The USVI And Their Motion In Opposition To JP Morgan's Request For Dismissal (Part 4) (9/12/26)

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1:00At QVC, fall shopping is more than just checking out. It's discovering the brands you love across beauty, fashion, home, and culinary, all in one place. Whether you're getting ready for crisp mornings, cozy nights, or everyday moments, QVC has what you need for the season ahead, with brands like Lori Geller, Philosophy, Ninja, and so many more. Shop now at QVC.com. What's up everyone and welcome back to the Epstein Chronicles. In this episode, we're going to pick up where we left off with the USVI and their motion to deny the requested dismiss by JP Morgan. 4. JP Morgan knowingly benefited. JP Morgan argues that the government does not plausibly allege a casual relationship between JP Morgan's participation in Epstein's sex trafficking venture and its receipt of a benefit, again relying on Geiss.

2:00That is wrong. Geiss is not controlling. Other cases, including those relied on by JP Morgan, hold that the statutory language and poses no such casual relationship requirement, and requires only that the defendant knowingly benefit financially. HH versus G6, hospitality incorporated. 2. 19 CV 755 2019 WL 668 2152 at 2. Southern District of Ohio December 6, 2019. Alligation that rentals over room constitutes a financial benefit from a relationship with the trafficker is sufficient. There is no question JP Morgan received financial benefits in the form of servicing accounts with hundreds of millions of dollars in assets and referrals of business opportunities from its relationship with Epstein, including the acquisition of one of the country's largest hedge funds as a customer. If the government must allege a casual relationship, it has. Kanoza is again instructive.

3:02There the court found that complaint adequately pled a symbiotic relationship between the companies and Weinstein, in which the company is affirmatively enabled and concealed Weinstein's predations as a means of keeping him happy, productive and employable, which led the financial and other benefits for the company. 2019 WL 498865 at 24. So to hear the government alleges a long standing and close relationship between JP Morgan and Epstein, in which JP Morgan knowingly received value from Epstein's business, connections and referrals in exchange for JP Morgan's participation in his sex trafficking venture. 2. The government pleads actionable seco accounts. 2. A seco applies to JP Morgan's conduct. JP Morgan baselessly contends that its conduct occurred entirely in New York, motion at 15. JP Morgan's criminal activity under seco occurred almost entirely in the Virgin Islands. For two decades, JP Morgan transacted business with a Virgin Islands resident and his Virgin Islands entities, including managing accounts worth hundreds of millions of dollars, the principal business of which was trafficking, including in and from the Virgin Islands.

4:16JP Morgan processed, redacted payments to women and girls sex trafficked in the US Virgin Islands, who at knew maybe victims of human trafficking. JP Morgan, through Staley, engaged in multiple visits to Epstein's residence on Little St. James, where the sex trafficking took place as part of its management of its business relationship with Epstein. Far from acting for only wholly personal reasons, at the time of these visits, Staley was serving in the role of JP Morgan's senior executive and head of private bank, which was dedicated to extremely wealthy clients like Epstein. JP Morgan assigned Staley to manage Epstein and his accounts for his wealth, connections and referrals of ultra wealthy and powerful clients. Thus Staley's job was to maintain a close relationship with Epstein, so that his money, connections and referrals would continue to flow to JP Morgan. Staley emailed freely with Epstein about his visits to Little St. James over his work email account and full view of JP Morgan. JP Morgan's conduct threatened the public safety and caused serious harm to the Virgin Islands and its residents by facilitating sex trafficking and the commission of sexual abuse against young women and underage girls in the Virgin Islands.

5:27By sharp contrast, and American charities for reasonable fundraising regulation incorporated versus Panela County, which JP Morgan claims is analogous, motion at 15 and 16, there were no allegations that the plaintiffs purposefully direct their efforts to or specifically advise on solicitation aimed at Panela's County. B. The government pleads actionable seco claims, one, elements of a seco claim, a, association with and participation in the enterprise. JP Morgan argues that all the government pleads is that JP Morgan earn money by providing ordinary banking services to a client, which is insufficient to establish shared common purpose. This is incorrect. The government alleges that JP Morgan, rather than provide ordinary banking services, process Epstein's payments to recruiters and young women who were trafficked in the Virgin Islands and elsewhere, with knowledge that Epstein was procuring women to perform commercial sex acts. Staley has been indicted for and pled guilty solicitation of a minor for prostitution and was a criminal felon and registered sex offender, and was repeatedly under law enforcement investigations for associated with trackers.

6:39JP Morgan handled Epstein's payments even though they had no discernible business or other legitimate purpose and engaged in a year's long pattern of ignoring obvious red flags and failing to demonstrate even basic due diligence on Epstein's accounts, which is particularly out of the ordinary, conduct by JP Morgan for a customer, it designated high risk. Further, JP Morgan catapulted Staley's career based on Staley's profitable work with Epstein and directed Staley to manage JP Morgan's relationship with Epstein in the pursuit of more profits and referrals of business opportunities. Staley filled his end of the bargain, establishing a close relationship with Epstein. In 2009 and 2010, after Epstein pled guilty to conduct that his child sex trafficking under the TVPA, Staley's JP Morgan email account and full view of JP Morgan shows multiple emails with Epstein discussing visits to Epstein's residences, including in the Virgin Islands, women who they refer to by the names of Disney princesses, that Epstein procured for Staley, discussions of sex with young women and photos of young women in suggestive poses.

7:49In 2011, following additional news stories about Epstein's human trafficking, JP Morgan's investigation extraordinarily consisted of asking Staley to discuss those reports with Epstein. This unlawful conduct and furtherins of the trafficking enterprise on lawful purpose constitutes association with and participation in the enterprise by JP Morgan. CEG hand in versus Limer, 112 F dot 3D 1339 1350 8th Circuit 1997. The law firms assistance with sham transactions and false court filings and furtherins of appliance misuse of bankruptcy to shield enterprise assets, constitutes association and participation. Taylor versus Betis 976 F dot S U P P 2 D 721 735 EDN C 2013. If a doctor or lawyer provide services that go to the heart of the allegedly fraudulent scheme, the professional may be liable for providing some direction in the affairs of the enterprise.

8:51The government also sufficiently pleads participation. JP Morgan argues that providing banking services, even with knowledge of an underlying fraud, is not enough to establish participation, motion at 19. Here too, the government alleges more that JP Morgan provided banking services with knowledge of wrongdoing. It alleges that JP Morgan directly or indirectly participated in the wrongdoing by handling payments for Epstein's sex trafficking with no conceivable relationship to Epstein's stated business interests, having a close up view of Epstein's sex trafficking through Staley and also over JP Morgan email and redacted. In the face of evidence of a list at purpose, which allowed the ongoing trafficking. B pattern of criminal activity. JP Morgan argues that the government does not alleged conduct related to the enterprise affairs. To the contrary, the government alleges extensive conduct by JP Morgan associated with the trafficking enterprise. C Supra Section 11 B1.

9:53JP Morgan also argues that the government does not alleged conduct within the past five years because its termination of Epstein's accounts in 2013 effectively ended its conduct. It did not. The government alleges redacted that occurred through 2019 and which allowed Epstein's ongoing sex trafficking. This satisfies Siko's requirement of a pattern of criminal activity, an instance of which was within five years of the filing of the suit, and triggers equitable tolling of the statute of limitations under Virgin Islands law to predicate criminal activity. Under Siko, criminal activity includes conduct violating any federal criminal law, the violations of which is a felony. This includes the TVPA and the BSA. The government claims that JP Morgan violated the TVPA on the grounds discussed above. JP Morgan repeats by reference its arguments on the TVPA as grounds for dismissing the government's TVPA based Siko claim. Motion at 20.

10:53The government restates by reference its arguments on opposition. See Supra. I see on the BSA based Siko claims JP Morgan argues that the government does not adequately redacted. Profitfall is back and so are predictions. Trade yours on CalShi America's number one prediction market platform. Dallas is currently trading at 59% to beat New York, meaning $100 trade pays out $162 if they win. Deload CalShi use code heart to get $20 when you trade 20 KALSHI CalShi trade on anything 18 plus only restrictions and eligibility apply trading involves risk not available in all jurisdictions. Rises, values and markets may differ from those mentioned for more see CalShi.com slash regulatory. It's fall in Jeep country and during the driving to fall sales event get a great deal on four by fours that refuse to be contained like Jeep Wrangler. Confidence built into every drive with the most awarded SUV ever Jeep Grand Cherokee and freedom that can't be denied with the open air freedom in Jeep Gladiator.

11:54After 85 years it's no surprise that Jeep became America's SUV brand get a great deal during the Jeep driving to fall sales event. Jeep is one more awards over its lifetime than any other SUV brand. Jeep and the Jeep Grill or Registered trademarks of FCA US LLC. Profitfall is back and so are predictions. Trade yours on CalShi America's number one prediction market platform. Dallas is currently trading at 59% to beat New York, meaning $100 trade pays out $162 if they win. Deload CalShi use code heart to get $20 when you trade 20 KAL S H I CalShi trade on anything 18 plus only restrictions and eligibility apply trading involves risk not available in all jurisdictions. Rises, values and markets may differ from those mentioned for more see CalShi.com slash regulatory. Just the opposite JP Morgan's redacted Ratslip for US 510 US 135 138 1994 PSA's willfulness element requires knowledge of unlawfulness. JP Morgan argues that Epstein's July 2019 arrest on trafficking charges change the meaning of these earlier transactions. It did not.

13:00JP Morgan elsewhere argues that allegations are not enough. By the time Epstein was charged in 2019, he had already pled guilty to child sex offense a decade earlier and repeatedly alleged to be engaged in trafficking. The 2019 charges highlighted what JP Morgan already knew that the women receiving his payments through JP Morgan may be victims of human trafficking. The government sufficiently alleges a willful violation. See, the government has standing for its BSA-based secoclaim. JP Morgan argues that the government lacks standing for its BSA-based secoclaim because it does not alleg an injury fairly traceable to the BSA violation. This argument fails because the government plausibly alleges that JP Morgan's redacted, harmed the Virgin Islands and its residents by facilitating the continuation of Epstein's trafficking. Suspicious activity reporting is critical to the United States' ability to utilize financial information to combat criminal activity and ensures that the government act when alerted to potential illegal conduct.

14:06A key purpose of federal banking regulations is to give law enforcement real-time information so that I can act to deter violations of the law and protect public safety. In fact, the federal government did ultimately take action to bring Epstein's trafficking to a halt. 3. The government pleads a CFDBPA claim. The CFDBPA makes it unlawful for any person to engage in unfair methods of competition in the conduct of any trade or commerce. The government claims that JP Morgan engaged in unfair competition by facilitating and redacted Epstein's trafficking to gain referrals over the other banks. The government seeks civil penalties under 12A, VIC, and the prayer for relief. JP Morgan is wrong that this claim is barred by the Act 6-year Statue of Limitations, motion at 25. The Statue of Limitations under this chapter is governed by Title 5, Virgin Island Code 31, 3B. Section 31, 3B, does not apply to a government enforcement action for a penalty as here, but only to an action upon a liability created by statute.

15:16Other than a penalty of forfeiture, which this, of course, is not. Virgin Island Code 5, Section 31, 3B. In any event, JP Morgan's redacted continued into 2019. JP Morgan also incorrectly argues that the government pleads insufficient facts about the business, opportunities, and competitors at issue. The government identifies the business referral at issue, and alleges that compliant banks were unfairly denied the opportunity. Moreover, the Federal Trade Commission clarified in its recently issued policy statement regarding unfair methods of competition that it is not necessary to show actual anti-competitive effects, but rather that the challenge conduct negatively affects competitive conditions. See Federal Trade Commission policy statement regarding the scope of unfair methods of competition under Section 5 of the Federal Trade Commission. Conclusion. For all the reasons that for the above, the motion to dismiss should be denied. This was signed by Carol Jacobs, the Acting Attorney General, and it was signed on February 15, 2023.

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