Ex at JPMC Response Und i sputed th at th cited email contains the quoted te xt and the Palm Bea ost aicle rep o1ied th at Palm eac olice wa ed th al Bea International Airpo1i to keep tabs Epsteins pri vate jet Disputed in sofa as USVI co nt ds that this fact upp 1i an infer ce that JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r Case Document Filed Page of Fmther contended th at the cited ater ial cannot be pr ese nted at trial in a dmi ssi ble fo1m Ex at Disputed in sofa as USVI conte ds at hi fac upp ts an infer ce at JPM ga kne or recklessly disregarded that Epstein ran a sex traffickin ve ntm See CSMF r,r Fmther contended th at the cited ater ial cannot pr ese nted at trial in admissible fo1m Case Document Filed Page of Ex at Di put in so far as SV I co nt ds at hi fa ct upp is an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r Fmiher co ntend ed th at the it ed at erial ann pr ese nted a tri a in a dmi ss ible fo 1m I September Li sa Waters then Managing irector A WM emails Erdoes an article about Epstein from age s;x that stated Sources tell age Six that Epstein high powered lawyers including Alan ershowitz erald e/court oy lack and enneth Starr have been neg tiating a deal with federal rosecut rs who are probing among ther things whether the gray haired money manager paid est alm each girls sex or transported them across state lines at JPMC Response ndi put ed th at Wat er email ed th qu ot ed ex Erd Di puted in so far as SV I co nt ds a hi fa ct upp is an infer a JPM an kne re kle ss di re arded that Ep in ran a traffi kin entur See CS MF r,r I a June internal risk assessment matrix Morgan ackn wledged allegati ns that Epstein supposedly bought his way to a lesser sentencing and a i a whole series girls stay quiet at Name isk tab JPMC Response Di put ed as th hara teriz a ti th at JPM ac kn ow led ge th a lle ati Undi puted th at he ited oc umen was atta hed a a il ent am JP MC empl oy es an include the qu ot ed lan ag Di put in so far as SV I co nt ds at hi fa ct upp is an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r Case Document Filed Page of September Epstein agreed to plead guilty to two prostitution charges in state urt including the solicitation of a minor to engage in prostitution in exchange a federal non rosecution agreement NP A pr viding him with i mmunity from federal child sex trafficking charges Ex at JPMC Response Di uted the ext en th at the lan age the NP A oes ot upp i prop os iti at he NPA pro id ed Ep in ith immunity fr fed ral hild traffi kin a ges The A was bas ed he auth ri ty fR Ale xa nd Acosta Unit ed Sta es A tto rne for th So hern Di tri Fl rida an do po i to bind th Unit tate as a fr brin in an har aga in st Ep in and was liinit ed to ffen th at ay ha ee co mmi tt ed Ep in ag ain th Unit tate fr in a round hrou in a round See US VI at Fm Ep in was in fa indi ed ith fed ral tr a ffi kin har in See SUMF Un i put at ep emb Ep in xec ut he NP A in hi he ag ed to pl ea guilty co un so li i ta ti pro st itu i in i at i Fl rida aw and so li itati min en a in pro tituti in i a ti Fl ri da at la US VI at see also UMF In exc a ge for Ep in co mpleti the nn and co nditi th NP A the ni ed at ag re ed in st itu har a ffen that er he ub jec th jo in in vest i gat i by th ral Bm ea In ti ga ti and th Unit tate A tt rn ey Offi an ff ses th at a ro fr th ed ra Gran Jm in ti ati an th a ag ain Ep in if an wo ul be di ini ss ed US VI a The ntial ffen that th gov ernm nt de cl in ed har Ep tein for included kn ow in in a nd affe ct in in rs at a nd for ign co mmer ce re rnitin nti in and ta inin an an a so kn ow in that th per so a ot attain he age a and wo ul be au sed a in a co mmer i a sex act as defin ed in U.S in i lati Titl Unit ed at Co de ct i a a nd I a Di puted in so far as SV I co nt ds a hi fa ct upp is an infer a JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entm See MF Morgan due diligence on stein in ctober ntained a news article discussing psteins plea deal Ex at Ex at JPMC Response ndi put ed th at a le ss i email ed cC ee re at ac hin an cto ber ai i icle fr he Ne rk os tha di sc sse Ep st ein pl ea deal See SV I at Undi pu ed tha thi a1iicle was a so includ ed in a a il fr a le ss i erd co in cC le re aters a nd ei ob er See SV I Case Document Filed Page of Disputed in sofa as USVI co nten ds that this fact upp 1i an inferen ce that JPM ga knew or recklessly disregarded that Epstein ran a sex traffickin ve nture See CSMF r,r On Jul Keating Casey Sheridan and Waters received a Ju NYT article titled Financier Starts Sentence in Prostitution Case The article reported But then the United States attorneys office in Miami became involved Last summer Mr Epstein got an ultimatum plead guilty to a charge that would require him to register as a sex offender or the government would charge him with sexual tourism according to people who were briefed on the discussions David Weinstein an attorney in the government Miami office declined to discuss the specifics of the case ut he did address the subject of Mr Epsteins means and prominent legal team and dismissed a proposal by Mr Epstein lawyers who opposed the application of the federal statutes in the case that he be confined to his house in Palm Beach for a probationary period Ex at JPMC Response ndi sputed th at th Jul New rk Times aicle was fo1wai 267ded to Keating Casey heridan and Wa ter and th at th cited document co nt a in the qu ted text Disputed in sofa as USVI co nt ds that this fact upp 1i an infer ce that JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r Further contended th at th cited ater ial ca nn be pr ese nt ed at trial in admissible fo1m On Jul Perry circulated to Verdon Dalessio McCleerey Waters Sheridan and Casey all Private Bank personnel for the pm EST Rapid Response Meeting on Jeffrey Epstein an article titled Rich Man Fought the Law and He Mostly Won and dated July The article stated But that plea deal does not account for all of the girls one as young as who alleged that Epstein sexuall abused them The slow dissatisfying resolution of the case sends a message to the public that there a different system of justice for the wealthy who Case Document Filed Page of hire high powered lawyers The plea deal also drops a federal investigation of Epstein Ex at JP MC Re pon Di sputed to exte USVI misstates docume quoted po1iio of the cited docume states ut at lea dea does ot acco un for all fi ve of gi rl one as yo un as who alleged at Epste in sex a ll abused slow dissat i sfy in esol i of case se ds a message to blic at ere a i ffe ent system of ju st i ce for wealt i hi h-p owe awye ea deal also dro a federal investigatio of Epste in USVI Ex at Othe i se und i sputed Disp ted in sofa as USV I conte ds at is fact is a infe ce at PMo ga knew or recklessly i srega ded at Epstein ran a sex traffic kin ve ur See CSMF r,r ur the co te ded that the cited mater i al ca nn ot be ese ted at tri al in admissible fo1m The NPA stated that the US Attorne Office and the Federa Bureau of Investigation have conducted their own investigation in Epsteins background and an offenses that ma have been committed by Epstein against the United States from in or around through in or around September including knowing in and affecting interstate and foreign commerce recruiting enticing and obtaining by an means a person knowing that the person had not attained the age of ears and would be caused to engage in a commercial sex act as defined in US in violation of Title United States Code Section a and Ex JPM Re pon Di sputed to exte USVI misstates docume quoted po1iio of the cited docume states ited States Atto rn eys Office a edera Burea of In vest i gat i ave co cted ir own in ves tigation in pste in bac gro un and a offenses that may ave bee committed by pste in aga in st the ited States from in around ro in around Septe be in cl in kn ow in gly in a affect in in terstate a fo i comme ce rec rn it in i cing a ob ta inin by any means a pe so kn ow in at perso ad atta in ed the age of years an wo ld be caused to gage in a comme cial sex act as efi in U.S in violation of Ti tl United States Code Sect i a and USV I Ex at Othe i se un disp ted Disp ted in sofa as USV I conte ds at is fact ppo i a infe ce at PMo ga knew or recklessly i srega ded at Epstein ran a sex traffic kin ve ur See CSMF r,r Case Document Filed Page of Fmther contended th a the cited a ter ial cannot be pr ese nted at trial in a dmi ssi ble fo1m The NP A stated The United States shall provide Epstein attorneys with a list of indi vi duals whom it has identified as victims as defined in US.C If any of the indi vi duals referred to above elects to file suit pursuant to US Epstein waives his right to contest liability and also waives his right to contest damages and agrees to waive any other cla i for damages Ex at JPMC Response ndi sputed th at th i te docum nt contains the qu ed te xt Disputed in sofa as USVI conte ds at hi fact upp an infer ce at JPM ga kne or recklessly disregarded that Epstein ran a sex traffickin ve ntm See CSMF r,r Fmther contended th a the cited a ter ial cannot be pr ese nted at trial in admissible fo1m The non rosecution agreement identified potential co conspirators of Epstein Ex at and JPMC Response Und i sputed th a the PA identified and as potential co-conspirators of Epstein as Disputed in sofa as USVI conte ds at hi fact upp an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex traffickin ve ntm See CSMF r,r Fmther contended th a the cited a ter ial cannot be pr ese nted at trial in admissible fo1m The non rosecution agreement identified Lesley Groff as a potential co conspirator of Epstein Ex at JPMC Response Und i sputed th a the A identified Groff as a tenti a co conspirator of Epstein Disputed in sofa as USVI conte ds at hi fact upp an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex traffickin ve ntm See CSMF r,r Fmther contended th a the cited a ter ial cannot be pr ese nted at trial in admissible fo1m On September Peny emailed McCleerey copying Dalessio stating Epstein signed a federa non rosecution agreement under which he would not be charged with related Case Document Filed Page of federal crimes if he successfully served out his time and abided by the conditions under the state charges He also waived his right to contest liability and damages in civil lawsuits by minor girls identified by the non prosecution agreement Ex at JPM Re pon Und i sputed at Pe a i led McClee ey copying Da ess i Septe be a the cited docume co tai uoted text Disp ted in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga knew or recklessly i srega ded at stein ran a sex tra fic kin ve ur See CSMF r,r Steve Cutler testified I know at a certain point I understood that there was a federal nonpros agreement and that sometime before I think we would have seen the non pros agreement Ex at JPM Re pon Und i sputed that utl test i fied at I know at a ce ia in in I understood at ere was a federal pros ag ee ent USV I Ex at Cutlers full test im fr at cited iion of transc ipt however states I kn ow at a ce ia in point I un de stood at the was a federa n-p ros ag ee I ca te ll you exactly And I cant te ll yo at I knew precise at te1ms of i were Id at disp ted at tle test i fied at by is date in by hi i refe ing to a ai dated see id at I think we wo ld have seen pros ag eeme Id at Disp ted in sofa as USV I conte ds at is fact is a infe ce at JP Mo ga knew or recklessly i srega ded at stein ra a sex traffic kin ve ur See CSMF r,r On March Jonathan Schwartz then General Counsel Investment Bank mailed Cutler Spoke with Jay Lefkowitz He represented Epstein in state plea/fed NPA process Believes any pre plea conduct is subsumed within plea NP A Ex at JPM Re pon Di sputed to exte USVI cites to wro page of doc me USVI Ex at co ta in oted text Ot wise un disp ted at Marc Sc waiiz emai ed utl and cited doc um ent co ta in ote text Disp ted in sofa as USV I conte ds at is fact is a infe ce at JP Mo ga knew or recklessly i srega ded at stein ran a sex traffic kin ve ur See CSMF r,r Case Document Filed Page of On October Dale ssi Private Bank Ri sk Management emailed Verdon then General Counsel Private Bank copying McCleerey Private Bank Ri sk Management and Waters Managing irector AWM Subject Epstein Dale ssio stated Anne Verdon Lisa asked me to send to you a list of PB entities in Epstein relationship with current balances Notable activity in Epstein personal account Cash withdrawals CTRs filed ytd withdrawals withdrawals transaction activity Ex at JPMC Response Di sputed extent USVI cites to the wro page the document USVI Ex at co ta in qu ted text Othe1wise undi sp uted at October Dalessio ailed Ve rd copying McClee1y Wa ters a nd Meis and the i ted document co nt a in he quoted te xt Disputed in sofa as USVI conte ds at hi fact upp is an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r alessio further stated in his email One of the accounts in the Epstein relationship is for his girlfriend I model funds into her account are transfers from Epstein for from See attached article The two others mentioned in the article are not PB clients They do appear to have Retail credit card active revoked Ex at em phasis added JPMC Response ndi sputed th at the cited oc um nt co ta in the qu ted text Disputed in sofa as USVI conte ds at hi fact upp is an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r Da lessio attached to his email a document Epstein transactions xis.zip which included millions of dollars in payments from Epstein accounts at JPMorgan to Epstein lawyers and their law firms including Alan Dersho witz Gerald Le/court Ro lack lack Srebnick and Case Document Filed Page of Jay Lefko witz Kirkland Ellis Ex at I also included twenty payments from Epste in accounts for Id at JPMC Response Di puted as to the ater iali ty of the se tatement to he claims at i ss ue in hi case See JPMC Ex pute at i te ma1 a ss i include a documen ti ed Epstein tran action xl zip an th at he ci ed doc umen includ es tran sactio fr Ep tein acco un to hi attorney includin Alan Dershowitz Gerald Lefcourt oy Bl ac Bl ac eb ni and Jay Lefk ow i Kirkland Elli ndi puted th at the cited document con ta in ran ac ion in the amoun Disputed in so far as USVI conte ds at hi fac upp i an inference at JPM ga knew or reckle ss ly di regarded that Ep tein ran a sex traffi kin ve ntur See CSMF r,r ctober the New Yo rk Po st reported THE owners of MC2 models are denying industry speculation that massage maven Jeffr ey Epstein is a secret financial backer of the agency being run by scandal scarred Jean uc runel wh was once accused of taking advantage of underage models Epstein who this week agreed to plead guilty to soliciting underage prostitutes at his Florida mansion in a deal that will send him to prison for about months reportedly gave millions to start MC2 which opened in October with offices in New York Miami and Tel Aviv One of the girls Epstein was accused of soliciting massages from was described in court documents as being just equals MC squared get it like the equation equals Epstein He just thinks everyone is too dumb to figure it out said a model industry insider Hes a desperate old man thatfantasi es and takes advantage of young girls MC2 president Jeffrey Fuller confirmed Brunel was a partner in the company but denied any working relationsh;p with either Epstein or Marie We have no relationship business wise with Gerald Marie Jeffrey Epstein has no ownership or involvement in our company and never has Jean uc Brunel and I are the only two partners and owners of MC2 Model Management Fuller Case Document Filed Page of said Epsteins rep said he was not involved in the agency He has no business relationship with them said Ho ward Rubenstein Ex IOI at JPMC Response Undisputed tha the cited document contains the qu ted text Disputed in sofa as USVI contends hat hi fact upp i an inference hat JPM ga knew or recklessly disregarded that Epstein ran a sex traffickin venture See CSMF r,r Further contended th at the cited ater ial cannot be pr ese nted at ri al in a dmi ssible fo1m JPMorgan admits that i JPMorgan approved a million Stand By Letter of Credit SBLC in Epstein name to support a loan from Mello United National to MC2 Mode Management LLC Ex at Resp JPMC Response ndi sputed th a JPM gan approved a milli tand Letter Credit BLC in Epsteins name to upp 1i a loan from Me llon United National to MC2 Model Management LL Disputed in sofa as USVI conte ds hat hi fact upp i an infer ce hat JPM ga kne or recklessly disregarded that Epstein ran a sex traffickin ve ntur See CSMF r,r JPMorga admits that a million letter of credit in Epstein name to backstop a loan from Mellon United National to MC2 Model Ma nagement LLC was subject to annual review at Resp JPMC Response ndi sputed th at the BLC was ub jec to annual eview Disputed in sofa as USVI conte ds hat hi fact upp i an infer ce hat JPM ga kne or recklessly disregarded that Epstein ran a sex traffickin ve ntur See CSMF r,r JPMorga admits that it renewed the SBLC i Epsteins name to support a loan from Mellon United National to MC2 Model Management LLC until March I Ex at esp JPMC Response Di sputed The cited re spo se tat es hat JPM admits th a it did renew a tand by Letter redi in Ep te in name to backstop a an fr Mell Unit ed Nati nal to MC2 Model Manage nt LLC in March USVI at Re sp Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r On October Chri topher French emails Mary Cas ey subject Re Jeffrey Epstein new LOC and states in response to Casey request to open a new line of credit for Epstein we do still have an existing MM LC that we issued a.few ears ago supporting the Modeling Agency loan to Mellon Ex I at JPMC Response Di sputed the extent SVI mi ssta te the document The qu oted lan age sta te we do sti ll ha ve an exis tin IMM that we i ss ued a few years ago upp rtin he Modelling Agency oa Mellon SVI Ex at Disputed at he ci ed documen establishes th at Maiy Casey was reque st in a ew line credit fo Ep ein In he cited documen it is cl ea Casey is pa ss in along the request fr Ri a rd a hn at Jeffrey Ep ein ffice and as kin for advice ow to proce ed SVI Ex at Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregai 267ded that Epstein ran a sex traffi kin ve ntur See CSMF r,r Ex at JPMC Response ndi sputed th a the cited oc ument con a in the qu ted ext Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPMorgan knew or recklessly disregai 267ded that Epstein ran a sex traffi kin ve ntur See CSMF r,r In a Jul email Erdoes tells Staley describing a Jul NY Post article The feds many not be quite done with JE Having just completed months in a fl jail for solicingsic prost sic from a minor he now might be under investig sic for other possible Case Document Filed Page of crimes inclduing sic whether there any evidence of child trafficking has settled several lawsuits by teens who say they were lured to his palm beach mansion for massages or sx sic The us AG in fl wouldnt comment lawyer jack goldberger says he know nothing of any probe and they are not and should not be any pending criminal investigations Ex at JPM Re pon ndi uted th at th cited oc um nt co ta in qu ed te xt Di put ed in so far as USV I co te ds at is fa ct upp i an in fe ce at JP Mo an kn ew ec kl ess di eg ar de a ste in ra a sex raffi kin ve ur See CS MF r,r The July NY ost article Jeffrey Epstein may face child trafficking probe states Ex at The Feds may not be quite done with Jeffrey Epstein aving just completed months in a lorida jail for soliciting prostitution from a minor he now might be under investigation for other possible crimes including whether theres any evidence of child trafficking reports The aily east Epstein has settled several lawsuits by teens who say they were lured to his alm each mansion for massages or sex The US attorney general in Florida wouldn comment Epsteins lawyer Jack Goldberger says he knew nothing of any probe and There are not and should not be any pending criminal investigations JPM Re pon Di sp ted exte nt SVI mi ss at es oc um NY os ai i i cle i itl ed ste in Prob See USVI at i se un i put ed th at th it ed doc um co ta in th te te xt Di put ed in sof ai as USV I co te ds at is fa ct upp i an in fe ce at JP Mo an kn ew ec kl ess di eg ar de hat Ep te in ran a sex raffi kin ve ur See CS MF r,r mih co nt ded th at th i ted ate rial ann be pr ese nt ed at tr i a in a dmi ss ibl fo 1m The July aily east article cited in the NY ost article states The Justice epartment is investigating Jeffrey Epstein for child trafficking and has widened the scope of its probe to include a famous modeling agency Federal investigators continue to investigate Epsteins activities to see whether there is evidence of child trafficking-afar more serious charge Case Document Filed Page of than the two in his non prosecution agreement the arrangement between Epstein and the epartment of Justice allowing him plead guilty to lower le el state crimes Trafficking can carry a year sentence The FBI is also investigating Epstein sfriend Jean uc runel whose MC2 modeling agency appears to have been a urce of girls from overseas who ended up on Epsteins private jets Ex at JPMC Response Und i puted th at the i ted document conta in the qu ted text Di puted in so far as SV I conte ds at hi fact upp is an inference at JPM an kne or reckle ss ly di re arded that Ep ste in ran a trafficking venture See CSMF r,r Further co nt nd ed th at the cited at erial ca nn be pre se nt ed at trial in a dmi ss ible fo1m JPMorgan admits that in certain its employees received reviewed or read a Newstex Web log Jezebel article Newstex article identifying MC2 as the modeling agency owned by Jean uc runel Ex at Resp JPMC Response Und i puted th at in ce1ia in JPMC empl oy ee re ei ved re iewed or read a New st We Blog Jezebel article identifying MC2 as delin a enc ow ned ea Luc Brnnel Di puted in so far as SV I conte ds at hi fact upp is an inference at JP Mo an kne or re kle ss ly di re arded hat Ep ste in ran a trafficking venture See CSMF r,r The Newstex article states a Jeffrey Epstein the billionaire financier who the FBI believes lested around underaged girls Ex at uying a 14-year old Yugoslavian girl named from her parents in order to keep her as his sex slave I aying women to bring him economically desperate teenagers to give him massages that ften led sexual ntact Id eceiving two 12-year old French girls as a birthday present I Case Document Filed Page of Flagg ing Epste ins relationsh;p with Jean Luc Brunel owner of MC2 Modeling and that Epstein Maxwell Brune Alfredo Rodriguez and used the agency to lure minor children mostly girls under the age of to engage in sexual pla for money Id References that the FBI is investigating MC2 and Brune for possibly engaging in child sex trafficking Id Mentions Epstein plea of soliciting sex with a minor and settling a dozen civil lawsuits from victims Id The se same civil complaints allege that oung girl from South America Europe and the former Soviet republics were recruited for Epstein sexual pleasure Id i Brunel along with numerous oung model was a frequent passenger on Epstein private jet according to flight manifests Id The agency owner also allegedly received million from Epstein in when he founded MC2 but denied any such pa yment from the billionaire pervert in when rumors started swirling Id Whether the money was a secret investment in MC2 or a pa yment for Brunel service as a procurer i unknown Id JPM Re pon Di sputed exte nt USVI mi ssta es i ted doc um i oted in states ying a Yugoslavian na ed fro pare ts in der to eep as hi sex ave USVI Ex at se nt ce quoted in states urin min hi ldre ost gi rl unde age of gage in sex al ay fo ey a sente ce oted in states Whet er oney was a sec et in vestme in MC2 or a ay fo Bmn serv i ces as a proc ur is unkn ow See USVI at he i se un dis pu ted at i ted doc um ent co nt a in quoted ext Case Document Filed Page of Disputed in sofa as USVI co nten ds that this fact upp 1i an inferen ce that JPM ga knew or recklessly disregarded that Epstein ran a sex traffickin ve nture See CSMF r,r Further contended th at th cited ater ial ca nn be pr ese nt ed at trial in admissible fo1m A DDR regarding Epstein approved by Morris then banke1 Sheridan then overseeing Morris and Keating then CEO US Private Bank stated As of Numerous articles detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating in child trafficking and molesting underage girls Jeffrey Epstein is required to register as a sex offender Jeffrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding solicitation for an undisclosed amount MC2 Model Management received million from Epstein in It is unknown if the money was given as a secret investment or payment for services as a procurer Jean Luc runel owner of MC2 Model Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children for sexual play for money In addition runel was a frequent passenger on Epsteins private jet and often visited Epstein in jail MC2 Model Management was issued a citation by the Florida Business and Professional Regulation for acting as a talent agent without a license MC2 Model Management LLC has two outstanding federal tax liens totaling Ex at Global Security Investigations Due iligence Unit circulated A Red ot Memo for Jeffrey Epstein containing the same information that was circulated to Morris Casey alessio and Perry among others in ear March Ex at JPMC Response ndi sputed th at MoITis eri a a nd Keatin approved the ited DDR and th at th cited DDR contains the qu ed text Und i sputed th at a ed ot Me for Jeffrey Ep ste in was ci ulat ed to MoITis Casey Dale ssio and Pen among ot March containing the qu ed language fr the DDR Disputed in sofa as USVI co nt ds that this fact upp 1i an infer ce that JPM ga knew or recklessly disregarded that Ep ste in ran a sex traffi kin ve ntur See CSMF r,r Case Document Filed Page of Id Disp ut ed in ofa as USV I co te ds at is fact upp i a in fe ce at JP Mo ga knew or rec kl ss ly i rega ded a tein ran a sex tra fic kin ve ur Se CSMF r,r urt he co nt ded hat he cited ater i al ca nn be pr nt ed at trial in admi ss ible fo1m JPMo an so wn due dili enc oc ess als requ i tha it research and vi civ il and ot her lawsu it tha may fi led a a i ns cl ie nts at JPM Re pon Di puted The cited ti ony for hi ro i tion doe not upp o1i concl io th Morgan du di li ge ce roce ss qui red hat mp lo ee re ea a eview civi law i in in it clie In qu ti abo er perso al i ew of ci i law it at a be filed aga in a cl i Ca a JP MC Pr i ate anke and not a ber of MC co mp liance function te ti fi ed hat a incl ded wit hin th di li gence i ew USVI Ex at i te ti relate nl Ca un dersta ding rega ding cond cting of due di li ge ce a doe not fl ec a overa ll po li cy by JP MC aff nat i vely req ire review i vil aw ui Di ut ed in ofa a USV I conte ds at i fact upp i a infe ce at JP Mo ga knew or rec kl ss ly i rega ded at tein ran a ex tra fic kin ve ur Se CSMF r,r In news re po rt sta Ep ste i wa ra ci fo a slew of a wsu its as many as un wh came is Pa lm ea ma si on fo a ss ag ses i a JPM Re pon Und i puted hat th cited docume nt an October aicle fro New York age Six go sip col um co ta in qu ed text Case Document Filed Page of Di puted in so far as SV I co nt ds a hi fac upp i an infer a JPM an kne re kle ss di re arded that Ep in ran a traffi kin entur See CS MF r,r Further co ntend ed th at th it ed at erial ann pr ese nt a ri a in a dmi ss ible fo1m Ex I at Di put in so far as SV I co nt ds at hi fa upp i an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r Ex I at Di put in so far as SV I co nt ds at hi fa upp i an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r The Febrna,y New York Po st article stated that the teen identified nly as Jane oe No says she was lured Epsteins alm each mansion and then sexually assaulted in his massage room then paid her Ex I JO at I The article further states Jane Do No I says she was when she went to Epsteins me to give him a massage and wound up getting sexually assaulted by him and that Epstein is currently on facing criminal charges related to Jane oe I I at Case Document Filed Page of JP MC es pon se Di pu ent a US VI i a i for the ed in it first a ti i pa quot ex a ppe a ag a nd See VI at e1 i und i put th at th cit do ument a i quot lan a Di in so fa as SV I ont ds at i fa pp i a infe ce at PM a kne or ckle ss i re a ded at in ra a traffi kin ent ur See MF r,r ihe te th a the cit a er i al ca nn ese ted a tri a in a dmi ss ible fo1m June pstein pled guil ty to fel licitati of prostituti and pr curement of a min engage in pr stitution on June and was sentenced to months in jail and required to register as a sex offender ef JP Morgan Chase ank A A nswer Second Am Comp A nswer JPM Re pon Di put ent cit a i upp 1i prop os iti at Ep in ea gu i lty on un Othe i un di ed Di in so fa as SV I co nt ds at i fa pp i a infe ce at PM a kne ckle ss i re a ded at in ra a traffi kin ent ur See MF r,r the ict i was a year old girl at Ex at Di in so fa as SV I co nt ds at i fa pp i a infe ce at JPM a kne ckle ss i re a ded at in ra a traffi kin ent ur See MF r,r Case Document Filed Page of Ex at Ex at Disputed in sofa as USV I conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded hat Epstein ran a sex tra ffi kin ve ntur See CSMF r,r In Langford communicated to Cutler concern about retai ing Epstein as a client Cutler te tified Those concerns are heightened if ou will by the human trafficking initiative that were doing gi en that he was convicted of these crimes Ex at JPMC Response Di sputed In the i ed tes imony Cutler es ified th a Langford co mmuni cated him co cern abou the reputational issue USVI at mph asis added Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga knew or recklessly disregarded that Ep ein ran a sex traffi kin ve ntur See CSMF r,r Ex at Case Document Filed Page of Di puted in so far as SV I co nt ds a hi fac upp i an infer a JPM an kne re kle ss di re arded that Ep in ran a traffi kin entur See CS MF r,r The August AM Op erati ns uman Trafficking Ov erview states that nearl two thirds the women trafficked for stitution worldw i de me from astern uro and rmer astern bloc countries such as Alban i a Mold va Ro man i a ulgar i a ussia elarus and Ukraine have been i dentified as maj trafficking urce countries for women and children at JPMC Response ndi put ed th at th i oc um nt co a in th qu xt Di put in so far as SV I co nt ds at hi fa upp i an infer ce at JPM an kne re kle ss di re arded that Ep in ran a traffi kin entur See CS MF r,r I additional news stories connects effrey Epstein to human trafficking at JPMC Response Di put ed th nt US VI ch arac rize th ne ws ri es as a dd iti a Undi pu ed that th i ed doc umen co nt a in he qu ed ex and tate that th ese ne ws rie a ppeared durin Di put in so far as SV I co nt ds at hi fa upp i an infer ce at JPM an kne re kle ss di re arded that Ep in ran a traffi kin entur See CS MF r,r November alessio emails Morr i and Casey with a cc McCleerey Subject Excer from recent articles alessi writes See below new allegations of an investigation related to child trafficking are you still mf rtable with this client who is a registered sex offender Ex at alessio attaches excerpts from four articles The alm each ost Epstein may be under new sex crime scrutin from feds Epstein may be under investigation for other sex cr i mes including child trafficking Acc rding the news website The ail east Case Document Filed Page of the feds are also checking whether a modeling agency run by a friend of the Wall Street Investor Epstein fed his appetite for underage foreign girls Epstein was known to fl young women from Eastern Europe to Palm Beach where theyd massage him among other services Id NY Post Epstein Probe The Feds may not be quite done with Jeffrey Epstein now might be under investigation for other possible crimes including whether there any evidence of child trafficking reports The Dai Beast Epstein has settled several lawsuits by teens who say they were lured to his Palm Beach mansion for massages or sex Id Palm Beach Daily News House arrest nears home stretch for Epstein Epstein has 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 A secret deal with federal prosecutors revealed Epstein could have been charged with multiple federal counts of sexual exploitation of minors resulting in much harsher penalties But the feds deferred to two state charges that got him an month sentence Id at Palm Beach Daily News article Woman sues Epstein for alleging abuse as teen alleges repeated sexual abuse by Epstein and that she was coerced into prostitution as a minor by Epstein assisted by his employee alleges Epstein has transferred and is transferring his assets overseas and elsewhere to conceal them from her and to Case Document Filed Page of revent fr ob tain i ng th se assets in any judgment she may rece i ve a a i nst i I at JPM Re pon Und i puted tha Da ss i ema i led i and Ca ing McC eere ember a a i contained quoted lan a Di ted the exte SV I mi ss ta the me ith re pe in clu ion of four ai i icle excerpt as a tt a me the exce ai pied in the cClee ey ema i e1wi und i puted th at the me contain the ed excerpt of li ed ai i icle Di ted in so fa a SV I conte ds at i fac pp i a infe ce at PM a kne or re kle ss ly i re a ded at ein ra a traffic kin vent ur See MF r,r ur the te ded th at the cited at er i al ca nn be ted at i a in a dmi ss ible fo1m The JPMC Cor po rate AML Co mpliance uman rafficking i nance Nature Sco and Control oj ect ov ember states that one the results achieved from the rogram was that JPM organ Led eff rt draw i ndustry attent io human trafficking as an A ML related i ssue and tes multiple i ndushy resentat io ns gi en JPMo rgan related human trafficking i ssues and or its human trafficking roject findings at ecember yan writes uca fear i will all ur ut i ng ood will the HT work if any ne sh uld ever say yet we ank Ep stein a known child sleaze uca resp nds That i what I was th i nking when I read th i I ll call you at JPM Re pon Und i puted th a the i ed docume ontain ted Di ted in so fa a SV I onte ds at i fac pp i a infe at PM a kne or reckle ss ly i re ai 267ded at Ep tein ran a traffic kin vent ur See MF r,r HT in yans email refers to a roject with i invest i gati ns related to human trafficking and certa i ty ol gy rk that they were oo king i thr ugh to i dentify human traffickin at JPM Re pon Und i puted th a an ified at HT wo efe ed to i the ema i i ed as SV I wa a projec at wa go in on wit hin in ti ati Case Document Filed Page of rel a ed human rn ffi kin an e1 i a in typo ogy wo rk th a the er oo kin di throu iden ify human ra ffi kin SV I a Di put in so far as SV I co nt ds at hi fa upp i an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r ecember uca writes angford again and states This will be raised to the apid es onse team Catherine eating after the first of the year McCleerey agrees th i cust mer should go Ex at JPMC Response ndi put ed th a Lu a email ed a gfo rd De ember and he it a il co a in th qu xt Di put in so far as SV I co nt ds at hi fa upp i an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r ecember eLuca writes angford and states I sent you an mail yesterday on that scum Epstein That looks good to I reminded McCleerey that he listened to days at the forum and this acc unt uld be pr blematic in several ways angford responds Goo Let me kn if McCleerey waffles on Epstein No atience for this Ex at JPMC Response ndi put ed th a Lu a email ed a gfo rd De ember and he it a il co a in th qu xt Di put in so far as SV I co nt ds at hi fa upp i an infer ce at JPM an kne ec kle ss di re ar ed that Ep in ran a traffi kin entur See MF r,r Janua,y alessio mails rris with a cc Casey erry and McCleerey Subject ap i esponse meeting this Thursday stating See attached draft document for the apid esponse meeting th i Thursday sic We were asked by the firms AM Compl i ance irector William Langford to re evaluate our onsorship stein and request re appr val from Steve Cutler if we wanted to retain Morr i responds I thought we decided this was not Case Document Filed Page of necessary Dalessio responds william langford requested that we responsor 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 Ex at JPM Re pon Di sputed exte nt USVI misstates i ted doc um ent or i in a email from alessio Mo is copy in Casey and McClee ey is se anmuy USVI at Ot wise un disp ut ed Disp ut ed in sofa as USV I conte ds at is fact upp i a infe ce at JP Mo ga knew or recklessly i srega ded at stein ra a sex tra fic kin ve ur See CSMF r,r On January Ryan wrote to Deluca BTW tomorrow is the rapid response meeting on Epstein the sleazy PB client Deluca responded the next day This is the gu who likes young girls correct Hope they do not cave Ex at Ex at JPM Re pon Di sputed exte nt USVI misstates th cited doc um Lu cas respo se to ya email on Januaiy states is is he who lik es yo un irl co ect ope at ey ot cave USVI at Ot wise und i sputed Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo ga knew or rec kl essly i sreg ai ded at stein ran a sex tra fic kin ve ur See CSMF r,r By sleazy PB client Ryan was referring to the allegations against Epstein of sexual misconduct with children Ex at JPM Re pon Di sputed USV I mi sc hai acter i zes Ryan testimo in hi ated i was likely ut not defi ni ti ve at se of sleazy PB clie refe ed allegat i aga in stein of sexual mi sco wit i See USVI at When you say sleazy PB li nt ai yo efe nin allegat i of sexual mi sco wit i hat yo ad refe ed to in a previo ail A ikely yes Disp ut ed in sofa as USV I conte ds at is fact upp i a infe ce at JP Mo ga knew or recklessly i srega ded at stein ra a sex tra fic kin ve ur See CSMF r,r Case Document Filed Page of On January Ryan emails Deluca copying Middlemiss writing Epstein was released in July from house arrest and the Palm Beach Post carried two articles saying that DOJ may be investigating for child trafficking via a modeling agency he is part owner in Ex at _R Ex at JPMC Response Di sputed the extent SVI mi ss ates the cited document The ci ed text reads Eps in was eleased in July from se anest and the al Bea os ca nied two a1ticles say in DOJ ay in ves ti ga tin fo hild trafficking ia a ode lin age cy he is pa1t ow ner in USVI Ex at Othe1wise undi pu ed Disputed in sofa as USVI conte ds at hi fac upp an inference at JPM ga knew or recklessly disregarded that Epstein ran a sex traffi kin ve ntur See CSMF r,r Ryan testified So Phil was of the mindset as was that Epstein had to go Ex at JPMC Response Und i sputed th at Ms yan testified So Phil was of the mind se as was I th a Epstein ad to go Dispu ed to he exte USVI co nt ds at ya tes imony es a li es DeLu ca min dset i respec to Epsteins sta tu as a client Th ci ed estimony was pro vided in es se a question hat yan und ood an email fr DeLuca to mean and is upp rt ed by her personal kn ow edge ofDeL ca i ews abo Epstein See USVI at Disputed in sofa as USVI conte ds at hi fac upp an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r Langford testified We were pushing it I had asked for this to be redone to push again to say its time that we exit Epstein Ex at JPMC Response Di sputed the ex ent USVI mi ss ates Langfords testimony Langford te stified We we pushing it I ha as th at this red push aga in say i ime th at we exi Epstein SVI Ex at Othe1wise undi sp ut ed Disputed in sofa as USVI conte ds at hi fac upp an inference at JPM ga knew or recklessly disregarded that Epstein ra a sex traffi kin ve ntur See CSMF r,r
