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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 The Virgin Islands epartment of Justice pe1formed address erification checks also called swee rough annually i conjunct io with Marsha/ls at JPM Re pon di pu ed at inne ti fied at at sw eep ith Mar a Ser i ce occ un ed per a onc a ear depe in fu nd i that the U.S Mar a rece i ve operat i al ep VI at Di the xte VI gg th a ro hl ann al eck were the on equ ir ed SV I DOJ lic Acc din ofU VI de ignee VI DOJ li i to pe fo andom eck on offe de eekl as we ll a an ann al weep ce a a ee CSMF i Pinn ey a es ifi th at dur in ea ld a ify the add sses ff der if ey cat if ey ad a ne a dd ess ith in at im I th ink it sev en ays at we ld a so go to ify eir a dd ess SVI at The address checks are warrants vernment officials po ssess the ab i lity to enter a sex offenders perty or conduct a search at JPM Re pon di ed at Pinne i fied ance the para rap Di ted in so fa a SV I gges at cited i a bli the prop os i ion as a le ga oncl i SV I at I certa i ears the US Marshalls and Virgin I slands fficials did ceed bey nd psteins ck If an ffender refused entry the go vernment fficials e1f rm i ng the check i ossess auth i zati to enter at JPM Re pon di ed at Pinne i fied anc the para rap VI at Di ted in so far a SV I gg th a the cited te timon tab li he prop os it i as a le al clu ion Ms inney testified that she nferred with the federal vernment ncern i ng th i ractice and was told that it was i i lar to a situation where a land wner has laced a gate at the border to his erty he ffi ci als were permitted to pr ceed ey nd that gate with ut a warrant at JPM Re pon di ed at Pinne i fied ance the para rap VI Ex Di ed in ofa a SV I gges at cited i tabli he prop os it i a a le al clu ion ur the di ed at Pinne fu ll Case Document Filed Page of testimony how am i uity as to he her the federal gove rnment co nfomed that this a nalo gy a pplied Ep tein dock See USVI at I was not improper or unusual for the Go ernment to confirm addresses at a sex offender place of employment as was done one ear with Epstein Ex at JPMC Response Undisputed that Pinne te tified that there was an in sta ce here Epsteins ve rifi cat ion was co nduc ted at hi office SVI Ex at A so undi put ed th at Pinne testified th at ve rified ther sex offenders in the USVI at their employer add ess Id at Disputed the ex ten USVI gges th a uch testimony es a li es at hi co nduc was improper or unu al as un upp o1 ted and disputed ther te tim in the rec rd See CSMF i I the Virgin Islands egislature amended its sex offender laws in part to obtain federalfundingfor its sex offender unit Ex at Ex at JPMC Response Undisputed that SVI a mended its sex ffender laws in and that Pinne te tified that by enhancing USVI la ws in th at ade li gib le be in the ir in I slan eligible to re ce i ve fundin for employees to nitor offenders in the ir in I slan SVI Ex at The US Government appro ed all changes to the Virgin Islands sex offender laws in advance Ex at Ex at JPMC Response Undisputed that the i ted testimony suppo 1t that the United ates Depaitment Justice ha to a ppro ve the amendment USVIs sex ff nder la ws in order fo USVI rec i ve he fundin USVI Ex at SVI Ex at Although Epsteins attorneys sought to coordinate with legislators concerning proposed changes to the Virgin Islands laws the Legislature ultimatel rejected Epstein proposed changes Ex at JPMC Response Di pu ted See CSM i i Case Document Filed Page of Epstein applied for and received a waiver in of hi travel notification requirements pursuant to these statut01y provisions Ex at Ex at JPM Re pon is pu ted Th USV I sex ff der aw sta es Atto rn ey ral ay at hi disc etio du ce thi twe ty day tice eq uir nt if a sex ff nd req ests a du ctio and provide information in upport of th que MC Ex as i added At rn ey razer testi fi ed th at Eps in atto rn eys rovided co espo de ce and in fo nn atio co ce rnin te in eed trave USVI at JP MC at see also CS MF i,i Acco in i re a in di sp ted th pste in app li ed for and eceive a pp rova for relaxa ti hi ti fi catio quir ur a nt to th ese at ut o1y prov i i Then Attorney General Vincent Frazer testified that he relied on representations of Epsteins counsel in forming his decision because he was satisfied with the representations which were satisfactory to conclude that there was not an undue risk to the community that would arisefrom the waiver Ex at Ex at JPM Re pon dis pu ted a Atto rn ey Fra ze te ti fied a li ed re pr ese nt atio of Eps in co un se wit es ect Eps in eed to tr avel fo in ess ac ti vi ti es a ow pste in rovided notice hi rave i a ai i a New Mex i co and ew Yo rk a i ti es USVI at Dis pu ted as th et th i ted re pr ese tati a acc ur ate as a ega or fac tu al at Fur er i sputed exte nt SVI gges thi test im suppo1is a infe re ce a wa i ve we egi tim ate granted and app ro iate See CSM i,i Epsteins lawyers themselves represented to Attorney Frazer that other states including Florida and New Mexico permitted Epstein to provide email notification of his travels and that there is no public safety necessity in requiring Mr Epstein to notify the Department in person each time he travels to or from the jurisdiction Ex at Ex at Case Document Filed Page of JPM Re pon dis pu ted a steins awyers ade re pr ese nt atio Atto rn ey ra ze USVI at USVI at Disp ut ed as to th et er i ted re pr ese nt atio are acc a as a legal or fac tu al atte hat Eps in lawyers we appropr i a in div i als dete nnin at li safety eq uir es Fm di sp ted to th ex USV I ggests is esti ppo 1t an in fe ce th at th waivers we egiti ate ran ted a approp ri a See CSM i,i As Ms Pinney explained and as the statute provides the travel notification statute only required notification of travel outside the United States While the Government had a policy in place to require notification of travel outside of the Territory but within the United States nothing in the Virgin Islands statute required such notification Ex at JPM Re pon is put ed as to a as at te prov i des as un upp ted by ci ed evide ce Un disp ut ed at Pinn ey esti fi ed at Im be rin ow at wi thin sta tu te i about otify in VI DO i a offe de as tifi ed any a ra ve tside of nit ed Sta es a th at we got a po li cy in ace we wanted ff ders to otify of yo kn ow a ravel to in cl de ts i de te1T i to SVI Ex a Travel notifications are not authorizations or requests the Government had no ability to restrict Epsteins travel Ex at JPM Re pon dis pu ted a Atto rn ey Fra ze tes tifi ed a hi un de stand in SON AR law pose was ot rest ict a perso ove nt It was to fo ll ow nit or ove ent USV I at Disp ut ed in sofa as USV I at se razers un derstand in aw to es a bli a legal co cl i SVIs aut ity Enhy into the Virgin Islands from overseas is controlled by federal authorities not the Virgin Islands Government Ex at JPM Re pon dis pu ted a A tt rn ey Fra ze tes ti fied a sto ecks a co ntr ll ed by th edera ni ted ates sto a de rotectio age cy SVI Ex at Disp ut ed to th ex th USVI co nt ds i as ro abi li ty to nit or nti into Virg in I a ds fr overseas See id at As A tt rn ey eral th ir in I slan did yo ave th abi li ty i yo ad a aw fo ce nt reaso to fin out was ti ave lin a paitic lar ane at tered th Vi in I a ds A Yes I im ag in I co ul MC Ex a Ex desc ib in po li i es to es a lis pa ti cove ra ge for a i1p and role patro in ito rin sec ity eck po in ts Case Document Filed Page of Facts Concerning Tax Benefits Granted to Epstein Companies The granted tax incenti es to two of Epsteins companies Financial Trust Compan and Southern Trust Company Ex at Exs JPMC Response Undispu ed that Financial rn Co mpan and So uthern Trns Co mpan we re gra ed tax inc nti ves USVI Ex USVI SVI Ex Disputed th ex ten USVI es he se were he nl ein-enti ies th at eceive benefits from USVI ee JPMC Ex at JPM JPMC Ex The first grant of benefits to an Epstein-owned company occurred in to Financial Trust Company Ex at Ex JPMC Response Undispu ed that the first gra of ED benefits a Ep ein-owned company occ uned in Financial Trns Co mp a USVI In Financial Trust applied for and received an extension of benefits Ex at JO Ex JPMC Response Undispu ed that in Financial rn st applied for and received an ex ension ofEDC benefits SVI Ex Epstein formed a new company So uthern Trust which applied for and received tax benefits in Ex at Ex JPMC Response Undispu ed that So uthern Trns app lied for EDC tax benefits in Disputed at Sout rn rn Co mpan rec eived ax benefi in USVI Ex a Each time that Financial Trust or Southern Trust sought benefits the companies submitted applications for the benefits Ex at Exs JPMC Response Undispu ed that each time Finan ia Trnst Sout rn rn so ht EDC benefits so me ne ubmitted a application for benefits behalf the company SVI Ex USVI Ex Each time that Financial Trust or Southern Trust sought benefits EDC held public hearings during which the benefits were discussed and the applicants were provided the Case Document Filed Page of opportunity to present their case and answer questions Ex at Ex Ex at Ex JPMC Response Undispu ed that the EDC held publi ear in gs regar in Finan ial Trn st or i in a application for benefits Financial rus application for od ifi ca ion of enefits a nd Sout rn Trn Co mpan ys ri ginal app li ca ion for nefit USVI Disputed th ex ten USVI gges ein was in attendance at eac he se meetin See JPMC Ex knowledge as heth the ED ld pu li hearings urin hi benefi we discussed and applications we provided he oppo1tunity to pr ese nt their case and answer questions eac ime th at inancial rns So hern Trnst sought nefi Each time that Financial Trust or Southern Trust sought benefits the EDC then held decision meetings where the board considered the applications and rendered decisions Ex at Exs JPMC Response Undispu ed that the EDC held decision mee ings re ga rdin Financial Trn st or i in a application for benefits Financial rus application for od ifi ca ion of benefits and Sout rn rnst Com pan ys ri ginal app li cation for nefi USVI JPMC la cks kn owledge as ther he EDC held ecision ee tin gs each time Financial rnst or So uthern Trns so benefits Dispu ed that the board rendered decisions at eac decision mee ing Id Epsteins Florida con iction was not a sufficient basis for revocation of benefits at that time because there was no evidence available to the EDC that Epstein solicitation of a minor/or prostitution in Florida was connected with the operation of Epstein USVI businesses Ex at JPMC Response Undispu ed that Benjamin te stified at th type of har ge was co nn ected the business opera ions SVI Ex a Di sputed th a Epsteins Florida co vic ion was a su ffi cie basis for re voca ti benefi because there was evidence available the EDC that Epsteins solicita ion of a min for prosti uti in Florida was co nn ected wi th the operation of Epsteins USVI businesses See e.g CSMF i,i The EDC did not ha access to Epstein companies dail financial transactions and was not aware of any connection between his conduct and the operations of his business Ex Case Document Filed Page of at Ex at Ex at JPM Re pon is pu ted at EDC was aware of a co nn ectio betwee steins conduct and eratio of is in ess See CSM i,i Di sp ted at EDC cou uest access to te in co an i es transactio See JP MC Ex at Indeed the EDC reached out to Epstein attorney in Janua,y to inquire whether media reporting regarding allegations of misconduct had any connection to the business of Epsteins Southern Trust Company His attorney responded to confirm we do not believe that these media discussions will have any impact on the business acti ities of STC Ex at Exs JPM Re pon dis pu ted at EDC conesponded i Eps in atto rn ey in Januaiy inqu ir he ed i a epo1i in egard in allegat i of mi sco ct ad a co nn ectio to siness of Eps in Sout rn Trns Co mp a USV I Ex at USVI Ex at USVI at Und i sputed hat Eps in at orney es ded wi th qu oted lang age USVI Ex at Disp ted extent USVI co nt ds at hi te tim es ab li es as a ega atte th at th cited out eac disc ai 267ged ED ob li gatio fo ll ow up allegatio of wro in Margarita Benjamin a witness with more than ears experience at the EDC testified that the cost benefit ratios provided to board members cannot be anal zed in isolation because the ratio doesnt give the full picture to anyone and can be misleading Ex at Governor Albert Bryan testified that the ratios were not intended for smaller financial firms like Epsteins companies Ex at JPM Re pon is pu ted at ja min esti fi ed at cost be efit ratios provi ed to bo ai bers ann be analyzed in i so atio beca se rat i does i ve fu ll i tur anyone and can be misleading jamin testi fi ed hat in contex of a specific ail between erself a Fle min and Stacey las ett was umm ai i zing at ju st give un favorable ratios itself wi th out ot er paii does i ve fu ll i ure anyone so i ca be mi ead in a th ats in th umm aiy of at I was ti in to say USV I Ex at Disp ut ed at Gove rn A be rt 1yan te ti fied at ratios we not int ded fo alle fi ancia fn lik stein co mp an i es Case Document Filed Page of testified a fo these a ller finan ial finns we we re a ll in tere sted in makin ur that we ave via ble finns at come re a nd ax residents th a ave a high ne wo i SVI Ex at Di pu ted as to he und rl in gges ti th a th cost benefit rati os were rel evant th ED co id eratio See JPMC Ex r,r Ms Benjamin further explained that the cost benefit ratios can be misleading because unless the business was already operating in the Territory the Government would not have received the tax revenue in the first place and has not lost anything Ex at Go ernor B1yan agreed testifying that the go ernment didn gi up anything because half of some is better than all of none Ex at JPMC Response Di pu ted that Benj a min te tifi th a th cost-benefit ratios ca be mi slead in Undi sp uted at nj a min te tifi ed the meanin favorable rati os can depend he her the co mpan was opera in in he tenito1y eca se i a company was existing in he tenito1y her was no tax dollars in paid the tenit So her it says axes fo ego ne i is realistically foregone eca se the co mpan wo ul not ha ve been in the tenit and in a ax ay in co mpan SVI Ex at Di sputed th a ove rn B1 yan ag reed wi th Benjamin te tim Fm i her disputed the extent SVI as to suppo 1i hi ate men wi th evidence fr the rec rd Th i ted SVI Exhibit does conta in the i ted pa ges Undisputed Governor B1 yan sta ed he quoted te at an ED public he a rin in Nove mb Disputed as the underl in gges ti that the cos t-ben efit rati os were rel evant th ED considerations See JPMC Ex r,r The ratio further ignores ancillary benefits that accrue to the Territory from the presence of high net-worth indi vi duals who engage in economic activity unrelated to their businesses that benefits the Territory Ex at JPMC Response Di pu ted to he extent sta temen consists fU SV ummai of SVI Ex Fmth disputed th ex ten USVI as to upp rt this sta temen i evidence from he record Th cited USVI Exhibit does not contain th cited pages The document speaks fo itself Di sputed as the und rl in gges ti hat the cos efit ratios we re ot rele va nt to he EDCs co side rati See JP MC Ex r,r uring a March public hearing Epstein attorney explained that a denial of an extension would likely cause a responsible business person to serious consider relocating the business if another territ01y offered similar benefits Ex at Ex Case Document Filed Page of JPM Re pon dis pu ted a ci ed doc um USV I Ex co ta in qu ed tex Disp ut ed at pste in wou ave re ocated if be efits were ot exte ded See MC Ex a Thus the EDC could not assume that it would collect Epstein tax revenue if the benefits were not extended Ex at JPM Re pon is pu ted to extent USVI as fai ed ppo rt hi sta ent i evidence fr eco ci ed USVI Exh ib i does co ta in a page urth dis pu ted a ste in wo ul have ocated if benefi we not ex de See MC Ex The EDC did not treat Epstein differently than any other beneficiary Ex at JPM Re pon is pu ted See JP MC Ex nr Di sp ted extent ate nt co i sts of SVIs umm aiy ofUSVI i er i sputed exte nt SVI as to suppo1i is state wi th ev i de ce fr eco ci ed USVI Exhibit does ot co ta in i ted pages Fact oncerning ecile de Jongh Emplo ment with Ep tein Cecile de Jongh became First Lady when her husband was elected Governor She testified that there no office of the first lady with a budget and she did not have an office First Lady was largely a ceremonial position that entailed giving speeches and attending social events Ex at JPM Re pon dis pu ted a Ceci de Jo beca Fi rst ady hu sba was ected Gove rn or SVI Ex at Di sp ted th at cited docume nt co ta in quoted ext See USVI is pu ted a Firs Lady was lai 267gely a ce ni a os i tion a ta i led i in eec es an at in social eve ts See CSM i,i During the time her husband was Governor Ms de Jongh was widely known and recognized to be employed by Epstein businesses and acting on their behalf Ex at Ex at Ex at JPM Re pon is pu ted a SVI Ex suppo1is state See USVI at Wha th atio ip between Ceci de Jo and Governor Jo hn de Jo A It li cly know hat it is hi wi fe Ot i se un disp ut ed Case Document Filed Page of er employment with Epstein had been widely reported and numerous witnesses confirmed their familiarity with her employment Ex at Ex at Ex at Ex at Ex at JPMC Response Di pu ed that SVI Ex suppo 1i the ate men See USVI at Whats th atio hip between Ceci de Jongh and Governor John de Jongh A It publicl known th at it is hi wi fe Othe1wise un dis put ed Ms de Jongh had no contact with personnel at the Department of Justice responsible for sex offender registration and monitoring Ex at JPMC Response Di pu ed to he ex ent he cited es tim does upp rt the broad proposition Pinne tes ified durin time could not say at was awa heth Ceci le de Jongh ever in eracted i the USVI DOJ re ga rdin Epstein USVI Ex at ecisions concerning whether or not to grant tax benefits were first made by the board members of the EDC Ex at JPMC Response Di pu ed Benjamin te stified at the oa rd wo uld make recommendations th Governor and th ove rn ha th final decision USVI Ex at See also CSMF Although the Governor her husband signed the tax benefit certificates that process was little more than a formality and could not happen without the EDC recommendation in the first place Ex at JPMC Response Di pu ed Th i ed tes im does upp i the prop os i ion that the ove rn approval was litt le re than a fo1mality On the co ntra1 nj a min tes ified th at fr the ove rn held the fin al decision SVI Ex at See also CSM Undisputed th at th i tes imony ates th at a ft er the change the bear sic of direct the Economic eve pm nt A uthori Co mmi ss i was es ible for ex ending nefi and ey lon ge required the approval the Governor USVI Ex a Ms de Jongh vigorous denied knowing about or facilitating Epstein crimes in the Virgin Islands Ex at Case Document Filed Page of JPMC Response Di pu ted hat Ceci de Jo vigoro sly nied kn ow in a or facilitating Epsteins cr ime in the Virgin I a nd Fmther disputed that Ms De Jongh in fact did ot kn ow about or facilitate Epsteins cr ime See CSMF i,i Ms Jo cited te sti ony includ ed sta tement ch as if so meb ody i intr od ced as so meb ody irlfriend I too it as face va lu hat thats th eir irlfriend USVI Ex at and I oo ed hirn in the eye a nd as ed hirn yo kn ow What he hell i go in that I ad a daughte and you know hat going an hat said was jus a mi ake i stoo so ebody be older than the we id at Ms Jongh fmth te stified ha li eved Epsteins explanation th at it was a mi ake Id a With respect to efforts to establi an English as a Second Language clas Ms de Jongh testified that she was not aware an of the women were potential trafficking victims Ex at JPMC Response Undispu ed that Ceci de Jo te stified as uch Di pu ed as to he underl in fact that Ceci de Jo was aware any of the wo men were ential trafficking vic im See CSMF i i The documents also make clear that the University merel agreed to offer an alread existing clas to individuals Ex at Ex JPMC Response Di pu ed Ceci de Jo wro Epstein tha UVI was tru ct urin the cla ss aro und he la dies See CS MF i Case Document Filed Page of JPMORGAN CHASE BANK N.A.S LOCAL CIVIL RULE COUNTERSTATEMENT OF ADDITIONAL MATERIAL FACTS I SUMMARY JUDGMENT CANNOT ENTER ON USVl CLAIMS A JPMC Did Not Know Of Or Recklessly Disregard Epstein Alleged Sex Trafficking Venture Rapid Respon se Meeting MC employee eg ul a rl held rapid es mee ing in light of derogato1 or notable infonn atio abo a client JPM Ex at JPM Ex at JPM Ex When a lle gatio are ade again st a client the mpl oyees re spo ible fo the clien relati hip wo uld be asked i tay in high ale1i and nit or in ow tho se allegat i develop toward a fo nn a esol uti uch as a cr imin al co i ti JPM at Ep tein was indicted in Fl rid a tate co mi for felony so licita ion of prosti uti July JPMC Ex JPM Ex at i SVIs law enforcement age i es did ope an in vestigatio in to ps in JPM Ex at On Octo er following ne ws ps tein anest for felony so licita ion of prosti uti und Florida tate law JPM doc nt ed a se rie of in ernal di sc ss ions abo ut its relation hip wi th Ep tein in to a rapid re ponse team mem randl The mem ran um states After internal di sc ss i wit Je aley Maiy Erdoe Cat herine Ke at in Jo hn Duf fy and Maiy Casey it was decided that we wi ll eep Mr Ep tein sole as a banking clien and a reactive clien ervice basis We ill ot proa ctive so licit ew in vest ment bu in ess from him JPMC Ex Case Document Filed Page of Fo ll ow in media re po 1is abo ps in ing guilty plea JPMC employees hel another me tin in Octo er to discuss he a nk relationship wi th Epstein JPMC Ex JPM Ex Epstein JPMCEx JPM at I-JPM-01 USVIs law enforcemen age cies did ot ope a in ves ti ga ti int Epstein JPMC Ex at A ft Ep ste in ple aded uil ty ate har ges for solici atio of prosti uti and procmemen a min for pros itu ion JPMC hel a ra pi re spo se me tin to discuss he Bank relationship wi th Epstein July JPMC Ex A the co nclu sio the Jul rapi response eet in i was determined that then-CEO of the US Pri vate Bank Catherine Keating wo ul go back JES tell him we a un co fo ia ble wi th Epstein and do ot wa nt to go to utl for approval JPMC Ex at In umm and early edia epo rt ggested th at ther ay ave een a mT nt in vestigatio in to Epstein JPM Ex JPM JPMC Ex JPM Ex Case Document Filed Page of JP MC employees did i ew he se repo1 is as a detennination th at Ep tein was engaged in go in unl aw ful conduct JPM at JPM SDNYLIT JPMC Ex JPM at Ke in McClee ey te tified at My view was it was the ep ut at i nal risk of the fom was in creas in wi th the se allegations if they were me We kne in previou ews ai i icles so me of he in fo 1m atio was ot hue So we needed to ge the fac Bu until then we ul have a eet in to review th cunent allegation in th pr ess That was i ew JPMC Ex at see also JPM Ex at JPMC employee did i ew he se repo1 i as a detennination that Ep tein was in fact und federal in vestigation JPMC Ex JPM Ex In re ponse to he new negative medi a on Ep tein JPMC held another rapid re ponse eet in Januaiy JPMC JPMC Ex JPM JPM at On Januaiy Wi lliain Lan gford a nd Ca therine Kea ing ad a me tin wit Je aley to di cu ss the ta tu of Ep tein acco unt JP MC Ex JPM at On Augu JPM held a fo i rapid es mee ing abo the Bank relation hip wi th Ep tein JPMC Ex Epstein Cash Usage Be twee a nd JPM Ex at Case Document Filed Page of Th ese cash transactions and irect a nd indire ct payments to wome co st i uted of the nearl milli of funds that fl owed hrou Epsteins acco unt between and PMC Ex at JPM at,r In Epstein in fo 1med Paul Mon i hi private banker at the ime tha hi cas i drawa were to pay for fuel expenses for hi personal a irplan whe traveling to foreign count rie JPM Ex In A st afte becoming CEO of JPMC Private Bank Jo hn Du ffy in vestigated Epsteins cash usage JPM Ex In a nd Duffy spoke to Ep ste in about hi cas i drawa a nd business act i vit i es JPM JPMC Ex JPM Ex JP MC Ex at Epstein in fo 1med Jo hn Du ffy at hi cas withdrawals we for fuel expenses for his personal a irplan whe traveling to fo eign co untrie JPMC Ex at JPMC Ex Duffy adv i sed Ep ste in to conduct cash wit hdra wa for fuel expenses from his aviatio acco unt after wh i Epstein began co ct in cash wit hdra wals ut of his Hyperion Air account JPM It is ot un commo to speak to a clien about unu sual cash act i vity JPMC at JPM at JPMC Ex at JPMC employees previously had advised Epstein to cease structur in cas wit hdra wals below the rep o1i in threshold JPM at Duffy believed Ep ste in explana ion that he used the cas withdrawa to purchase av iati fuel JPMC Ex at JPMC Ex Case Document Filed Page of nni estified at pste in ex lana ion at he sed cas wit drawals purc ase av i at i fuel seemed easo ab JP MC at steins fo ne acco un ant Ri cha a hn est i fied at steins i lots wo ld req es cash to pay fo fu in der to sec ur mo favorable rates JPMC Ex at Epsteins fo ne pilo awre ce Visoski bmitted a swo rn declaratio tha un i at leas cash was sed to pay fo fuel at Jo hn Kennedy In ernatio al aiipo i in orde to take adva tage of a sign i fican cash i sco un JP MC Ex With respect to ps in cas wit hd rawa i Lu ca est i fied at JP MC Ex at Maiyanne Ryan tes ified that JPMC Ex at JP MC Ex at Wi ll iain angford tes ified Bu at of day i drawa of cas is a wit drawal of cas And so especia ll sma ll do ll a wealt peop wit hd raw cas ey a of diffe hin gs JP MC Ex at Jo hn Du fy est i fied I was co ce rn ed abo Epste in se of cas a ge clie se cas in i ffe ent ways ey ai differe than yo kn ow than average person on Ma in St eet It was it was sized in at i at clie of Mr Epsteins et Case Document Filed Page of w01th or asset base as And it was unu a as it related to at was expected in hat account and was pretty consiste in se of that JPMC Ex at rank Perun test ifi ed I ave see ve lai ge amo unt of cash be taken ut of bank by Pri vate Bank client ove my time at the bank JPMC Ex at JPMC human trafficking expe rt Dr Kimberly Me hlman-Oroz co testified that hi h-n et wo1t in div idual making ignificant payment to their i ctims i atypical of traffic kin JPMC Ex at Dr Me hlman-Oroz co fmther te st ified If you co ul of give me a ubset of at yo say ing hat i wo ul ave conoborated eca se for example if yo re ask in me wo uld i ct im payme nt in cas co oborate an allegat i of trafficking I wo uld say no ats atypical or in co i ste nt i trafficking So you typically wo uld not see that as a co oborat in i ece of evide ce I wou ld typically see that in something at wo uld be se by othe i de to ow at ey were ot a i ct im JPMC Ex at Wi lliam Lan gford testified that lai cash wit hdra wals were ot the foc on use of cas a pait of JPMC Human Trafficking In itiative ic was foc sed the bu in ess of traffic kin That is peop set the crimina nt rpri se to capture impri so move and se ll the se vices right and ge erate the rimin a proceed ju st like trafficking JPMC Ex at Paul Mon i testi fi ed at it eve occuned to him that Epstein was i drawing cas fo the payment ated to sex a ab se sex trafficking and ad a so lutely ot never ea rd anyone at JPMC indi cate a uspicion that Epstein cash wit drawals were be in used or co ul be used for sexual abuse or sex traffic kin JPMC Ex at Case Document Filed Page of Jo hn Duf fy tes tified I ad reason to believe at Mr Ep tein-and at point in im did I believe Mr Ep st ein was co mmi tin rimin a acts throu JPM gan as sex trafficking JPMC Ex at Fonner Hea the Global Pri vate a nk and unen CEO of Asset and Wea lth Managemen Maiy Erdoe te ified he co ce rn was the cas payment and at the time the cas pa men we related to a irplane sage And ever at the time was tha so methin tha I was co nn ec tin in min wi th anything to do i any of the allega ti of at ay or ma have do ne and I wasnt awai of any go in thin gs that Mr Epstein was doing and the two thin gs ne ve the ever ca me to min co nn ect hem JP MC Ex at Erdoe fm i her te ified th at if he had leained an believed th at Ep ein was sex ally ab in yo un hildr yes he wo uld be I wou ld as to ave him exited fr the bank JPM Ex at Inve tigation of Other Ep tein Account Activity JPMC employee we aware media rep o1is in hi the ow and pre iden of MC2 Models Management denied eceiving finan ial upp rt from ha ving a work in relation hip wi th Ep tein JPMC Ex at JPMC employee in ves ti ga ted Ep ein acco unt activity includin hi in volve nt wit MC2 Model Management As pai i of th at inve tigation AML in ves ti ga or Maiyanne Ryan ote that MC2 a ppeai ed to be a egit ode lin age cy JP MC Ex at Wi lliain Lan gford ated that the odeling age cy re ally ells little about any ossib linka ges between the JPM accoun and bad act i vity JPM at Case Document Filed Page of Lan gfo esti fi ed at el in age cy i st at i didn ll an yt hin an ab ili ty as a bank know ats eally go in i a ode lin age cy is ex tr limi ted JP MC at Jan muy ya ai ed a gford a Phi uca ega in er in vestigatio in to Eps in in ic co nclu ded th at th we kin un JP MC Ex a In Marc JP MC in fo ned pste in at i was go in to ew mill io tan by ette credi LC i ss ed to pste in ac op a oan fr Me ll MC2 Mode Ma age JP MC at JP MC Ex Pr ior to BL ex i rin i ad eve bee ra JP MC at A concl sio eac ed by Ryan in investigatio was at pste in a spo so ed th ing of acco unt for two ad ult wo inclu in esc i ed as a wi llin paicipant in recaps th escapades JP MC Ex at In ope nin acco unt fo JP MC ad info 1m a ti egai in date i1 i er soc i a sec ity num be ive li ce se num ber a add ess JP MC MC Ex a ya a so ed at pste in pa i th gi rl a ode hu ge a un ts and desc ibed pste in as a gai Daddy JP MC at Case Document Filed Page of Ryan test ified hat he understood the te1m gar daddy to mean omebody that lik es to spe nd hi money ladies but at he did ot believe it impl ied financial ppo rt in exchange fo sex a favo JPMC Ex at JPMC Ex at Wi lliam angford testified that this act i vity was in many re spec ts in co i ste nt i the types of thing that we saw in hum an trafficking You know av in ow accou nt prov i in money providing documented expenses The human trafficking ente1pr i ses that we were focused were de i gned to traffic in dividuals keep em down do-do the bu ines and keep it off the radar This was different I mean it i ts pretty-I don like be avior But it diffe nt from typology of human trafficking at we ad bee focused on JPMC Ex at William angford testified that did not believe at JPMC Ex at William angford further te st ified at Maiya nn Ryan finding in er in vestigation of Epsteins accou nt activity did not estab li a link between JPMorgan and the operat i on by Ep ste in of a sex trafficking rin through the bank on its face in opinion JPMC Ex at Re comme ndation to Exit Were Ba sed on Reputational Ri sk William angford testified that he recommended exit in Ep ste in as a client due to reputational ri co cerns rat er tha legal concerns or concerns about Ep ste in account act i vity JPMC Ex at Langford further test i fied that he did ot Case Document Filed Page of believe th at Epstein was engaging in co inued illegal activity after hi plea JPMC Ex at Lan gford also estified that ifh believed her we going i olatio of la and th ers disagreed ove exit in a clien he wo uld have escalated th at decisio to the boa rd JPMC Ex at ph utl re co mm nd ed exiting Ep ste in as a client and refr a inin from engaging in fm i her siness wi th him ue to the repu ta tional ri crea ted fo he Bank JPMC Ex at JPM at utl further estified that IfMr stein was cont inuin to gage in unl aw ful activity we didnt want him as a client JPM Ex at Maiyanne Ryan tes ified th at he and Phil Lu ca a voca ted exi tin Ep ste in as a clien because he was a ep ut atio al ri the bank JPM at Epsteins fonner pri vate banke Maiy Casey escalated co ce rn for reputati nal risk JPM at Phil Lu ca estified that AM In ves ti ga ti recommendation exit Epstein was based ep ut atio al ri JPMC Ex at Wi th respect to Epsteins stat as a client John Duffy estified I was of th op ini hi reputati nal risk was wo rth having him as an acco unt thats co IT ect JPM Ex at Kevin McClee ey estified at Ep ste in ep re sented a ep ut atio al ri th fom JPMC Ex at Jus in Nelson tes ified th at un ders ood that Epstein was 1min ated as a li nt due to co sideratio of re pu ta tional ri JPM Ex Case Document Filed Page of Staley Fo ne JP MC exec tive es aley was th ost se ior a pr i aiy JP MC ployee espo sible fo Bank relatio hi wit pste in MC Ex a MC Ex a JP MC Ex at Jane oe tes ti fied at MC Ex at aley testi fi ed th at i ot bserve a yt hin at ca sed him questio et Eps in was gaged in sex rnffick in JP MC Ex at Sta ey Exc a ng ug gestive Em ai wit Ep te in Abo Wo A st pste in ailed Staley ow lo do you eed anyt ing Sta ey espo ded Ye JP MC Ex Sep ber ste in a i led es aley i ay in at be rk eley ote in ondo to ni ht JP ece ber stein a i led aley yo we wi th lai1 sic and I ad to ut up wit and at ac ed fo ll ow in suggestive otog ra of a yo un wo a Case Document Filed Page of JPMC Ex JPM Ex That same day aley es nd ed to Epstein ritin tell a French wine JPM Ex On ece mber Epstein emailed aley the following pho tog raph of a yo un wo man Case Document Filed Page of JPMC Ex JPM Ex On June Sta ey wrote to Ep ein is fre to nigh Ep tein re ponded ca ll aley replied Im wit A JPM Ex On July Sta ey e-mailed Epstein hat was fun Say hi to Snow Whi Ep tein re ponded hat hara cter wo uld you like next aley plied Beau ty a nd he Bea Ep ein es nd ed we ll ne side i availa JPMC Ex aley a a Clo se erso nal Relation hip wit Ep tein On Febmaiy aley emailed Ep tein ca llin him Family JPMC On Mai Ep tein emailed aley ritin Told yo u-famil Staley re ponded he same day ritin fami JPM Ex On Mai aley emailed Ep ein say in ha counted Ep tein a of our deepest friends And ost est of people JPMC Ex Case Document Filed Page of On March Ep tein email Staley in re spo se ca llin him family JPMC Ex On Ma ch Epstein ema il ed Staley say in I fo got to say hank Family JPM On Ma ch Epstein ema il ed Staley ri in yu fami do sic wo JPMC Ex On Ma ch Epstein ema il ed Staley say in Dear fami member do fre JPMC Ex Ep te in rov id ed Assista ce wit Graduate Sc ool Adm i ss ion Ap ril Ep te in emailed Staley wr i ing can mee ave inn er lun a weekend wit an of the following set ll oyd mit quantum comp utin mmTa ge ll-man anta-fe in st itute quark brian eene Col um ia tring eo le nar ss kind tring eo la rence krau se ri gins in ti ut phoenix a ri zona lee lin premi te in st itute loop quan um gravity ca see large adron coll id in sw itzerland private tom i JPMC Ex Staley fo1warded ema il Alexa Sta ey ritin Thi i from uncle Jeffre Add Li a Randell at Harvard JP MC On October Staley fo wa ded is feedback Epstein prov i ded on a draft of her sc olars hi essay JPMC Ex On Januaiy fo wai 267ded to Staley an ema il exc han ge had i Ep tein thanking him fo in vit in er to a ph ys ic co nfer ce in Ca li fo rn ia JP MC Case Document Filed Page of On September Staley fo1warded to Epstein an email fror about a profe sso at Columb ia University and asking Ep tein ifh co ul get to thi profe sso at Co lumbi a On Septembe Epstein re spo ded in a ap JPM Ex On November Ep ein emailed Staley in re spo se to an email a in abo applicat i to ritin can i with Richard Axe whe I get back he wo the Novel prize he ha guara nte ed me JPMC Ex On Januaiy Staley fo1wai 267ded to Epstein an email exchange between a profe sso and egai in GRE sco re ot se em in to be a problem accord in to my so ur ces JPMC Ex Also Januaiy Ep ste in emailed Staley ri in is now up from JPMC Ex Staley Made Pers a i i sNac ation to Ep ein Prope1 i ie On December hil Epstein was in cai 267cerated Staley made plans to i i Epstein in Palm Beach Florida JPM On October Ep ein emails wr i ing that es ta ey and ife ai go in to be at the ran ext weekend please coo rdin ate they get to tay in blue room i JPMC Ex On October Staley emailed Ep ein a kin if he could go to Santa Fe to hi Ep ein espo nd ed not today JPM On November Staley emailed Ep ein wr i ing So hen all hell breaks ose i and the world is cnbling I wi ll come her and be at peace Pre se ly Im in the hot ub with a la ss of white ine Thi i an amazi place Trnly amazing Next time were Case Document Filed Page of her to ge her I owe you much And I deeply appreci ate ur frien ds hip I ave few so profound JPM Ex On Janmuy Epstein emailed Staley a a i i to hi private island in SVI writing car a nd driver fo1mer lea aimed will pi ck yo up in st as we ave a ll the field pe1mits heli copte a so avai lble for a tour ai und remember I own the two bi marin as yac ht ave rand in st as a nd the mai in a at re oo yo can se atvs jet ki gym i will ga niz the harb at No nnan island if yo lik in the bvil as well as lunch at uan a JPM Ex On Januaiy Staley emailed Epstein a a i i to Epsteins island in SVI writing Wha a paradi se When I ire Im go in to pu a oo rin in fron of yo ur dock for oa A az in place JPM a ey hared Co nfiden ial Info1mati With Epstein On multipl occasio Staley hai ed with Epstein confidential infonn atio a transactions he a nk was truc urin or exploring JPMC Ex JPM JPM JPM Ex JPMC Ex JPM Staley discussed the co nfid ntial at of her clien at the Bank with Ep ein JPMC Ex Staley hai infonn atio protected by the atto rn ey client pri vi ege a Epsteins go in liti ga ti against JPM i Ep tein JPM Staley so licit ed feedba ck from Ep ein confiden ial drafts of hai older tt JPM Ex Staley kep Ep tein info1med a out he a of he a nk in ves iga ion in the allega ti aga in him JPM Ex JPM Ex Case Document Filed Page of Sta ley Vo ed for Epstein Je Sta ey vo hed fo Ep ste in multiple occas i by telling ther JPM executives and employees at Ep ste in was not gaged in cr imin al co ndu ct JPM Ex at Maiy Erdoes estified that Jes Sta le ad a ve1y different chai 267acte rizati of Epstein than th pr ess repo1 is follow in hi aiTest JPM Ex at Wi lliam Lan gford JPMCs fonner General Co un sel for Global Co mplian ce and Re ul ato Manage nt tes ified that Jes Staley to ld him th at wi th respect to Ep ste in co victio in ate har ges for so li citat i of pro sti tuti and procmemen a min or for prosti uti Ep ste in didnt do it uldn ha ve pled uil ty et cetera was responsible for i and at Ep ste in la wye we wo rkin get th uil ty ple a thrown ut JPM Ex at JPMCs fonner General Co un sel Step hen ler estified that Jes Sta ey ld him that Epstein ad turned a page paid hi de to society urn ed a co and was the raig ht and nan ow JPM Ex at teph utl relied Jes Sta eys views in evaluating th Bank elatio hip wit Ep ste in because Staley was a re spected memb er th erat in co li ttee and kn ew Epstein JPMC Ex at JPMC Did Not Participate In Any Epstein Sex-Trafficking Venture Attempts to Verifv Ongoing Investigation Following he Januaiy rapid response eet in employees wit hin JPM Cs Pri vate Bank discussed he Epstein relationship wi th aley Epstein abo th edia allegations hi Epstein cla imed were i ut rit JPM Ex at Case Document Filed Page of JPMC Ex JPM Ex at JPMC Ex at JPM Ex On March teph utl emailed Jo nath a Sc waiiz ask in if he poke to Staley about Ken Stai be friend That sa me ay Jonathan Sc waiiz replied Ye and didn get anything back from him so I ca ll ed him again sa id he ll call Epstein and get a li ve a me a nd number for a unent lawyer Th re ce nt headline re FBI reopening its in vestigation in aily Mail and NY os ove he wee and guilt-by-being-friend or i es abo Prince Andrew a nd fo 1mer Pre side lin to a in ic grea Cc in illiam JPM Ex On Mai Jo at han Sc aitz di sc sse i Ste ph utl then General Co un se fo JPM he need de e1mine here ther es ac uall a li ve federal in vestigation int Epstein JPMC Ex at JPM-SDNYLIT-0027 On March Jo at han Sc wa 1tz ai led Step hen at co nta cted Jay Lefkowitz Ep ein at orney to inquire ther her was any in ves ti ga ti Mr Lefkowitz expla ined that he and Epstein ad heai thin to ggest th at ther was a unen FBI ther aw enforcemen age cy inve tigation A to any ggestion in he edia of an ongo in in ves ti ga ti acco rdin to Jay he don see to ha ve any asis JPMC Ex at JPM-SDNYLIT-00274528 Case Document Filed Page of On about Ma Jo at han Sc waiiz spo ke to he United State Atto rn ey fo th Sout rn Di tric of Florida who did ot di clo any in ve iga ion in to ps tein JPMC Ex JPM Ex at JPMC al eac ed ut to he BI a for a co nt ac at th age cy ay have been wo rkin any go in in ves ti gat i int in Th FBI eve re urn ed the phone ca ll JP MC at JPM Ex at Currency Tran action Report Related to Ep tein etween and JP MC filed approximately CTRs relat ed to ps in a nd hi accoun in hi ch JPMC id ntified i elatio hi wit Ep ein flagged hi lai ge cas wit hdra wals JPM Ex at JPMC Ex Seve ty thr ee of th CTRs we filed before Ep ein wa aiTe ed in Jul JPMC Ex Law nfor ce men ever co tact ed JPMC in to any TR JP MC at JPM Ex at JPMC Ex at JPM Ex at Maiyanne Ryan te tified The SAR deci ion li ely with inve tigatio de paitm nt Cou ld an employee und ha ve di ss ed it with ano her person wit hin Case Document Filed Page of in vestigatio Sure But hey weren going ba ck to he usiness to di sc ss the meri ts of SAR filin JPMC Ex at In her expe1i epo rt Pesce opined that At times ba nk wi ll conduct transaction eviews oo kba cks Bank may conduct lookbacks if they are oo kin for a pai i icular kind of pa st activ i ty if they re ceive a reque st from law enforcement This nt ails a much more granu lar and poin ed review of hi stor ic a activity The ba nk wou ld see act i vity it wo uld not ha ve reviewed in he ordi na1 course of monitoring and notably the bank wo uld likel file SARs it wo uld not ha ve filed in fulfilling its day to da AML program obligatio JPMC was requir ed to perfo1m a transaction lookback in connection with the Co se nt Order owever regulators required the Bank to examine act i vity wit n-bank financial in stitutio There is ot hin in he required oo kba ck to suggest examiners were co ce rned that the bank failed prop erly to monitor hi h-ri Pri vate Bank clients or to detect human trafficking Moreover it i unlikely at even a broader-scoped lookback would ave uncovered Epsteins transac ions with indi viduals I have up vised numerous lookbacks They requir app in addit i nal sce nai os more pr ec i se hre olds to past activity at might not ha ve ale1ied under a banks monitoring syste They do not ge ne rall en ta il sett in thresholds at the low dollar amounts at issue here Impo1 i antly lookbacks ai co ndu cted i in fo 1m atio tha migh not ha ve been available or meaningful the und erly in transactions occuned Banks act i the infonn ation they ave efore them The USVI re ated demonstrative exhibits for use in deposi ions that co lle ct ranulai info1mation ow avai labl What may seem eleva nt in hin dsi ht ma ot have been a ai at he time JPMC Ex at i,i Case Document Filed Page of Wi lliam Lan gford testified tha obody from JPMCs business ever tried to dissuade him from filing a SAR related to a stome and that he was ot aware of any in sta ce in wh i an employee in JPMCs lines of business ever ti 267ied to dissuade a colleag ue from filing a SAR related to a stomer JPMC Ex at Wi lliam Lan gford tes ified that he never decided against filing a SAR related to a stomer that he believed was wa nant ed because the custome was pa1ticularly lar ge or val ab and at was ot aware of any instance in hi any JPMC employee believed a SAR shou ld be filed but failed to do so because the clie nt was paiticularly lar ge or val ab JPMC Ex at JPMC Ex at JPM Ex at Phil Lu ca estified tha obody from JPMC Private Bank ever ti 267ied to dissuade him from filing doing anything at all in connect i ith ps tein a nd that he was not aware of any in stance in hi an employee in JPM Cs Pri vate Bank ever ti 267ied to dissuade a colleag ue from PMC Ex at doing anything in connection with Ep ste in Case Document Filed Page of JPMC Ex at r,r JPMCEx JPMC Ex JPMCEx JPMC Ex JPMC Ex JPMC Ex at Case Document Filed Page of JP MCEx On June Phil DeLuca sent an email to Cynt hia A nnin desc ribin he hi sto of esca lati of Bank rel at i hip i Epstein JPM Ex On July Ma yanne ya se nt a ail to ev in McClee ey Jame Dale ss i and Phil DeLuca to fo ll ow up the Ep te in wi thd rawals and noted th at believed hi ex plan atio hat wi thd rawals fo fu el ee ed odd JPM Ex JPM CEx JPM Ex Case Document Filed Page of JP MC JP MC at JPMC Ex at JPM SDNY I Ex at JPM SDNY I JPMCEx JP MC Case Document Filed Page of JPM Ex at JPM DNYLIT JPM Ex at JPM Ex at USVI law enforcement expert aun Neill JPM Ex at Mr Nei ll tes tified that JPM Ex at Mr Nei ll fm i her te st ified th at JPM Ex at On July JPM employee began an in vestigation in to Epstein banking relation hip wi th the a nl JPMC Ex at JPM Case Document Filed Page of JPMC Ex at JPMC Ex at Case Document Filed Page of JP MC Ex at JP MC Ex at JP MC at Case Document Filed Page of JP MC at MC Ex at MC Ex at JP MC at Case Document Filed Page of JP MC at JPMC Ex at JPM Ex at JPMC Exited Ep tein a a Client Maiy rd oes estified hat in he became co cerned i Epstein cas usage and th expla nati was a ized amount of cas and eve th ough hat was hi ex pl anation for her he cas was being sed th at in co njun ctio wi th the cu lmin ation of Case Document Filed Page of eve1ything else a nd he fact that I didn kn ow lik Mr Ep ein I had rea on to vo uch for Mr Epstein to be a clien of he bank and I re co mmend ed exit and we exited JPMC Ex at In explaining the factors that went int Ep teins exi in Frank Peam te ified A number of fac to in paicular rder There was cont inu ed egat i ve edia that the lin of bu ine ss and the ri depaiiment continued to see There was continued cash and wire act i vity in man of Ep tein acco unt There was Ill say a long-time i ew of man of the people in he line of busine ss in the ri and co mplian ce ga nizati at Mr Ep tein uld be exited uld ave been exited as Im ur we ll cover and Je Staley was ger at he bank And I say the la st hin was at at ime the in tiy the eg ul ato environment was ad changed JPM ga ad eceive AML co se nt rd ers eai li in alo with a number of ot banks The eg ul ato view of bank role in comba ing money laundering teITorist finan in was ad changed And as paii of that ur insti uti was oo kin at ur i folio our book of hi h-ri sk client and taking a fre look at whet her or not we hould a in ta in ose relation hip So a number of factors JPMC Ex at On July JPM employee a nd exec ive includin John Duffy Maiy Erdoe Step hen Cutler and Ju st in Nelso me to discuss he stat of Ep ein relation hip with the Bank and decided to tenninate the elatio hip JPMC Ex JPM On July John Duffy emailed Maiy Erdoe a draft of ta lkin points to co mmuni cate the Bank deci i to exi Epstein as a client Du ffy wrote The repeti ive at ure of your cas u-ansac ions is a problem for us and our relation hip with you Th regulato1y tandai in the banking in tiy cont inue to evolve i a ve low to lerance fo cas activity whe co mbin ed with your personal hi sto1y So give he in ersec ion of the se Case Document Filed Page of ci cumsta ces we a in a uniquel a llen ged situatio Remediation is quir ed and we need to ask you in an de rl mann to find ano her bank fo yo ur eeds JPMC Ex On A st Maiy Er does emailed several JPM employees and executives including Cynt hi a A nnin Stephe utler ina henk nn a Dell osso John Duffy and Phil Di lo ri ritin Re our li nt exit the co ve satio we nt we ll and was ve1y professional I spect the call ast night might ave helped It ill move in a rd erly process Jo hn did an excelle ob JPM Ex On A st John Duffy emailed Justin Nelson ritin Thanks He and I spoke as we ll about hi adviso1y business and ethe ur i ot we wo uld wo rk with him I sa id yes as long as we we re not transac ing in JE accoun ts JPM Ex On Septe mber Jo hn Duf fy ailed Ju st in Nelso egai in a reque st from Ep ste in fo more redi ritin answer ne eds to be followed by hi is a great oppo1tunity to ove fo wai ith yo i ne bank JPM On Septe mber Jo hn Duf fy ailed Maiy Er does abo Epstein wr i ing Spoke i him Good co ve sat i Told JE no on sole stee PO A yes fo adviso1y role wit discretion Ye for custody in he clien ts name Tough ne he brough up re ga rdin Gates JE and JPM as co tiu stee While I expect that this wo uld be a to get through i ts sic like co-b randin i him We uld st ill discuss it Le ts ta lk und erstood JPMC Ex JPMC Did Not Knowingly Benefit From A Sex-Trafficking Venture Jainie Dimon estified that he did ot ecall any in volvement Ep ste in pai i in JPM acq ui sitio ofHig hbrid ge Capital Managemen LL and tha he was ot infonned Case Document Filed Page of hat Jef fr ey pste in eceived a mill io fee fo is wo rk in co nn ec ti i th at rn sac ti MC Ex a ste in co mp a in a i a Tm Co pany In ad bee etained as a co su lt ant by Hi idge Ca i al Ma age LL MC Ex Financial Co mp a In rece i ved a mill io fee fr Du in Swieca in gs In ated to MC ac qui sitio of a ajor i ty inte es in ig bri ge Capita Manage in MC Ex JP MC Ex JP MC at stein i ot eceive a fee fr JP MC in co nn ectio wi th MCs acq isi ti of a a ity in tere st in ig idge Cap i ta Ma age JP MC Ex at Leo lac was a gsta ding clie of th pr ivate bank JP MC Ex at ank eru te ti fied As fo un der and of th se ni leaders at Apo ll Global Ma age ent bank ad a estab li ed a ti hip i A ollo and i Bl ack My un ders a in is th at Leo Bl ack was of psteins cl ie ts as a ey a age And as fai as Ive bee able to dete in we do see a y-o I see any in trod ctio of eo lac as a ivate ba nk cl i nt ro Mr stein JP MC at see also MC Ex a II JPM Did Not Ob truct Or Attempt To Ob truct An Effort To Enforce The TVPA A st eai ea eceived a Gra Jm bpoe a fr th U.S Dis ti i co i fo th Sout rn is tr ict of Flo ida see kin a ll doc um nt efe n-in a tin to Jeffrey pste in JP MC Ex at A st be of eai ea AM a itigatio depaii spo to Assistant U.S At orney Ann Mai i Vi ll afana egai in th sco of th Grand Jm Case Document Filed Page of bpoe a ur ing co versatio AUSA stated at ear ea was not a a ge of in vestigation Mo eove a ber of AM Gro up as ed AUSA i a activity co ce rnin stein in vestigation mig ht have iggered a epo1i in quir fo Fi Th AUSA a swe ed th at qu es ti in th egative JP MC A st a Sep ber Ass i sta nt U.S Atto rn ey Mar i Vi ll afa a se nt ette to ea Stea cl a ify in scope of and bpoe a JP MC Ex In respo se to and oe a ear Stea reviewed ran sfe of steins acco unt in amo un ts a co cl ded at account does not appea to be im li cated in a ll eged wrongdo in and at th review revea ed ic i or un a ird paiiy wi ran sfe co sistent i ose tio ed in a ove desc ibe sic robable Ca se A ffi davit ews aiticles ased upon avai able facts hi in vestigation i closed and not hin urth is dee ed ecessa MC Ex at I UMMARY JUDGME ANNOT ENTER JPM AFFIRMATIVE DE FENS ES A tein Made Payment To US VI Official And ntitie ece ber stein wro to aw rn USVI a rtm of la nnin and Nat ur al esources DP NR at ad i ve fo gi rl in croix and as ed rn for ggestio he co ld donate MC Ex ece ber stein ir ected Ric a Ka hn Eps in acco un ta to ite a eck fro Sout rn rn Co mp a In DP NR fo a donation to a li li rai JP MC Ex In co nn ectio wi th at do at i aw rn wrote to Eps in ece be to suggest speci fi li rai ies to hi Eps in co ul do ate additio a ll wrote to Case Document Filed Page of Epstein If yo prefer to donate to sc hool librarie I can co nne yo with the Commissioner for Education Either way the TeITito1y in JPMC Ex Th USVI gover nm nt eviewed its corporate spo sors hip after it emerged that Jeffrey Ep ste in the convicted sex ffender gave ift to sc hool pupil and finan ced events for yo un hildren JPM Ex Epstein provided fundin for a scie nce fair fo hildren in rade sc hool in the SVI nm by the USVI epart ment of Edu cation He also ec ifi cally paid for tra vel and acco mm odatio for prize innin hildren to attend the science fair in St Thomas JPM Ex Epstein provided fundin for a ummer camp for children ith intellectual disabilities through hi USVI based cmporatio JPM Ex at Epstein funded a prize for the inn ers a sc hool essay wr itin competition JPMC Ex at Epstein paid for co mputer to be give to two 14-year-old st de nt atte ndin hi schoo in the USVI JPM Ex at Epstein purchased Kindle e-readers for se by a sc ool librai JPMC Ex at Epstein purchased over Microsoft urface tablets for se by children in SVI sc hool JPMC Ex at Epstein provided fundin through hi USVI businesses for a basketball tomnament in the USVI hi included children as yo un as six JPM Ex at Case Document Filed Page of On ece mber Ceci de Jo wrote to Epstein th at Governor Albeit Bi yan ha ggested two schoo Coral Reef Academy and Junior Ac hi eve nt to hi Epstein co ul mak a donation JPMC Ex JPM Ex at On ece mber Ceci de Jo wrote to Epstein th at Governor Albeit Bi yan ha reque sted that Epstein do ate the USVI Little League JPMC In one of Ep ein USVI ba ed bu in esses Financial Trnst Co mpan In FT do ated the Vi gin Island li ce Depai men JPM Ex at In A Epstein was a ed provide fun ding for two SVI police ffi cers at tend a mi cide in ves ti ga ti training program in New York wrote Cecile de Jo th at he always wo ul lik upp rt the se thin gs bu th at in he pa st it ha been looked upo wit spicio un ic Cec ile de Jongh re ponded pi i locally My though was at hi wo ul be ok because i is ec ifi cally homicide ra inin Epstein re ponded face face JPM Over multiple elec ion cycles Ep tein dona ed the axi mum amount allowed to he ca mp aign of Co gresswo man acey Pl as ke tt th elegate to the ni ted States se of Repre en ta tives fr the USVI JPMC Ex at JPM Congresswo man Pl asket previou ly wo rk ed for th USVI conomic Developmen A ri ty EDA and for a law fnm at repre se ed Ep tein related to hi USVI sinesses JPM Ex at JPM at Ceci de Jongh as ked Ep tein to do a ne to Co esswo man Stacey Pl asket JPM Ex at Ceci de Jo as ked Ep tein to do a to th Dem ocratic Pai iy behalf of Congresswo man acey Pl asket JPMC Ex at Case Document Filed Page of Co esswo an las et also as ed ps in do ate axi mum am un oc rati Co essio a Ca pai gn Co mm i tt ee hi was approx im ately MC Ex a ste in at ed do ate bu th do a ti was ret urn ed after stein failed to ee vett in qu ire ents MC Ex a MC Ex a stein req ested a Co esswo an lasket ca paign ee hi do a ti ano ymo JP MC un Cecile de Jo ailed pste in at hi lp wa needed beca se we a in to get Stacey las ett ected Congress fm tated hat we wo ld ave a fr i in acey a as ed stein i a of hi fr ie nd wo ld give to er ca paign MC Ex stein req ested ro Cec i le de Jongh a hi ployees a th in dividuals do a Co esswo a Pl as ett ca paign JP MC Ex JP MC at stein a hi oyees do ated over to Co esswo a Pl as ett ca paigns across hr ee co essio a elec ti cy cl es JP MC at un Er ik a Ke ll rh a a i led Ceci de Jo wi th bject elp I eed ra i se by Wednesday fo Stacey ink I ca as JE Anyone else you ca think of Ceci de Jo ep li ed I as ed im ah-ea JP MC Oc obe Ceci de Jo gh wro Eps in co at i ll send to De ocratic aity fo be fi Stacey las ett MC Ex Case Document Filed Page of Oc obe Cec i le de Jo gh a te in exc a ged ai rega ding a donation fro Ep te in personal acco unt to Cro i Di ict ocratic aiiy MC Ex JP MC Ex at A a of at a i th read Octobe Cecile de Jo wrote at fu ur vernor Kenn Mapp and Se ator Cele in Wh i te wo ike to ee yo MC Ex Nove be te in emailed Cec i le de Jongh to a ow did ur ca didates do Cec i le de Jongh re ponded at te twelve can di date at we gave co tributio to wo and at a ll raised funds fo two ca didate whom did not co nt i te to a they won a we ll al attached a li of cand i date a tated at ames in bold and above the line lin sic a inn ers MC Ex JP MC Ex Feb aiy Ceci de Jo a il ed tein rega ding upcoming electio and ca didates and stated at hi be bet i to give i de no min a uppo1t in the pr im aiy to li dify relatio hi a the tro gly the inn of the pr imai go in into general election JP MC Octobe Cec i le de Jongh a i led i ai Kahn at di ss ed po li tical co tributio i im I a ed about wr i ting ecks fr STC and aid to ta lk to yo is es i ye and in clude a list of four ca didates A li cia aine Do nn a Frett ego1y Stedmann odge and Athneil obby as Ka hn re lie at poke wit hj ee ye te day a to cut a ll ec from de Jo fo wa ds at emai to a ascal and a ks er to ecks eac in dicate below JP MC Ex Case Document Filed Page of Ceci de Jo agreed li st er tele ph num be DC website as co tact info1mation fo do at i from effrey Epstein JPM Ex November Ms de Jo emai ed Jeanne Br nnan copy in Richard Kahn wit bject AC eck asks Ms Br nn a to please prepa a eck in the amo unt of to below nti ty fr om STC as pe JE From Adr ian Dudley The ac is Island gaged Inc JP MC November Cecile de Jo wrote to Epste in that the app campaign is going to take at you gave to attack Jo hn and a ked an we sto payment on check to send a mes age JPM Ex September Epstein asked to prepare a eck to do ate to a per PAC associated with Governor Kenneth Mapp JPM Ex JP MC at December Sebastiano Palewon sky Cassinell i wrote to Ceci de Jo regarding a co ntribu tion to Mapp-Potter Inaugural Committee and stated Committee wo ul welcome any do at i at Mr Epstein wo uld be so in cli ed to make Ceci de Jo then wrote to Epstein to co nfom at wa nt ed to donate to Mapp Potter In augural committee and that it hould come from So ern Trn st JPM Ex JPMC Ex at December Ceci de Jo wrote to Epstei ega di a reque st from B1yan/Roach Inaugural Comm i ttee fo a donation from Ep ste in fo in augural eve nt JPMC Ex JP MC at Case Document Filed Page of On A st Ms Una asca ailed Ms Cecile de Jo at Epstein added thr ee ore Se nat ors the li st afte he me i th Governor last wee in St Croix JPMC Ex In Januaiy at the reque st of Cec ile de Jongh Epstein dona ed to he Specia vents Fund for Governor Jo hn de Jo elated to Governor de Jo ate of the nit ece ion JPMC Ex JPM Ex at JPM Ex at Epstein paid SVI Senato Ce estino White to co ul han in he a me of one of Ep ste in i lan ds JPM JPMC Ex at JPMC Ex From Januaiy to Januaiy Ceci de Jo was he First Lady of the SVI JPMC Ex at Ceci de Jo was he man age fo two of Eps ein SVI ased businesses FTC a nd JPM at In Ceci de Jo was paid in salaiy bonuses and ot benefits for her work as a man age for ne of Epsteins USVI-based sinesses JPM Ex Be tween and Ep ste in paid ove in tui ion payments for Jo hn and Cec ile de Jonghs hil ren to attend th Antilles sc ool and than fo heir hildren to attend Skidmo and A meri ca uni versities JPM Ex JPM JPMC Ex JPM Ex JPM at On Sep tember Cec il Jongh wrote to Eps ein at he and Governor Jo hn de Jo have put ey into he ca mp aign based at they th ht was go in happen wi th the tui ion payments JPM JPMC Ex at Case Document Filed Page of On Sep mber stein wro to Cecile de Jo to offe to lend ey to Gove rn John de Jongh so he inediatly has i ic in connect i wit a riminal ca brought against Gove rn de Jo Ep te in stated wo ul play any role in this yo lik and tated wo uld glad be thephone anonymo se i hn uinn and prosec to offer in suggestio i JPMC Ex JPM Ex at On ecember Governor Jo hn de Jo wrote to Ep te in to tate tha was nea to an agreement USVI Depar men of Ju ice acceptance of and tha Governor de Jongh wou like to take Epste in is off er and equest to boITow JPMC Ex Epstein oa ed Ceci de Jo and Jo hn Jongh ated to a riminal case brought against Governor Jo hn de Jo JPM Ex at JPM Ex at On June Governor Jo hn de Jo wrote to Epstein to aga in express my app ec iati and thank yo fo assista ce at a ve1y diffic ul ime it made matters much ea ier JP MC Afte Ep te in death Ceci de Jo was provided a lump um payment of in seve ran ce payme nt fo er te nnin at i from So ern Trn st Company JPMC Ex On November Cec il de Jo emailed ea nn Brennan wit ub ject Talking Points The attac hm ent Ta lking in ts contains talking points for reque te severa ce and tate at all employees were loyal to Jeffrey Epstein tha we a put a further di advantage to oyalty at was exhibited and that equested severa ce i ot a pay off bu an ac kn owledgement of ur tenure wit company and i ea rl Case Document Filed Page of dissolution hile we tran iti to oth employmen Cannot be een as a pa off as we were not co li i in any act JPM MC Ex On Febmaiy Ceci de Jo emailed Le ey Gro ff to as her to lea includ JE sc ed ule a me tin i fonner Se nat or Ce le tino White Tu esday Febmaiy at PM at he STC Office The PO wi ll be JPM Ex On Febmaiy Ceci de Jo wrote to Ep ein tating mi ht wa to co id er putting USVI Senato Ce estino Whi so so i of ont hl retainer becau se it wo uld et ein hi oyalty and access JPM Ex JPM at rom through Financial st Co mpan pen ore han milli in to th local economy JPMC Ex at I-JP On Januaiy hai McCollum the Co mmi ss i of the USVI Depai i men of Education wrote Everett Baine wo rk ed for RMC eseai C01poratio and Cec ile de Jongh I ha ve asked Mrs deJo includ employer Jeffe1y Epi ti sic in eview in a li of ote nti a donors to ee if he i familiar i individual to facili ta te in si de co tact RMC wi ll pl a li of po ss ible co tact fo eview We ai planning a eet in Febmaiy to bring to he tab le all pa1ii es at can assis DOE wi th makin hi visio a reality JPMC Ex On Januaiy verett Bain es wrote to Cecile de Jo copy in hai McCollum Co mmi ss i of USVI epaiime of catio wit he ub ect Intr od ctio DOE Publi Pri vate Paiiner hip He ri tes We wi ll eed influen ce like Mr Epstien ic a nd ot he rs can ope he doors a nd get Co mmi ss ioner an aud i ce It wou ld be wo nd rful i we co uld build a all co gro up of influencers ave a personal co mmi men VI and wou ld be wi llin pro id so me re so ur ces to get so Case Document Filed Page of initiati ves off he ground wit out a ll the politics and burea cracy associated with govt or foundation funding JPMC Ex JPM On Febmaiy Kai Pulliam Tmnbull of the Office the Commissio ner for the USVI Depaitment of ducation wrote to Cec ile de Jongh Co mmi ss ioner McCollum eq ue ted that I contact yo relative to yo ur ass uran ce to peak wit Mr Jeffrey Ep tein regarding ot indi idual the Depa11m nt of Educati ca po ss ibl co tact for funding JPM Epstein Gave US VI Government Officials And Entities Non-Monetary Benefits Ceci de Jo stay ed at Ep tein apaiime in New York fo ab ut a month in JPMC Ex JPMC Ex at In Febmai Ep st ein wrote Cecile de Jo to sta te that the vi govt i desperate fo cas and a ked if fo1mer ove rnor Jo hn de Jongh kn ew ofUSV I governme nt prope1iie that co ul se ve as collateral for a Inilli do llai loan fr Ep tein Ceci de Jo sta ted that wo ul et a li st GOVI prope1iie JPMC Ex JPM Ex at JPMC Ex at ov ernor Kenneth Mapp te tified at di sc ssed eCommerce i ss es i Ep tein and a ked him fo a ss i tance in preading the word that the Virgin I land had a unique attr ibu te that i was pu hin for bu ine ss in vestme nt egai in a redundant platfo1m that was tied in by fiber ptic and undersea cables into Fl ri da a nd int New York that cou ld benefit bu in esses JPMC Ex at ov ernor Mapp te st ified that he so ht Ep st ein ad ice ab ut ow to in crease bu ine ss in tment in the ir in I land JPMC Ex at Case Document Filed Page of ov ern app test ifi ed th at he so ht ste in a i ce ow to ccess ful in i ss uin at a so ea ll riti ca ll eeded ds fo finan in so riti ca finan in eeds te ni to JPM at ove rn app test ifi ed th at so ht Ep te in ass i tan ce in eg i lati ve fo 1t to all ow fi i a ri es to epa tri ate ir in co to mak SVIs ED rog ram at rac ti ve fmth tes tifi hat illiam Blum Ep te in at rn eys pe ra ft egis at i eg ar in ese epa tri at i fo 1t JP MC at On ece mb Ce lin a ni ma i ed Ms Ceci de Jo ith bjec Intr od ct i VIED A Bu in ess Amb ass a do at ac a et fr I A CE Kamal a th a qu est in yo ur co mpan ys a ss i sta ce i ro ot in th VIE tax in ce i ve progra as we ll as int ro du in yo ur Bu in ess Amb ass a do Yo lan da B1 an B1 an i ava il a bl assis yo i an a ll ges yo ay co unt a yo do bu in ess in ir in I land ill co ta ct in yo sc ed ul a eet in in ew yea JP MC Ex USVI Had Knowledge Of Epstein rime In cto Pa ge Six ubli ed an ai i cle itl ed ste in rop i I a es hi ate hat so id sex sca ndal mT undin ffr ey ste in a a kin waves in ai ibb an th billi a ir ow a pri vate ac getaway an ha eep finan i a i es gove rn ir in I lan ds Th a1ti cle fui ate hat ste in eg ul a rl fe ni oat oads yo un wo JPM SVIs sex ff de fil Ep te in co nt a in a copy a a il east ai icl itl ed Billi a ir op hil Goes ee th at Fl ri da aw fo ce nt faxed SVI DOJ in Jul JP MC at JP MC at Am ot hin gs i Case Document Filed Page of tate that Epstein had a ri va te Ca ribbean island that victims made allegations about ti ip ut of state and abroad Epsteins private jet that would ave been evidence of sex ti 267affic kin th at th FBl investigation re ac hed as far ba ck as and that the FBI ad identifie roughly victi JPM Ex a JPMC Ex a The Governments itne ss sex ff nder nitorin Ms In a i Borque testified that the Government was aware of the co ntent Epsteins sex offe nder file includin the Daily Be ast article JPM at On May Jane Doe filed a la ws ui in the So uthern Disti 267ict of Florida a lle in that Ep ste in was ti i in ictims to the USV I JPM Ex On Januaiy the Guardian publi hed an article titled Jeffr ey Epsteins Donations to Young Pupil Prompt US Virgin I a nd Re view It sta ted that the SVI was go in to review its co rp rat spo so hip after it ged th a Jeffrey Epstein the co icted sex offe nd and friend Prin ce Andrew gave ift sc oo pupils and finan ced eve nt for yo un children The a1iicle fm i her a ed that a wo man ad alleged that he was made to engage sexually wit Andrew at Epsteins ir in I slan prope1iy JPM Ex at JPM JPM Ex JPM at Case Document Filed Page of JPMC Ex at JPMC Ex at On Janmuy Jane oe fil ed a la ws ui in th Sout rn Di tri ct of New rk aga in Ep tein and ot alleging that he was required to erfo nn exual acts Ep ein in he SVI and at occasio afte uff rin ve rbal ab se and threat by Ep in and ot attempted sc ape from hi pri vate i land nl for a sea party ocate her and physically turn her to the a in he i land JPM Ex nr Pinn ey te tified at anyone includin USVI DOJ co uld have nm a sea for nline edia a1ticle Ep tein JPMC Ex at Fonner Attorney General Deni se George te ified at reviewed i vi co mpl a int aga in Epstein became he Attorney General JPMC Ex at Fonner Attorney General Carol ma acobs estified that he i the Virg in I lan ds wou ld be aware of any atio a pr ess acco unt JPM at Atto rn ey General Caro Thoma Ja cobs fm her te tified at if th USVI kn ew allega ti in civ il lawsuit they ad a re spo ibility to follow up the a lle gatio JPM Ex at USVl Lax Sex Offender Monitoring Of Epstein Facilitated His Crimes SVIs wi tne ss sex ffen de nit rin hani Pinn ey te tified that there was ever any in vestigatio by SVI DOJ in to Epstein JPMC at Case Document Filed Page of Ms Geo ge estified at beca AG in A pr i ere was a lot of in fo nn atio swi rlin aro un th ed i a wit es ect to at had been occ un ing on LS and USVI DO was eceiv in a lot ed i a inqu ir ies he sub ect JP MC at MC Ex at wan ed to fi ut at appened beca se hi thin we by fo so a years hi was min boggling JP MC at tarted a inqu ir i es into allegat i in clud in inqu ir in i USV I OJ and USV I olice Depa fin if were a com la in abo pste i ur ing sa iod aiied keeping up wit ed i a epo1is a civ i aws its in volv in pste in JP MC at MC Ex at Ms Geo ge estified at USVI OJ did ave th eso ur ces it eeded in vestigate stein MC Ex at USVIs itn ess Ms a i Pinn ey tes ti fied at budget co raints i ot in a way im pact USVIs abi li ty to ito pste in JP MC at In Ap i Fi rst ady Ceci de Jo wrote to pste in abo ut ran fe ing hi parole fro Fl ida to USVI Ms de Jo wrote at fo1warde th doc um sent he las wee Jo hn a ied to se i to in cent ut i was conupted in ce can ope eit Late in he ail ain stein rese ds at ac hm an ites ack anks se ding again to Jo hn Jo hn wi ll ai to in cent JP MC Ex Governor Jo hn de Jo estified at ai ed he pai ole qu es to Atto rn ey Ge eral and told th First ady to spea direc tl th Atto rn ey Gene ral abo it MC Ex at Case Document Filed Page of irst Lady Cecile de Jo estified that he never the At orney General abo it bu th at the Governor did and rel ayed to her how ps in ul proceed as the parole reque st JPM Ex at Th At orney General claimed ad no of utr eac either the de Jonghs re ga rdin tran feITing ps in parol to th USVI JPM at On May de Jongh fo1warded an email to Epstein wi th ugge ted lan age for USVI Sex Offender Regi tration and No ification Ac ORNA egislatio The ri inal sende infonn atio is to ff but the aut wr i es I co idered he lan age yo ared i me I believe thi language ay be best We need to be able to kn ow he her a person i at th addres ot To wa i ve th otice requir a ll oget her ill ot acce tab the federal DOJ program a na gers Remember they mu review and dete nnin if we a in co mplian ce This is th ugge ted language wi ll it wo rk for yo JPM Ex at tein replied at we ul add out of co untr for more than day ot he1 wise I co ul go for a day ti ip to Tortola at the last minut JPM Ex de Jo ep li es that This ne eds to be se ttled by Thur sday becau se goes away fo a week and AG ne eds to ubmi by June Don wa nt to ai bac and forth JPM Ex On May de Jongh a iled tein If yo co uld nl han ge thing in the bill ha wo ul it be The que tion of yo ur op priority came up tein replie that I wou ld add th at the attorney gene ral ca wa i ve the otice requirement if the offe ders vocat i quir es more than three intl u-i ps per yea JPM On June Maria odge Epstein attorney emailed At orney Ayala the legal co un se the USVI legi lature th following As promi sed I attac a copy of my Case Document Filed Page of notes amendme ts to bi ll I un derstand Se ator Russe ll as agreed ppo i JPMC Ex JPMC Ex PMC JPMC Ex at un Ms odge ema i led Way Anderso a USVI DO ega co un sel and Mo ica Car on ega co un sel to Atto rn ey General Ms odge wr i es tha in a phone ca ll I eceived from the AG today we ad i sc ssed commun i cat in with Atto rn ey Ca bo abo egisla ion Ms Carbo respo ds i USVIs counte proposal the egislation at Atto rn ey Carbon had eq ested PMC un Ms odge ema i led USVI Senato Ro a Ru sse ll bli copy in Epste in tha be li eves at Atto rn ey Car ons co un er proposal st i ll has a umber of prob ems states that se attac ed comprom i se proposal to Atto rn ey Ca bo and at it was spec i fically prepared to cover the OJ co ce rn at ere be off island travel wit some notice even in eme ge cy situat i but a ll ow otice expedited mea in those cases and also adopt some easonable ite ia for freq ent trave sta es tha hopes he i ll offer th i lang age rathe an draft the DO prepared JPMC Ex JPMC Ex Ms odge co un e1proposa eq ests the following exceptio to day req i eme provided oweve that a sex offe de provides easo able a li a proof satisfacto the epa tme of ice at he rave side United States freq ntl fo work or er egitima pmposes and a sex offe der travels tside ited ates fo eme ge cy situat i a ll ot i fy DO pr i depa ur by telep in wr i ing of trave side United States for pe iods of fo iy i homs or less and a ll ot i fy DO in wr i ing at leas twenty fo befo traveli side of ited ates fo pe iods of more an fo1iy eight and in any ch case a ll ify Case Document Filed Page of the DOJ in ritin up the sex ff nder return to thi juri sdictio a nd pro vided furth that the Attorney General ay at hi discretion reduce the twe ty ne ay otice requirement if a sex offe nder requests a redu ctio and pro vides info1mation in upp 1i of the request satisfacto to the DOJ JPM Ex Ms odge co unterprop osa also reque sts the following language conce rnin in fo 1m atio the sex offe nder mu st pro vide ithin twe ty ne days prior to tra ve away from the Virg in Islands the sex offe nd hall pro vide the info1mation set forth below in ritin to the Depaiiment Justice pro vided however that a sex offe de pro id es easo ab a nd liable pro of satisfacto to the epai iment of Justice that tra ve frequ ntl for work or ot legitimate pmposes and a sex offe nd tr avels fo emergency si tuati a ll provide in fo 1m atio the epai iment of Ju tice prior to departure by telephone in wr itin for travel away fr the Virgin Islands for periods of fo iy ei ht ur less and hall provide uch info1mation in ritin to th Depaitm nt of Justice in ritin at least twe nty four ur before traveling away fr the ir in I slan for periods of ore than fo1iy eig ht hours and pro vided fuith owever that the At orney General ay at hi di sc ti reduce this twe nty ne day otice quirement if a sex ff nd er requests a ed ctio and pro vides info1mation in upp 1i th que st i identifying infonn atio of the temp rai odg in locations includin addresses and nain es in th case of a sex offe nder provides reasonable and reli ab proof the DOJ th at travels frequentl fo work or ot le gi tim ate pmposes reli ab info1mation egai in ge ne ral rave ocatio and ai 267eas wo rk in li specific addresses and co nta ct telephone in fo 1m atio at hich th sex ffend can be contacted wit ut unre asona ble delay at a ll time hil tr aveling from the Virg in Islands and i i the dates Case Document Filed Page of the sex offende ill be staying at each temponuy odg in location in uch general ocatio and areas of wo rk JPMC Ex Ms Mon ic a Carbo legal counse to the Attorney General stated that at the time he was ot co ncerned about receiving input from Ms odge on the sex offende legislation because he kn ew at anything submitted ad to be approved by US DOJ JPMC JPMC Ex at Ms Pinn ey testified at anyone seeing that dra ft sex offende legislation outs id of DOJ wo ul ave been a problem defini ely and that definitely would ave een smp ri sed to he a at it had been sha ed with Epstein JPMC Ex at First Lady de Jo testified at she spoke to her husband Governor de Jongh abo Epsteins preferences for the SORNA egislation JPMC Ex at tes ified that ne ve spoke i the Attorney General abou Epstein in relation to the egislation but hu sba did JPMC Ex at Governor de Jongh initiall estified that he ever spoke to he First Lady the Atto rn ey General re gard in Epstein and the proposed legislation JPMC Ex at After eing confronted with documents he acknowledged speak in to both Ms de Jongh and he Atto rn ey General re gard in Epstein and the proposed egislation JPMC Ex at Atto rn ey General Frazer claimed ot to recall any int eractio i the Governor or First Lady re gard in the sex offe der egislation JPMC Ex at Atto rn ey General Frazer estified that believes that at some point a comprom i se was wo rk ed out between Epsteins team and USVI DOJ he lan guage of he amendme nt JPMC Ex at Case Document Filed Page of Ms de Jo estified that Epstein team a nd USVI DOJ eac ed an ag ee nt on the language of the amendmen ts bu th at Se ato Ru sse ll changed hi mind and a so that Atto rn ey General Frazer did push ard enough for the agreed language JPM Ex at On June th legislature of he USVI passed Act No an act a mendin apte oft itle of he Virg in I lan ds Code hi co nt a in he la ws of the USVI regarding the moni to rin and tracking of sex offenders wit hin USVI JPM Ex at Governor de Jongh a ppro ved th bill Jul Id at Th Ac deleted and replaced ub sec ti wit the following language A ll sex offenders required to re i in this jurisdiction hall appear in person at the DOJ at eas twe ty ne cale ndar days prior to any intended travel ts ide of United States and provide inform at i a ut their in ended travel as may be requir ed by th At rne General provided owever that the At orney General ay at hi di sc ti ed ce thi twenty-one day otice requir men if a sex offe nd que a reduction and provides in fo nn atio in upp rt of the requ est JPM Ex at It also de ted and repla ced subsectio i the follow in lan age Wi thin twe nty one days prior to Travel for days or ore the sex offe nd er a ll provide he following info1mation provided oweve th at th Attorney General may at hi discretion ed ce hi twenty-one ay otice requiremen if a sex offe de que a reduction and provides infonna ion in upp rt of request i iden ifying infonn ation of the tempora1y lodging ocatio includin add esses a nd name a nd ii the dates he sex offe nd er wi ll be ay in at eac emporaiy lodging location i the At orney General at hi discretion Case Document Filed Page of ay equ ir th in fo nn atio in lie th above in fo nn atio po qu est of a sex offe de MC Ex a ly Ms de Jongh sent pste in a ai i th ect line Nex sta ed I know thi was a on i ble wee a I am ea ll so abo ut ow thin gs ann ed ut owever all i not lost and we wi ll fig ur so thin ut by co min wit a ga a get aro un ese obstacles We i ll eed wo rk th rough Dowe and Whi to get thi acco mp lis ed In th ea tim we wi ll wo rk i in ce i ve th disc etio fo at fo yo at least ca do MC Ex ly Eps in wrote to Ms de Jo I app eciate yo ee pin a close wa ince nt i ss We wi ll ave to go fo an a soo I do want to alie a him so ispers in rn sse ll ea MC Ex ece ber anot er a endme nt to apte ofti tl passed a end in sec ti as follows ti ikin in aragra ph ay be qu ired th Atto rn ey Ge eral and in se iing prov i ded in oweve a sex offe de rovides reaso able a li ab proof sa ti sfac o1y to Depaii of stice th at ti ave freq ntl outs i de th ni ted ates fo wo rk ot er egiti ate poses a sex offe de u-avels outs i de th ni ted ates fo ge cy i atio shall notify th pai 267tin nt of stice ior to de paitur by te ep or in wr i ting of ti 267ave tside nit ed States fo io ur or ess a all otify th a 1tm nt of stice in ri in at east ur efore ti ave lin outs i de of th ni ted ates fo per i ods of han ur and in any case a ll ti fy epaitme of Ju ti ce in wr i ting upo sex offe ders ret urn hi ur isdictio JP MC Ex a Case Document Filed Page of It also amended by triking the a ua ge in in i ts ntir ety and in se iing new lan age at ead as follow A sex offe nd provides re asonable and reliable proof satisfacto to th partm nt of Ju st ice th at trave fr quentl ut si the United States fo work or ot legitimate pmpo ses and a sex offe nd travel tside the United States fo ge cy situat i a ll ti fy he Depaiiment of Ju tice pri depaiture by telephone in ritin of travel outs id the ni ted ates for period of ours le ss and a ll ti fy he Depaiiment of Ju tice in ritin at lea ur befo rave lin tside of the United States fo ri of ore han hours and in any case hall notify th Depaiiment of Ju tice in ritin up he sex offe nd return to thi jurisdiction oweve the Atto rn ey General ay at hi di sc ti ed ce he day otice requir nt if a sex ffend reque sts uch a redu ctio a nd pro vides info1mation in upp i of the que satisfacto to the Depaiiment of Ju tice The in fo 1m atio mu includ identifying infonn ation of the mp rai odg in location includin addres ses and nam es in th case of a sex offe der provide reasonable and reli ab proof sat isfacto1y to he Depaiiment of Ju tice that he travel for wo rk ot legitimate pmpo ses frequently reli ab info1mation egai ding ge eral travel locations and a eas of wo rk in li of ec ifi add esses a nd co nt act te ep ne in fo 1m atio at hi the ex offe nd can be contacted wi th out unr easo ab de la at all times hil traveling away from the Virg in I lan ds and ii The date the sex offende will be stay in at each temporaiy lodging ocatio in ch ge era locations a nd areas of wo rk JPMC Ex at In a Jul letter Atto rn ey General Frazer infonn ed Ms Mai odge at he was gra ting tein a waiver of the day notice quirement whe he traveled ut si of USVI Th letter tate that notice mu st be i ve the DOJ le ss than ur before ravel Case Document Filed Page of a nd at it ma be i ve in person by facsimile co es nd ce hi is signed by him by mail i an elec tr ni ignatur JPM at In an August ette At rne General razer in fo 1med Ms odge at after care ful re i ew yo ur le ter giv in addi ti nal in fo 1mati to upp i Jeffrey Epsteins reque st he was a ll ow in Epstein notify th DOJ hi int ion to tr avel ut of SVI wit hin ur pri depa1iure otify he was stay in in ne of hi ateside homes and provide a mTent li st and add esses of eac of hi ates i de me stay in in a n-pri vate lodging to provide he specifics of the nam i ty and add ess of the establishmen a nd hen was stay in in he an associa te to ti fy he depa1iment he city a nd ate or co unti in hi is mp orar il stay in and hi period stay in the juri sdictio JPMC Ex at Ms Pinn ey estified at was not aware of any ot her sex offe nd received reque sted a pe1manent waiver imilar at Ep ste in que ed JPMC at fmiher estified that I do wa say though-you said if they if anyone ever ade reque sts We go co mpl a int a ll th im yo kn ow So offe nd yo know co mpl a in about the frequen cy eve1ything all the time JPM at Mr Fra ze estified that during hi enure as Attorney General ever granted specia tre at men Epstein because of Mr Mrs de Jongh JPMC Ex at He co id red a nd co ntinu es to co side Mr de Jongh hi friend JPMC Ex at Mr Fra ze estified that he gave Epstein the waive ased the ep re se ntati of Epsteins lawyers that was a bu in ess man and nline research Mr Fraze sta ff id for him JPM Ex at Case Document Filed Page of Ms Ca rb do es recall do in any re sea wo rk this eq est for a wa i ve JPMC Ex Ms Pinne testi fi ed does know hat was provided to Mr Frazer in upp rt of waive JPM at In a Ma le ter o1 At orney General Thoma Jacobs wro te to Ep ste in hat hile provi i were rant ed in th pa SVI DOJ was ow quirin notification of any rave outs id of the U.S Vi gin Island in so at USVI DOJ hen Ep ste in was in USVI at lea calenda day pri ravel JPMC Ex at JPM Ex at Fonner Atto rne General Th as-Jacobs te st ified at he was mpri ed and co ce rn ed to see th waivers th at ad been anted Ep ste in in he pa st JPM at he testi fi ed th at id ot se a yt hin in hi file to upp i the waiver and at he better co ur se wou ld ha ve been ha ve him a dh cl osely to ta tu JPMC Ex at George te st ified at he reviewed Eps ein file a nd ne ve saw proof of a egiti ate rea so for frequent tr avel and hat ha a er think hat ma ybe Ep ste in did ot ave a JPM at A coup of weeks afte George became Atto rne General in Ap ril Governor B1 yan approached her ei th by ph in person he co ul recall her know th at Epstein was plannin to as her to in ate tifi catio quirem ts hat ad a ppli ed to him und Fo1mer Atto rne General Frazer expre ss ed a os i ion he reque and couraged her to me et wit Ep ein at orneys to di sc ss he reque st JPM Ex at JPM at Case Document Filed Page of A ft Ms Geo ge ad received eque Gove rn B1 ya exted to min to ake a decisio eque JP MC at Geo ge tified at li eves hat eac wa im prope beca Gove rn ld ave bee in vo ved in a aw fo ce atter MC Ex a tified at i in dicated to hat Eps in wa fl xin is po li tical in fl ce over or wit Governor in a effo1i to get a favorable re lt in a law fo ce i hi wa a red flag hat th fact hat th re qu wa ade be a of a co victed hi ld oles pr edato th rough Governor in tead of th reg lar a nn was co ce rnin a at i owe at it wa Gove rn priority for ea an at exis ed degree of po liti cal in fl ence te in over Gove rn or 1yan MC Ex at A ft de ying tein eque an ai to Gove rn B1 ya exp a inin ea fo er decision and expla in ing a tatute was th rotect th co mmuni ty i beca se fe lt a Governor B1 ya eeded an understa ding a to i po1ia ce and agnitude of th oti fi catio equ ir MC at te ti fi ed th at er re fu al re in tate th ot ifi catio equ ir lik im pacted ta ding wit Gove rn B1 ya beca wa doing job wi hout ect to any olitical inte fere ce a nTe pec ti ve of at po li tical in flu ce te in ay ave ad a at at ay ave ee fi rst im th at Gove rn B1 yan was faced wi th a MC Ex at Pinn ey tified at USVI OJ ever a ked fo te in awye in ut in to at Tie ld be clas ified a JP MC at Case Document Filed Page of September men Indyke wro te to Ms a i inn ey tati As yo req ested en Epste in appea ed at the epa tme of tice Tue sday I ave attac ed copies of pste in two asspo ts and a Memo andum expla in ing pste in qualifies as a tier offe de JP MC Ex a Ms Pinn ey testified at alt she inks a ll sex a offe ses a se io alike the statute classifies ce ia in imes at hi i levels depe in the detai of case JPMC Ex at Epstein served a 13-mont se tence and was conv i cted of so li i tati of a min JPMC Ex JP MC Ex der USVIs Sex Offe der Legislation a i offe se in cludes any sex offe se that is ot a i or Tie offense JPMC Ex a And a Tie offe se incl des any sex offe se aga in st a min at in volves use of min in prostitution in clud in so li i tati Id A mmaiy of a meet in i Ms Cai bo in dicates at Ms Cai want ed hi to be classified ighe be li eved ey were ab to put hi as a level PMC Ex It a so states that Ms Cai bo can eca ll whe er co i de ed hi mo sente ce whe looking a the tie ass i nm for pste in and ca ecall analysis about fact that solicitation of min is designated as a ier offe se un de the statu te JPMC Ex It fini er states that cant reca ll the process hi ch a tie was assigned made dete in at i be li eved it was likely he JP MC Ex Ms Pinn ey USVIs designee sex offe der monitor in of pste in testified that did not kn ow Epste in was classified as a Tier I offe de and i kn ow anyo se in the USVI gove rn me wou kn ow or co exp ain at bas i for classifying Epstein as a Tie I was PMC Ex at Case Document Filed Page of esti fi ed at sex ff ders are a ll ec ed ce a week in addi ti to an a nnu a ope rati th at perfo1 co li ance ecks fo a ll of th offe ders in at wee hu est im a ed at i was poss ib le a average ff nd wo ul ec ti es in a yea because th es i weeks in th yea JP MC at Ms Pinn ey estified at ere a no wee kl checks ly annual operation MC Ex a Ms est i fied at paii of reaso fo do in co mpli a ce ecks is so a if an in ves tigat is th and sees so et ing ic i th ey can epo1i it a at ore freq nt ecks a it less likely th at ff ders i ll gage in cr imin a activity eca se ey know th ey be in ec ed MC Ex a Ms Pinn ey estified at pose i to co nfom th at a ff de as prov i ded as th ei pe1 a ent esidence and also ir oye address is ue a co 1T ect JP MC Ex at SVI DO pe fo 1m ed a al five co li ance ecks pste in JP MC Ex JP MC at does know of any co li a ce ec be in los for stein th ose fi ve ecks was pr ese nt isla nl ce JP MC at No of co mp liance boxes were ec ed Needs In ves tigatio No in Co mp liance JP MC Ms as Jacobs testi fi ed at in vestigators ld ave fo ll owed up a ft i ss es wi th steins co mp liance ecks JP MC Ex at Mr Fraze estified a mi ght ave fi led a ges a co pla int in co mi ad kn ow at pste in was de in investigators access LSJ MC Ex at Case Document Filed Page of Pinn ey te tified at eve hen a offe nder i ot pr ese nt ey are ot in noncompliance and th at even th olicy was to fo ll ow up and he an ffend he wasnt her USVI DOJ lacked access to a boat so it co ul do so for Epstein JPMC Ex at JPMC Ex JPM Ex at JPM Ex Pinn ey is awa of any follow-up action at we tak re pond to he tip about Ep ein riminal ac ti vity JPMC Ex at JPMC Ex at When as ked if he fo und he co mpl a int edib estified at he made th decision to fo wa rd it on and hat i ma ave been redible but also th at th offe der was ve que ti na ble JPM Ex at rqu est ifi ed ha hi sex offende i kn ow fo se ndin th ese kin of hr eate nin a il JPM Ex at Thoma Jacobs ag eed hat USVI uld have followed up th private hef email and th at a udi and video of at was go in Li ttle St James wo ul be of in ere st if th we re in ere st in finding th Mr ste in was engaged in any sex ual mi sco ct JPM Ex Jacobs Tr at Case Document Filed Page of Government-Affiliated Officials Gave Epstein Influence And Acces In Ways That Facilitated His Crimes And His Transport of Victims Ep tein eased hangar pa ce fr th ir in I land A ority VIPA fo hi ai crafts JPM Ceci de Jo ne gotiated a ease wit VIPA fo a a gar for Ep tein aircraft JPMC Ex at IPA gra ed one of Ep ein employee a VIPA badge allowing ramp access at a USVI airpo1i i a IPA sco i JPMC Ex An Ep in employee was granted a U.S sto and rd Pro ection Sec urity Seal Th at sea allowed he employee esco 1i pa ss engers through U.S to orde Prot ec ti JPM Ex at Ceci de Jo and Governor John Jongh enli ed Ep tein upp i in av in Ca rlt on Dowe appo in ed as the Executive Dire cto ofVI A JPM Ex JPM Ex at JPMC Ex at On sev eral occasio Ep ein ad me tin gs wit xec ive Dir ecto owe JPMC Ex Governor de Jongh te ified th at VIPA ove saw all he aiipo1 i and the sea po1is in he Vii in I lan ds was es ible for sec urity wit hin USVI aiipo1i and ove aw he a iip rt sec uri ty office JPM at USVI expe1 i Brid get te Ca JPMC Ex at i,i Case Document Filed Page of On June Epstein wrote to Cec ile de Jongh to ask i in cha ge of sto ms in the v.i and sta ted at used to ave a eat elations hi wit glo ri a Lamb rt aiipo rt uper i so additionally tated her is a 1m ca1pe er as been difficult lat ely Ceci de Jo re spo ded hat spo ke to Kenn who wo uld ca ll head of sto ms ui Hanigan to find out who Mr Caipe te was and di sc ss with Epstein ate JPMC Ex JPMC Ex at Kenn obso was head ofVI A at poin in time JP MC at Epstein so ht Ceci de Jo assista ce to gift sto ms oyees in St Thoma sto ms and Border Protection office a turkey fo Thanksgiving JPM Ex Ceci de Jo aid hat i wo ul be fo Epstein to i ve hat i ft to sto ms officers JPMC Ex JPM Ex at Ceci de Jo did ot eck i anyone before stating i wo ul be fo Epstein to gift turkey to customs officers in USVI JPMC Ex at On Januaiy Epstein wrote to Cecile de Jo and Richard Kahn to ask ifth ere was a EB visa regional cente in USVI Cecile de Jo espo ded hat was hying to find fr om someo at Immigration Hillai odge Special Age nt in har ge JPMC Ex On Ma ch Ceci de Jo wrote to Ep te in at he ha spoke to an attorney in ce ull pe1 ia inin to immigration matter for a female in dividual employed by Epstein JPMC Ex Case Document Filed Page of Ceci de Jongh assisted Ep stein in enrolling three wo in Engli a a Seco nd Language ESL co ur ses i th University of the Virg in I lan ds UVI JPM Ex JPMC Ex JPM Ex at Ceci de Jo wo rk ed wi th Dionne Jack so he Vice Pr esident fo In stitutio nal Advance men at he UVI to help nr ll hre wo men in cla ss es wit the UVI JPMC at As part of the process for enrolling the yo un wo men in co ur ses Cecile de Jo wrote to Ep ein May to as What kin of visas do th ese ladie unentl ave he additionally ggested that the wo men co uld nr oll in he UVI to acq uire a I fo a dent visa if required Ep tein responded at ata ad an i sa and Julia a a i sa JPM An I fonn i required for a citize of a foreign co unti to ob a in a tuden For visa The fonn mu st be pr ese ed to the co su lar of fi cer hen a erso attend th eir i sa inter view JPMC Ex On June Cecile de Jo wrote Epstein to state at UV I was tru turin he clas around the ladie in regard the classes in hi pe Ep ein nr oll three wo JPM On November Ms Jeanne Brennan a iled Cec ile de Jo Th fi ve th sand ecks we wrote to UV I a ill ut sta ndin yo hink we uld follow up They we re ri tten in August JPM Ex On Febmaiy Ceci de Jo emailed Epstein in fo 1m atio ow an indi vidual cou ld obta in an I fonn through he UVI fo a tuden visa JPMC Ex Case Document Filed Page of May Cecile de Jo wrote Ca rlt Dowe in co nn ectio wi th a ette of upp i fo an visa a pp lica ti fo a wo an a ed rovided him um and i a i el in a as ed im to ease et i yo a wi llin to do is and we ca ta lk abo ut sam le ette JP MC Ex un Cecile de Jo wa co ied on an ail wit bjec ef fr ey as give Sc ed le in hi Le ley Groff ai at Jeffrey wi ll go to i a Mo day un a tate I kn ow yo i ll be oliday Jun Wi ll a ll be Ms ep li I mi drop off gi rl and co back to ST Copied a i are evera of te in i ti ms inclu in and JP MC Feb aiy Ceci de Jo ai ed Tho as Muka a of Island obal ac ting Faci li tie Ltd hi ch ow ed A ican Yac ht ai bo wi bject A YH dock at I ave been i in thi ubjec ome ought a I ink you ld co i de av in Cele in Wh i te go i yo an Jamie to earing I do not ink bers of th CZM Co mmi sion wi ll go agai Cele tino a uk a al i back I ha ah-eady di ss ed he atter wit Cele in and a ked fo hi advice a i was developing I wi ll ee i i available Ms de Jo ep li es eat I hink ca be ve elpfu JP MC Ex JP MC at In Ap i te in a Cecile de Jo di ss ed a new prac ti ce ac regai ding de ta lice at wou ave i gnifica nt a ges and allowance fo eci rocity wit ebo rah Ric a dso n-P eter i ecto fo Office of rofes io al Li ce ur a ealt annin at USVI Depaii of ea lth Ric ar so eter di sed is ur ing a phone ca ll wi tein and co fened i he de nt al li ce sing boai fo additio a in fo nation Case Document Filed Page of for ste in wro at ac wa ated to go efo Se ate Co mm ittee ea May 9t ce a proce ss i vet ed oa wi ll ave a clea er i dea at op ti a ov in fo wa MC Ex May Ceci de Jo wrote te in ad ews de ta li ce ur rn les and reg th AG office does ave th and ta ed wo ul et a know via text a awa i is espo addi ti a ll tated th at th Ac tin So li cito Ge era i a good fr ie of min Mac avi and th at ce eceive a onse fr Do a wo ul a i Mac and ti get it fa ti ac ed JP MC A Cec i le de Jon gh wro to Eps in th at Ce in Whi is go in to wo rk de nt al li ce in i a th at se him so of in fo add i tio a ll wro at Wh ite ad ated at i wo ul be easie fo him oo int and olve thin for yo i ad a co nti ac wit a eta in a co ul ate to ever a a yo ur nni sio to ave in fo ease to him JP MC etwee Septe be a Oc obe te in a Ceci de Jo exc anged ai ega in th de nt al li ce se a ppli catio fo Eps in a ed if ou ca ll Randy Kn ight Gove rn ors ief of Sta ff ega in app li catio Ceci de Jo gge ted a ho ul ot eca andy i ot exac tl a li ht dip atic and I do want th oa bers fee a ey are hr eate ed int approv in a ated a ad eac ed ut to rah ic a dso n-P eter a wou ca ll eve day a wo ul ca ll a a we ll rega in app li catio JP MC Ex USV I ta li ce wa approve in Nove be MC Ex USVI Funded The Bu ine ss It laim Were Front For Sex Trafficking Granting Them In Tax Incentive Case Document Filed Page of Th USVI as a lle ged at Epstein fonned an associatio in fact wi th bot co mpani es an n-profi ga nizati owned and operated to aid hi cr imin al effo1i Th USVI ha specifica ll alleged that one of he se co mpanie was STC hi eceived eco mi enefit from he USVI Economic eve pment Co mmi ss ion ED and ac ed as a co uit for payment to foreign wo credi ca ds airplanes and ot in tnun nt alities JPMC Ex I,I Margarita ja min te ified behalf of th USV I gove rnm nt that SVI Economic eve pmen Authority EDA i a emiautonomou nti ty un der the Governmen of the Virg in I lan ds JPM Ex at efits awa rd ed by th EDA mu st be approved by he Governor of the USVI JPMC Ex at Governor Jo hn de Jo approved he awa rd of ED benefits to STC in JPMC Ex at Governor Jo hn de Jo approved a rene wal of benefits TC JPM Ex at Governor Jo hn de Jo te tified at he gove rn ffi ce review EDC benefit a ppli cat i for a ppro val in volved eview in he decision that the board ma de to mak ure they co mpli ed i Economic eve pm nt Authority mi es and regulati JPMC at Governor Jo hn de Jo estified at whe co idering ED benefi a ppli cat i he wou ld re i ew he cove mem randl of at was provided by leg a co un se and ay get a little bi ore int the activ i ie and und and the type of bu ine ss tha was app in JPM Ex at Case Document Filed Page of ov ern Jo hn Jo est ifi at ev i ew in a pp li cat i wo ul eac so i a pp in to as th qu es ti an wo ul oo at finan ial pro ect i at ey ubmi ed JPM at ove rn Jo hn de Jo est ifi at wo ul oo if th ove i ew wo ul prov i de th bu in ess th type a ct i i ty I ay ay oo a app li cat i ju st und ersta if i was an unu ual in ess a nd at wo ul ev i ew th ega pini ak in ur i is co sis i th rnl es an eg ul at i oo kin a in ess a ct i i ty oo kin at th eco mi deve pm divers ifi cat i a was takin ace in te 1Ti to JP MC Ex a ove rn de Jon gh test ifi ed th at i un de rl in bu in ess a ct i i ty hu him a unu a I wo ul th a lik all in i idu a Id proba bl ca ll atto rn ey an a him to oo in to it an th ey wo ul epo i ac ove rn Jon gh JP MC Ex at ove rn Jo hn de Jo est ifi ed at was oo kin to see if bu in ess ac ti i ty was unu a an a as an ex ampl yea th ey ad so eo th at a pli ed th at wanted manu fact urin We do ave ve man a nu fact ur in ir in I an so I ju st oo at th a pp li cat i mak ur I un derstood So were oo kin at fo i dest in at i to se ll ir rod I ant ed see yo kn ow at ce tage th ir bu in ess ac ti i ty ey we oo kin at Was i i ey co id fo ign a th ey se llin So I wo uld oo a hin gs lik at JP MC Ex a Whe approv in fi ts fo Finan i a Trn st inclu in co id rin ps in rimin a co i ct i in co njun ct i ith ose fi ts Gove rn Jo hn de Jo tes tifi a Case Document Filed Page of we ole reco mm datio of Gove rn ors taff of legal co un el MC Ex at Whe co side rin th ED app li catio fo FT a STC Gove rn Jo hn de Jo tified at did ot find a of ir activity unu sual a did as a yo to do any fm i er in ve tigatio in to th MC Ex at Governor de Jo gh te ti fi ed th at di dn i ve uc ht beyo th reco mm datio of th ED a nd hi ega co un el to te in character a pp rov in EDC be efit for FTC MC Ex at Governor Albe i B1 yan was th aii a of th ED FT a pp licat i fo a ewa of be fi wa a pp roved in MC Ex at Governor Albe i B1 yan was th aii a of th ED a pp licat i fo be efit was appro ed in JP MC Ex at Th ig in al be efit granted to FT by in awa ded FTC a red ti in in co taxes MC Ex Whe FTC be fi we exte ded FTC was granted an ed cti in in taxe by EDC JP MC Ex at MC Ex at In EDC awarded a ce ii fi cate STC granting a ed ctio in in co taxe MC Ex at JP MC at Th ro progra th ED rant ed ove mi ll i in ax eaks FTC and JP MC Exh ib it MCs expe i Ca rl yn Ii in as pin ed at fro ei th Financial rn nor So uth rn Trn ca clo ge erat in ffic i nt be efit to USVI to off Case Document Filed Page of ax in ce i ves gra ted to ste in a ese co pan i es et a reac th hr es ld th co i de ed JP MC Ex r,r Whe ove rn de Jo approved awa of ED fi ts to STC is wi fe Ceci de Jo was a mp loyee of ED JP MC at ec i a Co i tio fo STC as pali of i DC efi hat we a pp rove by Gove rn or de Jon gh a dated th at STC prov i de its fu ll tim oyees a depe de nt wi th hun ed perce nt ploye aid edical in ur ance coverage as we ll as th fi ts in cl in itio im ur se JP MC Ex at un hil pste in was in carcerated in or i da Ceci de Jo signed a ce ii fi catio a ed to FTCs efi received fro at in a ste in was a bo a fide res i de of SVI JP MC Ex at several occasio offic i al co IT es de ce fr th ED A and ED elated to be efits awa ded ste in co mp a ies was add essed to Cec i le de Jo JP MC MC Ex JP MC Ex JP MC Sandra ess EDA rogra Co li ance Office who oversaw co mp liance re is fo FT a STC estified at perso dea lt wi th was Ceci de Jo as th ffi ce a age fo TC a STC Those in terac ti in cl ded urin un anno un ce i i ts wo ld as to see co mp liance perso a wo ld eak ith de Jo JP MC at A pr il in es se to a edia qu es rece i ved by Governor Jo hn de Jo ega in Ceci de Jo oyme nt wit FT hi le i was ED be fi ts Cec i le de Jo ggested to pste in at respo se be Ceci de Jo ITe tly wo ks fo in a i al rn st Co pany in capacity of ffi ce a age ad thin to do wi th Financial rn Case Document Filed Page of Co mp a eceiv in ED Tax be fi te in respo ded th at he wo ul im ply ate at Ceci de Jo is an ffi ce a ager to hi Cec i le de Jongh re ded at at Jo hn went i MC Ex Governor de Jo gh i ot pe ce i ve any co nfli ct of in te es in approving be efit fo te in co pan i fo hi is wife Cec i le Jo gh was an ployee JP MC Ex at Governor de Jongh i ot eque at legal co un se rovide an pin ion on any pote nti al co flict of inte es related hi a pp roval of be efit for co pan i for hi is wife was an ployee JP MC Ex at Governor de Jongh te ti fi ed hat wa ot awa of any in ve tigation un de iake to as any pote nti al co flict of inte est related hi a pp roval of be efit for co pan i fo ic hi i fe wa a mp loyee JP MC at Governor de Jongh i ot eque a as ss nt of any ote tial co nfl ict of in tere elated to hi approva of be efi for co pa ni es for ic hi i fe wa a mp loyee MC Ex at Marga i a ja min te tify in be a of USVI gove rnm te ti fi ed at no in ve tigatio into te in a is co mp a ie were un de1ia by EDC ot th an al co li a ce a dit MC Ex at Ja nu aiy USVI ED A Di ecto of Co li ance Step a ni wrote a ette tein ating at given ne edia i sio mT un in a pr in cipal of STC DA wa req ting a a ss ss nt of po tial imp act if any in es ac ti vi ti of STC a a pp roved by th EDC JP MC Ex Case Document Filed Page of MC Ex a San ra ess testi fi ed th at co pliance re is fo ED be fi cia ies ul done a nnu a ll MC Ex a Th firs co li a ce eview of was co eted Ap i cove ing pe iod of A pr il to ece be MC Ex Sandra ess testi fi ed hat th co li ance process for be fi ts relied in fo natio prov i ded by th ce1iifica older a so co at numbe rovided in cove shee of annual epo1i atc at co pany a provi ed in ppo 1i be hin th cover eet MC Ex at Th co mp liance ffi cer was tas ed with ev i ew in aracte of th peo le are ow ers of th co panies eceiv in tax be efits JP MC Ex at Ja nu aiy Ca rl os od ig ez ailed Ms Cecile de Jo i th bjec ai fos wo rk obligatio ated fo ll ow in Gree tin gs Ceci er i a list of hin gs Im doing for LSJ GS a Take cai of ve icles and ve hicl es a ve hi cles at angai eep fueled and clea Eve tim JE i i ts a ll hi ve icles ai was ed a deta i led also a gai ve hicl es ai was ed and de ailed Go JE a li to a irp i is aiT i va to th is a spai ve hi cle in case eh as i ss es lp wit lu ggage a brin to red oo for ik up eep angai bedroo eets always fr es la un de ed I br in to fo was hin a iro ing also bee do in ost ppin fo SJ GSJ fo os de a 1im nt So of ot ob li gat i in clude ick in up ests a contractors fro airpo1i a ing to a fro to els a SJ so eai ly rnin so late at ight Ive bee dea lin wit oat Case Document Filed Page of repair co ntr acto in Tortola to elp Randy and Pati i ck I do a ll boat egisti 267atio so me i ck up at ti i ca and anything requ ested fr me JPMC The public he a rin gs of he related awa rdin benefits reflec th at Co mmi ss i did ask que st ion regarding Ep ein riminal hi sto whe co idering an award of benefits STC JPMC Ex JPM Ex JPM JPMC Ex JPMC Ex JPM Ex On 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offic ial fr the Departin nt of Education Case Document Filed Page of the epartment of abor a nd he USVI police department The hil ren Cab in et wo rked to implemen gove rnmen policy re ga rdin hil dre i ss ue JPM Ex at One of the ini iative of the hildr Cabinet chai red by Ceci de Jo was to make ure at eve1y hild ca retaker at leas ad a hi sc ool degree and tha they worked toward an a ssoc iate degree JPMC Ex at Ceci de Jo te tified at as first lad he was e1y in volve in he National Governors Assoc iati JPM Ex at Ceci de Jo te tified at a Firs ady he had a Tw itter account at was amed he official Twitter account of U.S Virgin Island First Lady Ceci de Jo he fmther te tified at he idn hire someo se parate from the gove rnm to manage the account and tha it was likel man aged by a gove rnment mpl oyee JPMC Ex at Ceci de Jo te tified that he a a webs i as First Lady the USVI hat was se up by the public relati department for he Governor of the USVI JPM Ex at Th website fo First ady Ceci de Jo li ted the addres fo he Office of the Fir ady as the gove rn office and the ph number fo he ge eral sw i tc hb oard at the Government se JPM Ex at Ceci de Jo te tified tha as First ady he wo rked i protocol offic ial for the USVI Governmen Hou se egard in soc ial events related to her du ie a First a JPMC Ex at Ceci de Jo te tified at a Firs ady he saw role as wo rking behalf of all the Virgin Islander JP MC Ex at Case Document Filed Page of On ece mber Carole a pman the Executive A ss i a CEO of the USVI EDA ai ed Jennifer Nu gent Hill and Per cival Cloude the EDA that the CEO ha a ca ll fr th Firs ady and he as asked th at Epstein be on the oa rd agenda public hearin for the Janmuy th eet in Ceci de Jo estified at he ca lle the CEO of the EDA re ga rdin placing Ep tein is th oa age nda JPM Ex JPM at Governor Jo hn de Jo te tified at ass um ed th at Cecile de Jo tr ied to avo id hin gs co min overnor de Jongh des th at wo ul impact Ep ein JPMC Ex at ated August MASSEY GAIL LLP I Leonard A Gail Le ona rd A Gail pro ac vice Ra chel Morse pro ha i ce as Was hin on ti uit hi cago IL lgail asseyga il co 1m se asseyga il co Attorneys for JPMorgan Chase Bank NA es ect full ubmi ted WILMER CUTLER PICKERING HALE AND DORR LLP I Fel icia Ellsworth Feli cia Ell swo rth John Butt Andre a hlin State ti eet osto MA fe 1i cia.e ll sw01 th ilmerhale.com john butt ilmerhale.com andy ola hlin ilmerhale.com oyd Jo hn so I e1t oo Alan Sc oe fe ld Chri to pher oux World Tra de Ce er Greenwich ti 267eet New rk NY oyd.j hn so ilm rhal e.co Case Document Filed Page of ro boo i rh a co a a sc oe fe i rh a co hr istop i rh ale co Attorneys for JPMorgan Chase Bank NA
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