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Folders as described
epstein court records
← Back to Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1;22-cv-10904 (S.D.N.Y. 2022)
Extracted Text

Case Document Filed Page of Case Document Filed Page of Figur Indir ec Pa ts for th fit Wom from th Ep in A cc ount Beneficiary/Pa ee Amount togra ph Total Cas tl Wo rl dw i de In ac i fic Co ll ege of Or i nt al Medic in eve Kap a MD Co ll ege Total Total loo min gda Expre Case Document Filed Page of Beneficiary/Pa ee Amount I Syste Ta get lin a1y Ce ter Total otal Dr avid Pr ice Dr Ge ra Imb Dr ane Reca nt Office ased ge1y Care Total Case Document Filed Page of Beneficiary/Pa ee Amount Grand Total JPM Re pon Und i sputed hat thi i a umm aiy ansactio epai ed by SVIs pro ff ered expe1i Jo ge Amado Disp ut ed th at th is in fo1 at i was avai ab to Morgan in thi fo1 at urin ti pste in was a li nt of Morgan Di sputed as to et er perso is ed we min ey eceived payme ts as eir age i ot rovided in ci ed so ur ce is pu ted as to ate iality to th ex thi umm a fails put pste in ran sactio in th approp iate co text See JP MC i,i Disp ut ed in sofa as USV I conte ds at is fact upp is a in fe ce at JP Mo ga paicipated in ste in a ll eged sex tra ffi kin ve ur See CSM i,i JPMorgan also handled in legal fees from Epstein JPMorgan accounts for the benefit of three women Ex at and Figure copied below Figur Lega Fe es Pa nt for Women from the Ep tein A cc ount Date Check Payee Amount Memo line in ce A ull sq A da eskai des sq A da eskai des sq Total JPM Re pon i sputed th at i ted doc um ent a chaii ai umm ai ies ran sactio pr epai by USV I roffe ex rt Jo ge A ado Di sp ted th at thi Case Document Filed Page of in fo nn atio was available to JPMorgan in this fo1mat during he time Ep ste in was a client I Disputed in sofa as USVI conte ds at hi fac upp is an inference at JPM ga pai i icipated in Epsteins a lle ged sex tr afficking ve ure See CSM i,i Smaller Dollar and Gift Payment to Girl or Women and Payment Ex Jeffre Epstein Gift Tax Return Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of JPMC Response ndi sputed th at thi i a ummai of transac ions prepared by SVIs proffered expe i Jorge Amador Disputed th at thi info1mati was avai labl to JPMorgan in thi fo1mat during he time Ep ste in was a li nt of JPMorgan Di sputed as to he her the persons listed we re min they re ceived he payments as their age i Case Document Filed Page of not pro vided in he cited so urce Di pu ted as to ate ri ality the extent thi umma1 fails to put Ep te in transactions in the appropriate context See JP MC Ex i,i Disputed in sofa as USVI conte ds at hi fact upp i an inference at JPM ga paicipated in Epsteins a lle ged sex tr a ffickin ve ure See CSM i,i Case Document Filed Page of Case Document Filed Page of JPMC Response ndi sputed th at thi i a ummai transac ions prep a ed by USVI Disputed at hi info1mation was avai labl to JPM gan in hi fo nn at urin the time Epstein was a clien JPM gan Further dispu ed as to ate ri ality of he se payments based he a unt th at the are rovided to attome and law foms See JPMC Ex Disputed in sofa as USVI conte ds at hi fac upp is an inference at JPM ga pai i icipated in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i Case Document Filed Page of Case Document Filed Page of JPM Re pon Und i sputed hat thi i a umm aiy of ansactio epai ed by USV I Disp ut ed at is info1 a ti was avai able to JP Mo gan in is fo nat urin tim ste in was a clie JP Mo gan Disp ut ed as et er erso li ste we min ors ey eceived payme ts as ei age is prov i ded in ci ed so ur ce Disp ut ed as to ater i a li ty to th exte nt hi umm aiy fails put pste in ran sactio in appropr i a co nt ext See JP MC i,i Disp ut ed in sofa as USV I conte ds at is fact upp is a in fe ce at JP Mo ga paicipated in ste in a ll eged sex tra ffi kin ve ur See CSM i,i JPM Re pon i sputed hat thi i a umm aiy of ran sactio pr epai ed by USV I Disp ut ed at is in fo1 a ti was avai able to JP Mo gan in is fo nat urin tim ste in was a clie JP Mo gan mih dis pu ted as to ate iality of ese payme ts Case Document Filed Page of from Ep ste in to a commun i catio and reputation management fnm to any ofUSVI cla i ms aga in st JP MC See JPMC Disputed in sofa as USVI conte ds at is fact upp is an inference at JP Mo an paicipated in Epsteins a ll eged sex tr affic kin ve ntur From September through December JPMorgan handled in payments from Epsteins accounts to Alan ershowitz Roy ack Gerald e/court and Jack Go dberger relevant transactions identified and summarized in the chart below JPM Re pon se Und i sputed that thi i a ummaiy of transactions prepared by USV I Disputed at is info1mati was avai able to JPM gan in is fo nat urin the time Epstein was a client JPM gan urth disputed as to materiali ty eleva ce payments from Ep ste in to is atto sa aw fnm to USVI claim in is matter See JPMC Disputed in sof ai as USVI conte ds at is fact upp is an inference at JPMo an paicipated in Epsteins a ll eged sex tr afficking ve nture See CSM i,i Date Payee Amount A AN DERSHOWITZ A AN DERSHOWITZ A AN DERSHOWITZ A AN DERSHOWITZ Case Document Filed Page of JPMC Response Und i sputed th at thi i a ummai of transactions prepai ed by USVI Disputed at hi info1mati was avai lable to JPM gan in hi fo nn at urin the time Case Document Filed Page of Epstein was a clien JPM gan Fmther dispu ed as to ate ri ality rele va ce of payments from Ep ein hi attome sa law fnms to USVIs claim in hi a ter See JPM Ex Disputed in sofa as USVI co nt ds at hi fac upp an inference at JPMorgan pai icipated in Epsteins a lle ged sex tr a ffickin ve ure See CSM i,i From through JPMorgan handled in payments from Epstein JPMorgan accounts to various law firms including in pa ments from Janua,y through September in pa ments from September through June and from Ju through December relevant transactions identified and summarized in the chart below Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of JPMC Response ndi sputed th a thi i a ummai transac ions prep a ed by USVI Disputed at hi info1mation was avai labl JPM gan in hi fo nn a urin the time Epstein was a clien JPM gan Further dispu ed as to ate ri ality eleva ce of payments from Ep ein hi attome sa law fnms SVIs claim in hi a ter See JPM Ex Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPMorgan pai i icipated in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i JPMorgan Private ank Client Cash Transaction Guidelines states The receipt of large cash deposits and disbursements of cash withdrawals for other than client casual spending needs to be discouraged It is the primary responsibility of the anker to obtain explanations on the source of the cash and acceptability of the intended use of the case and to assess the plausibility of these explanations for large cash transactions Ex at Case Document Filed Page of JP MC es pon se Di sputed to exte USVI misstates i ed doc ment JPMorgan li ent Cas Transaction Gu i delines ast ev i ew date November state rece i of la ge cash depos i ts a disb ur seme ts of cas withdrawals fo ot er a client cas a spe in eeds i i sco ur aged See USVI at Othe i se un disp ed at cited doc me contains oted ext Disp ted in sofa as USV I conte ds at is fac ppo is a infe ce at PMo ga pai i icipated in Epstein a ll eged sex trafficking ve ur See CSM i,i From September through November JPMorga recorded cash wit dra als from Epstein JPMorgan accounts tota ing Ex at and Figure copied below Figu CT el at i ng to Epste in Acc ount a Ep tein pstein Hyperion NY a th Year tLL Total Total JPMC Response Undisputed that cited document is a summary of transactions prepared by USVI 2s proffered expert Jorge Am ador Disputed that this forma5.5 tion as available to JPMorgan in this format during the time Epstei was a client of JPMorgan Disputed as to ma ter3.8 ality to the nt this summary fails to put Epstein 2s transactions in the approp5.8 riate con5.8 ext See JPMC Ex Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participa4.7 ed in Epste4.7 2s alle ged sex-trafficking venture ee CSMF From through JPMorgan record ed in cash withdrawals from Epstein 2s Morgan accounts Ex at and Figure JPMC Response Undisputed that cited document is a summary of transactions prepared by USVI 2s proffered expert Jorge Am ador Disputed that this forma5.1 tion as available to JPMorgan in this format during the time Epstei was a client of JPMorgan Disputed as to ter3.8 ality to the nt this summary fails to put Epstein 2s transactions in the approp5.8 riate con5.8 ext See JPMC Ex Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participa4.7 ed in Epste4.7 2s alle ged sex-trafficking venture ee CSMF From to JPMorgan recorded in cash withdrawals from Epstein 2s JPMorgan accounts Ex at and Figure JPMC Response Undisputed that cited document is a summary of transactions prepared by USVI 2s proffered expert Jorge Am ador Disputed that this forma5.1 tion as available to JPMorgan in this format during the time Epstei was a client of JPMorgan Disputed as to ter3.8 ality to the nt this summary fails to put Epstein 2s transactions in the approp5.8 riate con5.8 ext See JPMC Ex Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participa4.7 ed in Epste4.7 2s alle ged sex-trafficking venture ee CSMF From to JPMorgan recorded in cash withdrawals from Epstein 2s JPMorgan accounts Ex at and Figure JPMC Response Undisputed that cited document is a summary of transactions prepared by USVI 2s proffered expert Jorge Am ador Disputed that this forma5.1 tion as available to JPMorgan in this format during the time Epstei was a client of JPMorgan Disputed as to ter3.8 ality to the nt this summary fails to put Epstein 2s transactions in the approp5.8 riate con5.8 ext See JPMC Ex Case Document Filed Page of Case Document Filed Page of Disputed in sofa as USVI co nt ds at is fac upp i a infer ce at JPM ga pai i icipated in Epsteins a lle ged sex tr a ffickin ve ure See CSM i,i From August through June JPMorgan recorded in cash withdrawals from Epstein JPMorgan accounts re evant transactions identified and summarized in the chart below Transaction Date Acct Amount Epstein Epstein Epstein Epstein Epstein Epstein Epstein Epstein Epstein Epstein Epstein Epstein NYSG Epstein Epstein Epstein NYSG Epstein Case Document Filed Page of Tran action Date Acc Amount Epste in Epste in Epste in Epste in Epste in Epste in Epste in NYSG Epste in Epste in Epste in Epste in Epste in rand Total JPM Re pon Und i sputed that i ed document is a UIIll naiy of transac ions prepai ed by USVI Disp ted at is info1matio was ava i la to JPMorgan in hi fo1mat dur in time ps in was a cl i of JPMorga Disp ed as to materiality exte this summaiy fails to ps i tra sactio in the approp ia co ext See JPMC Ex r,r Disp ted in sofai as USV I conte ds at is fac ppo i a infe ce at PMo ga pai i icipated in Epsteins a ll eged sex trafficking ve ur See CSM r,r From August through November JPMorgan recorded in cash withdrawals from Epstein JPMorgan accounts relevant transactions identified and summarized in the chart be ow Case Document Filed Page of Tra sactio Date Acct Amou Ep in Ep in Ep in Ep in Ep in Ep in Ep in Ep in Ep in Ep in Ep in Ep in NY Ep in Ep in Ep in NY Ep in Ep in Ep in Ep in Ep in Case Document Filed Page of Tran action Date Acc Amount Epste in Epste in Epste in NYSG Epste in Epste in Epste in Epste in Epste in Epste in NYSG Epste in Epste in Epste in Epste in Epste in Epste in NYSG Epste in Epste in Epste in Epste in Case Document Filed Page of Tran action Date Acc Amount Epste in Epste in ast St LL Epste in Epste in Epste in Epste in Epste in Epste in Epste in Epste in Epste in Epste in Epste in Epste in Epste in Epste in yper i yper i yper i yper i yper i Case Document Filed Page of Tran action Date Acc Amount yper i yper i yper i yper i yper i yper i yper i yper i yper i yper i Grand Total JPM Re pon Und i sputed tha i ed document is a mmaiy of transac ions prepa ed by USVI Disputed at is info1matio was ava i la to JPMorga in th i fo1mat dur in time ps in was a clie of JPMorgan Disp ed as to materiality to exte this summaiy fails to put ps i tra sactio in the approp iate co ext See JPMC Ex r,r Disputed in sofa as USVI conte ds at is fac ppo is a infe ce at PMo ga pai i icipate in Epsteins a ll eged sex trafficking ve See CSM r,r From September through November JPMorgan recorded in cash withdrawals from Epstein JPMorgan accounts re evant transactions identified and summarized in the chart be ow Tran action Date Acc Total a ps in ps in ps te in Case Document Filed Page of Tran action Date Acc Total a in in NYSG in in in in in in Eas 65th St in in in in in in in in in in in ein Case Document Filed Page of Tran action Date Acc Total a te in te in Hype ion Hype ion Hype ion Hype ion Hyperion Hyperion Hyperion Hyperion Hyperion Hype ion Hype ion Hype ion Hype ion Hype ion Hyperion rand Total JPM Re pon Und i puted that i ted document i a mmai of tran action prepa ed by USVI Di puted at i info1mati wa ava i lab to JPMorgan in th i fo1mat dur in time te in wa a clie of JPMorgan Di ted a to materiality exte thi ummaiy fail put te i tra acti in the approp iate co text ee JPMC Ex r,r Case Document Filed Page of Di ted in so fa as SV I co nt ds a i fac pp i a infe a PM a pai i icip a in Ep in a ll ed tr a ffickin re See CS i,i rom August thr ugh November Morgan recorded in cash withdrawal from Ep stein Morgan accounts re evant transactions i dentified and summarized in the chart be ow Tran action Date A Total a Hyp i Hyp i rand Total JP MC es pon se nd i put ed th at i ed doc umen i a ummai tran sac i prepai VI Di at i info1ma i a a va i ab JP Mo an in th i fo1mat dur i time Ep i was a cl i JP Mo ga Di pu ed as a ri a li ty th thi ummai fail put Ep i tra a ti in the appropri a See JP MC i,i Di put in so fai as SV I co nt ds at i fa upp i a infe ce at JPM a pai i icip a in Ep in a ll ed tr a ffickin en re See CS i,i at I at at I 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 pai i icipated in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i JPMorgan Benefited from Participation in Epstein alleged sex-trafficking venture JPMC Response Thi i a eade hi response i waiTa nt ed Di sp uted in sofa as SVI co ends th a the sta tement a nd documen cited below establish as a atter of la at JPM ga benefited fr paicipation in Epsteins alleged sex traffi kin ve ure JPMorgan first opened an account for Epstein in Ex at Resp JPMC Response ndi sputed th a Epstein ope ned an acco unt wit JPM Cs predecessor entities in Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i JPMorgan admits that it earned fees and revenue from providing banking services to Epstein Ex at Resp JPMC Response ndi sputed th a JPM gan earned fees and re ve nu from pro vid in banking se vices Epstein Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i One of the factors impacting bonuses for JPMorgan Private Bankers was the revenues that clients brought into the bank Ex at JPMC Response ndi sputed th a MoITis estified that revenues we re ne fac th a was tak into accoun de ermine the discre ionaiy nu a Pri va Banker wo uld receive Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i In Epstein brought in over million in revenue to the Private Bank Ex at JPM Re pon Di sputed hat th mill io in even in was fr Eps in acco un ts at th JP Mo ga Pr ivate at tl SVI mi sc ai izes oc um th mill io in cl des eve nu fr ot Pr ivate ank clie ts i a il See SVI Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at Mo ga be efited fr paicipat in in ste in alleged sex raffick in ve ur See CSM i,i Epstein million in revenue in was the most investor revenue for JPMorgan Wealth Management Ex at JPM Re pon Di sputed hat th cited docume nt estab li es th at pste in was respo sib fo os in vesto eve nu fo JP Mo gan Wea lth Ma age ent in Th i ted doc um ent fl ec eve nu es fr ly a a ll bset of JP Mo ga Pr ivate ank clie ts speci fi ca ll Pr ivate ank clie ts were catego ized as i ves Mo eove reve nu es related to ste in in cl ud ose der i ved fr ot cl ie ts in ci all See SVI Ex a Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce at Mo ga be efited fr paicipat in in ste in a ll eged sex raffick in ve ur See CSM i,i Epsteins million in revenue in was near double the amount of JPMorgan Wealth Management second highest client Ex at JPM Re pon Di sputed hat th cited docume nt estab li es a ste in was respo sib fo eve nu es eai ly do ble th a un of JP Morgan Wealt Manage nt seco hi es clie in ci ed doc um fl ects reve nu es fr nl a a ll ub se of Morga i va a nk cl ie ts specifica ll st th i va a nk cl ie ts were catego ized as in vesto Mo eove reve nu es ated to Eps in in cl de ose de ived fro ot er clie ts prin ip a ll See USVI at Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i In Jeffrey Epstein through the trading of his accounts and that sic of generates one of the largest annual revenue flows of private clients in the private bank Ex at In Epstein JPMorgan anker considered the Epstein Wexner relationship a crucial relationsh;p to the private bank Ex at JPM Re pon i sputed hat ci ed doc um ts co nt a in oted ext is pu ted to exte nt a SVI co te nd hat in was pr im aiy ri ve of th even fl ows or was th crncia at i hip acco unt we drive of reve nu a key a 1i relatio hip An yo be li eve at elatio hip was a ote rn cial relatio hi ivate ank is hat fa ir A was a rn cia elatio ip to pr i va a nk yes An pste in A Eps in was ey anager fo yes So erefo was paii of a imp iant elatio ip a Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ur See CSM i,i eading up to Epstein indictment in he was one of JPMorgan ve1 big clients Ex at Ex at JPM Re pon Und i sputed hat i ted doc ents Case Document Filed Page of Dis put ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex-traffick in ve ur In October Epstein JPMorgan accounts totaled approximately million Ex at JPM Re pon i sputed th at as of Octobe a Rap i es se Tea doc um ent states at pstein relatio hi co sis of bank in asset and di accounts wit balances ota lin approximately mi ll i USV I Ex at Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tra ffi cking ve ur See CSM i,i At the October Rapid Response Team meeting a fter internal discussion with Jes Staley Mary Erdoes Catherine Keating John Duffy and Mary Casey it was decided that we will keep Mr Epstein solely as a banking client and on a rea ctive client service basis Ex at Resp citing JPM SDNYLIT Ex JPM Re pon Di sputed exte nt USVI mi sstates qu ed doc um The doc um ent states a ft int rn al i sc ssio not disc ssio SVI Ex at th i se un dis pu ted at ci ed doc um conta in qu ed text JP Mo ga lacks knowledge as et th efere ced in ternal disc ssio in fact occ Ted Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tra ffi cking ve ur See CSM i,i Kevin McC eerey testified that these conditions were imposed to mitigate the risk presented by Epstein by capping the number of accounts and relationships with him Ex at JPM Re pon Di sputed th at McClee ey test i fie th at th ese co ditio we imp osed to mi tigate is prese ted by stein by capping num be of acco un ts a relatio hi ps i im McClee ey testi fi ed hat li mi ting Mr Eps in to a nkin and custody mitigated the risk presented by Mr Epstein because JPMorgan was 223not expanding the relationship based on the reputati onal risk that we knew of at the time in October of USVI Ex at McCleerey further test ified that 223limiting Epstein to being a banking--2.1 only client should have 223limit ed the risk presented by Mr Epstein because would cap the number of accounts and relations hips with him Id at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF In October JPMorgan continued doing busin ess as usual with Epstein 2s office Ex at JPMC Response Disputed that JPMorgan continue doing business as usual with Epstein 2s office in October JPMorgan did not continue doing business as usual with Epstein 2s office following his indictment and instea limited Epstein primarily to banking services See USVI Ex at he ci ted document is an October email from Casey sent after deci on was made to limit Eps4.6 ein to banking services that contains the te xt current understanding is that we are business as usual with stein5.9 office in the ntext whether to autho5.8 ize a new Letter of Cred5.8 it for Epste4.3 2s office See USVI Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF At the time,5.2 Mary Erdo5.2 es wanted to ve forward based on our earlier decision to continue doing business with Epstein Ex at Ex at JPMC Response Undisputed that the cited document regarding the decision whether to authorize a new Letter of Credit for Epstei in October contains the quoted text Disputed that Erdoes anted to move forw ard with authorizing a new letter of credit for Epstein in October JPMorgan lack knowledge as to Erdoes state of mind regarding whether or not to authorize a new Le tter of Credit for Epstein in October Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF By July Epstein 2s JPMorgan accounts had increased to to tal approximately million at Ex at Case Document Filed Page of Case Document Filed Page of JP MC es pon se Und i sputed tha a Rapid Respo se Meet in docume co a in quoted tex Epste in at i sh i ma i nly consists of bank in a asset accounts wit balances totali approximately i ll i USV I Ex at Disp ted in sofa as USV I conte ds at is fac ppo i a infe ce at PMo ga be efited fr om pai i icipat in in Epsteins a ll eged sex trafficking ve ture See CSM i,i On August Mary Casey emails Marcus Sheridan subject Re plan and said Also I would count Epstein assets as a probable outflow for or so as I can imagine it will stay pending Dimon re iew Ex at JPM Re pon Und i sputed that i ed doc me conta in ed text Di sp ted as to un de rl in gges ion at Dimo was in volved in a Epste in ev i ew Casey tes ified tha inte ded he email to efere ce Cutler a i mea it be Jamie Dimo as ad not hin to do wit is JPMC Ex at Mr er i da the ec i ient ema i a so est i fied Disp ted in sofa as USV I conte ds at is fac ppo i a infe ce at PMo ga efited from pai i icipat in in Epsteins a ll eged sex trafficking ve ture See CSM i,i On September Epstein JPMorgan accounts had a PCN Market Value of Ex at Ex at Resp JPM Re pon Und i sputed that i ed document identifies a PCN Mai Va lu of Disp ted in sofa as USV I conte ds at is fac ppo i a infe ce at PMo ga efited from pai i icipat in in Epsteins a ll eged sex trafficking ve ture See CSM i,i JPMorgan admits that in October Epstein was one of JPMorgan stop clients in the osel Held Business Group Ex at Resp JPM Re pon Und i sputed that Epste in was of JPMo gans top clie ts in osely Held Business Gro as Oc ober Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i Ex 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 be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i Ex 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 be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i Ex at Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ur See CSM i,i By Epstein was JPMorgan Private ank GIO biggest revenue producer Ex at JPM Re pon i sputed th at ci ed doc um co nt a in oted text Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ur See CSM i,i Jul Epstein was still activel trading through the GI Ex at JPMC Response Undisputed that cited document a July email from Nelson to McCleerey and Duffy states he assets Epstein keeps at J.P Morgan are his own money which he actively trades through our Gl obal Investment Opportunities desk with Paul Barrett 2s team VI Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF At the time Epstein nker stin5.9 Nelson described Epstein as and sophisticated investors on the desk Ex at JPMC Response Undisputed that Epstein 2s banker de scribed Epstein as 223one of the most active and sophisticated investors on the desk USVI Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF In September JPMorgan noted the impac of exiting Epstein roughly equated to oY revenue decrease in In it will be roughly a 2MM revenue impact.5.1 Ex at JPMorgan further noted cu rrently has with us and actually has TCP flows of 72MM this year Id JPMC Response Disputed that JPMorgan 223noted the imp5.7 act exiting Epstein equated to YoY revenue decrease in In it will be roughly a 2MM revenue impact The quoted text appear in a September email from Carmen Zee to Thomas Southmayd which was se nt after the decision was communicated to Epstein in August that JPMC ould be exiting his relationship See JPMC Ex Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF In or about the year Douglas 223Sandy Wa rner then CEO of JPMorgan said to Staley then Head of ivate Bank houl meet sic Epstein He 2s one of the most connected people I know of in Ne York Ex at JPMC Response Undisputed that Staley testified as to the quoted text Disputed to the extent the nderly6.1 ng ct requ6.1 ire4.9 credib6.1 ility eter4.1 mina4.9 tion6.1 Case Document Filed Page of Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF JPMorgan admits Epstein intr oduced and referred potential lients to JP6 Morgan Private Bank Ex at Resps JPMC Response Undisputed that Epstein introduced and referred clients Robert Burch I thryn Ruemmler and Ghislian5.5 xwell to JPMorgan Private Bank See USVI Ex at Resp JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein referred a number of ultra-high net wort clients to JPMorgan over the years Ex at Resp Ex at JPMC Response Undisputed that Epstein referred Robert Lee Burch I Kathryn Ruemmle4.5 and Ghisla4.5 Maxwell to JPMC See USVI Ex at Resp JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF One of the factors impacting bonuses for JP Morgan Private Bankers was new client acquisition Ex at JPMC Response Disputed that one of the factor impacting bonuses for JPMorgan Private Bankers was new client acquisiti on The cited document does not support the proposition as Nelson testified that new client acquisition wa3 223one of the factors that could be considered for compensation USVI Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF One of the objectives tha5.7 was instille4.5 in JPMorgan Private ankers was to acquire new clien5.5 Epstein referred Bill Gates a client to JPMorgan Ex at Case Document Filed Page of JPMC Response Disputed that 223one of the objectiv es tha4 was instille4.5 in JPMorg an Private Bankers was to acquire new clients The cited testimony does not support this proposition Disputed to the extent aley 2s testimony does not support the assertion that Epstein referred any clients to JPMC7.5 See JPMC Ex at don 2t think Epstein referred clients to the bank I met clients through him but I don 2t think he making a referral Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein referred Sergey Brin as a clie nt to JP6 Morgan Ex at JPMC Response Disputed Staley 2s testimony doe not support the assertion that Epstein referred any clients to JPMC7.5 See JPMC Ex at don 2t think Epstein referred clients to the bank I met clients through him but I don 2t think he making a referral JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein referred Google LLC as a clie nt to JPMorgan Ex at JPMC Response Disputed Staley 2s testimony doe not support the assertion that Epstein referred any clients to JPMC7.5 See JPMC Ex at don 2t think Epstein referred clients to the bank I met clients through him but I don 2t think he making a referral Disputed that pstein referred Google LLC as a client to JPMorgan See JPMC Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein referred the Sultan of Dubai Sultan Ahme bin Sulayem as a client to JPMorgan Ex at JPMC Response Disputed Staley 2s testimony doe not support the assertion that Epstein referred any clients to JPMC7.5 See JPMC Ex at don 2t think Epstein referred clients to the bank I met clients through him but I don 2t think he making a referral JPMC Ex at Resp Case Document Filed Page of Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce at JPM ga be efited fr paicipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i Epstein referred Mort Zuckerman as a client to JPMorgan Ex at JPMC Response Di sputed Sta eys tes tim does ot upp 1i the asse 1ii at Epstein refened any clients JPMC See JPM Ex at I don think Ep ste in refened clients to th bank I me client through him but I don think was makin a fen al See also JPM Ex at Resp Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce at JPM ga be efited fr paicipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i Epstein referred the as a client to JPMorgan Ex at JPMC Response Di pu ted aleys te sti does ot suppo1i he asse1iio th at Epstein refened any clients JPMC See JPM Ex at I don think Ep ste in refened clients to th bank I me client through him but I don think was makin a fen al Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce at JPM ga be efited fr paicipating in Epsteins a lle ged sex traffi ck in ve ntur See CSM i,i Epstein referred David Gergen as a client to JPMorgan Ex at JPMC Response Di pu ted aleys te sti does ot suppo1i he asse1iio th at Epstein refened any clients JPMC See JPM Ex at I don think Ep ste in refened clients to th bank I me client through him but I don think was makin a fen al Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce at JPM ga be efited fr paicipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i Epstein referred Boris Nikolic as a client to JPMorgan Ex at Ex at JPMC Response Di pu ted aleys te sti does ot suppo1i he asse1iio th at Epstein refened any clients JPMC See JPM Ex at I don think Ep ste in refened clients to the bank I me client throu him but I don think was makin a fen al See also JPM Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Boris Nikolic was a medical advisor who an a venture fund Ex at JPMC Response Undisputed that Morris testified during his deposition that 223Boris Nikolic was a medical advisor He was an entrepreneur runs a venture fund See USVI Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Boris Nikolic was 223somehow related to Bill Gates Ex at JPMC Response Undisputed at the cited dep5.7 sition contains quoted tes4.9 timon5.7 See USVI Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein referred Larry Summers as a clie nt to Morgan Ex at JPMC Response Disputed Staley 2s testimony does not support the assertion that Epstein referred any clients to JPMC7.5 See JPMC Ex at don 2t think Epstein referred clients to the bank I met clients through him but I don 2t think he making a referral Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein referred Thomas Pritz ker chairman and CEO of the Pritzker Organization as a client or for additional activitie or funds to Morgan Ex at Resp Ex at JPMC Response Disputed Staley 2s testimony does not support the assertion that Epstein referred any clients to JPMC7.5 See JPMC Ex at don 2t think Epstein referred clients to the bank I met clients through him but I don 2t think he making a referral See also USVI Ex at Resp Case Document Filed Page of Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein facilitated meetings between St aley and Ehud Barak Ex at JPMC Response Disp uted to the extent the cited tes5 timon5.8 does not s5 upport contention that Epstein facilitated meetings betw7.5 een Staley and Bara Staley tes5.2 tif4 that he met Barak US VI Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF In January Epstein facilitated5.1 an in troduction tween JPMorga5.2 execu5.2 tives and Ehud Barak and Staley directed his assistant to arrange the meeting through Jamie Dimon office Ex at JPMC Response Disputed JPMorgan Chase did not need5.7 Epstein to facilita4.6 te a meeting with Barak or others As JPMC 2s CEO testified don 2t think Jeff Epstein ever arranged for me to eet with anybody to my knowledge And I knew Ehud Barak We did not need introductions to anybody JPMC Ex at Further disputed to the extent that USVI conte nds that there was an introduction through pstein or that he facilitated a meeting between JPMC executive and Mr Barak Otherwise undisputed Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited par3.9 tic4.7 ipa4.7 ting in Eps5.1 i 2s alleged sex-trafficking venture See CSMF Epstein facilitated meetings between Staley and Peter Mand elson Ex at JPMC Response Undisputed that Staley testified that Eps4.5 ein facilitated meetings between Staley and Peter Mandelson USVI Ex at Disputed as to materiality in light of the fact that Epstei did not refer Mandelson to the Private Bank See JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Lord Peter Mandelson was a senior member of the British Government Ex at JPMC Response Undisputed that the cited documen states that Lord ter Mandelson is a ior membe4.5 of the British Governmen5.7 Disputed to ter3.8 ality in ligh5.8 the Case Document Filed Page of fact that Eps4.9 ein i not refer Mandelson to the P6 ivate Bank See JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF On June Epstein wrote to Staley 223well sic for all inten ds sic and purposes peter mandelson is now deputy prim minister Ex at Ex at at JPMC Response Undisputed that the cited docum2.6 ent contains the quoted language Disputed as to ter3.8 ality in ligh5.8 of the fa ct that Epstein did not refer Mandelson to the Private Bank See JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF On June Epstein wrote to Staley 223peter will be st aying at st over weekend do you want to organize either you or you and Jami sic quietly sic up to you Ex at Ex at at JPMC Response Undisputed that the cited docum2.6 ent contains the quoted language Disputed as to ter3.8 ality in ligh5.8 of the fa ct that Epstein did not refer Mandelson to the Private Bank See JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF In January Epstein wrote to Staley 223david gergen is coming to see me today sic we should talk before elve Ex at Ex at Ex at JPMC Response Undisputed that the cited documen contains the quoted language Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF David Gergen is a former adviser to Pres idents Nixon Ford Reagan and Clinton Ex at Case Document Filed Page of JPMC Response Undisputed that the cited document ates 223David Gergen is the me of a former adviser to Pres idents Nixon Ford Reagan and Clinton through USVI Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein cilitated meetings between5.6 JPMor gan employees nd Prince ndrew Ex JPMC Response Undisputed that Staley testified 223yes when asked 223but Jeffrey Epstein at least facilitated meetings tw een persons working at the bank and Prince Andrew is that fair USVI Ex at Disputed as to materiality in light of the fact that Epstein did not refer Prince Andrew to the Private Bank See MC Ex at Resp JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF On April Epstein wrote to Prince Andrew the Duke of York 223jes staley will be in ondon on thurs the sic i think you should meet if you are in town sic Ex at Ex at Ex at JPMC Response Disputed to the extent USVI misstates the quoted document Epstein 2s email to Prince Andrew states 223london not 223London See USVI Ex at Otherwise undisputed that the cited documen contains the quoted text Disputed as to ter3.9 ality in ligh5.9 of the ct at Epst ein did not refer Prince Andrew to the Private Bank See JPMC Ex at Resp JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF On May Epstein wrote to Staley re sic will to ee you on your trip6 to london Ex at Ex at at JPMC Response Undisputed that the cited document contains the quoted text Disputed as to mate4.8 ria4.8 lity in light of the f4 act th6 at Ep ste4.4 did not ref3.6 ince Andr3.6 to the Private Bank See JPMC Ex at Resp JPMC Res ponse to USVI RFA No JPMC Ex at Resp Case Document Filed Page of Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp i a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i On September Lesley Groff wrote to Epstein Jes Staley office called saying last night Jes met up with Prince Andrew and Tim Collins Ex at Ex at OJ Ex at JPM Re pon dis pu ted a i ted doc um nt co nt a in quoted ext is pu ted as to ate iality in li th fact at pste in did refe Prin ce An dr ew to th Pr ivate Bank See MC Ex a esp JP MC at es Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i Ex at th i se un dis pu ted a i ted a i co ta in th qu oted text Disp ut ed as to a ia li ty in light of fac a ste in i ot efe in ce An ew Pr ivate Bank See MC Ex a esp JP MC 73at es Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo gan be efited fr paicipat in in ste in a ll eged sex raffick in ve ur See CSM i,i On December Prince Andrew wrote to Staley Wishing you a very happy Christmas and New Year Sorry to have missed you this week Hope to catch up sometime after the New Year I will be at Davos as usual Ex at Ex at Ex at JPMC Response Disputed to the extent USVI misstates the quoted document which fails to llips es tween each ence con5.7 ained in the uote See VI Ex at Otherwise undisputed that the cited docu ment contains the quoted text Disputed as to mate4.8 ria4.8 lity in light of the f4 act th6 at Ep ste4.4 did not ref3.6 ince Andr3.6 to the Private Bank See JPMC Ex at Resp JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF In November Prince Andrew hosted Jami Dimon for dinner and performances at Buckingham Palace Ex at JPMC Response Undisputed that the Financial Times reported that Prince Andrew hosted an event in November that 223had a guestlist that included up to corporate and political heavyweights ranging from Ko fi nnan the former UN secretary-general to Indian industrialist Ratan Tata See USVI Ex at Disputed to the extent the document does not suggest there was a onnection between this event and Jeffrey Epstein In fact the documen states that David Mayhew a UK financier and adviser to JPMC at the time was 223key to organising th night JPMC Ex Disputed as to mate4.7 ria4.7 ity in light fac4.7 tha4.7 Epstei did not refer Prince Andrew to the Private Bank See JPMC Ex at Resp JPMC Ex 73at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein facilitated meetings between5.3 aley and Bill Gates Ex at JPMC Response Disputed to the extent the underl ying fact which is supported only by Staley5.7 2s dep5.7 sition tes4.9 imony requ5.7 ires a credib5.5 ility termination Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein introduced his JPMor gan banker Paul Morris to A ndrew Farkas Ex at JPMC Response Undisputed that Morris testifie that Epstein introduced him to Farkas Disputed as to materi ality in light of the fact that Farkas did not become Morris 2s client USVI Ex at and Epstein did not refer Farkas to the Private Bank See JPMC Ex at Resp JPMC Ex at Resp Case Document Filed Page of Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Andrew Farkas is a major real estate in vestor ho founded Island Capital Group Ex at JPMC Response Undisputed that the cited doc ument ates4.5 223Andrew Farkas is a major real estate investor who founded Island Capital oup See USVI Ex at Disputed as to ter3.8 ality in ligh5.8 of the fa ct at Farkas did become Morris 2s client USVI Ex at and Epstein did not refer Farkas to the Private Bank See JPMC Ex at Resp JPMC Ex at Resp Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein introduced JPMorgan to Da vid Mitchell a real estate developer Ex at JPMC Response Undisputed that Morris testifie that Epstein introduced him to Mitch5.4 ll VI Ex at Disputed as to materiality in li ght of the fact th6 at Mitchell did not become Morris 2s cl ient USVI Ex at Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF Epstein referred Robert Lee Burch II form er CEO of Jonathan Engineered Solutions and member of Jones advisory board as a client to JPMorgan Ex at Ex at Resp JPMC Response Undisputed Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein alleged sex-trafficking venture See CSMF In Epstein 2s JPMorgan Private Banker Cas ey noted that Epstein elped us source several man5.3 agers inclu5.3 ding Glenn Dubi and Steve ltzma5.3 Ex at Case Document Filed Page of Case Document Filed Page of JPM Re pon is pu ted to extent USVI misstates ci ed doc um Th cited doc um ent was not wr i by Maty Casey and ates ub in a Steve Salzma not Gle nn bin and Steve Sa tzma See USV I Ex at Ot e1wise un i sputed hat th cited oc um nt co ta in qu oted ext is pu te at ste in di in fac refe Saltz an to th i va at tl See JP MC Ex at Resp JP MC Ex at esp Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr patiicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i Ex See MC Ex a esp JP MC at es Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr patiicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i Ex at JPM Re pon dis pu ted a ci ed doc um co ta in th oted tex Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr patiicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i Ex at Ex at Case Document Filed Page of USVI Ex at USVI Ex at Di pu as to ate a 1ty th fact at Epstein di re fe Brin or age th Pri va Bank See JPM at es JPM at Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga enefite fr pai i icipating in Epsteins a lle ged sex tr a ffi cking ve ure See CSM i,i Sergey Brin became a client of JPMorgan San Francisco Private Bank in Ex at JPMC Response Undispu ed that Brin became a li nt of the Pri vate Bank in Disputed as th inferen ce that Epstein re fe ned Brin See JPMC Ex at Re sp JPMC Ex at Disputed in sofa as USVI co nt ds at hi fac upp i an inference at JPM ga enefite fr pai i icipating in Epsteins a lle ged sex tr a ffi cking ve ure See CSM i,i Staley referred Brin to Robert Keller JPMorgan Banke Managing Director in San Francisco Ex at Ex at JPMC Response Undispu ed that Brin was re fe ned to elle by Staley Di sputed as the inference at Ep ein efened Brin See JPM at es JPM Ex at Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i Ex at Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um ent co nt a in oted ext USV I Ex a Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ur See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ur See CSM i,i Ex at Case Document Filed Page of Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve nt ure See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve nt ure See CSM i,i On October Ann Borowiec emailed Jes Staley Catherine spoke to me about the need to have a NY team for Jeffrey Epstein as the advisor to the Google founders Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve nt ure See CSM i,i Case Document Filed Page of the Times since I knew he was a cl i ent I had it on desk and gave it to Pooja Ex at JPM Re pon is pu ted to ex ent USVI mi ss tate doc um ent orow i ecs a i tate Wh i ot hi USVI at Ot wise un disp ut ed Disp ut ed in sofa as USV I co te ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve nt ure See CSM i,i Ex at on USVI at Disp ut ed in sofa as USV I co te ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve ur See CSM i,i Ex at Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve ur See CSM i,i Case Document Filed Page of Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sofa as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve nt ure See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve nt ure See CSM i,i Ex at at JPM Re pon dis pu ted a i ted doc um ents co ta in quoted ext USVI Ex a Disp ut ed in sofa as USV I co te ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tra ffi kin ve ur See CSM i,i Case Document Filed Page of Ex at Disputed in sofa as USVI conte ds at hi fac upp is an inference at JPM ga benefite fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i Disputed in sof ai as USVI conte ds at hi fac upp is an inference at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i In Jul JPMorgan noted he overall Brin relationsh;p is one of the largest in the Private Bank of BN Ex at Case Document Filed Page of JPMC Response Undispu ed that the i ed document contains he quoted te xt USVI Ex at Disputed as to the inference that Ep tein re fe ne Brin See JPM at Resp JPMC Ex at Disputed in sofa as USVI conte ds at hi fac upp is an inference at JPM ga benefite fr pai i icipating in Ep tein a lle ged ex-trafficking ve ntur See CSM i,i Brin and the CEO CFO and CIO of his family offi ce Ba yshore Global met with Mary Erdoes Ke lly Coffey John Duffy and other JPMorgan regional e.xecutives Ex at JPMC Response Undi pu ed that the i ed document tate ergey as we ll as mbers of hi family office CEO CFO an IO have me wi th Maiy Er doe Kelly Coffey John Duffy and ot re i nal executives SVI Ex at Di pute as to he in fe ren ce th at Epstein refe1Te Brin See JPM Ex at Resp JPMC Ex at Disputed in so far as USVI co nt ds at hi fac upp i an infer ce at JPM ga benefite fr pai i icipating in Ep tein a lle ged ex-trafficking ve ntur See CSM i,i at Ex at Disputed as to ater iali ty in li ht of the fac th at Epstein did ot fer ultan Ahmed Bin ula ye a a clien to JPM ga See JPM Ex at Resp Disputed in so fai as USVI conte ds at hi fac upp i an inference at JPM ga benefite fr pai i icipating in Ep tein a lle ged ex-trafficking ve ntur See CSM i,i at JPMC Response USVI Ex at Disputed a to ater iali ty in li ht of the fac th at Epstein did not fer ultan Ahmed Bin Su la ye as a client to JPM gan See JPM Ex at Resp Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i at Ex at Ex at JPM Re pon is put ed to extent USVI mi ts tex fro ci ed ote See SVI Ex a th i se un dis pu ted Disp ut ed as to ater i a li ty in li ht of fac a ste in i ot refe Su lt an A hm ed Bin laye as a clie to JP Mo ga See MC Ex a esp Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at Mo ga be efited fr paicipat in in steins a ll eged sex raffick in ve nt ure See CSM i,i Sultan Ahmed bin Sula em was a senior United Arab Emirates official involved in ownership of the Dubai Ports Ex at JPM Re pon dis pu ted a i ted doc um sta es Su lt an A hm ed in laye i a se ior AE offic i al in volved in ow ers hip of ba i o1is USVI Ex a Disp ut ed as to ater i a li ty in li ht of fact hat Eps in did not efe lta Ahm ed Bin ul aye as a cl ient to JP Mo gan See JP MC Ex at Resp Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at Mo ga be efited fr paicipat in in steins a ll eged sex traffick in ve ur See CSM i,i On December Epstein wrote to Staley if you can have a one on one off the record with sultan sic he will meet you Ex at Ex at Ex at JPM Re pon dis pu ted a cited doc um ents co ta in quoted ext USVI Ex a USVI at USV I Ex at is pu ted as to ate iality in Case Document Filed Page of li of fact at Ep te in did not efer lta Ahmed Bin a em as a client JPMorga See JPMC Ex at Re Di ted in so fa a SV I conte ds at i fact i a infe ce at PM ga be efited fr paicipat in in tein a ll eged ex trafficking ture See CSM i,i ecem er pstein wr te Staley ch i na rts yet i sultan will meet ri ate gi ve gu i dance at at at JPM Re pon di ted at i ted doc um ent ta in quoted text VI Ex at USVI at SV I Ex at Di ted a ater i a lity in li of fact th at Ep te in did not efer lta Ahmed Bin a em a a client JPMorgan ee JPMC Ex at Re Di ted in so fai a SV I conte ds at i fact i a infe ce at PM ga be efited fr paicipat in in tein a ll eged ex trafficking ture See CSM i,i em er Ep ste i wr te Sultan bi ulayem op i ng taley sultan si Jes i free thurs i where and when i nly the tw of lease at at at JPM Re pon di ted at i ted doc um ent ta in quoted text VI Ex at USVI at SV I Ex at i pu ted a ate iality in li of fact that Ep te in did not efer lta Ahmed Bin a em as a client JPMorgan ee JPMC Ex at Re Di ted in so fai a SV I conte ds at i fact i a infe ce at PM ga be efited fr paicipat in in tein a ll eged ex trafficking ture See CSM i,i ecember Ep ste i wr te taley sultan i layin the gro undw rk esta lish a er io us resen si re utat io in the re gio i poo at at at JPM Re pon di pu ted at i ted doc um ent ta in quoted text VI Ex at USVI at i pu te a to ateriality in li fact that tein i efe lt an A med Bin layem a a clie to JPMorga See JPMC at Re Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga be efited fr pai i icipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i Epsteins client Leon Black was a customer of JPMorgan Private Bank Ex at Resp Ex at Ex at JPMC Response Undispu ed that Leon Bla ck was a th Pri vate Bank Disputed as ater iali ty in li ht of the fac th at Epstein did fer Leon Bl ack as a clien JPMorgan See SVI Ex at Re sp Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i One of Epsteins JPMorgan ankers testified Leon lack had a ve1y significant net worth and he was a CEO of a large investment firm and I looked at him as a priority prospect Ex JPMC Response Undispu ed that Mon i tes ified the cited info1mati USVI Ex at Di sputed as materi a lity in light he fac that Epstein did refer Leon Bl ac as a clien to JPM ga See SVI at es Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga be efited fr pai i icipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i Epstein occasionally brought opportunities to JPMorgan for them to deepen their relationship with Leon lack Ex at JPMC Response Undispu ed th at Ne so estified the i ed in fo nn a ion SVI Ex at Di sp ut ed as ater iali ty in li ht of the fac th at Epstein did not fer Leon Bl ac as a clien to JPM ga See SVI at es Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga be efited fr pai i icipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i In July Epstein sought a loan through JPMorgan on behalf of Leon Black for an art purchase Ex at Ex at Case Document Filed Page of JPMC Response Undisputed that the i ted email fr Duffy Erdoes discusses a loan Jeffr ey is pursuing Le be half USVI at and that Monis testified th at Epstein wa nt ed to bring him an ai i loan fo Le on Bla ck SVI Ex at Di sputed as materi a lity in li ht of the fact that Epstein did ot refer Le Bla ck as a li nt to JPM ga See USV I Ex at Resp Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce at JPM ga be efited fr paicipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i Ex at Disputed in sof ai as USVI conte ds at hi fact upp is an infer ce at JPMorgan benefited fr paicipating in Epsteins a lle ged sex traffi ck in ve ntur See CSM i,i Ex at JPMC Response Undisputed that the cited document co nt a in he quoted te xt USVI Ex at Disputed as to ater iali ty in li ht of the fac th at Epstein did not efe Leon Bl ac as a lient to JPM ga See USVI at es Disputed in sofa as USVI co nt ds at hi fac upp is an infer ce at JPMorgan be efited fr pai i icipating in Epsteins a lle ged sex traffi ck in ve ntur See CSM i,i Case Document Filed Page of at JPM Re pon dis pu ted a i ted doc um ent co nt a in quoted ext USV I Ex a Disp ut ed as a ter i a li ty in li ht of fact th a Eps in did not efer Leo Bl ac as a clie to JP Morga See USVI at es Disp ut ed in sofa as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve nt ure See CSM i,i USVI at Ot wise un disp ut ed Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve ur See CSM i,i Ex at JPM Re pon dis pu ted at i ted doc um ent co nt a in quoted ext USV I Ex at Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve ur See CSM i,i Case Document Filed Page of On March I Roy Navon wrote Jacob Frenkel and Staley Against all odds we have been granted a meeting with Prime Minister Netan ahu Staley rwarded the email from Navon to Epstein and said Thanks Epstein responded to Staley swprisee sic swprise Ex at Ex at Ex at JPMC Response Di pu ed to he ex ent USVI mi ss ates he ci ed documen Ep ein response to Staley sta te urpri see sic upri se sic SVI Ex at Othe1wise undi pu ed Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga benefite fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i On April JO Epstein wrote to Staley I will be back tomorow sic Karim Wade son of the senegalese president and one of the most important players in africa will be at the house this week i think you will enjoy him Ex at Ex at Ex at JPMC Response Undispu ed that the i ed documents co a in he quoted te USVI Ex at USVI at USVI Ex at Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga benefite fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i On September I Epstein wrote to Staley co founder of facebook sic and founder of spotify sean parker sic will be at the house for dinner on sunday-come Ex at Ex at Ex at JPMC Response Undispu ed that the i ed doc ument co a in he quote te USVI Ex at USVI at USVI Ex at Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga enefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i Ex at Resp Case Document Filed Page of Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga benefite fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i In August after JPMorgan informed Epstein of the decision to exit him from the bank Duffy and Erdoes decided it was okay to continue working with Epstein as long as it was through his client accounts Ex at Ex at JPMC Response Di pu ed Erdoes an Duf fy selec ti vely permitte further gage men her he clien irected at JPM intera ct i Epstein ut Ep stein co ul have decision makin a ri ty ove the accoun See JPMC Ex See also JPMC Ex a We cant sto so eo ne from being affi liated i so meb ody else Bu we wo uldn be taking direction fr Ep stein see also JPMC at JPMC Ex at Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga enefite fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i JPMorgan continued to work with Epstein on accounts for Le Black CEO of Apollo a private equity group Ex at Ex at Ex at Ex at Ex at JPMC Response Di pu ed to he extent he SVI mi sc ai teri zes JPMorgan as work in i Epstein acco unt for Le Bl ac Di pu ed to he exte the cited documents do ot suppo1i he asse1iio th at JPM gan co ntinu wo rk wit Ep ein acco unt for Leon Bl ac In the i ed de os i ion tes im Nelso is as ked was there ever a poin in time her Jeffrey Epstein was co luni ca tin i yo behalf of Leon Bl ac relat ed any in ves men ve hicle Justin Nelson replie I dont remember USVI at See also JPMC Re spo se to i supra Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ure See CSM i,i Duffy gave Epsteins JPMorgan Banker Nelson permission to continue a relationship with Epstein as a potential source of referrals Ex at Case Document Filed Page of JPM Re pon dis pu ted a urin hi deposi ti Ju tin Nelso es ded yes asked if afte Je ffr ey stein ad ee te nnin a ed Nelso got pe nni ss i of Jo hn Du ffy to cont inu a a ti hip ith ef fr ey ste in ere wi ll a pote nti a so ur ce of fu ur refe a SVI Ex at is pu te as to th scope of a ti hip i li ed by SVIs proposi ti See MC espo se to Disp ut ed in sofa as USV I co te ds at is fact upp i a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex raffick in ve ur See CSM r,r Nelson maintained a relationsh;p with Epstein after he was terminated as a client Ex at JPM Re pon dis pu ted as to ci ed deposi ti te tim USV I Ex at Disp ut ed in sofa as USV I co te ds at is fact upp i a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM r,r Nelson met with Epstein tol times after Epstein was terminated Ex at JPM Re pon dis pu ted as to ci ed deposi ti te tim USV I Ex at Disp ut ed in sof ai as USV I conte ds at is fact upp i a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM r,r JPMorgan admits that Mary Casey met with Epstein at his Manhattan townhouse two or three times between and before Epstein arrest in JPMorgan admits that Mary Casey also met with Epstein at his Manhattan townhouse once in and once in the summer of Ex at Resp JPM Re pon is pu ted to ex th USVI mi ssta es i ted doc um espo se ates th at Er does ot Casey wit Eps in twice at hi Ma nh at a tow nh se in a in umm USV I Ex at Resp dis pu ted a i ted doc um ent sta es a Maiy Casey et i Eps in at is Ma nh attan tow nh se two or hr ee occasio etwee and pr i Eps in aiT es in Id Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um nt co nt a in oted ext is pu ted as to ate iality in li th fact at pste in did refe eo lac as a cl ie to Morga See SVI Ex a esp Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i JPM Re pon dis pu ted a cited doc um nt co ta in qu ed ext USVI at Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i JPM Re pon dis pu ted a cited doc um nt conta in qu ed ext USVI at Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i Ex at JPM Re pon Un dis pu ted th at cited doc um nt conta in qu oted ext USVI at Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at Mo ga be efited fr paicipat in in ste in a ll eged sex raffick in ve ur See CSM i,i Ex at Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce th at JP Mo gan be efited fr paicipat in in ste in alleged sex raffick in ve ntur See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce th at JP Mo gan be efited fr paicipat in in steins alleged sex raffick in ve ntur See CSM i,i Case Document Filed Page of JPMorgan admits pstein was invol ed in the establishment of a customer relationship with Kathryn Ruemmler at Resp JPMC Response Undispu ed that the i ed document sta te that Mr Epstein had so me in volve nt in he establishment sto mer relationships etwee JPM private bank a nd Ghislaine Maxwell a nd a lu Ruemmler SVI Ex at Re sp Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i Ex at Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga enefite fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i at JPMC Response SVI Ex at Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i Case Document Filed Page of Ex at Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPMorgan benefited fr pai i icipating in Epsteins alleged sex tr affick in ve ntur See CSM i,i Ex at Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPMorgan benefited fr pai i icipating in Epsteins a lle ged sex traffi ck in ve ntur See CSM i,i Epstein was close friends with Glenn Dubin the billionaire co-founder of Highbridge and godfather to one ofDubin children Ex i Ex at Ex at JPMC Response Di pu ed to he ex ent he SVI in se i he wo close to describe the relati hip ndi sputed th a in the i ed deposition estimony Erdoes sta es I understood Mr Epstein to be ave ad a as relati hip i Mr Du in wife And I un ders ood that Mr Epstein was he godfat her of one of he Dubin th ld es the Dubin hil ren That was un ders tan ding USVI at Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPMorgan enefited fr pai i icipating in Epsteins a lle ged sex traffi ck in ve ntur See CSM i,i Epstein advised JPMorgan regarding the acquisition Ex at Ex at JPMC Response Di pu ed to he extent he USVI mischai 267acterizes Epsteins role regarding the acq ui si ti On June vo Moltke emails aley a nd Bri gs ocke co in ther JPM mpl oyees The ail Uinmai zes obse va ti from a ee tin he Case Document Filed Page of previous day wi th High rid ge One the items und Next steps states We continue to co nc rned a the role Jeffrey Ep ste in is is playing One concern that we have is th at Jeffrey has ee educating Glenn Hern a ur tru ct ure and va lu a ion thoughts hind ur backs at heir expec atio fo yes erday were hi her Thi i clearly in ur inter est SVI Ex at Thi infonn atio does not suppo1i the proposition at Ep ein a i sed JPM Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex a ffi kin ve ntur See CSM i,i Epstein al advi ed Highbridge regarding the acquisition Ex at Ex at JPMC Response Undispu ed that the Febmaiy email se nt from heph aley a nd Bri gs ocke copying Cook sets out a ti man proposal sic fo he economics a co ultin airnngemen at Hi hbri dge for Jeff Epstein USV I Ex at Disputed as th ex ten th USV I hai acterizes thi proposal as representative of any final advising aiTangement between Highbrid ge and Epstein or Epstein an JPM Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga be efited fr pai i icipating in Epsteins a lle ged sex a ffi kin ve ntur See CSM i,i On Ju James Von Moltke emailed Jes Staley and David Brigstocke with the subject line Thoughts on the meeting with Highbridge stating The good news is that we did not leave an mone on the tab and that based on the multiple range we discussed with Dimon et a They shou be encouraged to go ahead with the Dimon and Coulter lunch This would be a good part of a follow up discus ion ideally with you and prior to the Dimon Coulter meeting We continue to be concerned about the role Jeffrey Epstein is or is not pla ing One concern that we have is that Jeffre has been educating enn Henry about our structure and valuation thoughts Ex at JPMC Response Undispu ed that the i ed doc umen co nt a in he quoted te a lth the underl in document i fo1matted as a ser i es dis in bullet poin and as co inuous te as thi para gra ph pre se it SVI Ex at Di sp ted extent ci ed docu i se ec ti ve ote a i ut a pp ro pr iate co nt ext in sta ce a guage at USVI otes ggests Hi hbr idge ul enco ur aged to Case Document Filed Page of a ad ith he Dim an Co ult lun because the mul ipl ran di sc ss ed ith Dim et al The at em nt owev er a ppe a in iff nt unrel a ed ct i vo ltke em a il SV I at empha i a dd ed urth dis pu ted in sofa as USVI co nt ds a hi fact suppo is an infe re ce a Morgan fi ted fro a rti cipat in in pste in alleged sex ra ffi kin ve ur See CSM I,I On January the New York Times reported that JPMorgan had agreed to acquire Bank One and stated The combined company will be headed by William Harrison who is currently the chairman and chief executive of JP Morgan Chase James Dimon the chairman and chief executive of Bank One will become president and chief operating officer of the combined company He is to succeed Mr Harrison as chief executive in although Mr Harrison will remain as chairman Ex at JPM Re pon dis pu ted a i ted doc um ent co nt a in quoted ext USV I Ex a Disp ut ed in sofa as USV I co te ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve nt ure See CSM i,i urth co nt ded hat th cited ater i al ca nn be pr ese nt ed a ia in admissible Ex at Case Document Filed Page of Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve nt ure See CSM i,i at Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tra ffi cking ve ur See CSM i,i JPMorgan admits that Dubin Swieca Holdings Inc paid Financial Trnst Company Inc a fee related to JPMorgan acquisition of a majority interest in Highbridge Capital Management in Ex at Resp JPM Re pon dis pu ted a bin Swieca old in gs Inc aid Financial rn Co mp a In a fee related Morga ac qu isitio a ajor i ty inte es in ighbr i dge Cap i ta Ma age nt in USVI at es Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga be efited fr pai i icipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i Ex at at Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga be efited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i Highbridge managed billion in assets at the time JPMorgan acquired the majority interest Ex at JPMC Response Undispu ed that the i ed doc ument a New York Time ai i icle dated Septe mber sta te that Hi hbri dge man ages billion in asse SVI Ex a Disputed in sofa as USVI co nt ds at hi fac upp i an infer ce at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i On June JPMorgan completed its purchase of Highbridge and touted it as one of the largest and most significant strategic alliances in the hedge fund industry Ex at JPMC Response Di puted as USVIs ai erization th at th cited oc um nt uted anything Undispu ed that the i ed document dated June co nt a in he quoted te xt USVI Ex a Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga benefited fr pai i icipating in Epsteins a lle ged sex tr a ffi kin ve ntur See CSM i,i Case Document Filed Page of At the October Rapid Response meeting the Private ank imposed a condition on Epsteins accounts he could remain a banking but not an investment client Ex at JPM Re pon is pu ted SVI missta es concl sio of th eeting and ci ed doc um ci ed doc um does ppo 1t co cl sio th at th i va a nk im posed a co di ti at pste in co ul ot a in an in vest cl ie ci ed apid espo se Team ran um ates hat i was dec i ded hat we wi ll eep Eps in so ely as a ankin cl ient a a reactive clie se i ce bas i We wi ll ot proac ti ve so li cit ew in ves tm in ess fr him SVI Ex a MC decided a it wo ld roactive solici ew in vest in ess fr ste in ot a ste in co ld be a in ves tm cl i nt Id see also JP MC Ex at Disp ut ed in sofa as USV I co te ds at is fact upp ts a in fe ce at JP Mo ga be efited fr paiticipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i At the time Epsteins brokerage business was at Bear Stearns not JPMorgan Ex at Ex at JPM Re pon dis pu ted a i ted doc um ents ppo rt a ste in a a broke ra ge relatio hi wi th ai Steai SVI Ex a USVI at Disp ut ed in sofa as USV I co te ds at is fact upp ts a in fe ce th at JP Morgan or ea Stea be efited fr paiticipat in in ste in a ll eged sex tra ffi kin ve ur See CSMF i,i JPMorgan considered him problematic"from an investment standpoint Ex at Ex at JPM Re pon dis pu ted a i ted doc um ent a esti ppo rt a MC co i de ed ste in ro le a ti fr an in vest sta dpoint USVI at SVI Ex a Disp ut ed a hi fact is at a ll aterial iss es of is case Th cited ai ows at JP MC mp loyees a disc ss in Eps in ro le a ti be avior in co text of hi fai lur pay fees and beca se eve ran sactio beco es prob atic USVI at Thi di sc ssio as ot hin to do wit pste in at est in Ms Casey estified at ci ed ail related a ll ges cove rin Je ffr ey beca se was a di fic ult in vest cl ie and a refe ce ste in be in rob atic was in co nn ec ti wi th a in ves tm ate co cern USV I Ex at Case Document Filed Page of Disp ted in sofa as USV I conte ds at is fac ppo i a infe ce at PMo ga be efited from pai i icipat in in Epsteins a ll eged sex trafficking ve ture See CSM i,i at Epstein was the Private Bank investment arms biggest revenue producer Ex at I I I SVI Ex at See USVI Ex at See JPMC Ex a USVI Ex at Disp ted in sofai as USV I conte ds at is fac suppo i a infe ce at JPMo ga benefited from pai i icipat in in Epsteins a ll eged sex traffick i ng ve ture See CSM i,i Ex at JPMC Response to i supra Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce at JPM ga be efited fr paicipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i On March JPMorgan purchased Bear Stearns Ex at JPMC Response Undisputed that Mai JPM ga ase a nd Co purchased Beai Steai Disputed in sof ai as USVI conte ds at hi fact upp is an inference th at JPM gan or Beai Steai benefited fr paicipating in Epsteins alleged sex tr affick in ve ntur See CSMF i,i The purchase kept Bear Stearns which was heavi in mortgage backed securities investments from bankruptcy following the housing market crash that led to the Great Recession Ex at JPMC Response Undisputed that the i ted doc umen pro vides th cited info1mation SVI Ex at Disputed at he ci ed document is co mp ten evidence imp act the pur ase of ea Stea or at led to Be a Steai bankrnptcy Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce th at JPM gan or Beai Steai benefited fr paicipating in Epsteins alleged sex tr affick in ve ntur See CSMF i,i Ex at See JPM Ex at And i ts also co sis ten th at JPM gan retained Jeffrey Epstein as a li nt to deal i th eai teain litigation th at Jeffrey Ep ste in ha co ect A I don kn ow at id at expla inin reasons JPMC retained Epstein aro und hi time as Mr aley felt ve stro gly that Mr Ep in a paid hi debt soc i ety had se ved hi time and was so eo th at a ot of ther eople rn sted I think Mr Staley didnt ag ee wit he notion th at we uldn have him as a clien Disputed in sof ai as USVI conte ds at hi fact upp is an inference th at JPM gan or Bear Stea be efited fr paicipating in Epsteins alleged sex raffick in ve ntur See CSMF i,i Fmiher contended th at th cited ater ial ca nn be presented at trial in admissib f01m Case Document Filed Page of In August Epstein sued Bear Stearns for fraudulently overstat ing the value of Bear Stearns mortgages mortgage backed and asset backed securities and other derivative financial instruments the adequacy of its liquidity and capital reserves and the qual i ty of Bear Stearns risk management Ex JPM Re pon dis pu ted at on A Eps in nti ty in ancia st Co mp a In fi led a co aint aga in st Th ea te a Co mp a ies In a he co a int co ta in qu ed language Disp ut ed in sofa as USV I conte ds at is fact upp i a infe ce a JP Mo gan or ea te a be efited fr paicipat in in steins alleged sex raffick in ve nt ure See CSMF r,r ur co te ded a cited a ter i a ca nn ot be esented at ia in admiss i fo1 On Jul JPMorgan offered Epstein a proposal to settle his High Grade Fund and Bear Stearns claims together for million Ex at The following day Cutler responded This is not an honorable person in any way He should not be a client Id JPM Re pon is pu ted SVI misstates i ted doc um ent doc um ent does not suppo1i co tenti hat Mo gan offe ed stein a ro osal settle is cl aims for mi ll io Rat th cited doc um ows at MC responded to Ep in propo a sett hi claims fo i ll io See USVI Ex at ly James Co wrote to Staley Er does utl and enke I co veyed to Eps in our es pon se to is propo a to se tl is ig Grade un and ai ock cla i ms oget fo mi llio Id mph asis added disp ut ed at Cutler responded Co ai a utl es se co nt a in quoted tex Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex raffick in ve nt ure On July Cutler wrote to Erdoes regarding a settlement offer to Epstein I would like to put it and HIM behind us Not a person we should do business with period Ex at JPM Re pon dis pu ted at ai ed does a th a a i conta in th ted tex SVI Ex at _R Di sp ted th exte USVI co ten hat thi fact ppor an in fere ce hi litigatio ad any relevance to JP MC Case Document Filed Page of re ention exi decisions i re spec to Epstein See JPMC Ex at And i also co sis ten th a JPM gan re a in ed Jeffrey Ep ein as a client deal wi th the Bear eams liti ga ti at Jeffr ey Epstein ad co IT ect A I don kn ow at id at exp a inin reasons JPMC re a in ed Epstein aro und this im as a ey felt ve stro gly th at Mr Ep ein had pai hi debt to society a served hi im and was so me th a a ther eop le ste I think Mr Sta le didnt ag ee wit he ion that we uldn ha ve him as a clien Disputed in sofa as USVI conte ds at hi fac upp i an inference at JPM ga benefite fr pai i icipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i On August JPMorgan met for a fourth Rapid Response Meeting regarding Epstein and concluded that Duffy to reach out to Jes Stale and advi that we exit while things are a bit sett ed Ex at JPMC Response Undispu ed that a Rapid Re spo se eet in was eld A and he ci ed documen conta in th quo ed text SVI at Disputed in sof ai as USVI conte ds at hi fac upp i an inference at JPM ga enefited fr pai i icipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i On April Nina Shenker emailed Ke in McCleerey with the subject Rapid Response Shenker wrote If ou could break down between ddas brokerage and fund holdings and others i categories So that we can understand the process for ojjboarding the account Ex at Ke vi McC eerey responded with the attachment Rap i Response Team Jeffrey Espstein sic 3r Mtg Jan March update doc zip Employees were working to collect i nformat i on to understand the process for ojjboarding the account Id at JPMC Response Di pu ed SVI mi ssta te the i ed doc umen Und i spute th at Ap ril henk emails McCleerey an th ail co a in the qu ed ext McCleerey does owe er respond nk wi th the i ed at ac hmen Rather McCleerey fo wa rd henker email James alessio a tt ac hin the fil ti ed Rap id Re spo se eam Jeffr ey Esps ein ic Jan March upda e-doc zip and sta te Let sic discuss her que USVI at Case Document Filed Page of Disputed in sofa as USVI co nt ds at hi fact upp is an infer ce at JPM ga be efited fr paicipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i In Ju ly when Epstein approved the settlement Nina Shenker then GC to the Private ank wrote to Erdoes Steve Cutler at conclusion of JE approval of ear Stearns settlement asked when we are ofjboarding JE I reminded him that we have the other matter outstanding Ex at Ex at JPMC Response Undisputed that henker ailed Erd oes July and th at email conta in th quoted lan age USVI at Disputed in sof ai as USVI conte ds at hi fact upp is an inference at JPM ga be efited fr paicipating in Epsteins a lle ged sex tr a ffickin ve ntur See CSM i,i Ex at JPMC Response Undisputed that the cited document contains he quoted te xt USVI Ex at Disputed in sof ai as USVI conte ds at hi fact upp is an inference at JPMorgan be efited fr paicipating in Epsteins a lle ged sex traffi ck in ve ntur See CSM i,i Ex at Ex at I also don kn ow at we we ot off oa rdin Mr Epstein because th Hi hbrid ge litigation li tigatio claim id at We id ot a so offboai him once th Zwim matter was resolved id at ex pl a inin re aso JPMC retained Epstein ai 267ound this im as aley felt ve1y tron at Mr Epstein ad paid hi debt soc i ety ad se ved hi time a nd was so me th at a ot ther people tiu sted I think Mr aley didn ag re wi th the ti th at we ou ldn ave him as a client Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i urth co nt ded hat th cited ater i al ca nn be pr ese nt ed a ia in admissible Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um ent co nt a in oted ext USV I Ex a Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce th at JP Mo gan or ea Stea be efited fr paicipat in in ste in a ll eged sex ra fick in ve ur See CSMF i,i JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at JP Mo gan be efited fr paicipat in in ste in a ll eged sex raffick in ve ntur See CSM i,i Case Document Filed Page of The Talented Mr Epstein states in his early Epstein got a job teaching physics and math at alton the elite Manhattan private school While there he began tutoring the son of ear Stearns chairman Ace Greenberg and was friend with a daughter of Greenbergs Soon he went to ear Stearns where under the mentorship of both Greenberg and current Be ar Stearns C.E James Cayne he did well enough to become a limited partner-a rung beneath full partner Ex at JPM Re pon se Undisputed that the i ted document co nt a in quoted text USVI Ex at Disputed in sofa as USVI conte ds at is fact uppo1i an inference that JPM rgan or Bear Steams benefited fr paicipat in in Epsteins alleged sex trafficking ve ntur See CSMF i,i Fmihe co nt ended that the cited material ca nn ot be pre se nted at tria in admiss i f01m I August Alan Ace Greenberg who was now at JPMorgan wanted to continue to do business with Epstein so he went to Cutler for an exception to the felon policy Ex at JPM Re pon se Undisputed that the i ted emai states at Ace Greenberg wa nt to do business with Ep ste in and Todd Cook asks id Ace go to him fo an except i to the felo policy to wh i Melissa Getler states That my understanding USVI Ex at Disputed in sof ai as USVI conte ds at is fact uppo1i an inference at JPMorgan benefited fr paicipating in Epsteins a ll eged sex tr afficking ve ntur See CSMF i,i I his deposition Jes Staley agreed that Greenberg was a fairly important person with heft at JPMorgan around Ex at JPM Re spo se Di puted to extent USVI mi sc hai 267acte ri zes Staley testimony See USVI Ex at Und i puted tha Sta ey te st ified at Greenberg was im po rtan I at Disputed in sofa as USVI conte ds at hi fact upp is an inference at JPM rgan benefited fr paicipating in Epsteins a ll eged sex tr afficking ve ntur See CSMF i,i Case Document Filed Page of eginning in Staley and Erdoes had regular communication with Jeffrey Epstein relating to certain strategic initiatives and business proposals Ex at Ex at JPM Re pon dis pu ed at i ed doc um ents co a in quoted ext USVI Ex at USVI at Disp ut ed in sofa as USV I conte ds at is fac upp i a infe ce at JP Mo ga be efited fr pai i icipat in in steins a ll eged sex traffic kin ve nt ure See CSM i,i Ex at Ex at Disp ut ed in sof ai as USV I conte ds at is fac upp i a infe ce at Mo ga efited fr pai i icipat in in steins a ll eged sex traffick in ve ture See CSM i,i JPMorgan admits that Epstein and JPMorgan personnel discussed a potential donor advised fund relating to The Bill and Melinda Gates Foundation and Bill Gates Ex at Resp JPM Re pon dis pu ed at stein and JP Mo ga perso nn disc ssed a po tia donor advised fun at in The i ll a Me lin da Gates Fo un datio and Bi ll Gates USVI Ex at Resp Disp ut ed in sof ai as USV I conte ds at is fac upp i a infe ce at Mo ga be efited fr pai i icipat in in steins a ll eged sex raffick in ve nt ure See CSM i,i On Februa,y Epstein wrote to Staley regarding a potential donor advised fund for The Bill and Melinda Gates Foundation you could tie it initially just to the gates program sic miinimum sic gift million it could then be opend sic up later IT will be the largest foundation in the world done right its sic billion dollars in years Farming the Case Document Filed Page of investments to a i ghbr i dge is no brainer It will be the most sort sic after board in the counhy Ex at Ex at Ex at JPM Re pon dis pu ted a i ted doc um ents co ta in quoted ext USVI Ex a USVI at USV I Ex at Disp ut ed in sofa as USV I conte ds at is fact upp i a in fe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve ntur See CSM i,i In August Epstein wrote to Staley and Erdoes regarding noting it will be a very HIGH profile opportunity and recommending it require a minimum million donation Ex at Ex at Ex at JPM Re pon dis pu ted a stein a i led aley a Er does A st and wrote Thi i ll be ve HI profi I propose a min im um of mi ll i donation USVI Ex at Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tra ffi kin ve ur See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um ent co nt a in quoted ext USV I Ex a Disp ut ed in sofa as USV I conte ds at is fact upp i a in fe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve ntur See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um ent co nt a in quoted ext USV I Ex a Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp i a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp i a infe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i JPMorgan admits it had communication with Epstein about a fee for Epstein in connection with a proposed donor advised fund Ex at Resp JPM Re pon dis pu ted a MC ad co mmuni catio wit pste in abo ut a fee for ste in in co nn ectio wit a proposed do a i sed fun isputed as a ia li ty in light of fact th at as prov i ded in full cited espo se th do advised fun was eve es a lis ed and JP MC did pay pste in a fee See USVI at es Disp ut ed in sofa as USV I co te ds at is fact upp i a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex tra ffi kin ve ur See CSM i,i Case Document Filed Page of Ex at Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tr a ffi kin ve ur See CSM i,i On April Epstein emailed Staley can meet have dinner lunch a weekend sic with an of the following seth Lloyd mit quantum computing sic murray gell man santa fe institute quarks sic brian greene Columbia string theory sic leonard Susskind sic strings theory lawrence Krause sic origins institute phoenix Arizona sic lee smolin perimeter institute loop quantum gravity sic she can see the large adron sic collider in switzerland private tour Ex at Ex at Ex at JPM on is pu ted to extent USVI misstates doc um ent ote text ates can eet ave inn un a weeke sic wit a follow in set ll oyd mi qu an tum co mpu ting sic mm rny gell a sa nt a fe in ti ut arks sic br i a ee co lum bia st rin th eo1y i eo a sskind sic st rin gs eo1y aw ce kr a se sic or i i ns in stitute phoe ni ai i zo a sic lee olin pe i eter in stitute loop quant um grav i ty sic can see lai ge hadro i co ll ide in swi ze rl and pr ivate USVI at Ot wise un disp ut ed Disp ut ed in sofa as USV I conte ds at is fact upp is a infe ce at JP Mo ga be efited fr paicipat in in steins a ll eged sex tra ffi cking ve ur See CSM i,i Ex at JPM Re pon Case Document Filed Page of Dis put ed in sofa as USV I co te ds at is fact upp is a in fe ce at JP Mo ga be efited fr paicipat in in ste in a ll eged sex raffick in ve ur On September Staleyf01warded an email chain between him and Staley wife regarding a professor at Columbia to Epstein can sic get to this professor at Columbia Ex at Ex at Ex at On September Epstein responded in a snap Id JPM Re on is ted to ex USV I mi ss ates quoted doc um nt aleys wife and oted ai fr Sta ey eads Ca nu get hi rofessor at Co lum bia SVI Ex at th i se un dis pu te Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at Mo ga be efited fr paicipat in in ste in a ll eged sex raffick in ve ur See CSM i,i On December Erdoes wrote to Staley regarding Bernie Mada.ff glenn and I have been going back and forth all night This is terrible Just terrible has over Nicole has another client with We have HUNDREDS of clients with some The ny/palm beach community will be in shock Can you call JE to get scoop from down there Ex at JPM Re pon dis pu ted a i ted doc um co nt a in quoted ext USV I Ex a Disp ut ed in sof ai as USV I conte ds at is fact upp is a infe ce at Mo ga be efited fr paicipat in in ste in a ll eged sex raffick in ve ntur See CSM i,i On April in a CNN interview Jamie Dimon in response to a question about whether JPMorgan should have acted more quick after Epstein pleaded guilty to one of these charges in said Hindsight is afabulous gift Ex at JPM Re pon dis pu ted a im rovided qu ed es se USVI at Disp ut ed in sofa as USV I co te ds at is fact upp is a in fe ce at Mo ga be efited fr paicipat in in ste in a ll eged sex raffick in ve ur See CSM i,i Case Document Filed Page of I the same CNN i nterv i ew Jamie imon was asked the US Virgin Islands is alleging that your bank helped facilitate pa ments to Epstein victims and benefited from human trafficking while ignoring warnings those allegations have merit Dimon responded have some of the best lawyers in the world compliance out of the DOJ out of SEC important divisions who review all of these things and make decisions at the time based on what they know as best as they know Ex at JPM Re pon i pu te a im rov i de qu ed es se USVI at i put ed in so far as USV I co te ds at hi fact upp i an in fe ce at JP Mo an be fi ted fr paii i i pat in in ste in a ll eged sex tr a ffi kin ve ntur See CSM i,i JPMorgan Obstructed Enforcement of the TVP A Shaun Neill former Special Agent with the Federal ureau of Investigations I states that the FB I relies on financial institutions as a key partner to obtain the information necessary to answer the questions of who what when where and why Ex at The information in Morgan possession warranted a constant stream of information from MC to the FBI about Epstein Human trafficking is an ongoing crime with harm incurred every day that the crime continues Id at It shocks the conscience that it was not until Epsteins death in prison that JPMC suddenly recognized Epsteins prior banking transactions as Id at Neill further states that When it became public that Jeffrey Epstein had been arrested and that he had used cash to commit his sexual crimes against children MC impaired the governments ability to prosecute the crimes that it was investigating against Epstein I Further the sheer amount of cash being dispersed Case Document Filed Page of re than million was paid by Ep ste i men many wh had astern uro ean surnames and psteins an delin agen pstein uld ha been ederally char ed at a much earl i er date I at ad the FBI been tified this banking acti vi ty all i ng related Ep ste i pstein uld have been able cont i nue i cr i i nal act i i ty from nward I at JPM Re pon i pu ed doe not di te at ed i inclu ded in epo1i SVI proffe ed pe i a un Nei ll ow er JP di te unde rl in clu io and i ll i ss a eme th rec I Di ut in so fa a SV I ont ds at i fa i a infe ce at JP a ob truc ed fo cem nt of TVP A See CS MF i,i ur a ci mat i a ann be es at ti ial i adm i ss ib fo at Case Document Filed Page of Disputed in sofa as USVI conte ds at hi fact upp is an inference at JPM ga obs tru cted enforcement of TV A See CSMF i,i urth co nt nd ed that the ci ed ate ri al cannot be pr ese nt ed at tr ial in a dmi ssib fonn at JPMC Response Undisputed hat i ted doc umen co nt a in he quoted language USVI Ex at Disputed in sofa as USVI co te ds at hi fact upp is an inference at JPMorgan obstr cted enforcement of TV A See CSMF i,i In Brunel was arrested and charged with rape of minors and sexual haras ment and was under investigation for human trafficking Ex JPMC Response Di pu ted Brnn el was aITested in December ot See SVI Ex JPM Ex Brnn el was aITested at a is a rl es de Gaulle Aiiport in December co unt of ra and sexual assa rape a nd sex ua assau lt a min un der ra and sexual assa a min ove sex al arass men cr imin a assoc iati and human tr 267affic kin de tr men of min victi for pmposes sexual exploitation Disputed in sofa as USVI conte ds at hi fact upp is an inference at JPMorgan obs tru cted enforcement of TV A See CSMF i i Fmiher contended that the ci ted ate ri al ca nn ot be pr ese nt ed at tr ial in a dmi ssib fonn Case Document Filed Page of Ex at JPMC Response SVI Ex at Disputed in sofa as USVI conte ds at hi fac upp i an inference at JP Mo ga obs tru ed enforcement of TV A See CSMF i,i Facts Concerning Epstein Registration as a Sex Offender in the Virgin Islands Shani Pinney coordinator for the sex offender registry and former Attorney General Vincent Frazer both testified that they were not responsible for and did not enable Epstein crimes Ex at Ex at JPMC Response Undispu ed hat Pinne and Frazer estified as ch Disputed a tes im es ab li es as a le ga co nclu sio hat ey were re spo sib le fo and did enable Epsteins cr ime See e.g CSM i,i Epstein never failed to register as a sex offender Ex at JPMC Response Undispu ed th at Pinn ey estified that Epstein never failed to egis in the USVI See USVI at Shani Pinney coordinator for the sexual offender regishy testified that news reports were not sufficient basis to initiate an investigation because they did not contain the requisite concrete allegations of wrongdoing Ex at JPMC Response Undispu ed that Pinne estified as ch Disputed as th un de rl ying fac that news rep o1is were uffi i nt basis to ini ia an in ves ti ga ti int Epstein See CSMF i,i Case Document Filed Page of Former Attorney General Denise George similarly testified that she couldnt rely on news reports rumor or innuendo to initiate an investigation into Epstein Ex at JPMC Response Undisputed that George te tified as SVI Ex at Di spute as the underl in fact th at ne ws epo rt or or innuend co ul not se initiat an investigation into Ep te in See CSMF nf As witnesses testified absent an actual complaint from a victim or eyewitness evidence brought to the Department of Justices attention the Department could not initiate in estigations Ex at Ex at JPMC Response Undisputed that Pinne and George testified as uch Disputed as the underl in fact th a a se an ac a complaint fr a ictim eyewitness evide nce brought th Departm nt of Justices attention he Department co ul initiat in ves ti gatio See CSMF r,r Fmiher di sp ut th a th USVI lacked actual co mpl a int fr a victi or eyewitness See CSMF r,r Ms Pinney and Attorney George both confirmed they received no concrete complaints of misconduct by Epstein Ex at Ex at JPMC Response Undisputed that Pinne and George testified as uch Di pu ted in sofa as SVI contends th a the cited te sti establishes that the SVI acked ufficient evidence in ves ti ga Epstein or that in fo nn atio a out Ep te in mi sco ct ever reached USV I ffi cia See SUMF nf CSMF r,r Upon assuming her role as Attorney General Attorney George inquired of various agencies to confirm whether they had received any com laints regarding Epstein She found no evidence that any complaints had been received Ex at JPMC Response Undisputed that George te tified that he inquired wit th local VIPD a nd he SVI Depaiiment DOJ as paii of a ge neral inqun to find ut do we ave cases we ha ve a ecord of anyone co mpl a inin a out seeing so me hin that oo sp ici Li tl James or or wit es ect ef fre Epstein in paiticulai SVI Ex at Di pu ted to he extent USVI suggests that George inqun abo Epstein wi th any her age i es See id at I didnt inqun wit he federal authorities we re also here because th ey yo kn ow he yre go in disclose if ther es a pending in ves ti ga ti anything like at see also CSMF r,r U?vO?OP?F3O G?M?tI?OO?G0 W?ii?W8x??I7 I K?K A o(o3oBz 4K 30KCb 2e p2t 2A A Q?8F JK TZ N?M?r NEeD?M rq A WS?nY?GE mR?d YBWY xy?u?u i hSKI YjnU?zy?h ZF?gj?_?Ґ y:1y E?ak?2 g6 EeD T?J Lf Kf??w k?հ ngq 31Fs_g d6 TZ 5_ jz qr A..AA?A..AA g6 X?a M?N q?M 10Cy J?tZ m?E9q6t ORA?豕ar A i A i A i A I 1z I q?M CTX qY CTX qr a nd blWF uq??Ԑgg?8 9A A I 0b qr h:?WB p?c O?H lOK8 A Og I M?q qr un i W!k CTX yN?hY W?Qsyzo KMu?m M??N q?M CTX Y10Cy شl a GF3IW O?ǉcప H?X?D?S G5 G5 CTX qr q0T3 o3z I_ 3j i jh3 A 0b l??9Lڱ?lVy 1x 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