The USVI And Their Motion In Opposition To JP Morgan's Request For Dismissal (Part 1) (9/11/26)

0:00What's up everyone and welcome back to the Epstein Chronicles. In this episode we're going to take a dive right back into the core documents and we're going to start taking a look at the government of the United States Virgin Islands and their memorandum of law in opposition to JP Morgan Chase and their motion to dismiss. Introduction for two decades defendant JP Morgan Chase Bank North America facilitated and sustained Jeffrey Epstein's sex trafficking by handling and redacted his payments to young women and girls who were his victims and recruiters. Sex trafficking was the principal business of Epstein's accounts held by JP Morgan and JP Morgan profited handsomely from the hundreds of millions of dollars in assets in those accounts. In addition to Epstein's connections and referrals of ultra wealthy and powerful clients, more from the so-called ordinary banking services JP Morgan claims that provided to Epstein, JP Morgan broke every rule to facilitate Epstein's sex trafficking and feed off his wealth

1:01and his connections. In 2008 after Epstein pled guilty to felony charges for procuring a child for prostitution, conduct that is child sex trafficking under the TVPA, the expectation was that JP Morgan would cut ties with or at a minimum, closely monitored the convicted felon and registered sex offender, it did neither. Instead and decided at the highest level pending diamond review, JP Morgan continued to facilitate and sustain Epstein's sex trafficking by making the payments and covering up the trafficking, including for many years after it no longer held Epstein's accounts, which predictably enabled ongoing and future trafficking by Epstein. JP Morgan, through its head of private bank, assigned to manage Epstein and Epstein's accounts, made multiple visits to Epstein's Virgin Islands residents where women and girls were a sex trafficked. Only when there was nothing left to be gained upon Epstein's arrest and death in federal prison in 2019, redacted. The government of the United States, Virgin Islands, brings this action as parents'

2:04patriarchal seeking relief for JP Morgan's participation in Epstein's sex trafficking that took place in and was directed from the Virgin Islands. Throughout the decades when JP Morgan handled the redacted Epstein payments to victims and recruiters, Epstein lived in the Virgin Islands on his secluded private island, Little St. James. The government asserts claims for JP Morgan's violations of the Trafficking Victims Protection Act, 18 U.S. Code Section 1580, 1597, the Virgin Islands criminally influenced and corrupt organizations act, CECO, Virgin Island Code 14, Section 600-614, and the Consumer Fraud and Deceptive Business Practices Act, CFDBPA. JP Morgan tries to shift the blame for its participation onto the government, contending that the government had access to the same information on Epstein that JP Morgan did. This belies both facts, ignoring the allegations detailing Epstein's redacted. The TVPA establishes liability for those who participate in human trafficking and JP Morgan's

3:07efforts at misdirection to not alter its legal responsibility for its own conduct and the profound consequences for the dozens of women who was trafficking was uniquely visible, two and made possible by his bank. Unlike the government, JP Morgan had real-time knowledge of millions of dollars of payments, Epstein was making to young women who were his victims and recruiters, which had no conceivable relationship to Epstein's stated business interests. JP Morgan had real-time knowledge that Epstein was using accounts of his charitable organizations to make payments to young women, which had no conceivable relationship to his charities, stated purposes. JP Morgan's Global Corporate Security Division, Risk Management Division, and AML Compliance Director over the course of years repeatedly identified evidence of Epstein's child-sex trafficking and human trafficking. JP Morgan identified, redacted. JP Morgan had more of an up-close and personal view of Epstein's sex trafficking through his senior executive JP Morgan assigned to manage Epstein and Epstein's accounts

4:09who, in his role, built a close relationship with Epstein, visited Epstein's properties in the Virgin Islands and elsewhere, exchanged hundreds of messages with Epstein from his JP Morgan email account, and full view of JP Morgan, including some with photos of young women, discussed Epstein's provision of services to him during his travel on dates that closely corresponded with Epstein's payments to the same young women from his JP Morgan accounts, and discussed young women or girls procured by Epstein using the names of Disney princesses, Snow White, and Beauty and the Beast. JP Morgan's felt attempt to divert attention from its participation in Epstein's sex trafficking is understandable, as its attempted defenses to the government's TVPA, Seaco, and CFDBPA claims have no merit. The Epstein's social background between 1998 and 2013, JP Morgan serviced approximately 55 Epstein related accounts valued in the hundreds of millions of dollars. During this time, JP Morgan handled payments by Epstein to at least 20 young women or

5:11girls whom he trafficked and subjected to sexual assault in the Virgin Islands and elsewhere. The payments had no conceivable relationship to Epstein's stated business interests. Epstein also withdrew hundreds of thousands of dollars in cash over that time from JP Morgan accounts, especially significant as Epstein was known to pay for massages, sexual encounters, with young girls in cash. During this time, JP Morgan also processed payments by Epstein totaling almost $1.5 million to known recruiters of victims of Epstein's sex trafficking enterprise, including the MC2 modeling agency. Among the recipients of these payments were numerous women with Eastern European surnames who were publicly and internally identified as Epstein recruiters and or victims, including $600,000 to Jane Doe 1, a woman who JP Morgan's own due diligence reports stated Epstein purchased at the age of 14. Throughout its relationship with Epstein, JP Morgan's internal investigation teams identified evidence that he was engaged in criminal sex trafficking.

6:14In 2006, JP Morgan's Global Corporate Security Division reported that Epstein was indicted in Florida for felony solicitation of minors for prostitution. In 2008, Epstein pled guilty in Florida to solicitation or procurement of a minor for prostitution and became a registered sex offender. JP Morgan's continued relationship with Epstein after his criminal plea was reviewed and approved at the highest levels of the bank. In August 2008, internal email states, I would count Epstein's assets as a probable outflow for 2008, 120 million or so, so I can't imagine it will stay pending Diamond's review. Yet the assets did stay. Next part redacted, in 2010, JP Morgan's Risk Management Division discussed new allegations of an investigation of Epstein involving child sex trafficking. Throughout 2010 and 2011, JP Morgan's Compliance and Security Divisions reported evidence of Epstein's engagement in sex trafficking, including his settlement of a dozen civil lawsuits

7:18and his payment of $1 million to the MC2 modeling agency engaged with Epstein in child sex trafficking, learned girls on the pretext of providing modeling opportunities and careers. JP Morgan, through senior executive Jess Staley, engaged in multiple visits to Epstein's on Little St. James, where the sex trafficking took place as part of its management of its business relationship with Epstein. At the time of these visits, Staley was serving in the role of JP Morgan's 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 to other ultra wealthy and powerful clients. 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. Between 2008 and 2012, Staley exchanged over 1,000 messages with Epstein from his JP Morgan email account and full view of JP Morgan, including emails about his visit to Little

8:20St. James. A December 2008 email shows Staley planning to visit Epstein in early January of 2009 around the time of Staley's scheduled visit, Epstein wired $2,000 from his JP Morgan account to a woman with an Eastern European surname. In late August 2009, Staley emailed that he was visiting London. Epstein asked if he needed anything. Staley replied, yep. Soon after JP Morgan wired $3,000 from an Epstein account to the same Eastern European woman, and then in July of 2010, Staley emailed Epstein saying that was fun. Say hi to Snow White. Which Epstein responded what character would you like next? And Staley said beauty in the beast. Epstein was also emailed Staley photos of young women in seductive poses. Following the internal reports of additional law enforcement investigations into Epstein's ex-trafficking in 2010 and 2011, JP Morgan's response was to send Staley in 2011 to obtain Epstein's denial on which the bank hung its head.

9:21JP Morgan was at all times required by the federal law to perform due diligence on its customers and file SARS with the Treasury Department's Financial Crimes Enforcement Network. While Epstein was a customer, redacted, or perform even basic due diligence on Epstein, even though he was iriske. During this time, JP Morgan benefited from Epstein's wealth and connections. Epstein helped and promised to help Staley recruit ultra-wealthy clients to JP Morgan. Epstein introduced Staley to the owner of Highbridge Capital Management, LLC, one of the country's largest hedge funds. JP Morgan subsequently acquired Highbridge, which catapulted Staley's career with and beyond JP Morgan. In 2011, Epstein helped Staley to pitch the creation of a donor-advised fund, which would be an exclusive club, with a minimum $100 million donation. Epstein continued trafficking and sexually abusing young women and female children until his arrest in 2019. It was only after Epstein's death in federal detention in August 2019, redacted that

10:26JP Morgan acknowledged that redacted, and JP Morgan's illegal conduct, which continued until 2019, caused repeated, and continuous harm to the Virgin Islands and its residents. Alright, we're going to wrap up right here, and in the next episode we're going to pick up with the argument. All of the information that goes with this episode can be found in the description box.