diff --git a/vision-fixhub/court-05/4eec8f8d7c23bb48f79b23e64acdb2a1e8ce08ac56c2ffbe83aa3f2cf78be9d8.md b/vision-fixhub/court-05/4eec8f8d7c23bb48f79b23e64acdb2a1e8ce08ac56c2ffbe83aa3f2cf78be9d8.md new file mode 100644 index 0000000000000000000000000000000000000000..05bfcf330c46eaa6bba90b3eb65c753f17ce27f1 --- /dev/null +++ b/vision-fixhub/court-05/4eec8f8d7c23bb48f79b23e64acdb2a1e8ce08ac56c2ffbe83aa3f2cf78be9d8.md @@ -0,0 +1,945 @@ +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 1 of 19 +ECONOMIC DEVELOPMENT COMMISSION +INDUSTRIAL PARK DEVELOPMENT CORPORATION +April 17, 2008 +Cecile DeJongh +Manager +Financial Trust Company, Inc. +6100 Red Hook Quarter B-3 +St. +VI 00802 +Dear Mrs. DeJongh: +A-compliance review has been completed on Financial Trust Company, Inc. +Enclosed for your review and commentary is a copy of the compliance report +whuch covers the period of April 1, 1999 to December 31, 2006. +Please respond to this compliance report within ten (10) working days from receipt +of this letter. If you have any questions concerning this matter, do not hesitate to +contact me at 774-8104, Ext. 236. +Sincerely, +Director of Compliance +Co: +E. Clouden, Chief Executive Officer +Jr., Assistant Chief Executive Officer +Francois Dominique, Director Application & Intake +Sandra Bess, Compliance Officer +A DIVISION OF THE ECONOMIC DEVELOPMENT AUTHORITY +P.O. Box 305038 • ST. +P. IN 3503 - 57, GRO, US. VIC ADS 008 (90 73-30 (40 73-8006 +TOLL FREE 1-877-432-8784 • www.usvieda.org +VI-JPM-000022897 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 2 of 19 +• UNITED STATES VIRGIN ISLANDS +COMPLIANCE REPORT +Financial Trust Company, Inc. +As of December 31, 2006 +SUMMARY HIGHLIGHT: +• Financial Trust Company, Inc. has enjoyed seven (7) years of tax benefits. +• Financial Trust Company, Inc. met and exceeded the capital investment of +US $300,000. +• Capital Expenditures from 1999 to 2006 were $570,067 of which 96% +($546,447) was procured locally. +• Goods and Services from 1999 to 2006 were $4,252,064 of which 77% was +procured locally. +• Financial Trust Company, Inc. met its employment requirement of 11 fulltime employees. +• Financial Trust Company, Inc. met its residency requirement. +• Financial Trust Company, Inc. met the 20% management, technical and +supervisory requirement. +• Financial Trust Company, Inc. met the requirements of Special Conditions +#1, #2, #3 and #5. +• Financial Trust Company, Inc. did not specifically meet the requirements of +Special Condition #4. +• Financial Trust Company, Inc. complied with the requirements of the +procurement process. +• Financial Trust Company, Inc. met the reporting requirements. +VI-JPM-000022898 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 3 of 19 +Hamed, +Inwestors Dream +Title 29, Chapter 12 VIC, Section 715(a) states in part "upon proper application or +reapplication, public hearing and in compliance with all other relevant provisions +of this chapter pertaining to the grant of initial benefits, as determined and required +by the Commission, ny recipient, neutral development benefits (sic), may bo +HISTORY: +Financial Trust Company, Inc. was granted tax exemption benefits to conduct the +business of financial and economic consulting, money management, investment +advisory and fiduciary services for its clients. Such clients will include individuals, +trusts, foundations and business entities. Benefits were granted for a period of ten +(10) years commencing and terminating as follows: +Commencement +Income Taxes +Gross Receipt Taxes +Excise Taxes (Raw Materials) +Excise Taxes (Equip., Mach.) +Dividend Withholdings +Interest Withholdings +Real Property Tax +April 1, 1999 +April 1, 1999 +January 1, 2000 +January 1, 2000 +April 1, 1999 +April 1, 1999 +January 1, 2000 +Termination +March 31, 2009 +March 31, 2009 +December 31, 2009 +December 31, 2009 +March 31, 2009 +March 31, 2009 +December 31, 2009 +On November 6, 1998, the corporation filed Articles of Incorporation with the +Office of the Lieutenant Governor. A Certificate of Incorporation, authorizing +them to conduct business in the Virgin Islands was issued on November 30, 1998. +Upon completing an application to the Economic Development Commission +(EDC) on February 22, 1999, the Beneficiary tax benefits were approved by the +Governor of the Virgin Islands on November 26, 1999. The certificate of benefits +was executed by the Chairman of the EDC Board of Commissioners on March 21, +2000. Financial Trust Company, Inc. has enjoyed seven (7) years of benefits. +Financial Trust Company, Inc. is solely owned by Mr. Jeffrey Epstein. +Page 2 +VI-JPM-000022899 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 4 of 19 +INVESTMENT: +Commencing no later than one (1) year from April 1, 1999, the Beneficiary shall +be required to invest no less than U.S. $300,000 excluding inventory, in +accordance with the EDC Rules and Regulations. +FINDINGS: +As of December 31, 1999, Financial Trust Company, Inc. met the investment +requirement of $300,000. During the period covered by this report the Beneficiary +made additional investments totaling $270,067. Financial Trust Company, Inc. +invested a total of $570,067 as of December 31, 2006. +CAPITAL EXPENDITURE: +Eligible +Supplier +150,539 +572 +YEAR +1999 +2000 +2001 +2002 +2003 +2004 +2005 +2006 +Grand Total +1,399 +152,510| +VI Supplier +326,226 +23,030 +1,599 +21,860 +12,906 +- +1,781 +6,535 +393,937 +Non-Vi +Supplier +14,220 +880 +505 +6,215 +744 +1,056 +23,620 | +Total +326,226 +187,789 +2.479 +22,937 +12,906 +6,215 +2,525 +8,990 +570,067| +FINDINGS: +From 1999 to 2006 a total of $570,067 was procured in capital expenditures. Of +the expenditures categorized; 69% ($393,937) were purchases from Virgin Islands +Suppliers, 27% ($152,510) were procured from Eligible Virgin Islands Suppliers +for Leasehold Improvements and Office Equipment and the remaining 4% +($23,620) from Non-Virgin Islands' suppliers for Office Equipment and Furniture +and Fixtures. +Page 3 +VI-JPM-000022900 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 5 of 19 +CAPITAL EXPENDITURES +1999 - 2006 +4% +27% +D Eligible Vi +Supplier +• V Supplier +• Non-Vi +Supplier +69% +GOODS AND SERVICES: +YEAR +1999 +2000 +2001 +2002 +2003 +2004 +2005 +2006 +Grand Total +Eligible VI +Supplier +281,142 +47,558 +47,635 +44,621 +78,551 +36,443 +45,799 +581,749| +Vl Supplier +30,338 +154,391 +170,589 +453,622 +415,191 +445,240 +435,554 +596.029 +2,700,954 +Non-Vi +Supplier +3,615 +52,735 +109,194 +238,419 +299,441 +166,863 +59590 +39,404 +969,361 +Total +33,953 +488,268 +327,441 +739,676 +759,253 +690,654 +531,587 +681,232 +4,252,064 +FINDINGS: +The total expended for goods and services from 1999 through 2006 was +64,252,064. Purchases from Virgin Islands suppliers totaled $2,700,954 (64%): +5969,361 (23%) was spent with Non-Virgin Islands' suppliers; and the remaining +$581,749 (14%) was procured from Eligible suppliers. +Page 4 +VI-JPM-000022901 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 6 of 19 +GOODS & SERVICES +1999 - 2005 +26% +15% +59% +• Eligible VI +Supplier +• Vi Supplier +Non-Vi +Supplier +LOCAL PROCUREMENT: +In accordance with Division 10 of the Economic Development Commission Rules +and Regulations, the beneficiary must comply with procurement procedures +(Section 708-701 to 708-718). +FINDINGS: +From 1999-2006, the beneficiary's total expenditures were $4,822,131. 64% +($3,094,891) of the purchases were made from Virgin Island Suppliers of which +the majority was spent on leasehold improvements, legal/accounting, and +charitable contributions. 21% ($992,981) were made from Non-Virgin Islands +Suppliers and the remaining 15% ($734,259) was purchased from Eligible Virgin +Islands Suppliers. +The non local expenditures totaling $992,981 comprised mainly of equipment, +furniture/fixtures, +market services and legal/accounting. A total of $767,057 +was procured for legal/accounting and +market services which are exempt +procurement in accordance with Section 708-704 (e) of the EDC Rules and +Regulation; $162,900 included purchases of insurance, travel, dues and +subscriptions, supplies and repairs and maintenance. The Beneficiary indicated that +these were aggregate purchases from 2000 to 2006 which included computer +supplies and CCH Tax guides. The remaining capital expenditure were non-local +Page 5 +VI-JPM-000022902 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 7 of 19 +purchases for office equipment and furniture and fixture totaling $22,564. Several +purchases were exempt in accordance with the EDC Rules and Regulations +(promulgated 1981), section 708-704 (b) and Section 708-705 (a). +In January 2000, after approval of benefits and prior to receipt of certificate, the +Beneficiary purchased furniture totaling $3,372 from Crate and Barrel, a non- +Virgin Islands supplier and in March 2000 a specialized computer in the amount of +$4,947 was purchased from Micro Computer. In accordance with the EDC Rules +and Regulations Section 708-707 (Rules promulgated 1981), the Beneficiary was +required to provide proof that solicited quotes were on a competitive basis. The +Beneficiary stated that these items were specific brands not available in the Virgin +Islands. +Total Procurement +1999 - 2005 +100% +80% +60% +40% +20% +0% +• Non-local +• VI +• Eligible VI +Suppliers +Cap Exp +22,564 +387,402 +151,111 +Goods & Svcs +929,957 +2,104,925 +535,950 +Page 6 +VI-JPM-000022903 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 8 of 19 +EMPLOYMENT: +The Beneficiary shall employ no later than one year from September 7, 1999 no +less than eleven (11) persons on a full-time basis who are residents of the Virgin +Islands as defined in Title 29, V.I. Code Section 703(e). +Also, in accordance with Section 710(a) Title 29, Chapter 12, VIC (Amended +1992), after the third year of operation, a beneficiary shall be required to have at +least 20% of its management, supervisory, and/or technical positions filled by +residents of the United States Virgin Islands unless granted a waiver by the +Commission. +§708-605 Full-Time Employment .......... +For the purposes of this division, +"full-time" employees or employment shall mean employment, on a permanent and +continuous basis, for thirty-two hours or more per week. +FINDINGS: +YEAR +1999 +2000 +2001 +2002 +2003 +2004 +2005 +2006 +TOTAL +1 +10 +11 +11 +11 +AVERAGE +FULL +TIME +1 +10 +11 +11 +11 +11 +== +AVERAGE +V.L. RES. +0 +10 +11 +11 +11 +12 +11 +11 +AVERAGE +AVERAGE +% V.L. Res. +0% +MGMT. +1/1 +100% +100% +6/6 +6/6 +100% +6/6 +100% +6/6 +100% +717 +100% +777 +100% +6/6 +20% +V.I. +MGMT +0% +100% +100% +100% +100% +100% +100% +100% +From September 6, 2000 to December 31, 2006 the average full-time employment +ranged from ten (10) to twelve (12) employees. The Beneficiary met the +requirement of eleven (11) full-time employees, and also met the 80% residency +requirement and the 20% management requirement for the period covered in this +report. +Page 7 +VI-JPM-000022904 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 9 of 19 +In the second quarter of 2004, Tequasi Hendricks a senior at the Eudora Kean High +School was hired as a part-time clerical employee. The Beneficiary stated Ms. +Hendricks walked into the office off the street, inquired about a job, filled an +application and was hired. They stated that Ms. Hendricks exhibited exceptional +work habits and was therefore hired as a full time Researcher/Bookkeeper after +graduating from high school in 2005. +SPECIAL CONDITIONS: +The following conditions shall apply: +1. The Beneficiary shall provide all employees with health care insurance, +funded by the Beneficiary +• From 2000 to 2001, the Beneficiary provided Health, Vision, Life +and Dental insurance to all full-time employees. Health and dental +coverage was also provided to employees' eligible dependents +through Canada Life Assurance. +• From 2002 to 2006, the Beneficiary provided Health, Dental and +The Benefician paid Ur of the in and ranic or any. +eligible employee except Tequasi Hendricks whom the Beneficiary +stated preferred to be covered by her mother's insurance. The +Beneficiary also paid 100% dental and health insurance coverage +• Canada Life Assurance and United HealthCare Insurance +Company are both registered with the Lieutenant Governor's +Office of Banking and Insurance. +Page 8 +VI-JPM-000022905 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 10 of 19 +2. The applicant shall provide all employees a qualified retirement plan funded +by the Beneficiary. +• In 2001, the Beneficiary provided all full-time employees a +SEP/SRA Plan with Merrill +as Custodian. From 2002 to +2006 the Beneficiary established an American Funds Savings +Incentive Match Plan for Employees ("SIMPLE") incorporated +with an Individual Retirement Agreement (IRA). The Simple IRA +is offered to all employees receiving at least $5,000 in +compensation. The Beneficiary makes a matching contributior +qual to 100% of elective deferrals up to a limit of 3% per calendal +year. It is noted that from 2000 to 2005 eight employees, and in +2006 nine employees, participated in the Simple IRA Plan +facilitated by the Beneficiary. +3. The applicant shall provide employee training and tuition reimbursement +program for eligible employees. +The Beneficiary provided documentation to show the training +provided to employees. +• In 2000 the Beneficiary provided in-house training on Power-point +to all staff and specialized training in Communication, Typing, +CPA Review and Finance to the accounting employees. +• Training in Conversation Power Video was provided in 2001 to all +staff. Computer classes were provided to the messenger/custodian, +Front Desk Seminar to the receptionist and CPA reviews and +books purchased for the accounting and research staff. +• The entire staff was provided Quick-books training in 2002 and the +accounting staff with CPE and CPA courses. +• In 2003 the entire staff attended three (3) different Skill-path +Seminars and one (1) course in CPE continuing education. +• In 2004, the Skill-path Seminars were provided to the receptionist, +accounting and research staff. Tax Seminars and CPA review +courses were provided. +Page 9 +VI-JPM-000022906 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 11 of 19 +• CPE Tax Seminars and classes with UVI Cell were offered in 2005 +to the accounting staff. +• In 2006, the Network Administrator was provided training with +Skill-path. The Controller attended two (2) courses in CPA +continuing education. The Bookkeeper registered for a one-day +course at the University of the Virgin Islands - Intro to Insurance +and Captive Management. And the Receptionist and Custodian / +Messenger attended a Conference on the Status of Women. +Additionally, the Beneficiary provided tuition reimbursement to! +]in 2002, Tequasi Hendricks in 2003 and Jermaine Ruan in 2005 +for classes taken at UVI. +4. The applicant shall make annual contributions of $50,000 or one percent +(1%) of gross receipts tax exemption value, whichever is greater, to be +distributed annually as follows: +(a) 50% to educational scholarships +(b) 25% for charity +(c) 25% for co-op marketing with EDC +However, after issuance of its certificate, applicant shall prepay the first five +(5) years of contribution fixed at $50,000, or the sum of $250,000, to be +distributed as follows: +(a) $187,500 to a tax-exempt entity from which annual distributions of +not less than $25,000 to educational scholarship and $12,500 to +charity shall be made, and +(b) $62,500 for co-op marketing with IDC +Page 10 +VI-JPM-000022907 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 12 of 19 +CERTIFICATE REQUIREMENT: +Gross +Year +Gross +Receipt +Receipt +Exemption +1% Gross +Receipt +Exemption +Value +After Certificate issued - five (5) years prepayment +Contribution +per EDC +Certificate +250,000 +50% to +Educational +Scholarships +125,000 +Tax Exempt Entity +25% +Charity +25% Co-op +Marketing +with EDC +62,500 +B2,500 +- +2000 +2001 +2002 +2003 +2004 +2005 +2006 +50,000 +50,000 +Total Contribution per EDC Certificate +350,000 +25,000 +25,000 +175,000 +12,500 +12.500 +87,500 +12,500 +12,500 +87,500 +The Beneficiary provided documentation for the period January 2000 to December +2006 showing total contributions of $1,762,465; $313,875 from Financial Trust +Co., Inc. and $1,448,590 from the J. Epstein Foundation; made to charities, +educational scholarships, educational symposiums (other) and Co-op Marketing to +the EDC. +Total +Contributions +J. Epstein +Foundation +Educational +Scholarships +Co-op +Charity +Marketing +with EDC +Other & +Educational +Symposiums +Ineligible +Contributions +Financial Trust +Co., Inc. +Certificate +Requirement +Variance +J. Epstein +Foundation +Over / Short +Contributions +313,875 +350,000 +(36,125) +1,448,590 +1,412,465 +187,500 +187,500 +21,625 +50,000 +(28,375) +649,431 +621,056 +11,053 +75,000 +25,000 +87,000 +(13,947) +(12,500) +434,497 +420,550 +(12,500). +4,397 +14,300 +4,397 +357,662 +362,059 +14,300 +7,000 +21,300 +Page 11 +VI-JPM-000022908 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 13 of 19 +In 2005 and 2006, Financial Trust Co. Inc. did not directly contribute total +requirement in charitable contributions in the area of educational scholarship and +charity. However, it is noted that additional contributions were made from the J. +Epstein Foundation. A total of $1,448,590 was reported, of which $1,261,000 was +over the requirement of $187,500 prepaid by Financial Trust Co., Inc. Mr. J. +Epstein, sole owner of Financial Trust Company Inc. personally funds the J. +Epstein Foundation. +In addition, the Beneficiary was initially notified that a contribution of $12,500 +was not due for the 2006 Co-op Marketing with EDC. However during this audit, +reconciliation of the Beneficiary's contribution account identified an error in +recording a duplicate payment. Adjustments were made and the Beneficiary was +notified of payment due and restitution to be made accordingly. +Following are actual contributions made by Financial Trust Co., Inc and the J. +Epstein Foundation: +ACTUAL CONTRIBUTIONS: FINANCIAL TRUST Co., INC. +Year +Total +Contributions +1. Epstein +Educationa +oundation +Scholarship +Charity +Other - +1. Epstel +Co-op +Marketing +with EDC +Ineligible +2000 +2001 +2002 +2003 +2004 +2005 +2006 +Totals +189,401 +80,920 +600 +1,313 +13,528 +18,081 +10,032 +313, 875 +187,5001 +1,150 +600 +551 +50 +17,620 +600 +: +- +62,500 +187,500 +1,110 +2,295 +21,625 +808 +7,000 +625 +870 +11,053 +5 +3,578 +46 +167 +4,397 +12,500 +75,000 +200 +150 +600 +500 +2,950 +3,800 +6,700 +14,300 +' S187,500 prepaid to the J. Epstein Foundation for 5 years (2000 - 2005) +Page 12 +VI-JPM-000022909 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 14 of 19 +Inwestors Dream +In 2000, the Beneficiary set up and made an initial payment of +$187,500 to a tax exempt entity; the J. Epstein Virgin Islands +Foundation, Inc. as requested in the EDC benefits certificate. The +Beneficiary also made an additional charitable contribution of $1,901. +In 2001, the Beneficiary made a total contribution of $80,920. +Educational Scholarship totaling $17,620 to the Ruby Rutnik +Scholarship Fund and Antilles School Inc. Contributions in the +amount of $600 was made to several charities and a contribution of +$50 was reported as other for personal contributions by Mr. J. Epstein. +And a payment of $62,500 was made to the EDC for Co-op +marketing. +In 2002, a total of $600 was contributed by the Beneficiary toward +educational scholarships. +In 2003, the Beneficiary contributed $808 primarily to educational +scholarships. +In 2004, the Beneficiary contributed a total of $13,528; $7,000 was +given to charities and $3,578 reported as other for personal +contributions made by J. Epstein. +In 2005, the Beneficiary contributed a total of $18,081; $1,110 made +to educational scholarships, a shortage of $23,890, $625 to charities, a +shortage of $11,875, and a payment of $12,500 to the EDC for Co-op +marketing. +In 2006, the Beneficiary contributed a total of $10,032; $2,295 given +for educational scholarships, a shortage of $22,705, 5870 to charities, +a shortage of $24,130 and $167 reported as other for personal +contributions by J. Epstein. +Page 13 +VI-JPM-000022910 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 15 of 19 +ACTUAL CONTRIBUTIONS: J. EPSTEIN FOUNDATION +Year +Total +Educational +Contribution Scholarships +Charity +Educational +Ineligible +Symposium +Contribution +2000 +2001 +2002 +2003 +2004 +2005 +2006 +Totals +38,000 +11,100° +281.477 +179,886 +263,976 +250,314 +423,837 +1,448,590 +25,000 +500 +120,281 +135,250 +162,610 +90,200 +115,590 +649,431 +13,000 +10,600 +90,100 +43,136 +95,866 +138,019 +43.776 +434,497 +71,096 +5,000 +20,595 +260,971 +357,662 +1,500 +500 +1,500 +3,500 +7,000 +The J. Epstein Foundation is a tax exempt entity established by Financial Trust, +Company Inc., the Beneficiary, primarily for making charitable contributions to the +Virgin Islands community. +In 2000, the J. Epstein Foundation received $187,500 from Financial +Trust Company, Inc. as required by the Beneficiary's certificate. The +J. Epstein Foundation made a contribution of $38,000; $25,000 to the +Community Foundation of the VI for educational scholarships and +$13,000 to charities such as the American Cancer Society, the St. +Croix Shriner's Club, Caribbean Light Lodge Scholarship Fund, +Beacon Schools and the United Way of St. +/ St. John and St. +Croix. The charitable contribution was $500 over the certificate's +commitment. +In 2001, the J. Epstein Foundation contributed $500 to educational +scholarships and $10,600 to charities. These charities included: +Antilles School, Inc., Charlotte Amalie High School PED, Women's +Business Center, the St. +Baseball Explorers and the St. +| Youth Soccer Association. These contributions were $26,400 +" Per benefits certificate: commitment was not made. +Page 14 +VI-JPM-000022911 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 16 of 19 +short of the certificate's commitment: $24,500 - educational +scholarships and $1,900 - charities. +In 2002, All Saints School, UVI/Tom Joyner Foundation, Inc. and +Antillies School received $120,281 toward educational scholarships. +A total of $90,100 was given as charitable contributions to: Antilles +School, Arts Alive, Beacon School, the Safety Zone, Elrod Hendricks +Little League +West and Zero Tolerance Inter-Neighborhood +Basketball. Additionally, a total of $71,096 was contributed to an +Educational Symposium on Artificial Intelligence. A member of the +Beneficiary's management staff stated that Mr. Epstein likes to enable +students of a community to become accessible to the world of science +and other topics. He therefore invited some famous scientists to the +Virgin Islands for a symposium. The symposium was advertised via +all the Virgin Islands newspapers and radio airwaves. An invitation +was also extended to public and private school students. These +contributions were $243,977 over the certificate's commitment. +In 2003, a total of $135,250 was made for educational scholarships to +All Saints Cathedral School, Antillies School, Ruby Rutnik +Scholarship Fund, Inc., Senator Carlton Dowe Summer Enrichment +Program and St. Mary's School. The Boys and Girls Club, Cheetahs +Track Club, Kidscope, Inc., St. +/ St. John Sickle Cell Disease +Association, We From Upstreet Inc., V.I. Montessori School and the +RLS Hospital Cancer Fund are some organizations which received +charitable contributions totaling $43,136. A contribution was also +made to the Auburn University for the Ed +_, Jr. Symposium. +is a Virgin Islands resident who has excelled in +academia. These contributions were $142,386 over the certificate's +commitment. +In 2004, the J. Epstein Foundation contributed a total of $162,610 in +educational scholarships to All Saints Cathedral School, Antilles +chool, the Community Foundation of the VI Inc. and the Rub +utnik Scholarship Fund. A total of $95,866 in charitabl +contributions were made to some charities which included; Dinn Brosay +Page 15 +VI-JPM-000022912 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 17 of 19 +f/b/o Yankees Pee Wee Team, Humane Society of St. +_ Ras +Tafari Improvement Association, Inc., the Virgin Islands Golf +Federation, Inc. and the Women's Coalition of St. Croix. A +contribution of $5,000 was made to an Educational Symposium. +These contributions were $226,476 over the certificate's commitment. +In 2005 contributions from the J. Epstein Foundation Fund to +Educational Scholarships totaled $90,200. These were given to All +Saints Cathedral School, Alpha Kappa Alpha Sorority, Inc., Antilles +School, Julius E. Sprauve, Miss. Virgin Islands Scholarship Fund and +the Ruby Rutnik Scholarship Fund, Inc. A total of $138,019 was given +to charities which included UVI Upward Bound Parent Association, +Caribbean Chorale, +Inc., BAPO Softball League and Catholic +Charities of the Virgin Islands. An additional contribution of $20,595 +was made to an Educational Symposium on Physics. +In 2006, the J. Epstein Foundation made charitable contributions +totaling $43,776 to The St. +Storm Baseball Club, the United +Way of St. +-St. John, the Community Foundation of the +Virgin Islands. Educational scholarships totaling $115,590 was given +to The Friends of the St. +Public Library, Miss. Virgin Islands +Scholarship, +All Saints Cathedral School, Antilles School and +Interscholastic Athletic Association. The J. Epstein Foundation hosted +the CERCA Physics Conference and contributed a total of $260,971. +It is noted that during the period covered in this report, Financial Trust Company, +Inc. ($7,000) and the J. Epstein Foundation ($14,300) made contributions totaling +$21,300 to organizations not qualified to receive tax-deductible contributions in +accordance with the Internal Revenue Service. These organizations include the St +-St. John Chamber of Commerce, the 2004 Congressional Campaign +Committee, People for Progress, the Governor's Special Events Fund and the +Dejongh Francis 2006 Transition. +Page 16 +VI-JPM-000022913 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 18 of 19 +5. The applicant shall utilize the services of resident licensed broker dealers +whenever possible, given market conditions. +• The Beneficiary provided documentation showing Seslia +Securities, a FINRA registered broker was utilized as a Broker of +Record for their Savings Incentive Match Plan. +REPORTING REQUIREMENTS: +IDC Annual Report: +Income Tax Return / +Audited Financial Statements +Lt. Governor's Annual Report: +VIESA Report: +Affidavit of IDC Beneficiary: +Publication Notices +Current +Current +Current +Current +Current +Current +FINANCIAL ANALYSIS REVIEW: +Cost Benefit Analysis reflects an approximate ratio of 1 to 21 for the years 1999 to +2006. This means that for every $1 given up in tax benefits $0.21 was spent in the +local economy which includes employee taxes paid, local wages, local taxes paid, +local procurement of goods and services and capital expenditures, a loss of $0.79. +This includes the value of tax exemptions on personal income tax of Mr. Jeffrey +Epstein, the sole owner of Financial Trust Company, Inc. +Page 17 +VI-JPM-000022914 + + +Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 19 of 19 +CONCLUSION +1. Met the investment requirement. +2. Met the full-time employment requirement. +3. Met the residency and management requirement. +4. Complied with the procurement requirements. +5. Complied with Special Condition #1 by providing Health, Life and Dental +Insurance funded by the Beneficiary. +6. Complied with Special Condition #2 by providing a qualified retirement +plan funded by the Beneficiary. +7. Complied with Special Condition #3 by providing training and tuition +reimbursement to eligible employees. +8. Did not specifically comply with Special Condition #4 - annual charitable +contributions in 2005 and 2006. There was a shortfall of $12,500 for Co-op +Marketing +with the EDC and $42,322 to charity and educational +scholarships. However, contributions made from the J. Epstein Foundation +for charity and educational scholarships exceeded the overall requirement. +9. Complied with Special Condition #5 by utilizing resident licensed broker +dealers. +10. Complied with the reporting requirements of the EDC. +Prepared by: Sandra Bess +Reviewed by: Margarita A. Greenidge | +April 14, 2008 +Page 18 +VI-JPM-000022915 \ No newline at end of file diff --git a/vision-fixhub/court-05/4eec8f8d7c23bb48f79b23e64acdb2a1e8ce08ac56c2ffbe83aa3f2cf78be9d8.receipt.json b/vision-fixhub/court-05/4eec8f8d7c23bb48f79b23e64acdb2a1e8ce08ac56c2ffbe83aa3f2cf78be9d8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fcc62c3053e8686893594a372c7b86790fb3395b --- /dev/null +++ b/vision-fixhub/court-05/4eec8f8d7c23bb48f79b23e64acdb2a1e8ce08ac56c2ffbe83aa3f2cf78be9d8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1804, + "dataset": "marble-joined", + "doc_id": "4eec8f8d7c23bb48f79b23e64acdb2a1e8ce08ac56c2ffbe83aa3f2cf78be9d8", + "engine": "marble-apple-vision", + "event_count": 21, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "e82b5d3738114557d71b75747328b1feec8b6d617cbb494e65a74854cdc4e127", + "output_sha256": "b71c079f9544ac074afe8392a318b85ea188a98ba16c9663af6852c81dba8fd8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/4f033f76824e1ae6de21ced660565803a9b798b45efc7ff906ef4afd9ecaf8eb.md b/vision-fixhub/court-05/4f033f76824e1ae6de21ced660565803a9b798b45efc7ff906ef4afd9ecaf8eb.md new file mode 100644 index 0000000000000000000000000000000000000000..e0d0f2b209838f4b33a4246b6f13f061cdbb39fb --- /dev/null +++ b/vision-fixhub/court-05/4f033f76824e1ae6de21ced660565803a9b798b45efc7ff906ef4afd9ecaf8eb.md @@ -0,0 +1,147 @@ +Case 1:22-cv-10904-JSR Document 113 Filed 04/06/23 Page 1 of 3 +BRENDAN V. +(202) 434-5800 +bsullivan@/wc.com +- JR. +LAW OFFICES +& CONNOLLY LP. +680 MAINE AVENUE SW +WASHINGTON, DC 20024 +(202) 434-5000 +WWW.wC.coM +April 6, 2023 +EDWARD BENNETT +1920-1988) +PAUL R. CONNOLLY (1922-1978) +Hon. Jed S. Rakoff +Via ECF +Re: +Third-Party Defendant James Staley's Motion to Sever and Reconsider +Dear Judge Rakoff: +Third-Party Defendant James Staley became a party to these cases less than a month ago. +The allegations against him are baseless but serious: Mr. Staley is accused of aiding and abetting +Jeffrey Epstein, one of the most notorious criminals in recent American history. As to potential +liability, Third-Party Plaintiff JPMorgan Chase Bank, N.A. seeks to hold Mr. Staley liable for the +entirety of any judgment entered in not one but two cases. It also seeks to disgorge several years +of compensation. All that is to say: the stakes could hardly be higher for Mr. Staley. Disproving +these false and highly-publicized allegations is of paramount importance to him. Yet this Court's +scheduling rulings have severely prejudiced his ability to do so. Despite the high stakes and the +massive volume of discovery, the Court entered a schedule that afforded Mr. Staley less than one +month to serve written discovery and roughly two and a half months to complete fact discovery. +By contrast, even though JPMorgan seeks to offload all liability onto Mr. Staley, it has been +afforded six months to complete fact discovery. +This breakneck pace is unnecessary and prejudicial to Mr. Staley. He therefore respectfully +requests that the Court grant two, independent forms of relief: first, the Court should sever the +third-party claims against Mr. Staley from the claims against JPMorgan and order that those sets +of claims be tried separately; second, the Court should reconsider its prior scheduling order and +(a) grant Mr. Staley the right to take 7-hour, in-person depositions of all witnesses; (b) set a May +8, 2023 deadline for Mr. Staley to respond to the third-party complaints; (c) vacate the current fact +discovery deadlines as to Mr. Staley; (d) set a new trial date in March 2024; and (e) order +JPMorgan and Mr. Staley to meet and confer on all other deadlines. +Background: On November 24, 2022, Jane Doe 1, on behalf of a purported class, filed a +complaint against JPMorgan, alleging that it was "the lifeblood for [Epstein's] sex-trafficking +venture." Compl. 9| 140. The Doe complaint alleges (without citation to any evidence) that Mr. +Staley, who was a high-ranking executive at the bank, knew that Mr. Epstein was engaged in sex +trafficking. The United States Virgin Islands then filed its own complaint, which also included +allegations about Mr. Staley. Those two cases were consolidated for discovery, and, pursuant to +the original Case Management Plan, the parties had to complete all fact discovery by April 24, +2023—a full five months after the Doe complaint was filed. Dkt. 16 (Doe case). The Court set +trial for September 5, 2023. + + +Case 1:22-cv-10904-JSR Document 113 Filed 04/06/23 Page 2 of 3 +& CONNOLLYu* +April 6, 2023 +Page 2 +On March 8, 2023, JPMorgan filed two third-party complaints against Mr. Staley. Those +complaints are largely based upon the plaintiffs' allegations and seek to hold Mr. Staley fully liable +for any judgment in both cases. The third-party complaints also seek repayment of all +compensation that JPMorgan paid to Mr. Staley from 2006 to 2013. Although the third-party +complaints are heavily based on the allegations by Doe and the USVI, JPMorgan does make +significant additional allegations against Mr. Staley. +On March 14, 2023, JPMorgan filed a standard waiver of service signed by undersigned +counsel, which stated that "I understand that I, or the entity I represent, must file and serve an +answer or a motion under Rule 12 within 60 days from 03/09/2023." Dkt. 64. Two days later, on +March 16, 2023, this Court held a scheduling conference to address how Mr. Staley's late addition +as a party would impact the case schedule. At the conference, undersigned counsel requested that +the Court set trial in March 2024 in light of the magnitude and gravity of the case. The Court +instead continued the trial for only six weeks, to October 23, 2023. During the conference, the +Court raised the fact that JPMorgan had filed a waiver of service, which provided Mr. Staley 60 +days to respond under Federal Rules of Civil Procedure 4(d)(3) and 12(a)(1)(A)(ii). The Court +encouraged JPMorgan to personally serve Mr. Staley, apparently expecting that personal service +would vitiate the waiver and trigger the 21-day response deadline under Rule 12(a)(1)(A)(i). +The parties then presented the Court with their positions on all interim deadlines via email. +As Exhibit A reflects, Mr. Staley proposed a standstill of all depositions until May 31, 2023, and +that fact discovery close on July 31, 2023. During an off-the-record argument regarding the +schedule, Mr. Staley's counsel explained, among other things, that Mr. Staley could not adequately +prepare a defense with any less time and that lead counsel for Mr. Staley has a federal criminal +trial beginning in late May 2023. The Court's scheduling order nonetheless set a May 30 deadline +for the close of fact discovery. Dkt. 74. The Court also required that Mr. Staley serve all +interrogatories and requests for admission by April 7—less than a month after he entered the case +and before any response to the complaint was due. Id. The Court further ordered that there would +be no standstill of depositions, ruling instead that Mr. Staley could re-depose any witnesses +deposed before April 24. The Court stated, however, that Mr. Staley's depositions would be +limited to two hours and had to be conducted telephonically. Id. Finally, the Court ordered Mr. +Staley to respond to the complaint by April 26 46 days from when he waived service. Id. +The discovery in this case—which JPMorgan did not begin sending until March 21—has +been voluminous. Mr. Staley has, to date, received well over 45,000 documents, spanning 240,000 +pages. We estimate that it would take over 900 hours of attorney time to review that volume +(assuming a 50 document per hour pace). It appears that JPMorgan and the other parties are +continuing to make rolling productions, meaning that the volume of documents will only continue +to grow. +Argument: As to the scheduling issue, a motion for reconsideration should be granted in +order to "prevent manifest injustice." Kolel Beth Yechiel Mechil of Tartikov v. YLL Irrevocable +Tr., 729 F.3d 99, 104 (2d Cir. 2013). As to the +issue, it is governed by Federal Rules of +Civil Procedure 14(a)(4) and 42(b) under which this Court has the discretion to sever third-party +claims and order that they be tried separately "IfJor convenience, to avoid prejudice, or to expedite +and economize." Fed. R. Civ. P. 42(b). Here, to prevent a manifest injustice and to avoid severely + + +Case 1:22-cv-10904-JSR Document 113 Filed 04/06/23 Page 3 of 3 +& CONNOLLYu* +April 6, 2023 +Page 3 +prejudicing Mr. Staley's defense, the Court should, for four reasons, grant the independent forms +relief mentioned above - modification of the schedule and +First, Mr. Staley is severely prejudiced by the schedule and cannot adequately prepare a +defense without reasonable time for discovery. His lead counsel has trial in May-meaning that +the current schedule effectively deprives Mr. Staley of his longtime lawyer and choice of counsel. +But even absent the trial conflict, the present schedule affords Mr. Staley grossly insufficient time +to mount a defense. The allegations against him are slanderous, and the potential damages are +astronomical. Given these stakes, he should, at the very least, be afforded the same rights as any +other litigant before this Court, including those in this case. This is all the more true given the +volume of discovery and the late date on which Mr. Staley started to receive it. But, despite +JPMorgan trying to stick Mr. Staley with all the liability, he has somehow ended up with less time +than any other party. JPMorgan has no answer to Mr. Staley's prejudice other than to state that he +received a deposition subpoena when a non-party. This isn't a serious argument: preparing for a +deposition as a non-party witness bears no relation to defending and trying an entire case. And, if +anything, it is the other parties who have an advantage due to their prior knowledge and possession +of documents: the USVI and counsel for Doe have been involved in Epstein-related litigation for +years, and JPMorgan possesses a library of relevant materials, which it presumably reviewed precomplaint, given that its relationship with Epstein has received such scrutiny. +Second, the current schedule deprives Mr. Staley of basic procedural rights. By allowing +Mr. Staley to re-depose witnesses whose depositions occur before April 24, the Court recognized +that Mr. Staley has a lot of catching up to do, given JPMorgan's several-month (at least) head start. +But the Court limited those depositions to just two hours and required that they be conducted +telephonically. Rule 30, however, provides that civil litigants have "1 day of 7 hours" to conduct +their examinations. Fed. R. Civ. P. 30(d)(1). The Rule also defaults to in-person depositions. Fed. +R. Civ. P. 30(b)(4). But Rule 30 is not the only Rule that has been modified for Mr. Staley. Both +Rule 4(d)(3) and Rule 12(a)(1)(A)(ii) provide that any defendant who timely returns a waiver of +service need not respond to any complaint until 60 days after the request was sent. That is exactly +what Mr. Staley did. And yet this Court shaved two weeks off Mr. Staley's response deadline. +Third, Mr. Staley's defenses raise different issues and require broader discovery than +JPMorgan's defenses. For example, Mr. Staley's defenses will require exploration of his +relationship with JPMorgan dating back to at least 2000—23 years ago—and extending well +beyond the time he left. Similarly, JPMorgan seeks damages that exceed what it may owe +plaintiffs, claiming, for example, losses from "adverse publicity" that would require document +discovery-even expert discovery—far beyond plaintiffs' case, Dkt. 59 9 64. It is impossible to +take the necessary discovery on such issues in a matter of 10 weeks. +Fourth, there would be no prejudice to any other party from severing the third-party claims. +The plaintiffs support [ +•. And JPMorgan should not be heard to complain given that it +has the most to gain from the prejudice to Mr. Staley. And even if there were some minor prejudice +to JPMorgan's witnesses from having to appear at two trials, that prejudice pales in comparison to +the prejudice that Mr. Staley would suffer if he were not granted additional time for fact discovery. +Respectfully submitted, +Is/ Brendan V.L +1. 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\"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "1b1a8b1629aa391b4e56522654f2c6901035ff793a793f6dd65d6d337073fa07", + "output_sha256": "fb9a0679b190dd93951720449f58edd1045d48e0544b395436edc51250ddc8e9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13.md b/vision-fixhub/court-05/4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13.md new file mode 100644 index 0000000000000000000000000000000000000000..63389685ea40e532febfce58e3970e6ef90fa0e0 --- /dev/null +++ b/vision-fixhub/court-05/4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13.md @@ -0,0 +1,36 @@ +Case 1:22-cV-10904-JSR Document 263-54 Filed 08/07/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 263-54 Filed 08/07/23 Page 2 of 2 +From: +Sent: +To: +Viani, Lisa X [/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=LISA.VIANI] +1/13/2011 4:26:12 PM +1. Магу C | +]; Morris, Paul V [paul.v.morris@jpmorgan.com] +Subject: +Location: +Start: +1/14/2011 2:30:00 PM +End: +1/14/2011 2:45:00 PM +Show Time As: Tentative +William Langford, Jes Staley & Catherine Keating RE: Jeffrey Epstein +Dial-in: 866-446-5908 / Participant passcode: 51690015 +Required +Attendees: +Optional +Attendees: +Langford, William D; Staley, Jes; +Mary C; Morris, Paul V +Cutler, Stephen M +When: Friday, January 14, 2011 9:30 AM-9:45 AM (GMT-05:00) Eastern Time (US & Canada). +Where: Dial-in: 866-446-5908 / Participant passcode: + +Note: The GMT offset above does not reflect daylight saving time adjustments. +***$*~***** +Mary L +and Paul Morris will join the call in Catherine's office. diff --git a/vision-fixhub/court-05/4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13.receipt.json b/vision-fixhub/court-05/4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e41cd905cf625306f9058fa4ee14f1a46919ab2b --- /dev/null +++ b/vision-fixhub/court-05/4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -43, + "dataset": "marble-joined", + "doc_id": "4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "c37b9c5562f54cde5692abbff4e86f37664872671da0d5fe92fee23c1c9a5efd", + "output_sha256": "8f1c84ef58a0511e1ec0d64908c52a22ff276ca1d54b177046ed76b210fecf6d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c.md b/vision-fixhub/court-05/4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c.md new file mode 100644 index 0000000000000000000000000000000000000000..2301269ea9507842b3f69235993da3683d4f4d2b --- /dev/null +++ b/vision-fixhub/court-05/4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 267-52 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c.receipt.json b/vision-fixhub/court-05/4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..83fa6110062636ea234d92476f33dd0c90d33230 --- /dev/null +++ b/vision-fixhub/court-05/4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "01568ec64e949d19ffdea89257b9ef620b04afc9ee0e73c45b99fb56bc61ee18", + "output_sha256": "c356633d1ceb924629e53a88a6e0a2ac7fd653bd702add270ccbc03523bc7e34", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21.md b/vision-fixhub/court-05/4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21.md new file mode 100644 index 0000000000000000000000000000000000000000..c963857c3849982cc843e79c78faf558000d4f0e --- /dev/null +++ b/vision-fixhub/court-05/4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 239-13 Filed 07/25/23 +_Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21.receipt.json b/vision-fixhub/court-05/4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c47f79a7709b9ac95abdf4878757250bb66ac9af --- /dev/null +++ b/vision-fixhub/court-05/4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "6404c439215a047c47a8fd6d90af887e330338d622222591acad2ca26be44551", + "output_sha256": "9ee478821b59559a53fd8085fa269aa65d03fbdd708445f84b533837fbe81971", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351.md b/vision-fixhub/court-05/4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351.md new file mode 100644 index 0000000000000000000000000000000000000000..1af539f8722691d60373e0535ce8d5ba6e48410c --- /dev/null +++ b/vision-fixhub/court-05/4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 311-60 Filed 08/25/23 + + +Filed Under Seal diff --git a/vision-fixhub/court-05/4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351.receipt.json b/vision-fixhub/court-05/4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d2520b8e3eebc7acd9d17a0bb45b2ef09c91582f --- /dev/null +++ b/vision-fixhub/court-05/4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "e4d05a8fa3587512210491a1efb71188fac197ad9bcf1675292f87aaaf77de3f", + "output_sha256": "b706961551e7e1e126ee7ca0f0ee8d910193e06b888765c6d730e28ec6f8a7cf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527.md b/vision-fixhub/court-05/4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527.md new file mode 100644 index 0000000000000000000000000000000000000000..f7019b26dc45b4d958f25820b81ed301d90fd87e --- /dev/null +++ b/vision-fixhub/court-05/4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527.md @@ -0,0 +1,106 @@ +Case 1:22-cV-10904-JSR Document 243-29 Filed 07/25/23 Page 1 of 4 +TO: Jeffrey Epstein +FROM: Noah Greenhill +TEL: +DATE: 1/3/10 +FACSIMILE COVER SHEET +FAX NUMBER: 212-517-7779 +FAX NUMBER: +#PAGES (incl. cover): 5 +100 •d + +€t:€I 0łoZ-€0-83J +ESTATE_JPM010125 + + +Case 1:22-CV-10904-JSR Document 243-29 Filed 07/25/23 + +AFFIDAVIT OF GLENN DUBIN +) +) ss.: +STATE OF NEW YORK +COUNTY OF NEW YORK +Glenn 1 +being duly swor, deposes and says: +1. +I am over (wenty-one years of age and am competeat to testify to the matters +stated in this affidavit. I have personal knowledge of the facts and statements herein. +Each of the facts and statements herein is truc and correct. +2. +Starting in 2002, an cntity that I both owned and controlled, currently known as +& Swieca Asset Management, LLC ("DSAM"), owned interests in the general +partner and in the investment manager of D.B. Zwirn Special Opportunitics Fund, L.P. +(thc "Zwim Fund"). The Zwirn Fund was named after Daniel Zwim ("Zwim"). While +Zwim was responsible for the day-to-day management and opcrations of the Zwim Fund, +after Zwim spun off his business from DSAM (then known as Highbridge Capital +Management, LLC), I helped introduce investors to Zwim, invested my personal and +family foundation assets with Zwim, and my firm allocated assets of Highbridge Capital +Corporation ("HCC") to an account managed by Zwim's company which was also the +investment manager of the Zwim Fund. +One of the early investors that I introduced to Zwim was Jeffrcy Epstein +("Epstein"). Epstein was both a personal friend of mine and a long-time investor in +HCC. My understanding is that beginning in 2002 Epstein invested assets in the Zwim +Fund through an cntity called Financial Trust Company, Inc. +200'd + +EV: ET 0102-60-931 +ESTATE_JPM010126 + + +Case 1:22-cv-10904-JSR Document 243-29 Filed 07/25/23 + +4. In the fall of 2006, Zwirn called me and told me that he was firing the Zwirn +Fund's Chief Financial Officer. Zwim told me that there had been various irregularities +at the Zwirn Fund, including that investors" moncy was usc to pay for an airplane that +would be owned by Zwim's company. +During October 2006, Zwirn told me that he was making attempts to contact each +investor in the Zwirn Fund, including Epstein, to explain the inegularities to them. +6. After speaking with Zwirn, Epstein called me very upsel. Epstein said that Zwirn +had initially described the irregularities as "nonmaterial", but on a subsequent call, +Zwira's description of the issues made it clear to Epstein that the problems were in fact +very material. Epstein told me that when he confronted Zwirn about the earlier +description of the irregularties, Zwim said that his counsel had told Zwirn to use the word +"non-material". Epstein felt that Zwin had lied to him. Epstein told me thal he wanted +to redeems Financial Trust Company, Inc.'s entire capital account in the Zwirn Fund +immediately and that Epstein had made that demand to Zwin. +7. +I subscquently spoke to Zwirn about Epstein's demand. Zwim was concerned +thal a complete redemption could cause a "run-on-the-bank." Zwim asked me to discuss +with Epsicia roducing his demand to onc-half of Financial Trust Company, Inc. 's total +capital accout in the Zwim Fund at the time, and I agreed I would discuss it with +Epstcin. +8. +Subscquently, I participated in a three-way call with both Zwim and Epstein. +During this call, Epstein demanded from Zwim the withdrawal of all of Financial Trust +800 d + +0: 0102-0220 +ESTATE_JPM010127 + + +Case 1:22-cV-10904-JSR Document 243-29 Filed 07/25/23 Page 4 of 4 +Company, Inc.'s capital account in the Zwirn Fund. Epsicin said he wanted to redeem all +of Financial Trust Company, Inc.'s 140 plus million dollars in that capital account +immediately. Zwim responded that such a redemption could cause a "run-on-the-bank" +and asked Epstein lo Icduce his redemption demand to half of that amount. Zwim said +that if Epstein made only a partial redemption request, Zwirn would honor the request +quickly. During this discussion with Epstein, Epstein agreed to redcom slightly more +than half of Financial Trust Company, Inc.'s total capital account and said thal Financial +Trust Company, Inc. would redcem 80 million dollars, and Zwim agreed to honor that +request. Zwim did not dispute that Epstein had the right to the total redemption of +Financial Trust Company, Inc.'s capital account in the Zwim Fund. It is my +understanding, +based on subsequent conversations with Epstein, that after this +conversation, Epstein made a written request for that partial redemption of Financial +Trust Company, Inc.'s capital account in the Zwirn Fund and that Zwim refused to honor +this request. +Swom to before me this J +day of February, 2010. +-(Scall: +Notury Public +Tinath, Damally +State & New York +* New York +Ma Camillion Capita: 6/8/2013 + +ESTATE_JPMO10128 diff --git a/vision-fixhub/court-05/4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527.receipt.json b/vision-fixhub/court-05/4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f593123f6dc3ff09f129b4d86043f1818df208a3 --- /dev/null +++ b/vision-fixhub/court-05/4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -118, + "dataset": "marble-joined", + "doc_id": "4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "fa8e5d36f33a605d50c93850b0b25ce050551466f731313379350e03732ea484", + "output_sha256": "a604024d99de447a0a3ec028b9a7714fe7cf9b710eaa903bde81aa408c4f9195", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5.md b/vision-fixhub/court-05/4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5.md new file mode 100644 index 0000000000000000000000000000000000000000..881262b196f4da123990cbaefea36d7ca612b25a --- /dev/null +++ b/vision-fixhub/court-05/4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5.md @@ -0,0 +1,35 @@ +Case 1:22-cV-10904-JSR Document 326-88 Filed 09/08/23 Page 1 of 2 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-88 Filed 09/08/23 Page 2 of 2 +Staley, Jes +"jeevacation@gmail.com sjeevacation@gmail.com> +1/19/2011 3:00:30 AM +Fw: Cookie Checking In... +:) +From: +To: Staley, Jes +Sent: Tue Jan 18 21:51:59 2011 +Subject: Fw: Cookie Checking In... +Huh? +From: Cookie Neil +Date: Tue, 18 Jan 2011 20:33:13 -0500 +To: +Subject: Cookie Checking In... +Hi +Spoke with Jim today and he mentioned that the the GRE score is what it is - not to worry - the score does not seem to be a +problem according to my sources... +What's going on with your applications? Have you heard back from anyone? Any thoughts or is Columbia still high on your +list? +Look forward to hearing from you! +Best, +Cookie +Cookie Neil | Director for Science Development | Columbia University +Columbia Alumni Center | 622 West 113th Street, New York, NY 10025 + +JPM-SDNYLIT-00012289 \ No newline at end of file diff --git a/vision-fixhub/court-05/4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5.receipt.json b/vision-fixhub/court-05/4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8e12c19c60d30be2ef80dc3946e00396e60e86f5 --- /dev/null +++ b/vision-fixhub/court-05/4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "35122c3cb4c6a9b8dcb7eea6b53c01efeaf26c2297f9f27dea2ed9773513c1a3", + "output_sha256": "55ea534bdc5aae8e014c3f3821d319f145476dd49028efb2e67da61caab5051d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21.md b/vision-fixhub/court-05/4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21.md new file mode 100644 index 0000000000000000000000000000000000000000..23e3b7541cc086abb5db4a56004107ac913b81e6 --- /dev/null +++ b/vision-fixhub/court-05/4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21.md @@ -0,0 +1,161 @@ +Case 1:19-cr-00830-AT Document 56 +Filed 05/25/20 SDe ageNAof 5 +DOCUMENT +ELECTRONICALLY FILED +DOC #: +DATE FILED:_ 5/25/2021 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +United States of America +V. +Deferred Prosecution Agreement +19 Cr. 830 (AT) +Michael +Defendant. +TO: MICHAEL +On November 19, 2019, a grand jury sitting in this District returned a six-count indictment +(the "Indictment"), which charged Michael | +("'you") with committing offenses against the +United States, to wit, conspiring to knowingly defraud the United States and to knowingly make +and use a false writing or document, in violation of 18 U.S.C. § 371, and three counts of knowingly +making and using a false writing or document, in violation of 18 U.S.C. § 1001. However, after a +thorough investigation, and based on the facts of this case and your personal circumstances, the +U.S. Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined +that the interests of justice will best be served by deferring prosecution in this District. Upon your +acceptance of responsibility for your behavior and by your signature on this deferred prosecution +agreement (the "Agreement"), prosecution will be deferred during the term of your behavior and +satisfactory compliance with the terms of this Agreement for the period of six months from the +date of this Agreement. +The terms and conditions constituting your good behavior and satisfactory compliance are +as follows: +(1) You shall refrain from violating any federal, state, or local law. You shall immediately +contact your U.S. Pretrial Services Officer if arrested or questioned by a lawenforcement officer. +(2) You shall associate only with law-abiding persons. +(3) You shall work regularly at a lawful occupation, regularly attend school, and/or support +or care for your legal dependents, if any, to the best of your ability, as approved by your +J.S. Pretrial Services Officer. You shall notify your supervising U.S. Pretrial Services +Officer prior to any work or school changes. +(4) +You shall not leave the contiguous United States without permission of your +- 1 - + + +Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 2 of 5 +(5) +You shall notify your supervising U.S. Pretrial Services Officer immediately of any +change in your place of residence. +(6) You shall follow your supervising U.S. Pretrial Services Officer's instructions and +advice. +(7) You shall report to your supervising U.S. Pretrial Services Officer as directed. +As a further condition you hereby consent to disclosure, by any federal, state, or local +government agency, or by any medical or substance abuse treatment provider, to the U.S. Pretrial +Services Officer supervising your case, of such medical and treatment records as may be requested +by the Pretrial Services Officer to evaluate deferral of prosecution in this case. You further agree +that you will execute any additional consent forms that any such agency or provider may require +to release such information. +Special conditions are as follows: +You shall truthfully and completely disclose all information with respect to the activities +of yourself and others related to your employment by the Bureau of Prisons ("BOP"), which +information can be used for any purpose. You shall agree to meet with and be interviewed by the +USAO-SDNY, the Federal Bureau of Investigation, the Department of Justice, Office of the +Inspector General ("DOJ-OIG"), and any other law enforcement agency designated by this Office. +You shall complete 100 documented hours of community service, preferably related to the +criminal justice system, including working with recently released inmates. The specific type of +community service to be performed must be approved by your Pretrial Services Officer. +The USAO-SDNY may at any time revoke or modify any condition of this provisional +release or change the period of such supervision, which shall in no case exceed six months. The +USAO-SDNY may discharge you from supervision at any time. The USAO-SDNY may at any +time proceed with the prosecution for this offense should the USAO-SDNY, in its sole discretion, +deem such action advisable. +If upon completion of your supervision a written report from your supervising U.S. Pretrial +Services Officer is received to the effect that you have complied with all the rules, regulations and +conditions and special conditions applicable to your deferred prosecution, no further prosecution +will be instituted in this District for the above offenses. +Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from +taking any administrative action against you, including suspension or termination of employment, +based on the facts alleged in the Indictment, the facts identified in the course of the investigation +that led to the Indictment, or your own statements to the DOJ-OIG or any other law enforcement +entity. Nothing in this Agreement shall be interpreted to require the BOP or the DOJ-OIG to delay +- 2- + + +8969ł2 +Case 1:19-cr-00830-AT | +Document 56 Filed 05/25/21 + +any administrative action until after the expiration of the period of deferment contemplated by this +Agreement. You agree that a copy of this Agreement, including your admission and acceptance +of responsibility, shall be provided to the BOP. +If you successfully complete the term of supervision and fulfills all the terms and +conditions of this Agreement, the Government will move the Court to dismiss the Indictment as to +the defendant. +It is further understood that this Agreement and the terms and conditions set forth herein +are limited to the facts and circumstances of this case and lack precedential value. +Dated: New York, New York +May 20, 2021 +AUDREY STRUASS +United States Attorney for the +Southern District of New York +Jessea Lmergan +Nicolas Roos +Jessica Lonergan +Assistant United States Attorneys +Tel.: 212-637-2421 / 1038 +- 3- + +Case 1:19-cr-00830-AT Document 56 +Filed 05/25/21 Page 4 of 5 +The undersigned hereby consents to the foregoing. The undersigned hereby further admits +that he willfully and knowingly completed materially false count and round slips regarding +required counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center +("MCC") on August 9, 2019 and August 10, 2019. The undersigned expressly waives any and all +rights to a speedy trial pursuant to the Sixth Amendment to the United States Constitution, the +Speedy Trial Act, §§ 3161 et seq., and any other pertinent provisions, and consents to the +adjournment of all pending proceedings in this case. The undersigned further waives the +applicable statute of limitations with respect to any prosecution that is not time-barred on the date +that this agreement is signed. It is the intent of this provision to toll the applicable statute of +limitations during the pendency of the deferred prosecution. +The undersigned understands that pursuant to Title 18, United States Code, Section +3161(h)(2), this Agreement is subject to approval by the Court. Should the Court refuse to +approve, and thereby reject, this Agreement, neither party shall be bound to any term of this +Agreement, and no admissions in this Agreement may be used against the undersigned. +Finally, the undersigned acknowledges that he has read this Agreement and has carefully +reviewed each provision with his attorney. The undersigned and his attorney acknowledge that no +threats, promises, or representations have been made, nor agreements reached, other than those set +forth in this Agreement. The undersigned further acknowledges that he understands and +voluntarily accepts each and every term and condition of this Agreement. +Dated: New York, New York +May 20_, 2021 +Montell Hagins +Montell Figgins (May 20, 2021 15:49 EDT) +Montell Figgins, Esq. +Attorney for Defendant +Mchal theme +(May 20, 2021 16:04 EDT) +Michael +Michael +Defendant +-4- + + +Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 5 of 5 +Pursuant to 18 U.S.C. §3161(b)(2), exclusion under the Speedy Trial Act of the period of +time during which the prosecution of the defendant is deferred pursuant to this Agreement is +hereby approved. +Dated: New York, New York +May_25, 2021 +Honorable Analisa Torres +United States District Judge +The undersigned hereby consents to the foregoing and will accept supervision of the +above-named defendant on the conditions set forth herein. +Dated: New York, New York +May _ +→ 2021 +Francesca +Digitally signed by +Piperato +Francesca Piperato +Date: 2021.05.24 10:32:36 +-04:00 +United States Pretrial Services Officer +- 5 - diff --git a/vision-fixhub/court-05/4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21.receipt.json b/vision-fixhub/court-05/4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8c8dbcbdf88e9880062b261416f2077d3d34c4ef --- /dev/null +++ b/vision-fixhub/court-05/4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -61, + "dataset": "marble-joined", + "doc_id": "4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "94014da1d30c3251345a333880435cabaa86c110983b10d90d668818953c4283", + "output_sha256": "fdab514c9c68972100b209c0592b947affea11004c11f194abe83d4e14b49a03", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971.md b/vision-fixhub/court-05/500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971.md new file mode 100644 index 0000000000000000000000000000000000000000..4e13b305b50636d546dbdda699188aa05a61ac62 --- /dev/null +++ b/vision-fixhub/court-05/500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971.md @@ -0,0 +1,46 @@ +Case 1:22-cV-10904-JSR Document 240-21 Filed 07/25/23 Page 1 of 3 + + + +Case 1:22-cV-10904-JSR Document 240-21 Filed 07/25/23 Page 2 of 3 +From: +Sent: +To: +Subject: +Attachments: +Ryan, Maryanne X [maryanne.x.ryan@jpmchase.com] +3/12/2013 1:41:47 PM +DeLuca, Phillip A [phillip.a.deluca@jpmchase.com] +FW: High Profile +Rapid Response Team - Jeffrey Espstein 3r Mtg - Jan 2010-doc.zip; +Here you go. I am working from home as I still feel lousy. Head cold that won't go away. +From: Ryan, Maryanne X +Sent: Tuesday, February 19, 2013 4:44 PM +To: DeLuca, Phillip A +Subject: High Profile +Here are the ones that | think should be closed, where the LOB has disagreed and signed off to keep. +DeLuca Deposition + +22 +334640-CAK +04/19/2023 +PB customer Jeffrey Edward Epstein is an American financier and science and education philanthropist, who is convicted sex offender. On multiple +occasions this relationship has been escalated and approved to remain, including by Steve Cutler. (Rapid Response Doc attached) +Redacted - Privileged + +JPM-SDNYLIT-00194272 + + +Case 1:22-CV-10904-JSR Document 240-21 Filed 07/25/23 Page 3 of 3 +to keep open that I think we would like to exit, +Redacted - Privileged +Maryanne Ryan +Legal and Compliance +AML Investigations +VP, Compliance Director +194 +Ave South +Iselin, NJ 08830 +Phone 732-452-8071 + +JPM-SDNYLIT-00194273 diff --git a/vision-fixhub/court-05/500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971.receipt.json b/vision-fixhub/court-05/500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9b59f2c963cd0edc2b8131d30c3258bf97db07f3 --- /dev/null +++ b/vision-fixhub/court-05/500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -78, + "dataset": "marble-joined", + "doc_id": "500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "6c771def5f16385090bb57d4c5f3537e396ae629b69e7d21d3ef8e2a3cf2bfec", + "output_sha256": "df9ba6383857b28a20eb81e6d4568051399f714f2a3c9ed6d2bcbe1cbaa101f8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c.md b/vision-fixhub/court-05/5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c.md new file mode 100644 index 0000000000000000000000000000000000000000..d99c2119049e078849c8a4e005fa0581a42dda12 --- /dev/null +++ b/vision-fixhub/court-05/5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c.md @@ -0,0 +1,21 @@ +Case 1:22-cv-10904-JSR Document 287-3 Filed 08/18/23 Page 1 of 1 +Supreme Court of Maryland +Annapolis, MD +CERTIFICATE OF GOOD STANDING +STATE OF MARYLAND, ss: +1, Gregory Hilton, Clerk of the Supreme Court of Maryland, do hereby +certify that on the twenty-second day of March, 2012, +John Marcus McNichols +having first taken and subscribed the oath prescribed by the Constitution and Laws +of this State, was admitted as an attorney of said Court, is now in good standing, +and as such is entitled to practice law in any of the Courts of said State, subject to +the Rules of Court. This certificate of good standing is valid through the +thirteenth day of October, 2023. +ESPREME COURT +OF MARYLAND +In Testimony Whereof, I have hereunto +set my hand as Clerk, and affixed the Seal +of the Supreme Court of Maryland, this +fourteenth day of August, 2023. +Lages dillon +Clerk of the Supreme Court of Maryland diff --git a/vision-fixhub/court-05/5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c.receipt.json b/vision-fixhub/court-05/5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a124190f82c30dcd42b227660a68114422877aaa --- /dev/null +++ b/vision-fixhub/court-05/5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "fbc7ca790fcb075a7471e4db9399a51f891819644a192ccea6ccab990dc32daa", + "output_sha256": "d758efd355d3357387296b9e8833ecffd08a64522cb43d3407a4a2995ba1c51e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279.md b/vision-fixhub/court-05/503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279.md new file mode 100644 index 0000000000000000000000000000000000000000..f0dab74c3263a84a2836000b680005f830e914ec --- /dev/null +++ b/vision-fixhub/court-05/503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279.md @@ -0,0 +1,311 @@ +Case 1:22-cV-10904-JSR Document 194-21 Filed 06/20/23 Page 1 of 5 + + + +Case 1:22-cv-10904-JSR Document 194-21 Filed 06/20/23 + +VI-JPM-000007663 +Company Hame: Southern Trust Cempany Ins +Gross Necessa of Sales +Other Anoms +Enterest Income +Devadeed Incons +Rental Incons +Gross Waact Paid in the Vi Conclude sagain, sha car +Average No of Empleases Fell Time +Averses No, ef Emplosees, (Part Time Cuber) +Averane No of Residents, Fell Time +Antone No ef Readers Per Time Ober +Asemes No ef Nes Reudess Full Tre +Attle No. of Non-Reseats, Part Time Other +Other Empires Cents (Linemployment & health insursess, semen, al +romance etc.) +Ernipsee Income Taurs Perd and Wahheld +TAXES AND DUTIES (Provide dollar Meguet paid +Gross Recry Taxes Cand +Grosa Rectipes Encapuen ValuE. +Real Preserv Tax Pard +Real Pronetty Tax Exengton Velue. +ENGIM TeNEs Pand +Exce Tases Freneunn Value Refund +Income Tanes Pand +Encome Tess Esception Value Refund +Custants Duties Paid +Custome Dates Enemmon Value/Refund +Othes +el escapions for such 1axi +Hotel room mers rad +Orber Taxes Fees Pad lo VI Governmens (lou suretiv) +Shuthedder Dandends +Vi Degasmens of Late Elabor dusbase feet. +Butters Lense renewal +Franchise 1as +Notary somasson fees +Comfisals of rood sanding fee +IDTAL TANES PAID: +TOTAL VALUE OF ENEMPTIONS AND ON REFUNDS: +Digible for Tee Benefits +E41 +Ineligible for Tan Benefts** +151 +Total +54.690,266 +558).371) +52.008,905 +-51.353) +52.919,000 +soil +85.452.242 +$4.868 305) +51.690.366 +S6.065.513 +86.877.310 +-31.253 +$2.919,000 +Tatel +Saurse Decement Needed +$001.571 Please submut the form WISS +10 +10 +5334.367 +5199 314 Pease submit the fare W/355 +Tres +Health insurance +Svenle IRA +FICA FUTA. +Workman's Come +(Continum, Education +J06 TOTAL +Searce Desumess Neede +so Farm 720VT er 7208 +Su Form 720V7 or 7208 +Preperty tor stressment +Froperty ter assessment +Eroom 721 +Form 721 +$291, 989|Form 1120, 11205, 1065, sv 1040 with sex escularion worksheer +$47.996 Form 1120, 11/05, 200, er 1040 with ter cekuites worksheet +Please keep copies of receipis for review dy WEDC Complience Offner +Prose trep ropies of recripts for review by VEGE Compliance Offices +Form 722 +{Pinne keen copies of reseipts jor itview by VIEDC Compliance Offure +NA Note no exemptions claimed +S:selMote no eremations shamed +Note no exemptions claimed +30524 sete = raempren claimed +Note: no esemptions chimed +Es Noir no premphony clemed +EMpie no exemptions claimed +5295.910 +542.798 +Balance per Tae +Return +Dilfarence +malanation +501 +$1.500.266 +S6.005.613 +56811,210 +- 31.252 +$2-919,000 +sisisis|als +Other Implores Cort Brasheem +Sosun +Lection on Intones Tan Beturn +$160 031 +521,239 +Corts include in site 14, 17,12, 19, mapectivel +561,543 +$1,391 +$34 ME + + + +Document 194-21 Filed 06/20/23 +Case 1:22-cv-10904-JSR +EXPENINTURES FOR GOODS, SERVICES, PLANT & 6QUIPMENT +Row meierials and cormonents purcheses +Repair Maintenance +Beet +Interess +Other Bank Charnes +Adventising/Promotion Marketing Experises +Meals Emerainment +Travel Expenses. +Freisto & Postage Cures +Insurance. +VIEDC FRIe +Seanlare +Culities cel, wuer.clest.stc.) +Supplies and Office expense +Other (List Separin) +Dues and subscriptions +EDC Fees +Busiers expenses +Other espsuch satine, outside serves reuthuaties +SUBTOTAL, G0005 AND SERVICES +CAPITAL EXPENCITURES +Building & leprovements +Leason imprements +Machinery guinent. +FuntureFiatures +Vehicles +Dober (Lin Serenirin) +SUBTOTAL CAITAL EXPENDITU MES +S6.249 +$17,002 +S18.181 +55618) +513,000 +563,060) +MERCE. +Sapollen +563.671 +TION FOR VARIANCES IN BETWEEN EDC REPORT AND TAX RETURNS: +It Supers +514,579 +5138,393 +51,399 +S2,690 +56,760 +5E.506) +52,064 +530,064 +5101,379| +530.246 +5,180 +51,699 +5338.453| +74,614 +3,820) +IRTAS +520.8381 +S0: 5138,003/ +5217) +S1.ELZ +58.820 +56,760. +58.508 +8.3641 +$27.002 +31.535.225 SL545.289 +513.764 +5818.560 +S52,548 +$180 +517.9001 +$13,000 +517,500 +S1.6M +53.586,726 51,200-245 +MONSOON SHINE +4,186 +$29.187 +58,820) +Belaose.e9c.TRs.(E3M +520.838 +S115.893 +51.616] +$3,380 +$8.506 +52.054 +517.002 +51.585.289 +5119,560 +557,647 +5180 +513,000 +5175N3 +81.699 +34.384.804 +HEnnett +53.38050%5 deshuctihle limitain. +$29.187 Amount caritalized includod in schedule L +85.829 Amount capitaliand inchaded in schedale L +531434) + +$4.186 538.007 +51.590.512 | 52.075.253) +$3,391,34E +ER EDE CERTIFICATE +Certficane neguiremen +Percent achieved to date +5553,248 +5400.0к0) +135313) +VI-JPM-000007664 + + +Case 1:22-cv-10904-JSR Document 194-21 Filed 06/20/23 Page 4 of 5 +EDC ANNUAL REPORT +Value of Exemptions of Stockholders/Partners/Members +BENEFICIARY +Southern Trust Company, Inc. +Fiscal Year Ending December 31, 2018 +Stoakholders, +Partners or Members +Jeffrey E. Epstein +Soctal Security +No. +Physical +Address +Little Saint James +Island, St +USVI +Diatributable +Shares +EDC Income +100 +EDC Annual +report. +Business +Activity +Balance Tax +Total Tax Due EDC Credit +Due +See page 1 of See page 1 of See page 1 +EDC Annual +EDC Annual +report. +report. +TOTAL S +Note: Totals of EDC Credit and Balance Tax Due must be carried forward to the EDC Annual Report and reported under Taxes and Duties (See instructions). + + +Case 1:22-cv-10904-JSR Document 194-21 Filed 06/20/23 Page 5 of 5 +A +D +E +F +G +EDC INCOME +A +TOTAL GROSS INCOME +Percent of total income subject to Exemption +_(A). +_(B)._ +TOTAL TAX DUE +Amount of Tax Subject to the Exemption E +_(D)_ +_(C) +EXEMPTION PERCENTATE +F +EDC EXEPMTION CREDIT +_(E) +X +_(f). +%= +G +$ +$ +$ +Line G included on49d of the 2018 Form 1040 Schedule 5 Line 74 +notation EDC credit +2,964,750 +16,232,605 +18.26% +291,989 +53,329 +90% +47,996 +VI-JPM-000007666 \ No newline at end of file diff --git a/vision-fixhub/court-05/503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279.receipt.json b/vision-fixhub/court-05/503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a605e649251ade720e42e622aaaa1f75bb09438e --- /dev/null +++ b/vision-fixhub/court-05/503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -293, + "dataset": "marble-joined", + "doc_id": "503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "dd1354a6376a45e7c3a38476a3ea40265ff4b52c92942ef5cbe027a6182988b9", + "output_sha256": "f67a4fd1d9aef76412d94db22d3409bc4716519e27c38b94b3e43f5a689de754", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46.md b/vision-fixhub/court-05/506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46.md new file mode 100644 index 0000000000000000000000000000000000000000..5129651033f03ede1faa69109e6e640d78fe32b4 --- /dev/null +++ b/vision-fixhub/court-05/506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46.md @@ -0,0 +1,11 @@ +Case 1:22-cv-10904-JSR Document 53-2 Filed 02/21/23 Page 1 of 1 +The Supreme Court of South Carolina +Certificate of Good Standing +I, Patricia A. Howard, Clerk of the Supreme Court of South Carolina, do +hereby certify that Charlotte Eleanor Loper was duly sworn and admitted as an +attorney in this state on November 19, 2019, and is currently a Regular Member +of the South Carolina Bar in good standing. +Patricia A. Howard +CLERK +Columbia, South Carolina +February 14, 2023 diff --git a/vision-fixhub/court-05/506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46.receipt.json b/vision-fixhub/court-05/506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..70b7cb0a5e5f4cb218c683321cf2779764197b15 --- /dev/null +++ b/vision-fixhub/court-05/506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ae044b7343f41eda5a17f8f47bed3d9264d5a08683eca3fc0de98e5f9310eb72", + "output_sha256": "0547357f4621bdb773e75da89e37a59164df1ff209bb48b4bc368d285ef56bfc", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a.md b/vision-fixhub/court-05/508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a.md new file mode 100644 index 0000000000000000000000000000000000000000..784dcef6359b28f2d7f28a0e24afdc8924f28315 --- /dev/null +++ b/vision-fixhub/court-05/508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 158-80 Filed 05/23/23 +•Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a.receipt.json b/vision-fixhub/court-05/508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f126a4eb700481158f234a6bc8ebd26c1a7d205c --- /dev/null +++ b/vision-fixhub/court-05/508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "a42df724884b62ade863fa24a1fa851203d93fd985aef244f13a05c9e9098643", + "output_sha256": "bee50e8242c652f39b9c4423f4edbc040c215b1019447bb6b4e05a42a25d7438", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/50946c12815138d84b877119e15f42c48d979c5ab43eb801bef7070652bcd09b.md b/vision-fixhub/court-05/50946c12815138d84b877119e15f42c48d979c5ab43eb801bef7070652bcd09b.md new file mode 100644 index 0000000000000000000000000000000000000000..b8f2290bb51c6f848946e7d1ae50a14bcac52676 --- /dev/null +++ b/vision-fixhub/court-05/50946c12815138d84b877119e15f42c48d979c5ab43eb801bef7070652bcd09b.md @@ -0,0 +1,69 @@ +Case 1:22-cv-10904-JSR Document 284-42 Filed 08/14/23 + + +FILED UNDER SEAL + + +From: +Sent: +To: +Subject: +Case 1:22-cv-10904-JSR Document 284-42 Filed 08/14/23 Page 2 of 3 +Jeffrey Epstein [jeevacation@gmail.com] +4/9/2009 1:22:57 PM +Cecile de Jongh +Re: confidential +ok, re germaine, we need the most competent people, he has not really kept up... brice, and curtis have both +complained. i don't mind replacing himm, and i really don't like the settlement +issue,, he owed us fill +disclosure +On Thu, Apr 9, 2009 at 9:18 AM, Cecile de Jongh I +wrote: +Thanks - sending again to John. Vincent is off island and Gov't closed for Easter weekend +until Tuesday (can you believe it). John will email to Vincent. +From: Jeffrey Epstein cieevacation@nmail.comz +To: Cecile de Jongh +Sent: Thursday, April 9, 2009 9:08:01 AM +Subject: Re: confidential +Cecil//+ I will talk to the attorney today.. here is the attachment +Chris lane is the man in charge of the interstate compact in florida//. The interstate compact dictates +that Receiving states MUST now take probationers. But it is the sending states discretion on whether or +not to apply. That is the norm,. As the receiving state is responsible for the cost of supervision, In the +past states had previously turned down transferees. The interstate compact does not now allow the +state to turn down transfers. Normally as " community control" has to be a heightened and hence, more +expensive supervision,i.e. once a week reporting (as opposed to once a month and on weekends and +holidays.) Florida usually does not askanother state to take on the added expense. As compared to the +normal probation it costs more, so that in my case the VI has to agree to the same terms and conditions +as the normal community control provisions that I would be subject to if I stayed. +I think best that the head of the compact commission for the VI - Ms. Swan should deal with Chris Lane ( +Floridas' interstate compact administrator) . +, my assistant has spoken to +him previously and he thought this was accomplished with little fuss. The question that remains is +where on my side do we start. The probation officer, (Duane +Neither one knows anything about this yet) or the probation compact person, the person in the office +that usually handles transfers. I will get his number. //. Someone on this end must fill out the transfer +request forms. l assume Duane. +On Thu, Apr 9, 2009 at 8:59 AM, Cecile de Jongh +Jeffrey, +wrote: +I forwarded the document you sent me last week to John and he tried to send it on to +Vincent. He then tried to open it to print it out and the file is corrupted- Vincent can't open +either. I tried to reopen and print or to resend and I can't open it either. Can you resend to + +ESTATE_JPMO16557 + + +Case 1:22-cV-10904-JSR Document 284-42 Filed 08/14/23 Page 3 of 3 +John has one question: Would it not be better to have your attorney write a letter to the AG +(Vincent) requesting the transfer and then we move from there? He (John) sees nothing +wrong with taking that approach rather than having just phone calls back and forth especially +since you are a resident of the VI. +In either case, can you try to resend the document? +Cecile +From: Jeffrey Epstein +To: Cecile de Jongh +Sent: Thursday, April 2, 2009 10:48:06 AM +Subject: confidential +call me when you get a chance + +ESTATE_JPMO16558 diff --git a/vision-fixhub/court-05/50946c12815138d84b877119e15f42c48d979c5ab43eb801bef7070652bcd09b.receipt.json b/vision-fixhub/court-05/50946c12815138d84b877119e15f42c48d979c5ab43eb801bef7070652bcd09b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4790147cbcc4cbbe45811dfd7cfe9cbbf56bcdfe --- /dev/null +++ b/vision-fixhub/court-05/50946c12815138d84b877119e15f42c48d979c5ab43eb801bef7070652bcd09b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -82, + "dataset": "marble-joined", + "doc_id": "50946c12815138d84b877119e15f42c48d979c5ab43eb801bef7070652bcd09b", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "5ef919920dc70fb5eae3c8c683f314708152f63efaa0b25017a8fd3349ac8669", + "output_sha256": "1dd503c0aa05a3ba930f693dc971917343be894ae3eecdc91dd430ec45aa8684", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/509e7628b81b8b6923d2718a51ceb2fbd47ab4e0c7f2b9b6ae6970c38e9bbf6f.md b/vision-fixhub/court-05/509e7628b81b8b6923d2718a51ceb2fbd47ab4e0c7f2b9b6ae6970c38e9bbf6f.md new file mode 100644 index 0000000000000000000000000000000000000000..84faa39b023aaf9114fbfce2bd86144c591154f7 --- /dev/null +++ b/vision-fixhub/court-05/509e7628b81b8b6923d2718a51ceb2fbd47ab4e0c7f2b9b6ae6970c38e9bbf6f.md @@ -0,0 +1,926 @@ +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 1 of 41 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-cv-10904 (JSR) +JPMORGAN CHASE BANK, N.A.., +Defendant/Third-Party +Plaintiff. +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +V. +JAMES EDWARD STALEY, +Third-Party Defendant. +DECLARATION OF FELICIA H. ELLSWORTH IN SUPPORT OF JPMORGAN +CHASE BANK, N.A.'S OPPOSITION TO THE GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS' MOTION FOR PARTIAL SUMMARY JUDGMENT +Pursuant to 28 U.S.C. § 1746, I, Felicia H. Ellsworth, declare under penalty of perjury as +follows: +I am a member in good standing of the bar of the Commonwealth of Massachusetts. I +am one of the attorneys representing Defendant JPMorgan Chase Bank, N.A. ("JPMC") +in the above-captioned action and have been admitted to this Court pro hac vice. I am a +Partner with the law firm of Wilmer Cutler Pickering Hale and Dorr LLP, 60 State +Street, Boston, Massachusetts 02109. I am familiar with the facts set forth herein, and +if called as a witness, I could and would competently testify thereto. +1 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 2 of 41 +2. +Attached as Exhibit 54 is a true and correct copy of excerpts of the transcript from the +July 7, 2023 deposition of Bridgette Carr, designated confidential pursuant to the +3. Attached as Exhibit 55 is a true and correct copy of excerpts of the transcript from the +May 26, 2023 deposition of James Dimon, designated confidential pursuant to the +4. +Attached as Exhibit 56 is a true and correct copy of excerpts of JPMC's Responses and +Objections to Third-Party Defendant James E. Staley's Requests for Admission. +5. Attached as Exhibit 57 is a true and correct copy of excerpts of the transcript from the +March 29, 2023 deposition of Francis Pearn. +6. +Attached as Exhibit 58 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00072548, designated confidential pursuant to the +7. +Attached as Exhibit 59 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00139994, designated confidential pursuant to the +8. +Attached as Exhibit 60 is a true and correct copy of excerpts from the June 23, 2023 +Expert Report of Teresa A. Pesce, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +Attached as Exhibit 61 is a true and correct copy of excerpts of the transcript from the +March 15, 2023 deposition of Mary Erdoes, designated confidential pursuant to the +2 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 3 of 41 +10. Attached as Exhibit 62 is a true and correct copy of excerpts of JPMC's Responses and +Objections to USVI's First Requests for Admission. +11. Attached as Exhibit 63 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00149115. +12. Attached as Exhibit 64 is a true and correct copy of the Rubenstein, Who We Are page, +available at https://rubenstein.com/who-we-are/#. +13. Attached as Exhibit 65 is a true and correct copy of excerpts of the transcript from the +June 27, 2023 deposition of Jorge Amador, designated confidential pursuant to the +14. Attached as Exhibit 66 is a true and correct copy of excerpts of the transcript from the +April 7, 2023 deposition of Mary l +15. Attached as Exhibit 67 is a true and correct copy of excerpts of the transcript from the +July 12, 2023 deposition of Marcus Sheridan, designated confidential pursuant to the +16. Attached as Exhibit 68 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00755535. +17. Attached as Exhibit 69 is a true and correct copy of excerpts from JPMC's Responses +and Objections to Doe's First Set of Interrogatories. +18. +Attached as Exhibit 70 is a true and correct copy of excerpts of the transcript from the +June 10, 2023 deposition of James Staley. +19. Attached as Exhibit 71 is a true and correct copy of excerpts of the transcript from the +July 18, 2023 deposition of Catherine Keating, designated confidential pursuant to the +3 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 4 of 41 +20. Attached as Exhibit 72 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00902699, designated confidential pursuant to the +21. Attached as Exhibit 73 is a true and correct copy of excerpts of Third-Party Defendant +James E. Staley's May 23, 2023 Responses and Objections to The United States Virgin +Islands' Requests for Admission. +22. Attached as Exhibit 74 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00153462. +23. +Attached as Exhibit 75 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00136978. +24. Attached as Exhibit 76 is a true and correct copy of excerpts of the transcript from the +April 21, 2023 deposition of Justin Nelson, designated confidential pursuant to the +25. Attached as Exhibit 77 is a true and correct copy of excerpts of the transcript from the +July 13, 2023 deposition of John Duffy, designated confidential pursuant to the +26. Attached as Exhibit 78 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00754968, designated confidential pursuant to the +27. Attached as Exhibit 79 is a true and correct copy of excerpts of the transcript from the +May 24, 2023 deposition of Stephen Cutler. +4 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 5 of 41 +28. Attached as Exhibit 80 is a true and correct copy of excerpts of the transcript from the +July 7, 2023 deposition of Shaun O'Neill, designated confidential pursuant to the +29. Attached as Exhibit 81 is a true and correct copy of excerpts from the June 23, 2023 +Expert Report of Joe Fonseca, designated confidential pursuant to the Protective Order +in this matter and filed under seal. +30. Attached as Exhibit 82 is a true and correct copy of an article titled, +modeling +agent Jean-Luc Brunel found dead in prison cell" dated February 21, 2022 available at +https://www.cnn.com/2022/02/19/europe/jean-luc-brunel-jeffrey-epstein-deathintl/index.html. +31. Attached as Exhibit 83 is a true and correct copy of an article titled "Billionaire Jeffrey +Epstein Arrested for Sec Trafficking" dated July 7, 2019, available at +https://gothamist.com/news/billionaire-jeffrey-epstein-arrested-for-sex-trafficking. +32. Attached as Exhibit 84 is a true and correct copy of Exhibit 19 to the May 26, 2023 +deposition of Inais Borque. +33. Attached as Exhibit 85 is a true and correct copy excerpts of produced by Plaintiff the +Government of the United States Virgin Islands, I +stamped VI-JPM-000012446_U +designated confidential pursuant to the Protective Order in this matter and filed under +34. Attached as Exhibit 86 is a true and correct copy of excerpts of the VIPA Police +Manual. +35. Attached as Exhibit 87 is a true and correct copy of excerpts of produced by Plaintiff +stamped VI-JPM- +5 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 6 of 41 +000006467, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +36. Attached as Exhibit 88 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018027, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +37. Attached as Exhibit 89 is a true and correct copy of a document produced by Plaintiff +the Government of the United States Virgin Islands, | +stamped VI-JPM- +000018041, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +38. Attached as Exhibit 90 is a true and correct copy of excerpts of the June 23, 2023 +Carlyn Irwin Expert Report, designated confidential pursuant to the Protective Order in +this matter and filed under seal. +39. Attached as Exhibit 91 is a true and correct copy of excerpts of the transcript from the +July 6, 2023 deposition of Carlyn Irwin, designated confidential pursuant to the +40. Attached as Exhibit 92 is a true and correct copy of excerpts of the transcript from the +May 10, 2023 deposition of Bonnie +designated confidential pursuant to the +41. Attached as Exhibit 93 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00026008, designated confidential pursuant to the +6 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 7 of 41 +42. Attached as Exhibit 94 is a true and correct copy of excerpts of the transcript from the +July 13, 2023 deposition of Francis Pearn, designated confidential pursuant to the +43. Attached as Exhibit 95 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00127953. +44. Attached as Exhibit 96 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00001893. +45. Attached as Exhibit 97 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00449994. +46. Attached as Exhibit 98 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00127944. +47. Attached as Exhibit 99 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00010814, designated confidential pursuant to the +48. Attached as Exhibit 100 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00157090. +49. Attached as Exhibit 101 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00152748_R. +50. Attached as Exhibit 102 is a true and correct copy of excerpts of the transcript from the +May 24, 2023 deposition of Maryanne Ryan, designated confidential pursuant to the +51. Attached as Exhibit 103 is a true and correct copy of excerpts of the transcript from the +April 28, 2023 deposition of Kevin McCleerey. +7 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 8 of 41 +52. Attached as Exhibit 104 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00119630. +53. Attached as Exhibit 105 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00274774, designated confidential pursuant to the +54. Attached as Exhibit 106 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00127930, designated confidential pursuant to the +55. Attached as Exhibit 107 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00452980. +56. Attached as Exhibit 108 is a true and correct copy of excerpts of the transcript from the +May 3, 2023 deposition of William Langford, designated confidential pursuant to the +57. Attached as Exhibit 109 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00127928. +58. Attached as Exhibit 110 is a true and correct copy of the June 16, 2023 Expert Report +of Jorge Amador, designated confidential pursuant to the Protective Order in this matter +and filed under seal. +59. Attached as Exhibit 111 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00755043. +60. Attached as Exhibit 112 is a true and correct copy of a document produced by third +stamped Estate_006622, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +8 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 9 of 41 +61. Attached as Exhibit 113 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00136519, designated confidential pursuant to the +62. Attached as Exhibit 114 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00231636, designated confidential pursuant to the +63. Attached as Exhibit 115 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00230825, designated confidential pursuant to the +64. Attached as Exhibit 116 is a true and correct copy of excerpts of the transcript from the +May 30, 2023 deposition of Francis Pearn, designated confidential pursuant to the +65. Attached as Exhibit 117 is a true and correct copy of excerpts of the transcript from the +May 18, 2023 deposition of Richard Kahn, designated confidential pursuant to the +66. Attached as Exhibit 118 is a true and correct copy of the May 26, 2023 Declaration of +P. Visoski, Jane Doe 1 v. Deutsche Bank, Case No. 1:22-cv-10018 (JSR). +67. Attached as Exhibit 119 is a true and correct copy of excerpts of the transcript from the +April 20, 2023 deposition of Phillip DeLuca, designated confidential pursuant to the +68. Attached as Exhibit 120 is a true and correct copy of excerpts of the transcript from the +June 30, 2023 deposition of Kimberly Mehlman-Orozco, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +9 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 10 of 41 +69. Attached as Exhibit 121 is a true and correct copy of excerpts of the transcript from the +April 18, 2023 deposition of Paul Morris. +70. Attached as Exhibit 122 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00036580, designated confidential pursuant to the +71. Attached as Exhibit 123 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-W-00025201, designated confidential pursuant to the +72. Attached as Exhibit 124 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00152809, designated confidential pursuant to the +73. Attached as Exhibit 125 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00026008, designated confidential pursuant to the +74. Attached as Exhibit 126 is a true and correct copy of excerpts of the transcript from the +July 10, 2023 deposition of Stephen Cutler, designated confidential pursuant to the +75. Attached as Exhibit 127 is a true and correct copy of excerpts of the transcript from the +July 12, 2023 deposition of Mary Erdoes, designated confidential pursuant to the +76. Attached as Exhibit 128 is a true and correct copy of excerpts of the transcript from the +March 3, 2023 deposition of Jane Doe 1, designated confidential pursuant to the +10 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 11 of 41 +77. Attached as Exhibit 129 is a true and correct copy of excerpts of the transcripts from +the June 11, 2023 deposition of James Staley, designated confidential pursuant to the +78. Attached as Exhibit 130 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00006171. +79. Attached as Exhibit 131 is a true and correct copy of a document produced by third +stamped ESTATE_JPM002773, +designated confidential pursuant to the Protective Order in this matter and filed under +80. Attached as Exhibit 132 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006718. +81. Attached as Exhibit 133 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006716, designated confidential pursuant to the +82. Attached as Exhibit 134 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006791. +83. Attached as Exhibit 135 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006792, designated confidential pursuant to the +84. Attached as Exhibit 136 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00008342. +85. +Attached as Exhibit 137 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00008669. +11 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 12 of 41 +86. Attached as Exhibit 138 is a true and correct copy of' a document produced by JPMC, +stamped JPM-SDNYLIT-00013210, designated confidential pursuant to the +87. Attached as Exhibit 139 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013402. +88. Attached as Exhibit 140 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013463, designated confidential pursuant to the +89. Attached as Exhibit 141 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013475. +90. +Attached as Exhibit 142 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013669. +91. Attached as Exhibit 143 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013762. +92. Attached as Exhibit 144 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00005845, designated confidential pursuant to the +93. Attached as Exhibit 145 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006553, designated confidential pursuant to the +94. Attached as Exhibit 146 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006886, designated confidential pursuant to the + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 13 of 41 +95. Attached as Exhibit 147 is a true and correct copy of' a document produced by JPMC, +stamped JPM-SDNYLIT-00010121, designated confidential pursuant to the +96. Attached as Exhibit 148 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00010989, designated confidential pursuant to the +97. Attached as Exhibit 149 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00012289, designated confidential pursuant to the +98. Attached as Exhibit 150 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00012466, designated confidential pursuant to the +99. Attached as Exhibit 151 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004661. +100. Attached as Exhibit 152 is a true and correct copy of a document produced by third +stamped ESTATE_JPM001758, +designated confidential pursuant to the Protective Order in this matter and filed under +101. Attached as Exhibit 153 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006586. +102. Attached as Exhibit 154 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00006592. +13 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 14 of 41 +103. Attached as Exhibit 155 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006874. +104. Attached as Exhibit 156 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00012494. +105. Attached as Exhibit 157 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004394, designated confidential pursuant to the +106. Attached as Exhibit 158 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004388, designated confidential pursuant to the +107. Attached as Exhibit 159 is a true and correct copy of a document produced by third +stamped ESTATE_JPM002742, +designated confidential pursuant to the Protective Order in this matter and filed under +108. Attached as Exhibit 160 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006704, designated confidential pursuant to the +109. Attached as Exhibit 161 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00010330, designated confidential pursuant to the +110. Attached as Exhibit 162 is a true and correct copy of a document produced by JPMC, +stamped .JPM-SDNYLIT-00010603, designated confidential pursuant to the + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 15 of 41 +111. Attached as Exhibit 163 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004186, designated confidential pursuant to the +112. Attached as Exhibit 164 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00010284, designated confidential pursuant to the +113. Attached as Exhibit 165 is a true and correct copy of a document produced by third +stamped ESTATE_JPM003001, +designated confidential pursuant to the Protective Order in this matter and filed under +114. Attached as Exhibit 166 is a true and correct copy of a document produced by third +stamped ESTATE_JPM002019, +designated confidential pursuant to the Protective Order in this matter and filed under +115. Attached as Exhibit 167 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013770. +116. Attached as Exhibit 168 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00205452. +117. Attached as Exhibit 169 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00269718, designated confidential pursuant to the +15 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 16 of 41 +118. Attached as Exhibit 170 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00269719, designated confidential pursuant to the +119. Attached as Exhibit 171 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-W-00021957, designated confidential pursuant to the +120. Attached as Exhibit 172 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00033761, designated confidential pursuant to the +121. Attached as Exhibit 173 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00021997, designated confidential pursuant to the +122. Attached as Exhibit 174 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00037446, designated confidential pursuant to the +123. Attached as Exhibit 175 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00037463, designated confidential pursuant to the +124. Attached as Exhibit 176 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00022528, designated confidential pursuant to the + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 17 of 41 +125. Attached as Exhibit 177 is a true and correct copy of excerpts of a document produced +by JPMC, I +stamped JPM-SDNYLIT-W-00017133, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +126. Attached as Exhibit 178 is a true and correct copy of excerpts of a document produced +by JPMC, +stamped JPM-SDNYLIT-W-00008055, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +127. Attached as Exhibit 179 is a true and correct copy of excerpts of a document produced +by JPMC, +stamped JPM-SDNYLIT-W-00020952, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +128. Attached as Exhibit 180 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00000183, designated confidential pursuant to the +129. Attached as Exhibit 181 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00000001, designated confidential pursuant to the +130. Attached as Exhibit 182 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00000211, designated confidential pursuant to the +131. Attached as Exhibit 183 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00022540, designated confidential pursuant to the +17 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 18 of 41 +132. Attached as Exhibit 184 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00008100, designated confidential pursuant to the +133. Attached as Exhibit 185 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00022549, designated confidential pursuant to the +134. Attached as Exhibit 186 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00008123, designated confidential pursuant to the +135. Attached as Exhibit 187 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00008144, designated confidential pursuant to the +136. Attached as Exhibit 188 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00136910, designated confidential pursuant to the +137. Attached as Exhibit 189 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00136911, designated confidential pursuant to the +138. Attached as Exhibit 190 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00100966. +139. Attached as Exhibit 191 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00150176. + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 19 of 41 +140. Attached as Exhibit 192 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00100998, designated confidential pursuant to the +141. Attached as Exhibit 193 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00030327, designated confidential pursuant to the +142. Attached as Exhibit 194 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00016246, designated confidential pursuant to the +143. Attached as Exhibit 195 is a true and correct copy of excerpts from JPMC's Responses +and Objections to The United States Virgin Islands First Requests for Admissions. +144. Attached as Exhibit 196 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00902715, designated confidential pursuant to the +145. Attached as Exhibit 197 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00373074. +146. Attached as Exhibit 198 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00373254. +147. Attached as Exhibit 199 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015321. +148. Attached as Exhibit 200 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015326, +19 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 20 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +149. Attached as Exhibit 201 is a true and correct copy of Exhibit 7 from the July 20, 2023 +deposition of Denise +150. Attached as Exhibit 202 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016517, +designated confidential pursuant to the Protective Order in this matter and filed under +151. Attached as Exhibit 203 is a true and correct copy of excerpts of the transcript from the +June 6, 2023 deposition of Albert Bryan. +152. Attached as Exhibit 204 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016246, +designated confidential pursuant to the Protective Order in this matter and filed under +153. Attached as Exhibit 205 is a true and correct copy of excerpts of a document produced +by Plaintiff the Government of the United States Virgin Islands, +stamped VI- +JPM-000006066, designated confidential pursuant to the Protective Order in this matter +and filed under seal. +154. Attached as Exhibit 206 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025237, +designated confidential pursuant to the Protective Order in this matter and filed under +20 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 21 of 41 +155. Attached as Exhibit 207 is a true and correct copy of excerpts of the transcript from the +May 29, 2023 deposition of Stacey Plaskett. +156. Attached as Exhibit 208 is a true and correct copy of excerpts of the transcript from the +May 29, 2023 deposition of Cecile de Jongh, designated confidential pursuant to the +157. Attached as Exhibit 209 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015885, +designated confidential pursuant to the Protective Order in this matter and filed under +158. Attached as Exhibit 210 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015674, +designated confidential pursuant to the Protective Order in this matter and filed under +159. Attached as Exhibit 211 is a true and correct copy of a document produced by third +stamped ESTATE_JPM059741, +designated confidential pursuant to the Protective Order in this matter and filed under +160. Attached as Exhibit 212 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016163, +designated confidential pursuant to the Protective Order in this matter and filed under +161. Attached as Exhibit 213 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015950, +21 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 22 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +162. Attached as Exhibit 214 is a true and correct copy of a document produced by third +stamped ESTATE_JPM022478, +designated confidential pursuant to the Protective Order in this matter and filed under +163. Attached as Exhibit 215 is a true and correct copy of a document produced by third +stamped ESTATE_JPM022479, +designated confidential pursuant to the Protective Order in this matter and filed under +164. Attached as Exhibit 216 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016210, +designated confidential pursuant to the Protective Order in this matter and filed under +165. Attached as Exhibit 217 is a true and correct copy of a document produced by third +stamped ESTATE_JPM058471, +designated confidential pursuant to the Protective Order in this matter and filed under +166. Attached as Exhibit 218 is a true and correct copy of a document produced by third +stamped ESTATE_JPM060696, +designated confidential pursuant to the Protective Order in this matter and filed under +22 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 23 of 41 +167. Attached as Exhibit 219 is a true and correct copy of a document produced by third +stamped ESTATE_JPM058976, +designated confidential pursuant to the Protective Order in this matter and filed under +168. Attached as Exhibit 220 is a true and correct copy of a document produced by third +stamped ESTATE_JPM023608, +designated confidential pursuant to the Protective Order in this matter and filed under +169. Attached as Exhibit 221 is a true and correct copy of a document produced by third +stamped ESTATE_JPM012505, +designated confidential pursuant to the Protective Order in this matter and filed under +170. Attached as Exhibit 222 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015733, +designated confidential pursuant to the Protective Order in this matter and filed under +171. Attached as Exhibit 223 is a true and correct copy of excerpts of the transcript from the +May 24, 2023 deposition of Kenneth Mapp. +172. Attached as Exhibit 224 is a true and correct copy of excerpts of the transcript from the +May 30, 2023 deposition of John de Jongh. +173. Attached as Exhibit 225 is a true and correct copy of a document produced by third +stamped ESTATE_JPM066053, +23 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 24 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +174. Attached as Exhibit 226 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016303, +designated confidential pursuant to the Protective Order in this matter and filed under +175. Attached as Exhibit 227 is a true and correct copy of a document produced by third +stamped ESTATE_JPM030178, +designated confidential pursuant to the Protective Order in this matter and filed under +176. Attached as Exhibit 228 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024203, +designated confidential pursuant to the Protective Order in this matter and filed under +177. Attached as Exhibit 229 is a true and correct copy of a document produced by third +stamped ESTATE_JPM021286, +designated confidential pursuant to the Protective Order in this matter and filed under +178. Attached as Exhibit 230 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024371, +designated confidential pursuant to the Protective Order in this matter and filed under +24 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 25 of 41 +179. Attached as Exhibit 231 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024370, +designated confidential pursuant to the Protective Order in this matter and filed under +180. Attached as Exhibit 232 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO11964, +designated confidential pursuant to the Protective Order in this matter and filed under +181. Attached as Exhibit 233 is a true and correct copy of a document produced by third +stamped ESTATE_JPM064333, +designated confidential pursuant to the Protective Order in this matter and filed under +182. Attached as Exhibit 234 is a true and correct copy of a document produced by third +stamped ESTATE_JPM064334, +designated confidential pursuant to the Protective Order in this matter and filed under +183. Attached as Exhibit 235 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024927, +designated confidential pursuant to the Protective Order in this matter and filed under +184. Attached as Exhibit 236 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO22970, + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 26 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +185. Attached as Exhibit 237 is a true and correct copy of a document produced by third +stamped ESTATE_JPM050241, +designated confidential pursuant to the Protective Order in this matter and filed under +186. Attached as Exhibit 238 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO50265, +designated confidential pursuant to the Protective Order in this matter and filed under +187. Attached as Exhibit 239 is a true and correct copy of a document produced by third +stamped ESTATE_JPM060776, +designated confidential pursuant to the Protective Order in this matter and filed under +188. Attached as Exhibit 240 is a true and correct copy of a document produced by third +stamped ESTATE_JPM061002, +designated confidential pursuant to the Protective Order in this matter and filed under +189. Attached as Exhibit 241 is a true and correct copy of a document produced by third +stamped ESTATE_JPM061003, +designated confidential pursuant to the Protective Order in this matter and filed under +26 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 27 of 41 +190. Attached as Exhibit 242 is a true and correct copy of a document produced by third +stamped ESTATE_JPM055381, +designated confidential pursuant to the Protective Order in this matter and filed under +191. Attached as Exhibit 243 is a true and correct copy of a document produced by third +stamped ESTATE_JPM021989, +designated confidential pursuant to the Protective Order in this matter and filed under +192. Attached as Exhibit 244 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO12219, +designated confidential pursuant to the Protective Order in this matter and filed under +193. Attached as Exhibit 245 is a true and correct copy of a document produced by Plaintiff +the Government of the United States Virgin Islands, | +stamped VI-JPM- +000021920, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +194. Attached as Exhibit 246 is a true and correct copy of a document produced by third +stamped ESTATE_JPM061123, +designated confidential pursuant to the Protective Order in this matter and filed under +195. Attached as Exhibit 247 is a true and correct copy of a document produced by third +stamped ESTATE_JPM062263, +27 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 28 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +196. Attached as Exhibit 248 is a true and correct copy of a document produced by third +stamped ESTATE_JPM062254, +designated confidential pursuant to the Protective Order in this matter and filed under +197. Attached as Exhibit 249 is a true and correct copy of a document produced by third +stamped ESTATE_JPM065842, +designated confidential pursuant to the Protective Order in this matter and filed under +198. Attached as Exhibit 250 is a true and correct copy of a document produced by third +stamped ESTATE_JPM060812, +designated confidential pursuant to the Protective Order in this matter and filed under +199. Attached as Exhibit 251 is a true and correct copy of a document produced by third +stamped ESTATE_JPM020484, +designated confidential pursuant to the Protective Order in this matter and filed under +200. Attached as Exhibit 252 is a true and correct copy of Exhibit 20 from the May 29, 2023 +deposition of Cecile de Jongh. +201. Attached as Exhibit 253 is a true and correct copy of excerpts of the transcript from the +May 26, 2023 deposition of Inais Borque. +28 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 29 of 41 +202. Attached as Exhibit 254 is a true and correct copy of Exhibit 5 from the May 26, 2023 +deposition of Inais Borque, designated confidential pursuant to the Protective Order in +this matter and filed under seal. +203. Attached as Exhibit 255 is a true and correct copy of Exhibit 37 from the March 15, +2023 deposition of Mary Erdoes. +204. Attached as Exhibit 256 is a true and correct copy of Exhibit 4 from the July 7, 2023 +deposition of Jean-Pierre Oriol, designated confidential pursuant to the Protective Order +in this matter and filed under seal. +205. Attached as Exhibit 257 is a true and correct copy of Exhibit 5 from the July 7, 2023 +deposition of Jean-Pierre Oriol, designated confidential pursuant to the Protective Order +in this matter and filed under seal. +206. Attached as Exhibit 258 is a true and correct copy of excerpts of the transcript from the +July 7, 2023 deposition of Jean-Pierre Oriol, designated confidential pursuant to the +207. Attached as Exhibit 259 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000061108, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +208. Attached as Exhibit 260 is a true and correct copy of Exhibit 10 from the July 13, 2023 +deposition of Carol +209. Attached as Exhibit 261 is a true and correct copy of excerpt of the transcript from the +July 18, 2023 deposition of Shani Pinney, designated confidential pursuant to the + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 30 of 41 +210. Attached as Exhibit 262 is a true and correct copy of excerpts of the transcript from the +July 20, 2023 deposition of Denise +, designated confidential pursuant to the +211. Attached as Exhibit 263 is a true and correct copy of excerpts of the transcript from the +July 12, 2023 deposition of Carol +, designated confidential pursuant to +the Protective Order in this matter and filed under seal. +212. Attached as Exhibit 264 is a true and correct copy of excerpts of the transcript from the +July 17, 2023 deposition of Denise +, designated confidential pursuant to the +213. Attached as Exhibit 265 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016557, +designated confidential pursuant to the Protective Order in this matter and filed under +214. Attached as Exhibit 266 is a true and correct copy of excerpts of the transcript from the +July 13, 2023 deposition of Vincent Frazer, designated confidential pursuant to the +215. Attached as Exhibit 267 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024492, +designated confidential pursuant to the Protective Order in this matter and filed under +216. Attached as Exhibit 268 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024494, +30 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 31 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +217. Attached as Exhibit 269 is a true and correct copy of a document produced by third +stamped ESTATE_JPM030223, +designated confidential pursuant to the Protective Order in this matter and filed under +218. Attached as Exhibit 270 is a true and correct copy of a document produced by third +stamped ESTATE_JPM030225, +designated confidential pursuant to the Protective Order in this matter and filed under +219. Attached as Exhibit 271 is a true and correct copy of a document produced by third +stamped ESTATE_JPM030228, +designated confidential pursuant to the Protective Order in this matter and filed under +220. Attached as Exhibit 272 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025221, +designated confidential pursuant to the Protective Order in this matter and filed under +221. Attached as Exhibit 273 is a true and correct copy of a document produced by third +stamped ESTATE_JPM030179, +designated confidential pursuant to the Protective Order in this matter and filed under +31 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 32 of 41 +222. Attached as Exhibit 274 is a true and correct copy of Exhibit 1 to the July 18, 2023 +deposition of Shani Pinney. +223. Attached as Exhibit 275 is a true and correct copy of the legacy file copy of the Act No. +7372, Bill No. 29-0239, Twenty-Ninth Legislature of The Virgin Islands, Regular +Session, 2012, available at +https://stthomassource.com/legacy_files/userfiles/file/vetoed%20bills%2071912/Act%2 +0No_%207372%20-%20Bill%20No_%2029-0239.pdf. +224. Attached as Exhibit 276 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025227, +designated confidential pursuant to the Protective Order in this matter and filed under +225. Attached as Exhibit 277 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015021, +designated confidential pursuant to the Protective Order in this matter and filed under +226. Attached as Exhibit 278 is a true and correct copy of Bill 0444, a bill passed in the +United States Virgin Islands in 2012. +227. Attached as Exhibit 279 is a true and correct copy of excerpts of a document produced +by Plaintiff the Government of the United States Virgin Islands, +stamped VI- +JPM-000012237, designated confidential pursuant to the Protective Order in this matter +and filed under seal. +32 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 33 of 41 +228. Attached as Exhibit 280 is a true and correct copy of excerpts of a document produced +by Plaintiff the Government of the United States Virgin Islands, +stamped VI- +JPM-000012328. +229. Attached as Exhibit 281 is a true and correct copy of 14 Virgin Islands Code +§ 1721B(a)(1). +230. Attached as Exhibit 282 is a true and correct copy of produced by Plaintiff the +Government of the United States Virgin Islands, +stamped VI-JPM000012616, +designated confidential pursuant to the Protective Order in this matter and filed under +231. Attached as Exhibit 283 is a true and correct copy of a document produced by Plaintiff +the Government of the United States Virgin Islands, | +stamped VI-JPM- +000087959, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +232. Attached as Exhibit 284 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016129, +designated confidential pursuant to the Protective Order in this matter and filed under +233. Attached as Exhibit 285 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025693, +designated confidential pursuant to the Protective Order in this matter and filed under +234. Attached as Exhibit 286 is a true and correct copy of a document produced by third +stamped ESTATE_JPM044489, +33 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 34 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +235. Attached as Exhibit 287 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016521, +designated confidential pursuant to the Protective Order in this matter and filed under +236. Attached as Exhibit 288 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015782, +designated confidential pursuant to the Protective Order in this matter and filed under +237. Attached as Exhibit 289 is a true and correct copy of excerpts of the June 16, 2023 +Expert Report of Bridgette Carr, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +238. Attached as Exhibit 290 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024879, +designated confidential pursuant to the Protective Order in this matter and filed under +239. Attached as Exhibit 291 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016458, +designated confidential pursuant to the Protective Order in this matter and filed under +240. Attached as Exhibit 292 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016316, +34 + + +Case 1:22-cV-10904-JSR Document 265 Filed 08/07/23 Page 35 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +241. Attached as Exhibit 293 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025196, +designated confidential pursuant to the Protective Order in this matter and filed under +242. Attached as Exhibit 294 is a true and correct copy of a document produced by third +stamped ESTATE _JPM024114, +designated confidential pursuant to the Protective Order in this matter and filed under +243. Attached as Exhibit 295 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024119, +designated confidential pursuant to the Protective Order in this matter and filed under +244. Attached as Exhibit 296 is a true and correct copy of a document produced by third +stamped ESTATE_JPM020206, +designated confidential pursuant to the Protective Order in this matter and filed under +245. Attached as Exhibit 297 is a true and correct copy of the travel website of the U.S. +Department of State regarding student visas, available at +https://travel.state.gov/content/travel/en/us-visas/study/student-visa.html. +246. Attached as Exhibit 298 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO20983, +35 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 36 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +247. Attached as Exhibit 299 is a true and correct copy of a document produced by third +stamped ESTATE_JPM064398, +designated confidential pursuant to the Protective Order in this matter and filed under +248. Attached as Exhibit 300 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO22289, +designated confidential pursuant to the Protective Order in this matter and filed under +249. Attached as Exhibit 301 is a true and correct copy of a document produced by third +stamped ESTATE_JPM029515, +designated confidential pursuant to the Protective Order in this matter and filed under +250. Attached as Exhibit 302 is a true and correct copy of a document produced by third +stamped ESTATE_JPM055329, +designated confidential pursuant to the Protective Order in this matter and filed under +251. Attached as Exhibit 303 is a true and correct copy of a document produced by third +stamped ESTATE_JPM059347, +designated confidential pursuant to the Protective Order in this matter and filed under +36 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 37 of 41 +252. Attached as Exhibit 304 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000087870, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +253. Attached as Exhibit 305 is a true and correct copy of a document produced by third +stamped ESTATE_JPM023450, +designated confidential pursuant to the Protective Order in this matter and filed under +254. Attached as Exhibit 306 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015784, +designated confidential pursuant to the Protective Order in this matter and filed under +255. Attached as Exhibit 307 is a true and correct copy of Exhibit 19 from the May 29, 2023 +deposition of Cecile de Jongh, designated confidential pursuant to the Protective Order +in this matter and filed under seal. +256. Attached as Exhibit 308 is a true and correct copy of a document produced by third +stamped ESTATE_JPM021434, +designated confidential pursuant to the Protective Order in this matter and filed under +257. Attached as Exhibit 309 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO15122, +designated confidential pursuant to the Protective Order in this matter and filed under +37 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 38 of 41 +258. Attached as Exhibit 310 is a true and correct copy of Plaintiff the Government of the +United States Virgin Islands' Second Amended Complaint, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +259. Attached as Exhibit 311 is a true and correct copy of excerpts from the transcript of the +May 26, 2023 deposition of Margarita +260. Attached as Exhibit 312 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000017983. +261. Attached as Exhibit 313 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018005. +262. Attached as Exhibit 314 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000019063. +263. Attached as Exhibit 315 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016245, +designated confidential pursuant to the Protective Order in this matter and filed under +264. Attached as Exhibit 316 is a true and correct copy of excerpts of a document produced +by Plaintiff the Government of the United States Virgin Islands, +stamped VI- +JPM-000013479, designated confidential pursuant to the Protective Order in this matter +and filed under seal. +38 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 39 of 41 +265. Attached as Exhibit 317 is a true and correct copy of a document produced by Mark +Paneth, +stamped MP-00001858, designated confidential pursuant to the +266. Attached as Exhibit 318 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000023078. +267. Attached as Exhibit 319 is a true and correct copy of a document produced by Plaintifi +000023091. +stamped VI-JPM- +268. Attached as Exhibit 320 is a true and correct copy of excerpts from the May 17, 2023 +deposition of Sandra Bess. +269. Attached as Exhibit 321 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015014, +designated confidential pursuant to the Protective Order in this matter and filed under +270. Attached as Exhibit 322 is a true and correct copy of a document produced by third +stamped ESTATE_JPM018432, +designated confidential pursuant to the Protective Order in this matter and filed under +271. Attached as Exhibit 323 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000022897. +39 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 40 of 41 +272. Attached as Exhibit 324 is a true and correct copy of a document produced by third +stamped ESTATE_JPM055884, +designated confidential pursuant to the Protective Order in this matter and filed under +273. Attached as Exhibit 325 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000016206. +274. Attached as Exhibit 326 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018885, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +275. Attached as Exhibit 327 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000016200, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +276. Attached as Exhibit 328 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018918, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +277. Attached as Exhibit 329 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018934, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +40 + + +Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 41 of 41 +278. Attached as Exhibit 330 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018551, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +279. Attached as Exhibit 331 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000017233. +280. Attached as Exhibit 332 is a true and correct copy of Exhibit 37 from the May 26, 2023 +deposition of Margarita +281. Attached as Exhibit 333 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000016492. +282. Attached as Exhibit 334 is a true and correct copy of Exhibit 14 from the May 29, 2023 +deposition of Cecile de Jongh. +283. Attached as Exhibit 335 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-W-00008805, designated confidential pursuant to the +Dated: August 7, 2023 +(s/ Felicia Ellsworth +Felicia H. Ellsworth +41 \ No newline at end of file diff --git a/vision-fixhub/court-05/509e7628b81b8b6923d2718a51ceb2fbd47ab4e0c7f2b9b6ae6970c38e9bbf6f.receipt.json b/vision-fixhub/court-05/509e7628b81b8b6923d2718a51ceb2fbd47ab4e0c7f2b9b6ae6970c38e9bbf6f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..855462d71cf8e108b9a9117f53a0cdb45e391161 --- /dev/null +++ b/vision-fixhub/court-05/509e7628b81b8b6923d2718a51ceb2fbd47ab4e0c7f2b9b6ae6970c38e9bbf6f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -9970, + "dataset": "marble-joined", + "doc_id": "509e7628b81b8b6923d2718a51ceb2fbd47ab4e0c7f2b9b6ae6970c38e9bbf6f", + "engine": "marble-apple-vision", + "event_count": 43, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "34a89f2dd0ce4d813dbd19ef4d82311a47fa479874ffeed43a61a056d12fac59", + "output_sha256": "cf5a2e6d85975de936f47c8dc6df1616f5f0d9dd50322d112cc8a1d763351655", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212.md b/vision-fixhub/court-05/50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212.md new file mode 100644 index 0000000000000000000000000000000000000000..9641f6089c6b628ffce5067c76ff0e8e4dc8f85a --- /dev/null +++ b/vision-fixhub/court-05/50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212.md @@ -0,0 +1,149 @@ +Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 1 of 5 + + + +From: +To: +CC: +Sent: +Subject: +Attachments: +Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 2 of 5 +Bonnie K + +6/9/2010 10:16:07 PM +Jeffrey Epstein +Epstein Article - dtd. 6-9-2010.pdf; Epstein Article dtd. 5-27-2010.pdf +Hi Paul - +I have regressed the DDR back to you for additional information. +Redacted - Privileged +DDR Name: Jeffrey Epstein ~ +DDR Link -> Notes://PPUSMC017/85256F64005749BC/6BCDEBE8A049C44485256E6F0063C802 +/5EE4238F2F8C2E1485256D2400745A6D +Redacted - Privileged +Please update the Transaction Profile/Expected account activity - specifically, please note monthly cash +withdrawal activity, ranging $30k to $50k and the purpose of these cash withdrawals. +Please update the summary to include the client's current personal circumstances, business activities, +etc. I have attached a couple of articles to assist. +Further, please update the "Financial Trust Company Inc." DDR - last update 2003. This entity holds the bulk of +the wealth held for Mr. Epstein within the relationship. +DDR Name: Financial Trust Company, Inc. ~ +DDR link -> Notes://PPUSMC017/85256F64005749BC/58A38C458E8182CD8525727C0067562D +(26A36B1774A08A5485256D240076F422 +Since this is a BVI entity, please ensure that you obtain evidence of tax declaration (e.g., a statement from +the lawyer / accountant and 5 yrs of tax statements). +3 entities within the relationship do not currently have DDRs. Please create DDRs for the following entities: +• 116 East 65th St LLC +• NES, LLC +• Zorro Trust +If you have any questions, please feel free to contact either me or Jim Dalessio. +Thanks, +Bonnie +Bonnie K +, VP, CAMS | Private Bank Risk Ngut & Control +712 Main, tl Fl, Houston, TX 77002 (TX2-N045) +Tel: 713.216-5136 +Fax: 713.216-7970 + +WIT: +DATE: 4-77 +C. Campbell, ADR CRR CSR #13921 + +JPM-SDNYLIT-00008237 + + +Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 3 of 5 +DOWIONES. +Local +ATTORNEYS SETTLE FEE DISPUTE WITH BILLIONAIRE LAW FIRM HAD SOUGHT MONEY FOR +LEGAL BILLS FROM SEX OFFENDER +y Jane Musgrave The Palm Beach Post +314 words +9 June 2010 +South Florida Sun-Sentinel +FLSS +Palm Beach +3B +English +Copyright 2010, South Florida Sun-Sentinel. All Rights Reserved. +A men Who claimed he Pal leach rese of sexual buse pise is apparenty who represented 15 +in court papers filed late Monday, attorneys representing Miami law firm Podhurst Orseck said a settlemen +had been reached with Epstein. +Terms of the agreement weren't spelled out +Podhurst Orseck filed suit against Epstein last month, claiming his refusal to pay its legal bill constituted a +violation of an agreement the money manager signed to escape federal charges. As part of the 2007 plea +deal, Epstein agreed to pay attorneys to negotiate settlements on behalf of the 33 women who told federal +prosecutors he had paid them for sexually charged massages at his Palm Beach mansion when some were +as young as 14. +welve of the women sought the help of Podhurst partner Robert Josefsberg, who was appointed t +legotiate settlements. He also represented three women in civil lawsuits that were also settled fo +undisclosed amounts. About a dozen other women hired other attorneys to represent them. Most of those +lawsuits are still pending. +Epstein pleaded guilty to two sex-related charges and was released from the Palm Beach County jail in July +after serving 13 months of an 18-month jail sentence. In return, federal prosecutors agreed not to pursue him +for crimes that could have sent him to prison for decades. +Billionaire sex offender Jeffrey Epstein had argued law fir inflated its costs. Photo(s) +Document FLSS000020100609e6690003z + +2010 Factiva, Inc, All rights reserved. + +JPM-SDNYLIT-00008238 + + +Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 4 of 5 +DOWJONES +A SECTION +JUDGE ORDERS N.Y. PAPERI TO GIVE UP EPSTEIN TAPE +y MICHELE DARGAN Daily News Staff Write +29 word: +1 May 2010 +alm Beach Daily New: +PBDN +DN1 +1A +English +Copyright 2010 The Palm Beach Daily News. All Rights Reserved. +alm Beach Post File Photo hv LIma Sanghvi Jeffrey Epstein, shown in this 2008 file photo, spoke to 'Nev +York Dailyi News' reporter +Rush on tape. Since Epstein has asserted his Fifth Amendment privileg +in depositions, the taped conversation is the only way! the jury can hear Epstein in his own words, attorneys +for client Jane Doel say. +The New York Daily News must turn over a tape-recorded interview between reporter +Rush and sex +offender Jeffrey Epstein because the information cannot be obtained anywhere else and outweighs +reporter's privilege, a federal judge has ruled. +Attorneys Brad +and Paul Cassell have been fighting to obtain the tape in representing their client +Jane Doe, a minor at the time of Epstein's abuse. Since Epsiein has asserted his Fifth Amendment privilege +in depositions, the taped conversation is the only way the jury can hear Epstein in his own words, the +attorneys say. +After listening to the 22-minute recording and reading the transcript, Manhattan U.S. District Judge +McKenna agreed in his six-page ruling. +Of particular relevance, McKenna noted "a statement included in the first full paragraph attributed to Mr. +Epstein at page 15 of the transcript... the court finds that the materials at issue 'are not reasonably +Portions of the recording can be used related to liability and damages, the ruling says. +But whether the attorneys will have the tape in time for the start of their July 17 trial is still in question. +The judge's order says the recording +and transcript will be held in +decided or the time to file a notice of appeal has expired. +or under seal until any appeal is +Ne're happy that the court agreed with our argument that this important evidence supporting Jane Doe +ase can be presented to the jury," Cassell said by phone Tuesda +Laura Handman, attorney for the New York Daily News, said they are appealing the decision. +non-prosecution agreement. +- mdargan@pbdailynews.com +Document PBDN000020100602e65r0000d +Page 1 of 2 2010 Factiva, Inc. All rights reserved. + +JPM-SDNYLIT-00008239 + + ++ +Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 5 of 5 + +2010 Factiva, Inc. All rights reserved + +JPM-SDNYLIT-00008240 diff --git a/vision-fixhub/court-05/50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212.receipt.json b/vision-fixhub/court-05/50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8222e221d3be8192baa4127a5d61d3a016effa64 --- /dev/null +++ b/vision-fixhub/court-05/50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -150, + "dataset": "marble-joined", + "doc_id": "50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212", + "engine": "marble-apple-vision", + "event_count": 13, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "01b6a21f6e61741f620b8d8d17eb9c3a27ac8954a2bcda0861459be5432d746f", + "output_sha256": "ec9f3ea9abab59493a1e098d811b02e4b00cbbcca41887137de16f3a431ed387", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/50de972db3ef067a4576e51fef4a215f512aa90ac42dbc9f7b59149a6f88b1a8.md b/vision-fixhub/court-05/50de972db3ef067a4576e51fef4a215f512aa90ac42dbc9f7b59149a6f88b1a8.md new file mode 100644 index 0000000000000000000000000000000000000000..2b25aa8dbbd6f6529bb9abec61ef575303fd0436 --- /dev/null +++ b/vision-fixhub/court-05/50de972db3ef067a4576e51fef4a215f512aa90ac42dbc9f7b59149a6f88b1a8.md @@ -0,0 +1,385 @@ +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 771 +Filed 08/10/22 Page 1 of 7 +LCMCMAXT +3111 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-x +UNITED STATES OF AMERICA, +V. +20 CR 330 (AJN) +GHISLAINE MAXWELL, +Defendant. +-x +Before: +HON. ALISON J. NATHAN, +Jury Trial +New York, N.Y. +December 22, 2021 +3:41 p.m. +District Judge +APPEARANCES +DAMIAN +United States Attorney for the +Southern District of New York +BY: MAURENE COMEY +ALISON MOE +LARA POMERANTZ +ANDREW ROHRBACH +Assistant United States Attorneys +HADDON | +AND +Attorneys for Defendant +BY: JEFFREY S. PAGLIUCA +LAURA A. MENNINGER +-and- +BOBBI C. STERNHEIM +-and- +& GRESSER +BY: +CHRISTIAN R. EVERDELL +Also Present: Amanda Young, FBI +Paul Byrne, NYPD + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | +Document 771 Filed 08/10/22 Page 2 of 7 +LCMCMAXT +3112 +(Jury not present) +THE COURT: Good afternoon, everyone. We haven't +heard anything from the jury, so I think it is time to consider +putting in a note regarding tomorrow since we don't have a +response on that. So the note I have drafted, with your input, +let me know, +"Hello, jury. If your deliberations are not +completed today, do you wish to deliberate tomorrow, Thursday, +December 23rd?" And then I have a box for "yes" and a box for +"no." "Please check yes or no. If yes, what time would you +like to deliberate from? Blank a.m. to blank p.m. Judge +Nathan." +Any thoughts or requests? +MS. COMEY: Seems perfect. +MS. STERNHEIM: Fine. Thank you. +THE COURT: What I'll do is we'll send that in and I +think everybody just wait, my assumption is it will come right +back out and we'll reconvene. I'll see you in a moment. +(Recess) +THE COURT: As that went in, a note came out. So I +don't have a response yet, but I have a note. +"May we please have the following testimonies in a +binder." The first one is Jane, Wong, Kate. There is +something else written next to Jane. +MS. STERNHEIM: Judge, I'm not reading the note, but +they got Jane. It wasn't in a binder. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +LCMCMAXT +Document 771 Filed 08/10/22 Page 3 of 7 3113 +THE COURT: Well, fair enough. Fair enough. I don't +know if they're asking for another copy. +MS. STERNHEIM: Or with holes in it, at least. +THE COURT: I'll show it to you there. Next to Jane, +it says -- +. I think maybe, Ms. Sternheim, you've intuited. +In parentheses, it says, "Being returned," crossed out, and +then it says, "No." +MS. STERNHEIM: Judge, of the three testimonies they +got, Jane was the last and it was Juan in a binder. The other +two were in binders. +THE COURT: I see. +I see. I didn't know that. +MS. STERNHEIM: It was in the rush of trying to get it +to them quickly. +THE COURT: Well, we could dispute that, but -- so I +guess, because they didn't return it, I guess they are asking +for another copy, three-hole punched and in a binder, in +addition, Juan and Kate. My clerk will show you the note if +you'd like to see it. +MS. COMEY: That's fine, your Honor. I believe +Ms. Drescher is going to print out those transcripts right now +with the agreed-upon redactions and we'll hole punch them and +put them in binders. +THE COURT: Okay. I think the response is coming out, +so we'll just sit tight for a minute. +(Pause) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE +Document 771 Filed 08/10/22 Page 4 of 7 +LCMCMAXT +3114 +The response is, "No, thank you." Asterisk, "Jurors +have made plans for tomorrow." +So, we will get them what they've asked for as quickly +as possible. And then, everyone, please be ready to go at +4:25. +We'll bring them out for dismissal. +I had one quick additional point I wanted to make +about the request yesterday for the question regarding Annie's +testimony and the request from the defense was to also put in +the limiting instruction. I wanted to note that the limiting +instruction went in on the transcript of Annie's testimony, as +well. So they did have that. +All right. Anything to address, Ms. Comey? +MS. COMEY: No, your Honor. +THE COURT: Ms. Sternheim? +MS. STERNHEIM: No, thank you. +THE COURT: We'll see everyone at 4:25 unless we hear +anything further. As soon as you have the materials, give them +to +• please. Thank you. +(Recess) +THE COURT: Any matters to take up before we bring +them to dismiss them? +MS. COMEY: No, your Honor. +MS. STERNHEIM: No, thank you. +THE COURT: Okay. Bring in the jury, please. +(Continued on next page) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE +Document 771 Filed 08/10/22 Page 5 of 7 +LCMCMAXT +3115 +(Jury present) +THE COURT: Thank you, members of the jury. I did get +your note that you declined my invitation to deliberate +tomorrow. +We had assumed trial would be proceeding and I +wanted to give you the option to deliberate tomorrow, but +understand you have plans. +We will resume Monday at 9:00 a.m. Same instructions +as previously indicated. As soon as all 12 of you are there, +you may deliberate. Before then, please wait until all 12 of +you are there. +Please stay safe over the long weekend. Obviously +we've got the variant and I need all of you here and healthy on +Monday. So please take good care and take cautions. +Somewhat related to that, the district is going to +announce some new protocols on Monday, including specific mask +requirements. So the district is going to require everybody to +wear either N95s or KN95s or KF94s to be in the courthouse. +We'll supply those for you. We'll have supplies on Monday. +You're also welcome to take some for the long weekend if you'd +like those to help be cautious. +It's a long weekend, it's a holiday, it's imperative +that you continue to follow my orders regarding the rules in +this case as I know that you have, but I have to repeat it. +It's critical that you, outside of deliberations, don't discuss +this case with each other or anyone else. No consumption of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE +Document 771 Filed 08/10/22 Page 6 of 7 +LCMCMAXT +any media of any kind through any means about the case and no +communications through any means about the case. +Continue to +keep an open mind until you resume your deliberations on +Monday, the 12 of you. +If you have any issues that arise regarding either +COVID or any issues of concern, you contact +and +she'11 communicate to me if there are any issues. +I wish you a very happy holiday, a restful time with +your families, and we'll see you on Monday. +Thank you so much. +Happy holidays. +(Continued on next page) +3116 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +LCMCMAXT +Document 771 Filed 08/10/22 Page 7of7 +3117 +(Jury not present) +THE COURT: Any matters to take up, counsel? +MS. COMEY: No. Thank you, your Honor. +MS. STERNHEIM: No. Thank you. +THE COURT: You heard the announcement that's about to +be forthcoming regarding the masking rules. So that will be +true for everyone. +Come Monday, we'll have supplies if needed. +And please take my words of caution, as well. I need -- well, +I don't need all of you, but I need most of you back here on +Monday. In the meantime, happy holidays. See you Monday. +(Adjourned to December 27, 2021 at 9:00 a.m.) +* * * \ No newline at end of file diff --git a/vision-fixhub/court-05/50de972db3ef067a4576e51fef4a215f512aa90ac42dbc9f7b59149a6f88b1a8.receipt.json b/vision-fixhub/court-05/50de972db3ef067a4576e51fef4a215f512aa90ac42dbc9f7b59149a6f88b1a8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cc8e587ac1da0c518c80bfc2f459886cb98035ca --- /dev/null +++ b/vision-fixhub/court-05/50de972db3ef067a4576e51fef4a215f512aa90ac42dbc9f7b59149a6f88b1a8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -428, + "dataset": "marble-joined", + "doc_id": "50de972db3ef067a4576e51fef4a215f512aa90ac42dbc9f7b59149a6f88b1a8", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "dca73d94337c37f91862cd12b82c6e2b0d6b387963cd40e1126b5e79a18c8e72", + "output_sha256": "6e9a63b127f6b82c25031ac93ab0fef850e9556bd63a161ee8d0cf7e7c462fbc", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/50e1f78247043993240a647ff46598f7d6e3d705822d3028cb7d10088315acd3.md b/vision-fixhub/court-05/50e1f78247043993240a647ff46598f7d6e3d705822d3028cb7d10088315acd3.md new file mode 100644 index 0000000000000000000000000000000000000000..45de4bd75b8c9eff954e9392aa23ce6c123095bd --- /dev/null +++ b/vision-fixhub/court-05/50e1f78247043993240a647ff46598f7d6e3d705822d3028cb7d10088315acd3.md @@ -0,0 +1,20 @@ +Case 1:22-cV-10904-JSR Document 265-67 Filed 08/07/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 265-67 Filed 08/07/23 Page 2 of 2 +Armine, Cynthia[cynthia.armine@jpmchase.com]; Cutler, Stephen +M[stephen.m.cutler@jpmorgan.com]; Shenker, Nina O[nina.o.shenker@jpmorgan.com]; Dellosso, +Donna[Donna.Dellosso@jpmorgan.com] +Duffy, John Rljohn.r.duffy@jpmorgan.com]; Dilorio, Phil[phil.diiorio@jpmorgan.com] +From: Erdoes, Mary E|/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT/CN=RECIPIENTS/CN=MARY.ERDOES] +Fri 8/9/20139:14:57 PM (UTC) +Subject: Privileged and confidential follow up +Re our client exit, the conversation went well and was very professional. I suspect the call last night +might have helped. +It will move in an orderly process. +John did an excellent job. +ME + +JPM-SDNYLIT-00150176 diff --git a/vision-fixhub/court-05/50e1f78247043993240a647ff46598f7d6e3d705822d3028cb7d10088315acd3.receipt.json b/vision-fixhub/court-05/50e1f78247043993240a647ff46598f7d6e3d705822d3028cb7d10088315acd3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d2d69e0ed432ab955392b070ba5bcd5679d1e02c --- /dev/null +++ b/vision-fixhub/court-05/50e1f78247043993240a647ff46598f7d6e3d705822d3028cb7d10088315acd3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "50e1f78247043993240a647ff46598f7d6e3d705822d3028cb7d10088315acd3", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "e3702d3fd2529143ec0c500f2aa1511e7550e2f9de9017a9bd18a4d36b5bfff0", + "output_sha256": "35ff79f0351fb88d46fe08551d408e451702c601d744cceb379ed3978db32817", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191.md b/vision-fixhub/court-05/50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191.md new file mode 100644 index 0000000000000000000000000000000000000000..dce0ec4855cad9dda7eb9254c2fc9ec9841a4c54 --- /dev/null +++ b/vision-fixhub/court-05/50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191.md @@ -0,0 +1,938 @@ +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 1 of 30 +IN THE UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +JANE DOE, individually and on behalf of +all others similarly situated, +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +Case Number: 1:22-cv-10019-JSR +Case Number: 1:22-cv-10904-JSR +JAMES EDWARD STALEY +Third-Party Defendant. +THIRD-PARTY DEFENDANT JAMES STALEY'S +MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 2 of 30 +TABLE OF CONTENTS +PRELIMINARY STATEMENT +1 +BACKGROUND +..2 +LEGAL STANDARD +6 +ARGUMENT.. +...7 +I. The Indemnity and Contribution Claims (Counts I and II) Fail as a Matter of Law +.. 7 +A. +JPMorgan's Shotgun Pleading Warrants Dismissal of Counts I and II +...7 +B. +There Is No Right To Indemnity or Contribution Under the TVPA +8 +C. JPMorgan's Indemnification Claim Fails for Additional Reasons. +11 +i. Mr. Staley's Contractual Indemnity Precludes Common Law Indemnity Here... 12 +ii. JPMorgan Fails To State a Claim for Indemnification Because USVI and Doe +Seek To Hold JPMorgan Directly, Not Vicariously, Liable +13 +ili. JPMorgan's Indemnification Claim Fails Because JPMorgan's Alleged +Misconduct Was Outside the Scope of Mr. Staley's Responsibilities +D. JPMorgan's Contribution Claim Fails +14 +15 +16 +E. JPMorgan Cannot Receive Contribution for Punitive Damages +II. Because the Indemnity and Contribution Claims Fail, the Employment Claims Should Be +Dismissed For Non-Compliance with Rule 14 +III. The Employment Claims Fail on the Merits +A. The Employment Claims Are Time-Barred +B. +The Employment Claims Are Improperly Pleaded +i. JPMorgan Fails to State a Claim for Breach of Fiduciary Duty +18 +18 +. 20 +• 21 +ii. JPMorgan Fails to State a Claim Under the Faithless Servant Doctrine +... 23 +CONCLUSION +. 25 +ii + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 3 of 30 +TABLE OF AUTHORITIES +CASES +Access 4 All, Inc. v. Trump Int'l Hotel & Tower Condo., +2007 WL 633951 (S.D.N.Y. Feb. 26, 2007) +ALP, Inc. v. Moskowitz, 167 N.Y.S.3d 45 (Ist Dep't 2022) +V. +, 397 F.3d 515 (7th Cir. 2005) +v. Loc. Union No. 3, 751 F.2d 546 (2d Cir. 1984).. +Aozora Bank Ltd. v. Deutsche Bank Sec., 29 N.Y.S.3d 10 (Ist Dep't 2016). +Ashcroft v. Iqbal, 556 U.S. 662 (2009)... +Babbitt v. Koeppel Nissan, Inc., 2020 WL 3183895 (E.D.N.Y. June 15, 2020) +Barmapov v. Amuial, 986 F.3d 1321 (11th Cir. 2021) ... +Baron v. Grant, 852 N.Y.S. 374 (2d Dep't 2008) +Bd. of Managers of the 125 N. 10th Condo. v. 125North10, LLC, +55 N.Y.S.3d 374(2d Dep't 2017)......... +Bellis v. Tokio Marine & Fire Ins. Co., 2002 WL 193149 (S.D.N.Y. Feb. 7, 2002) +Cannariato v. Cannariato, 24 N.Y.S.3d 214 (2d Dep't 2016).. +Cisse v. Annucci, 2022 WL 1183274 (N.D.N.Y. Apr. 21, 2022) .. +v. S.A.C. Trading Corp., 711 F.3d 353 (2d Cir. 2013). +Corley v. Country Squire Apartments, Inc., 80 N.Y.S.2d 900 (2d Dep't 2006). +Don Prods./Kingvision v. I +1. 950 F. Supp. 286 (E.D. Cal. 1996) +Ebel v. G/O Media, Inc., 2021 WL 2037867 (S.D.N.Y. May 21, 2021) +Ellul v. Congregation of Christian Bros., 774 F.3d 791 (2d Cir. 2014) +Felice v. Delporte, 524 N.Y.S.2d 919 (4th Dep't 1988). +Feltenstein v. City Sch. Dist. of New Rochelle, +2015 WL 10097519 (S.D.N.Y. Dec. 18, 2015). +Genesee/Wyoming YMCA v. Bovis Lend Lease LMB, Inc., +951 N.Y.S.2d 768 (4th Dep't 2012)..... +10 +18,19 +8,10 +.. 8 +19 +6 +7,22 +8 +14 +13 +15 +19 +8 +...7 +14 +.. 7 +24,25 +18 +17 +...9 +13 +iii + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 4 of 30 +Grewal v. Cuneo, 2016 WL 308803 (S.D.N.Y. Jan. 25, 2016) +Herman v. RSR Sec. Servs. Ltd., 172 F.3d 132 (2d Cir. 1999). +Honeywell, Inc. v. J.P. Maguire Co., 1999 WL 102762 (S.D.N.Y. Feb. 24, 1999) +In re Bernard L. Madoff Inv. Sec. LLC., 721 F.3d 54 (2d Cir. 2013). +25 +8,10 +12 +. 8 +Kramer v. Time Warner Inc., 937 F.2d 767 (2d Cir. 1991). +Lamela v. Verticon, Ltd., 128 N.Y.S.3d 91 (3d Dep't 2020) +..3 +12,13 +. 23 +Laub v. Faessel, 745 N. Y.S.2d 534 (Ist Dep't 2002). +Le Metier Beauty Inv. Partners LLC v. Metier Tribeca, LLC, +2015 WL 7078641 (S.D.N.Y. Nov. 12, 2015)... +Levy v. Young Adult Inst., Inc., 103 F. Supp. 3d 426 (S.D.N.Y. 2015) +Litle v. Arab Bank, PLC, 611 F. Supp. 2d 233 (E.D.N.Y. 2009)... +McCarthy v. Turner Constr., Inc., 953 N.E.2d 794 (N.Y. 2011). +v. Levi & Korsinsky, LLP, 2021 WL 535599 (S.D.N.Y. Feb. 12, 2021)... +Nassau Roofing & Sheet Metal Co. v. Facilities Dev. Corp., 523 N.E.2d 803 (N.Y. 1988) +Neurological Surgery, P.C. v. MLMIC Ins. Co., 175 N. Y.S.3d 266 (2d Dep't 2022)... +. 17 +19,20,21 +• 10 +13 +..25 +16 +Noble v. Weinstein, 335 F. Supp. 3d 504 (S.D.N.Y. 2018) .. +.9 +Nw. Airlines, Inc. v. Transp. Workers Union of Am., 451 U.S. 77 (1981). +9,10,11 +Paulsen v. Stifel, Nicolaus & Co., 2019 WL 2415213 (S.D.N.Y. June 4, 2019). +3 +Petrosurance, Inc. v. Nat'l Ass'n of Ins. Comm'rs, 888 F. Supp. 2d 491 (S.D.N.Y. 2012). +Phansalkar v. Andersen Weinroth & Co., L.P.., 344 F.3d 184 (2d Cir. 2003). +Poller v. BioScrip, Inc., 974 F. Supp. 2d 204 (S.D.N.Y. 2013). +Rombach v. Chang, 355 F.3d 164 (2d Cir. 2004). +Rubio v. BSDB Mgmt. Inc., 2021 WL 102651 (S.D.N.Y. Jan. 12, 2021). +Scalia v. Emp. Sols. Staffing Grp., LLC, 951 F.3d 1097 (9th Cir. 2020) +Sea Trade Mar. Corp. v. Coutsodontis, 744 F. App'x 721 (2d Cir. 2018) +..6 +24,25 +22 +.20 +21,24 +11 +23 +Serv. Sign Erectors Co. v. Allied Outdoor Advert., Inc., 573 N. Y.S.2d 513 (Ist Dep't 1991)..... 12 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 5 of 30 +Starr Int'l Co. v. Fed. Rsrv. Bank of N.Y., 906 F. Supp. 2d 202 (S.D.N.Y. 2012) +State Nat'l Ins. Co. v. Certain Interested Underwriters at Lloyd's London, +2022 WL 4547444 (S.D.N.Y. Sept. 29, 2022). +Tex. Indus., Inc. v. Radcliff Materials, Inc., 451 U.S. 630 (1981). +Tobia v. United Grp. of Cos., Inc., 2016 WL 5417824 (N.D.N.Y. Sept. 22, 2016). +U.S. Fire Ins. Co. v. Raia, 942 N.Y.S.2d 543 (2d Dep't 2012) +United States. ex rel. Kester v. Novartis Pharms. Corp., +23 F. Supp. 3d 242 (S.D.N.Y. 2014)....... +12 +17 +8,9,11 +. 22 +22 +Yukos Cap. S.A.R.L. v. L +1, 977 F.3d 216 (2d Cir. 2020). +Ziglar v. Abbasi, 582 U.S. 120 (2017). +• 7,22 +21,23,24 +9 +Zino Davidoff S.A. v. Selective Distrib. Int'l Inc.., 2013 WL 1245974 (S.D.N.Y. Mar. 8, 2013)... 7 +Zohar CDO 2003-1, Ltd. v. Patriarch Partners, LLC, +286 F. Supp. 3d 634 (S.D.N.Y.2017)..... +17,18 +STATUTES +18 U.S.C. § 1591 +28 U.S.C. § 1367. +N.Y. C.P.L.R. $ 213. +N.Y. C.P.L.R. § 1401 +4,9 +17 +19 +15 +RULES +Federal Rule of Civil Procedure 8 +Federal Rule of Civil Procedure 9(b) +Federal Rule of Civil Procedure 10(b). +Federal Rule of Civil Procedure 12(b)(6) +Federal Rule of Civil Procedure 14 +Federal Rule of Civil Procedure 18 +Federal Rule of Evididence 201(b)(2) . +7,8 +.. passim +.. 7,8 +.. 6, 18 +16,17 +... 17 +... 3 +V + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 6 of 30 +PRELIMINARY STATEMENT +In November 2022, Plaintiff Jane Doe sued JPMorgan Chase Bank, N.A. ("JPMorgan"). +Her complaint asserts that JPMorgan ignored Jeffrey's Epstein's sex-trafficking crimes to retain +him as a lucrative banking client, which in turn enabled Epstein to victimize Doe and others. The +Government of the U.S. Virgin Islands ("USVI") filed its own suit alleging that JPMorgan enabled +Epstein to operate his enterprise out of its territory. +Confronted with documented failures in its anti-money-laundering compliance (along with +a history of such failures in other matters), JPMorgan sought to change the narrative and deflect +blame by pulling Jes Staley, one of its former employees, into the two cases via two third-party +complaints. The bank claims its fifteen-year-long relationship with Epstein was in fact all Mr. +Staley's fault and that he must pay the plaintiffs' damages. JPMorgan further seeks to claw back +years of compensation from Mr. Staley, plus damages for "harm" to its already-sullied reputation. +But JPMorgan has failed to state any viable claim against Mr. Staley. Indeed, the thirdparty complaints, while creating provocative media fodder, never explain how an employee who +is not alleged to have had decision-making authority over Epstein's accounts-and who is not +alleged to have seen any of the suspicious account activity that other JPMorgan employees +ignored caused the plaintiffs' alleged injuries. +Each of JPMorgan's four claims is legally deficient. Neither the indemnification claim +(Count I) nor contribution claim (Count II) is actionable. +First, the indemnification and +contribution claims fail because the bank engages in defective, shotgun pleading that improperly +tries to combine multiple claims (all lacking) into two cursory counts. Second, the indemnification +and contribution claims fail to the extent that they are based on the plaintiffs' claims under the +Trafficking Victims Protection Act ("TVPA") because that statute does not permit contribution or +1 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 7 of 30 +indemnification. Third, the indemnification claim fails because JPMorgan does not (and cannot) +plausibly allege that its liability is solely attributable to Mr. Staley's conduct. Fourth, JPMorgan's +contractual indemnification of Mr. Staley as one of its officers bars the bank's indemnification +claim against him under black-letter New York law. Fifth, JPMorgan fails to identify any distinct +injury for which it seeks contribution. +The two additional claims—-alleging that Mr. Staley breached his fiduciary duty to the bank +during his employment and violated the "faithless servant doctrine" ("Employment Claims" at +Counts III and IV)— also fail as a matter of law. They do not meet the requirements for impleading +under Rule 14. And, for various reasons, they are deficient on the merits. +Whether or not JPMorgan is liable to Doe and the USVI remains to be seen. What is certain +is that the bank cannot treat Mr. Staley as its publie relations shield by asserting claims that lack +any legal (or factual) basis. +BACKGROUND +Third-Party Defendant James Edward "Jes" Staley is a former JPMorgan executive.' He +began his career at the company in 1979 and +up the ranks to the highest levels of management. +See JPMorgan's Third-Party Compl. ("Complaint" or TPC"') 9| 16.- From 2001 to 2009, Mr. Staley +was the Chief Executive Officer of the bank's Asset Management group. Starting in 2009, Mr. +Staley moved to the Corporate and Investment Banking division, where he served as its Chief +Executive Officer and reported to Jamie Dimon, the bank's President and Chairman. Id. Per its +" Although he vigorously denies many of the allegations in this case, Mr. Staley treats as true the +Third-Party Complaint's factual allegations for purposes of this motion. +2 See 22-cv-10019, ECF No. 59, and 22-cv-10904, ECF No. 70. Although JPMorgan filed two +third-party complaints, one in each of the cases by USVI and Doe, Mr. Staley addresses them +together in this memorandum given their overwhelming overlap. Only when content from the +complaints differ will this filing distinguish between them (e.g., "Doe TPC" or "USVI TPC"). +2 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 8 of 30 +bylaws, JPMorgan agreed to indemnify corporate officers such as Staley "to the fullest extent +permitted by applicable law." Ex A at 7.3 +Mr. Staley left JPMorgan in January 2013, eventually joining its competitor Barclays as +Chief Executive Officer. TPC 9|21. Upon departing JPMorgan, Mr. Staley allegedly signed an +Agreement and Release in which he agreed to be bound by JPMorgan's code of conduct even after +he left employment at the bank. Id. +Since November 2022, JPMorgan has been embroiled in lawsuits relating to the bank's +alleged involvement with Jeffrey Epstein and his sex-trafficking enterprise. These suits began +when Plaintiff "Jane Doe" sued the bank on November 24, 2022, with the U.S. Virgin Islands +filing a similar complaint about a month later. +Doe's Allegations: Doe's class action complaint alleges that JPMorgan supplied the +"financial lifeblood" of Epstein's sex trafficking enterprise by providing him and his associates +banking services and access to exorbitant amounts of cash from 1998 through August 2013. First +Am. Compl., 22-cv-10019 ("Doe FAC"') at 1-2, ECF No. 36. Doe claims that JPMorgan provided +these services even though it knew that Epstein was engaged in sex trafficking. Id. While Doe +alleges that JPMorgan's knowledge stemmed in part from what Mr. Staley observed, she alleges a +plethora of other ways that JPMorgan knew of Epstein's misconduct completely independent of +Mr. Staley's observations: (1) Epstein's widely reported arrest in 2006 that resulted in his +incarceration and registering as a sex offender, id. I 42, 79-81, 190-99, 216; (2) Epstein's +3 This Court can consider matters appropriate for judicial notice when reviewing this motion to +dismiss. Kramer v. Time Warner Inc., 937 F.2d 767, 773 (2d Cir. 1991). JPMorgan's bylaws +qualify because they are "not subject to reasonable dispute" and "can be accurately and readily +determined from sources whose accuracy cannot reasonably be questioned." Fed. R. Evid. +201(b)(2); see also Paulsen v. Stifel, Nicolaus & Co., 2019 WL 2415213, at *3 (S.D.N.Y. June 4, +2019) ("Courts in this Circuit have routinely taken notice of public disclosure documents filed +with the SEC that are proffered as part of [a] motion to dismiss.") (collecting cases). +3 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 9 of 30 +involvement in civil lawsuits, which resulted in payments that were sent from JPMorgan bank +accounts, id. 11 83, 200, 207-11; and (3) Epstein's suspicious transaction history that included +large cash withdrawals, wires to women with Eastern European surnames, and payments to known +conspirators, id. 11 182, 261-62. Doe alleges that she was trafficked by Epstein and unnamed +associates. Id. 11| 159, 237. +Doe also alleges that JPMorgan skirted banking regulations to conceal its involvement with +the trafficking enterprise. Id. 1| 178. The bank, for example, neglected to file Suspicious Activity +Reports (SARs) required by anti-money laundering laws and failed to adequately conduct "Know +Your Customer" due diligence. Id. 11 180-82, 271. Doe alleges that, had the bank followed these +standard practices, Epstein's conduct would not have flown under the radar for years. Id. 9 272. +Awareness of Epstein's criminal conduct reached the bank's highest levels, including CEO Jamie +Dimon, id. 911 216-17, and the CEO of private banking, Mary Erdoes, who nevertheless advocated +to keep Epstein as a client, id. 19 161, 214. JPMorgan continued to serve Epstein for the financial +benefits to the bank, such as access to his network of wealthy potential customers. Id. 19 164-71. +Notably, Doe alleges that JPMorgan's misconduct extended beyond 2013—when Mr. +Staley left the bank. In particular, JPMorgan refused to file SARs and continued to recommend +Epstein as a client to others. Id. 4 187. +Four of Doe's claims survived JPMorgan's motion to dismiss: (1) negligently failing to +prevent physical harm; (2) negligently failing to exercise reasonable care as a banking institution +providing non-routine banking; (3) knowingly benefitting from participating in a sex-trafficking +venture in violation of 18 U.S.C. § 1591(a)(2); and (4) obstructing enforcement of the TVPA in +violation of 18 U.S.C. § 1591(d). Order on Motion To Dismiss, 22-cv-10019, ECF No. 66. +4 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 10 of 30 +USVI's Allegations: USVI's complaint makes similar allegations. It claims that JPMorgan +provided financial services and cash to Epstein even though the bank knew of his sex trafficking +through various means, including (1) Epstein's suspicious transactions, such as wires to victims, +withdrawals of large sums of cash, and payments to known recruiters, see USVI First Am. Compl., +22-cv-10904 ("USVI FAC") 1142, 66-67, and (2) public reports of Epstein's arrest and +misconduct, id. 11 36-40, 48. USVI alleges that internal messages at the bank show that JPMorgan +employees were aware of these facts and that this knowledge reached the highest levels of the +bank, including CEO Jamie Dimon, id. 11l 44-51, 86. And JPMorgan's failure to follow required +banking practices permitted the sex trafficking conspiracy to operate. Id. 11 76-78, 82. Following +the Court's order on JPMorgan's motion to dismiss, the only remaining claim brought by the USVI +arises under the TVPA. Order on Motion To Dismiss, 22-cv-10904, ECF No. 90.4 +JPMorgan's third-party complaints: JPMorgan filed a third-party complaint in each case. +Both complaints plead identical claims for common law indemnification, contribution, breach of +fiduciary duty, and breach of the faithless servant doctrine. +JPMorgan first brings omnibus claims for contribution and indemnification that seek to +hold Mr. Staley liable for all of the claims that Doe and the USVI bring against JPMorgan, lumping +together Doe's common law and federal statutory claims. JPMorgan alleges, despite contrary +assertions in the plaintiffs' complaints, that the plaintiffs seek to hold the bank liable "based in +substantial part on the acts or omissions of Staley." TPC 9| 46. Thus, it alleges, if JPMorgan is +4 Despite the Court's dismissal order, USVI has filed a second amended complaint that repleads +all the original claims (even those that were dismissed). This motion will address only the claim +in the USVI's operative complaint that was not dismissed. While reserving all rights, Mr. Staley +notes that, even if JPMorgan's complaint reached the repleaded claims, the same analysis would +apply because there is no conflict between New York and Virgin Island law on contribution and +indemnification. +5 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 11 of 30 +held liable, then Mr. Staley must pay the bank "for all damages awarded" to the plaintiffs by means +of indemnification and/or contribution. Id. I 48, 55. +JPMorgan's claims for breach of fiduciary duty and breach of the faithless servant doctrine +rely on the duties he owed the bank as an employee and his alleged agreement to abide by the +bank's Code of Conduct, which he purportedly signed each year between 2006 and 2012, id. 19 18- +19. JPMorgan alleges that Mr. Staley breached his duties by acting against the interests of the +bank, "failing to report" or "fraudulently concealing" information about Epstein, "affirmatively +misrepresent[ing]" facts about his personal interactions with Epstein, and "repeatedly provid[ing] +misleading information to JPMC when vouching for Epstein's character and conduct." Id. 99| 59- +61, 74-77. As for the breach-of-fiduciary-duty claim, JPMorgan seeks damages related to (1) the +"cost of defending," and "adverse publicity from," these lawsuits, and (2) "any amounts in +damages" that JPMorgan might have to pay out to the plaintiffs. Id. 9 64-65. For the faithless +servant claim, JPMorgan seeks disgorgement of Mr. Staley's compensation from the amorphous +"period of his disloyalty." Id. 91 78. The bank also seeks punitive damages. Id. 19 66, 79. +LEGAL STANDARD +Under Federal Rule of Civil Procedure 12(b)(6), "a complaint must contain sufficient +factual matter, accepted as true, to state a claim to relief that is plausible on its face." Ashcroft v. +Iqbal, 556 U.S. 662, 678 (2009) (internal quotation marks omitted). "A claim has facial +plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable +inference that the defendant is liable for the misconduct alleged." Id. While the Court must draw +all reasonable inferences in the complaint's favor, it need not accept as true "mere conclusions of +law or unwarranted deductions of fact." Petrosurance, Inc. v. Nat'l Ass'n of Ins. Comm'rs, 888 F. +Supp. 2d 491, 502 (S.D.N.Y. 2012) (internal quotation marks omitted). +6 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 12 of 30 +"Claims that sound in fraud are subject to the heightened pleading standards of" Rule 9(b). +v. S.A.C. Trading Corp., 711 F.3d 353, 359 (2d Cir. 2013). Such allegations must be "stated +with particularity," meaning that they must "specify the time, place, speaker, and content of [any] +alleged misrepresentations," "explain how the misrepresentations were fraudulent," and "plead +those events which give rise to a strong inference that the defendant had an intent to defraud, +knowledge of the falsity, or a reckless disregard for the truth." Id. (cleaned up). In other words, +"a plaintiff [must] set forth the who, what, when, where and how of" alleged fraudulent conduct. +United States. ex rel. Kester v. Novartis Pharms. Corp., 23 F. Supp. 3d 242, 252 (S.D.N.Y. 2014). +Rule 9(b) applies to fiduciary-duty claims that sound in fraud. Babbitt v. Koeppel Nissan, Inc., +2020 WL 3183895, at *5 (E.D.N.Y. June 15, 2020). +ARGUMENT +I. The Indemnity and Contribution Claims (Counts I and II) Fail as a Matter of Law. +A. JPMorgan's Shotgun Pleading Warrants Dismissal of Counts I and II. +As an initial matter, the claims for indemnification and contribution are procedurally +improper because they violate Rules 8 and 10(b) by lumping together all of the plaintiffs" +outstanding claims under singular causes of action for contribution and common law +indemnification. For each of these claims, JPMorgan seeks relief under two distinct bodies of +law—federal law for the plaintiffs' TVPA claims, and state law for Doe's common-law claims +even though these claims require distinct analyses. See Don +Prods./Kingvision v. +950 F. Supp. 286, 288-89 (E.D. Cal. 1996) (noting that right to indemnity for claim arising under +federal law must be treated separately from right relating to state-law claim); Zino Davidoff S.A. +v. Selective Distrib. Int'l Inc., 2013 WL 1245974, at *4 (S.D.N.Y. Mar. 8, 2013) ("Whether a +defendant who incurs liability under a federal statute may pursue either contribution or +indemnification is a question of federal law."). This haphazard style of pleading is "flatly +7 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 13 of 30 +forbidden by the spirit, if not the letter, of" Rules 8(a)(2) and 10(b), because, among other vices, +it confuses the parties, courts, and factfinders and hinders cogent analysis of each claim +independently. Barmapov v. Amuial, 986 F.3d 1321, 1324 (11th Cir. 2021) (citation omitted); +Cisse v. Annucci, 2022 WL 1183274, at *2 (N.D.N.Y. Apr. 21, 2022) (identifying failure to +separate "into a different count each cause of action or claim for relief" as "shotgun pleading" +(citation omitted)). The Court should dismiss the indemnification and contribution claims for this +reason alone. +B. There Is No Right To Indemnity or Contribution Under the TVPA. +JPMorgan's indemnification and contribution claims also fail to the extent that they seek +to offload liability for the plaintiffs' TVPA damages because the TVPA does not permit claims for +indemnification or contribution against third parties. When an underlying claim arises under +federal law, "there is no claim for contribution [or indemnification] unless the operative federal +statute provides one." In re Bernard L. Madoff Inv. Sec. LLC., 721 F.3d 54, 65 (2d Cir. 2013); see +Herman v. RSR Sec. Servs. Ltd., 172 F.3d 132, 144 (2d Cir. 1999) (affirming dismissal of New +York state-law claims for contribution and indemnification for liability under Fair Labor Standards +Act). Such claims are available only through (1) "the affirmative creation of a right of action by +Congress, either expressly or by clear implication," or (2) "the power of federal courts to fashion +a federal common law of contribution [or indemnification]." Tex. Indus., Inc. v. Radcliff Materials, +Inc., 451 U.S. 630, 638 (1981).S Yet courts have been particularly "reluctant to recognize a right +of contribution [or indemnification] as a matter either of federal common law or of statute." +, 397 F.3d 515, 523 (7th Cir. 2005) (collecting cases). +5 While these cases address contribution, their "rationale • +• extends to claims for +indemnification." +v. Loc. Union No. 3, 751 F.2d 546, 548 (2d Cir. 1984). +8 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 14 of 30 +The TVPA does not mention contribution or indemnification. To determine whether a +statute nonetheless contains an implied right, courts have traditionally looked to "the language of +the statute itself, its legislative history, the underlying purpose and structure of the statutory +scheme, and the likelihood that Congress intended to supersede or to supplement existing state +remedies." Nw. Airlines, Inc. v. Transp. Workers Union of Am., 451 U.S. 77, 91 (1981). While +the sole consideration is Congress's apparent intent, in recent decades the Supreme Court has +signaled that courts should adopt "a far more cautious course before finding implied causes of +action." See Ziglar v. Abbasi, 582 U.S. 120, 132 (2017). +First, as mentioned, the TVPA provisions invoked by the plaintifis are completely silent +on the issue. See generally 18 U.S.C. § 1591. This omission is "significant" given that Congress +certainly knows how to unambiguously create such rights. See Nw. Airlines, 451 U.S. at 91-92 & +n.24 (contrasting § 11(f) of the Securities Act of 1933, where Congress did so); Texas Indus., 451 +U.S. at 640, n.11 (same). And this silence rings loudly given that Congress has routinely amended +the TVPA since its enactment in 2000 and yet has never included such rights. Simply put, if +Congress had wanted to include indemnification and contribution, it would have.® +Second, causes of action for contribution or indemnification would cut against the TVPA's +mission to protect trafficking victims. Noble v. Weinstein, 335 F. Supp. 3d 504, 515 (S.D.N.Y. +2018) (explaining that civil remedies portion of TVPA serves "the remedial purpose of *enhancing +... protections of trafficking victims"') (quoting Trafficking Victims Protection Reauthorization +" The Supreme Court has also suggested that the lack of an express right to contribution or +indemnification can be "dispositive" unless "the language of the statutes indicates that they were +enacted for the special benefit of a class of which petitioner is a member." Nw. Airlines, 451 U.S. +at 91-92. Here, JPMorgan is not among the class that the TVPA is intended to protect, which +consists of trafficking victims. Rather, it is the party "whose conduct the statute was intended to +regulate." Feltenstein v. City Sch. Dist. of New Rochelle, 2015 WL 10097519, at *3 (S.D.N.Y. +Dec. 18, 2015) (citation omitted) (rejecting indemnity and contribution under the ADA). +9 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 15 of 30 +Act of 2003, 117 Stat. 2878, § 4 (effective Dec. 19, 2003)). As evident in this litigation, such +claims serve to only to complicate and add expense to victims' suits. See Litle v. Arab Bank, PLC, +611 F. Supp. 2d 233, 241 (E.D.N.Y. 2009) (finding right of contribution under Anti-Terrorism Act +would not further goal of compensating victims of terrorism because it would add expense to +litigation); +397 F.3d at 523 ("[A]ll that a right of contribution does is add to the costs +of litigation, and so unless there is a compelling reason to suppose that the legislature would want +such a right to be enforced... it will not be." (citation omitted)). And to the extent that the statute +is intended to deter would-be traffickers, permitting indemnification or contribution claims would +undermine that purpose. See +1, 397 F.3d at 523 (reasoning that absence of contribution +or indemnification to divide damages among coconspirators itself "performs [a] deterrent +function" for would-be violators who must risk being the unlucky one saddled with liability). +Third, the TVPA's remedial scheme makes clear that Congress did not intend to include +rights to contribution or indemnity. Courts have routinely cautioned against creating any federal +common-law rights of indemnity or contribution in areas where Congress has created +comprehensive legislative remedies." Access 4 All, Inc. v. Trump Int'l Hotel & Tower Condo., +2007 WL 633951, at *7 (S.D.N.Y. Feb. 26, 2007); Nw. Airlines, 451 U.S. at 93-94. The TVPA +presents such a comprehensive scheme. Along with criminal punishments, it provides for various +civil causes of action. And the "express provision for private enforcement in certain carefully +defined circumstances ... strongly counsels against judicially engrafting additional remedies." +Herman, 172 F.3d at 144. Indeed, it is not the Court's "place simply to alter the balance struck by +Congress" in determining how damages should be apportioned. Nw. Airlines, 451 U.S. at 98. +Fourth, the relevant legislative history in the TVPA is silent on indemnity and contribution, +showing that Congress did not even contemplate, let alone intend, for such rights. Without express +10 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 16 of 30 +language or even a hint of intent, "the essential predicate for implication of a private remedy simply +does not exist" here. Id. at 94. +Further, it would be improper to craft such a remedy from federal common law. The +situations in which such judicial legislating is welcome are "few and restricted," Texas Indus., 451 +U.S. at 640, and they generally fall into one of two categories: (1) when "a federal rule is necessary +to protect a uniquely federal interest," or (2) when "Congress has given the court the power to +develop substantive law." Id. (cleaned up). Neither applies here. A defendant's "right of recovery +from another [potential] wrongdoer ... does not implicate any [federal] interests." Scalia v. Emp. +Sols. Staffing Grp., LLC, 951 F.3d 1097, 1105 (9th Cir. 2020). And there is no indication that +Congress "has given the courts the power to develop substantive law" in the area of sex-trafficking +enforcement, as it has in admiralty law, for example. Tex. Indus., 451 U.S. at 640. +Since there is no hint that Congress intended for there to be a right of contribution or +indemnification under the TVPA, and this issue does not implicate a federal interest or area of law +expressly left to the courts to develop, the Court should not imply such causes of action here. +JPMorgan's claims for indemnification and contribution arising under the TVPA—which include +all of the claims alleged in the USVI FAC-therefore fail. +C. JPMorgan's Indemnification Claim Fails for Additional Reasons. +JPMorgan's claim for indemnification fails for three other reasons: (1) JPMorgan's +contractual indemnity of Mr. Staley precludes any claim for common law indemnification in favor +of the bank; (2) both Doe's and USVI's complaints allege that JPMorgan was directly, not +11 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 17 of 30 +vicariously, liable for the misconduct; and (3) JPMorgan fails to allege that the decisions that +caused plaintiffs' injuries were solely within Mr. Staley's province at the bank.? +i. Mr. Staley's Contractual Indemnity Precludes Common Law Indemnity +Here. +Under black-letter New York law, contractual indemnity between parties flowing only in +one direction extinguishes common law indemnity flowing in the other direction. Serv. Sign +Erectors Co. v. Allied Outdoor Advert., Inc., 573 N.Y.S.2d 513, 514 (Ist Dep't 1991) ("With the +subject of indemnification clearly contemplated and expressly addressed by ….. contract, we hold +that under these circumstances there could only be a one-way obligation to indemnify by ... the +indemnitor, and any reciprocal obligation is extinguished."); accord Lamela v. Verticon, Ltd., 128 +N.Y.S.3d 91, 94 (3d Dep't 2020) (collecting cases); Honeywell, Inc. v. J.P. Maguire Co., 1999 +WL 102762, at *6 (S.D.N.Y. Feb. 24, 1999). +Here, JPMorgan agreed to indemnify Mr. Staley-as an officer and employee to the +"fullest extent" permitted by law. Ex. A [Section 5.01 of 2004 Bylaws]. These bylaws serve as a +contract between the company and its officers. But nowhere in the bylaws or otherwise did Mr. +Staley agree to indemnify JPMorgan. Since the parties agreed that JPMorgan would indemnify +Mr. Staley without a reciprocal right to indemnification for the bank, the common law +indemnification claim benefitting JPMorgan is foreclosed. +" Mr. Staley assumes that if the Court were to imply a cause of action for contribution and +indemnification under the TVPA, it would find that New York state law supplies the rule of +decision. See Starr Int'l Co. v. Fed. Rsrv. Bank of N.Y., 906 F. Supp. 2d 202, 233-34 (S.D.N.Y. +2012). Since Doe's common law claims are likewise analyzed under New York law, the Cour +an analyze the viability of these claims together +12 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 18 of 30 +ii. JPMorgan Fails To State a Claim for Indemnification Because USVI and +Doe Seek To Hold JPMorgan Directly, Not Vicariously, Liable. +Even if common law indemnification were available, the claim still fails because the +plaintiffs' complaints seek to hold the bank liable for its own actions, not as Mr. Staley's employer. +Under New York law, a "party cannot obtain common-law indemnification unless it has been held +to be vicariously liable without proof of any negligence ... on its own part." McCarthy v. Turner +Constr., Inc., 953 N.E.2d 794, 801 (N.Y. 2011); see Lamela, 128 N.Y.S. 3d at 94 (common law +indemnification is available only "in favor of' one who is held responsible solely by operation of +law because of his [or her] relation to the actual wrongdoer'" (emphasis added) (citations +omitted)); Bd. of Managers of the 125 N. 10th Condo. v. 125North10, LLC, 55 N.Y.S.3d 374, 376 +(2d Dep't 2017) (affirming dismissal of claim for common-law indemnification where party +seeking indemnity's liability was not "purely vicarious" (emphasis added) (citation omitted)). In +other words, indemnification claims are not cognizable where the purported indemnitee's "liability +... in the [pending] main action" would be based on "its own" failures. Genesee/Wyoming YMCA +v. Bovis Lend Lease LMB, Inc., 951 N.Y.S.2d 768, 771 (4th Dep't 2012) (citation omitted). +Here, none of the plaintiffs' claims seeks to hold JPMorgan liable solely because it +employed Mr. Staley. To the contrary, both Doe and USVI premise liability on JPMorgan's own +alleged misconduct. Underlying the outstanding common law and federal law claims is the +allegation that JPMorgan provided financial services to Epstein and his associates in furtherance +of their trafficking enterprise. +Doe FAC 11 313, 326, 350, 473-74; USVI FAC 19 6, 94. These +services included, for example, allowing Epstein to withdraw large sums of cash without question. +Doe FAC 911 326, 350, 474. Doe also alleges that JPMorgan failed to follow "AML and antistructuring reporting requirements found in the Bank[] Secrecy Act [BSA] and other laws," failed +to "timely file with the federal government the required SARs that financial institutions must file +13 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 19 of 30 +with FinCEN whenever there is a suspected case of money laundering or fraud," and "concealed +from the federal government its numerous cash payments to... co-conspirators." Id. 91 474-79. +The USVI makes similar allegations. USVI FAC 191 6, 76-77, 82, 87. There is no allegation that +this conduct by JPMorgan was undertaken solely by (or even known to) Mr. Staley. +The bank is solely responsible for those acts; nowhere is it alleged—in either the plaintiffs' +complaints or JPMorgan's third-party complaints that Mr. Staley provided cash or participated +in decision-making on BSA compliance. In fact, it is not even alleged that Mr. Staley was aware +of Epstein's cash withdrawals or at all involved in the compliance function's consideration of +whether the Epstein transactions breached banking laws. And even if he did, Doe's allegations +regarding the bank's willful failure to follow regulations extends beyond 2013, when Mr. Staley +was no longer working at the bank. Doe FAC | 187. Nor is it alleged that Mr. Staley had decisionmaking authority for Epstein's accounts such that he helped decide whether to keep Epstein as a +client. In short, it is clear on the face of these complaints that the bank is not being sued as Mr. +Staley's employer, but rather because it allegedly provided Epstein with the financial tools and +cover to maintain his trafficking ring +iii. +JPMorgan's Indemnification Claim Fails Because JPMorgan's Alleged +Misconduct Was Outside the Scope of Mr. Staley's Responsibilities. +JPMorgan's claim for indemnification also fails because it seeks to hold Mr. Staley +accountable for actions outside the scope of his responsibilities at the bank. Under New York law, +indemnification is actionable only where the "injury was due solely to the [proposed indemnitor]'s +negligent performance or nonperformance of an act solely within [his] province." Corley v. +Country Squire Apartments, Inc., 80 N.Y.S.2d 900, 900 (2d Dep't 2006) (emphasis added); Baron +v. Grant, 852 N.Y.S. 374, 374 (2d Dep't 2008) ("The party seeking indemnification must have +delegated exclusive responsibility for the duties giving rise to the loss to the party from whom +14 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 20 of 30 +indemnification is sought." (citation omitted)). Here, both USVI and Doe allege that they were +injured by JPMorgan's decisions to retain Epstein as a client and to continue providing financial +services that served as the "lifeblood" of his sex-trafficking scheme. Doe FAC 9| 193; USVI FAC +9 94. They likewise claim that they were injured by JPMorgan's refusal to follow federal banking +regulations. Doe FAC 11 326-27; USVI FAC 191 6, 76-77, 82, 87. JPMorgan has not pleaded that +Mr. Staley had decision-making authority over Epstein's accounts or the compliance department, +let alone that these were "solely within his province" at the bank. JPMorgan concedes this, alleging +that the conduct it places at issue in the third-party complaints "were not in connection with the +performance of [Mr. Staley's] duties for JPMC." TPC 9| 42. Thus, JPMorgan has failed to +adequately plead indemnification. +D. JPMorgan's Contribution Claim Fails. +To state a claim for contribution, JPMorgan must plead that (1) Mr. Staley breached a duty +that he owed to either the plaintiffs or JPMorgan; (2) his breach caused an injury; and (3) the injury +was the same injury for which JPMorgan is being held liable. Bellis v. Tokio Marine & Fire Ins. +Co., 2002 WL 193149, at *17 (S.D.N.Y. Feb. 7, 2002); see N.Y. C.P.L.R.§ 1401. JPMorgan fails +to plead elements (1) and (3). +First, JPMorgan has failed to properly plead that Mr. Staley breached a duty that he owed +to either the plaintiffs or to the bank. Nowhere in the complaint does JPMorgan allege that Mr. +Staley owed a duty to USVI or to Doe. And while Staley may have owed a fiduciary duty to +JPMorgan through their employee-employer relationship, JPMorgan has failed to adequately plead +that such a duty was breached, as explained further below. See infra pp. 21-23. +Second, JPMorgan has not adequately pleaded that Mr. Staley caused the same harm for +which the bank has been sued. No right of contribution arises where the injuries allegedly caused +by the party are "separate and distinct." Nassau Roofing & Sheet Metal Co. v. Facilities Dev. +15 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 21 of 30 +Corp., 523 N.E.2d 803, 805 (N.Y. 1988). Here, JPMorgan has failed to plead the injuries for +which it is seeking contribution. Instead, JPMorgan merely claims that "i]f Doe is successful on +her claims ... Staley's actions caused or substantially contributed to any resulting damages." TPC +153. This terse statement fails to state what harm Mr. Staley is being alleged to have caused. +Perhaps this is no surprise because whatever injury the bank caused simply could not be the same +as what Mr. Staley allegedly caused. The crux of the plaintiffs' complaints is that JPMorgan +provided the "financial lifeblood" of Epstein's sex trafficking ring by providing access to limitless +cash and helping Epstein evade detection by ignoring banking regulations. Doe FAC 11 313, 326, +350, 473-74; USVI FAC 11| 6, 94. JPMorgan fails to allege how Mr. Staley, a lone bank employee +who has no banking license and who is not alleged to have had control over Epstein's accounts or +a formal compliance role, contributed to injuries that are uniquely caused by a financial institution. +JPMorgan also alleges that Mr. Staley sexually assaulted Doe. TPC 11 27, 52. Even +accepting this baseless allegation as true as is required, it does not provide a basis for JPMorgan +to seek contribution. Doe's claims do not seek damages for battery; instead, she seeks all damages +arising from JPMorgan's financial support of Epstein's sex trafficking ring. +Because JPMorgan has failed to adequately plead the requirements for contribution, this +claim must be dismissed. +E. JPMorgan Cannot Receive Contribution for Punitive Damages. +Even if the Court finds that the contribution claim should stand, it should strike JPMorgan's +attempt to receive contribution for any potential punitive damages awarded to Doe or USVI. +$ JPMorgan's contribution and indemnification claims against Mr. Staley depend on the plaintiffs" +pleading valid claims against JPMorgan. But the plaintiffs' claims against JPMorgan are deficient +for at least the reasons identified by JPMorgan in its motions to dismiss, which Mr. Staley hereby +incorporates by reference, for purposes of preservation. See Mot. To Dismiss, 22-ev-10019, ECF +No. 46; Motions To Dismiss, 22-cv-10904, ECF Nos. 40, 123. +16 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 22 of 30 +JPMorgan seeks "contribution for all damages awarded to Doe [and USVI]," who in turn both seek +punitive damages. TPC 1 55; Doe FAC 1|1 321, 346, 404; USVI FAC 1| 109. But because punitive +damages are "in the nature of a penalty," contribution among tortfeasors for these damages "is not +permissible." Felice v. Delporte, 524 N. Y.S.2d 919, 920 (4th Dep't 1988). +II. Because the Indemnity and Contribution Claims Fail, the Employment Claims +Should Be Dismissed For Non-Compliance with Rule 14. +Count III (breach of fiduciary duty) and Count IV (violation of the Faithless Servant +doctrine) do not belong in this case. If those two Employment Claims are the only claims +remaining, the Court should dismiss them without prejudice under Rule 14(a). +Rule 14(a) permits a party to implead another "who is or may be liable to [the third-party +plaintiff] for all or part of the [plaintiff's] claim against [the third-party plaintiff]." Fed. R. Civ. P. +14(a)(1). This "standard is not a mere technicality," as "li]mpleader under Rule 14(a) is narrowly +construed." Le Metier Beauty Inv. Partners LLC v. Metier Tribeca, LLC, 2015 WL 7078641, at +*3 (S.D.N.Y. Nov. 12, 2015). A third-party claim satisfies Rule 14(a) only "when the third party's +liability is somehow dependent on the outcome of the main action or when the third party is +secondarily liable to the defendant." Zohar CDO 2003-1, Ltd. v. Patriarch Partners, LLC, 286 F. +Supp. 3d 634, 656 (S.D.N.Y. 2017). Unlike for supplemental jurisdiction under 28 U.S.C. +§ 1367—or for analyzing a discretionary motion to sever claims "the mere fact that the alleged +third-party claim arises from the same transaction or set of facts as the original claim is not +enough." State Nat'l Ins. Co. v. Certain Interested Underwriters at Lloyd's London, 2022 WL +4547444, at *2 (S.D.N.Y. Sept. 29, 2022). Only if impleader is proper with at least one predicate +claim- +-that is, one dependent on the outcome of the main action— can the third-party plaintiff join +non-dependent claims. See Fed R. Civ. P. 18(a). +17 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 23 of 30 +Here, the Employment Claims are properly joined under Rule 18(a) only if Mr. Staley first +is properly impleaded based on a third-party claim that satisfies Rule 14(a). If the Court dismisses +the contribution and indemnity claims, then impleader of the independent Employment Claims is +improper. Neither Employment Claim depends on the outcome of the plaintiffs' claims against +JPMorgan. Zohar, 286 F. Supp. 3d at 656. While JPMorgan relies on Doe's and USVI's +allegations as the basis for the purported breach of fiduciary duty, that alone is not sufficient. In +theory, JPMorgan could prevail entirely in the main actions and evade any liability yet still prevail +against Mr. Staley on the Employment Claims and secure disgorgement of his salary or +compensatory damages independent of what it could have owed the plaintiffs. See TPC 91 64-65, +78. Whereas the "crucial characteristic of a Rule 14 claim is" a defendant trying to "transfer to +the third-party defendant the liability asserted against him by the original plaintiff," the +Employment Claims here are "the type" that JPMorgan "could have asserted in an independent +action." Zohar, 286 F. Supp. 3d at 656-57 (citation omitted). Accordingly, if, as argued above, +the indemnification and contribution claims fail, the Employment Claims cannot stand. +II. The Employment Claims Fail on the Merits. +The Employment Claims are also subject to dismissal under Rule 12(b)(6). +A. The Employment Claims Are Time-Barred. +"Although the statute of limitations is ordinarily an affirmative defense that must be raised +in the answer, a statute of limitations defense may be decided on a Rule 12(b)(6) motion if the +defense appears on the face of the complaint." Ellul v. Congregation of Christian Bros., 774 F.3d +791, 798 n. 12 (2d Cir. 2014). Such is the case here. +In New York, the limitations period for breach of fiduciary duty claims generally depends +on the substantive remedy that the plaintiff seeks. ALP, Inc. v. Moskowitz, 167 N. Y.S.3d 45, 52 +(1st Dep't 2022). There is only a three-year limitations period when, as here, the remedy sought +18 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 24 of 30 +is "purely monetary." Id.; see TPC at 13-14 (prayer for relief). JPMorgan may argue that a sixyear limitations period applies, claiming that this case should be covered by the longer limitations +period for actions by a corporation against their directors and officers. N.Y. C.P.L.R. § 213(7); +see Levy v. Young Adult Inst., Inc., 103 F. Supp. 3d 426, 434-35 (S.D.N.Y. 2015). The claim is +time barred either way. Mr. Staley left JPMorgan in early 2013, TPC 1 16, which was when his +fiduciary duty and duty of loyalty to the company ended, and which is thus the most recent date +the claim could arise. JPMorgan, however, waited over 10 years to file these claims. Its suit falls +well outside even the six-year statute of limitations, so the Court should dismiss the claims. +To be sure, for "an action based upon fraud," the discovery-accrual rule extends the +limitations period to the greater of six years or "two years from the time the plaintiff or the person +under whom the plaintiff claims discovered the fraud, or could with reasonable diligence have +discovered it." N.Y. C.P.L.R. § 213(8). Because JPMorgan's Employment Claims sound in fraud, +see infra pp. 20-21, JPMorgan bears the burden to plead and establish that "the fraud could not +have been discovered prior to the two-year period before the commencement of the action." +Cannariato v. Cannariato, 24 N.Y.S.3d 214, 216 (2d Dep't 2016) (noting burden rests with +plaintiff to raise sufficient factual issue and that the issue can be resolved at pleading stage). +Despite that burden, JPMorgan has pleaded zero facts as to why it could not have discovered the +alleged claims before the past two years. +What is more, there is a duty to inquire; a plaintiff cannot claim ignorance of an alleged +fraud when the facts call for investigation. Aozora Bank Ltd. v. Deutsche Bank Sec., 29 N.Y.S.3d +10, 14 (Ist Dep't 2016). In other pleadings in this case, JPMorgan heralds a "bombshell" Miami +Herald story from November 2018 that blew the lid open and "exposed shocking details" about +Epstein's decades-long operation. JPMorgan Mot. to Dismiss Doe Compl. at 1-2. And in February +19 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 25 of 30 +2020 two years after JPMorgan concedes that it learned of Epstein's misconduct through the +article media outlets reported that Mr. Staley was under investigation by the U.K.'s Financial +Conduct Authority for his connection to Epstein.? Surely the "bombshell" article, Epstein's +subsequent arrest in 2019, Doe FAC 121, and the public investigation into Mr. Staley put +JPMorgan on notice of at least the duty to inquire into its own dealings with Epstein, including +Mr. Staley's alleged involvement. After all, numerous JPMorgan employees knew that Mr. Staley +had a relationship with Epstein, and the bank had access to Mr. Staley's communications from his +tenure that JPMorgan now alleges reflect that relationship. As pleaded, the Complaint provides +no explanation for why JPMorgan sat on its putative claims. The Court should dismiss the +Employment Claims, which concern a job Mr. Staley left more than a decade ago, as time barred. +B. The Employment Claims Are Improperly Pleaded. +Untimeliness aside, JPMorgan fails to properly plead the Employment Claims. As an +initial matter, both claims must meet the heightened pleading standard of Rule 9(b). The standard +applies to not only causes of action stylized as fraud claims, but also those in which the "gravamen" +of the claim relies on dishonest conduct. Rombach v. Chang, 355 F.3d 164, 171-72 (2d Cir. 2004). +"Courts have found non-fraud claims to sound in fraud where the underlying conduct alleged has +been fraud or closely linked with fraudulent behavior, such as ... claims that the other party has +attempted to induce action through misrepresentations or material omissions. This can include +claims for breach of fiduciary duty." Levy, 103 F. Supp. 3d at 443 (collecting cases). +Here, Counts III and IV sound in fraud. Both rely on the same alleged underlying +conduct-namely, that Mr. Staley supposedly subverted the interests of his employer JPMorgan, +" See, e.g., +Clark, Barclays CEO Under Investigation Over Links to Jeffrey Epstein, Wall +Street Journal (Feb. 13, 2020), https://www.wsj.com/articles/barclays-ceos-links-to-jetfreyepstein-probed-by-u-k-regulators-11581582115?mod=djemalertNEWS. +20 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 26 of 30 +to which he owed a duty of good faith and loyalty. TPC 11 56-79. For support, JPMorgan +practically trips over itself alleging varied deception by Mr. Staley: It alleges that he deceived it +about a material conflict of interest, "fraudulently conceal[ed]" his misconduct, secretly "act[ed] +against the interests" of the bank, "repeatedly provided misleading information, "affirmatively +misrepresented" facts," and "consistently and misleadingly vouched" for Epstein. TPC 11| 59-62. +These claims, which rely on allegedly fraudulent statements and conduct, are precisely the kind +that trigger Rule 9(b) scrutiny. E.g., Rubio v. BSDB Mgmt. Inc., 2021 WL 102651, at *4 (S.D.N.Y. +Jan. 12, 2021) (applying Rule 9(b) to counterclaim for violation of faithless servant doctrine +because "the gravamen of" the claim was "Plaintiff's alleged fraudulent misrepresentations"); cf. +Levy, 103 F. Supp. 3d at 447 (finding Rule 9(b) not triggered where breach claim "d[id] not allege +that Levy tricked the organization into taking action it would not otherwise have taken"). Having +leveled claims of fraud, JPMorgan must plead with particularity when and how Mr. Staley +allegedly deceived the bank. +i. JPMorgan Fails to State a Claim for Breach of Fiduciary Duty. +JPMorgan fails to meet its burden and plead a viable breach of fiduciary duty claim. Under +New York law, "a plaintiff must allege: (1) the existence of a fiduciary relationship, (2) misconduct +by the defendant, and (3) damages directly caused by the defendant's misconduct." Yukos Cap. +S.A.R.L. v. +, 977 F.3d 216, 241 (2d Cir. 2020) (cleaned up). +The Complaint falls far short. First, while sweeping, the actual allegations of misconduct +are conclusory and fatally vague, especially in the face of Rule 9(b). When, how, and from whom +did Mr. Staley "fraudulently conceal" facts and observations about Epstein? TPC 9| 60. When, +how, and to whom did Mr. Staley "affirmatively misrepresent" Epstein's activities or "providel] +misleading information" on Epstein's character and conduct? TPC 161. The Complaint leaves +21 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 27 of 30 +the parties and the Court guessing as to the critical "who, what, when, where and how of the alleged +fraud" underlying this claim. Kester, 23 F. Supp. 3d at 252. Such cursory pleading violates Rule +9(b) and merits the claim's dismissal. Babbitt, 2020 WL 3183895, at *5. Nor does JPMorgan +properly plead that Mr. Staley had any duty to report to the bank information about Epstein or their +alleged relationship. An agent, like Mr. Staley, is obligated to disclose only "information that is +relevant to the affairs of the agency entrusted to him," not every fact on every topic. Poller v. +BioScrip, Inc., 974 F. Supp. 2d 204, 227 (S.D.N.Y. 2013); see also Neurological Surgery, P.C. v. +MLMIC Ins. Co., 175 N. Y.S.3d 266, 269 (2d Dep't 2022) (A "cause of action alleging fraudulent +omission or concealment of material information requires an allegation that the defendant had a +duty to disclose that information." (emphasis added)). Since JPMorgan has nowhere alleged that +Mr. Staley had any official responsibilities regarding the Epstein accounts, Mr. Staley's purported +failure to disclose information to the bank about Epstein does not give rise to a breach of his +fiduciary duty. +Second, the Complaint fails to properly plead damages "directly caused by the defendant's +misconduct." U.S. Fire Ins. Co. v. Raia, 942 N. Y.S.2d 543, 545 (2d Dep't 2012). For a breach of +fiduciary duty claim, JPMorgan must plead both that it suffered damages and "that the alleged +misrepresentations or other misconduct were the direct and proximate cause of the losses claimed," +not merely a but-for cause. +Tobia v. United Grp. of Cos., Inc., 2016 WL 5417824, at *22 +(N.D.N.Y. Sept. 22, 2016) (dismissing breach of fiduciary duty claim for failure to allege +"damages directly caused by Defendants' conduct"); accord Laub v. Faessel, 745 N. Y.S.2d 534, +536-37 (Ist Dep't 2002). +JPMorgan notably does not plead that, as of this date, it has actually lost any money from +Mr. Staley's alleged deception. Indeed, Doe and USVI assert that JPMorgan "financially benefited +22 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 28 of 30 +by earning millions of dollars" through its connection to Epstein, including from "interest, +commissions, fees, and other financial benefits." Doe FAC 11| 267-68; USVI FAC 911 95-98. The +only damages that JPMorgan points to for Count III are (1) costs in defending, and "adverse +publicity from," these lawsuits, and (2) "any amounts in damages" that JPMorgan might have to +pay to the plaintiffs. TPC 111 64-65. But neither form of alleged damages suffices. Mr. Staley did +not "directly cause" this litigation initiated by independent plaintiffs some ten years after he left +the company, nor any of the associated publicity. Indeed, many of the allegations in USVI's and +Doe's complaints are completely unrelated to Mr. Staley's conduct. Similarly, any secondhand +damages that JPMorgan might have to pay to the plaintiffs are completely remote and speculative +and thus improperly pleaded. See, e.g., Sea Trade Mar. Corp. v. Coutsodontis, 744 F. App'x 721, +725-26 (2d Cir. 2018) (noting that in order to succeed on breach of fiduciary duty claim, plaintiff +must prove "non-speculative damages" and that "the claim is not enforceable until damages are +sustained"). Given JPMorgan's clear failure to point to any non-speculative damages that it has +incurred through Mr. Staley's purported disloyalty, it has failed to properly plead a cause of action +for breach of fiduciary duty, and this claim must be dismissed. +ii. JPMorgan Fails to State a Claim Under the Faithless Servant Doctrine. +Count IV's claim that Mr. Staley violated the Faithless Servant doctrine fails for similar +reasons. "New York courts are far from clear regarding the contours of —and interplay between +a claim for breach of fiduciary duty and the faithless servant doctrine." +977 F.3d at 242. +And some courts treat the cause of action as merely an alternate form of recovery for a breach of +fiduciary duty claim. Id. But under the doctrine, one who owes a duty of loyalty to an employer +but is "faithless" in the performance may be liable to forfeit his compensation. Phansalkar v. +Andersen Weinroth & Co., L.P., 344 F.3d 184, 200 (2d Cir. 2003). Courts apply alternate standards +23 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 29 of 30 +to decide whether an employee's conduct merits disgorgement. See Rubio, 2021 WL 102651, at +*4. One standard requires that the "misconduct and unfaithfulness ... substantially violate the +contract of service," while another requires that an agent "act adversely to his employer in any part +of a transaction, or omit to disclose any interest which would naturally influence his conduct in +dealing with the subject of his employment." Id. at *4 (cleaned up). But however the standard is +stated, "New York courts have applied the faithless servant doctrine only in the limited +circumstances where the employee has acted directly against the employer's interestsas in +embezzlement, improperly competing with the current employer, or usurping business +opportunities." Ebel v. G/O Media, Inc., 2021 WL 2037867, at *7 (S.D.N.Y. May 21, 2021). +Along with lacking particularity for the same reasons as Count III, ° Count IV does not +remotely allege such "limited circumstances." Id. The complaint here repeats +phrases, such +as that Mr. Staley "acted as a faithless servant," "abandoned the interests of [JPMorgan]," and +"violated the [JPMorgan's] Code of Conduct in a way that permeated his service," id. 91 70-71, +74, but it lacks factual allegations that match the claim. There are no allegations that Mr. Staley +embezzled, competed against JPMorgan, usurped business opportunities, or undertook any other +activity that would put him at financial odds with the bank. Ebel, 2021 WL 2037867, at *7." The +1° The drive-by allegations for Count IV are just as conclusory as those relating to the breach of +fiduciary duty claim. They fail under Rule 9(b), as JPMorgan does not detail when, how, and to +whom Mr. Staley allegedly "consistently and misleadingly vouched for Epstein's good character," +or when and how he subverted purported deliberations over whether the bank should keep Epstein +as a client. TPC 1| 72. Nor does JPMorgan say to whom Mr. Staley "made misrepresentations" +when "protecting Epstein" from scrutiny. Id. 9 77. Given the charges of deceit, the bank must +plead with particularity. And it is especially inadequate to just reference hundreds of pages of the +plaintiffs" allegations that JPMorgan denies in its answer and even in its third-party complaints. +Rubio, 2021 WL 102651, at *5 (dismissing faithless-servant counterclaim based on "insufficient +conclusory statements"). +" That the bank pleaded zero direct damages from Mr. Staley's alleged breach of fiduciary duty— +instead relying on the speculative and remote costs of this litigation underscores the mismatch. +24 + + +Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 30 of 30 +closest JPMorgan gets is alleging that Mr. Staley lied to keep Epstein as a lucrative client for the +bank. But misconduct whose only remuneration is incremental profit from "increasing the amount +of referred business" to the employer is not actionable under the very narrow faithless servant +doctrine. +v. Levi & Korsinsky, LLP, 2021 WL 535599, at *6 (S.D.N.Y. Feb. 12, 2021) +(dismissing claim against lawyer who "acted unfaithfully to benefit other law firms and a mentor +of hers" outside her firm when the only financial benefit derived from actions that profited her +firm as well). While JPMorgan "does allege insubordination and dishonesty, [it] fails to allege +any element of self-dealing on [Mr. Staley]'s part," so the claim is "not actionable under the +faithless servant doctrine." Grewal v. Cuneo, 2016 WL 308803, at *8 (S.D.N.Y. Jan. 25, 2016). +The Court should therefore dismiss Count IV. +CONCLUSION +For the foregoing reasons, Mr. Staley respectfully requests that the Court dismiss the +Complaint. +Date: April 24, 2023 +Respectfully submitted, +By: /s/ Brendan V. +Jr. +Brendan V. +_Jr. +Zachary K. L +Stephen L. Wohlgemuth +] & CONNOLLY LLP +680 Maine Avenue SW +Washington, DC 20024 +Tel: (202) 434-5252 +Fax: (202) 434-5029 +zwarren@wc.com +Counsel for Third-Party Defendant +James Edward Staley diff --git a/vision-fixhub/court-05/50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191.receipt.json b/vision-fixhub/court-05/50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f895acd690db323d9ddcbb95c136b8bd64e31581 --- /dev/null +++ b/vision-fixhub/court-05/50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -370, + "dataset": "marble-joined", + "doc_id": "50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191", + "engine": "marble-apple-vision", + "event_count": 35, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "084d6a27d079fa2f9b1c0642d65e9748cf0b45716a87ff07eed2cbe2c1267753", + "output_sha256": "d6f1e7572f3f63619d246fd894ebb9b47e586432d04fa29f1d8e8bdeaaff53ec", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/50ef9433c303df710cdbc4f453eefcce0451391d86aa4d0a135be3cbd9c5184f.md b/vision-fixhub/court-05/50ef9433c303df710cdbc4f453eefcce0451391d86aa4d0a135be3cbd9c5184f.md new file mode 100644 index 0000000000000000000000000000000000000000..47aeb0d1b3bece2c6a2623d615b54bffbf3ce565 --- /dev/null +++ b/vision-fixhub/court-05/50ef9433c303df710cdbc4f453eefcce0451391d86aa4d0a135be3cbd9c5184f.md @@ -0,0 +1,182 @@ +Case 1:22-cV-10904-JSR Document 238-28 Filed 07/25/23 Page 1 of 7 + + + +Case 1.22-cv-10904-JSR Document 238-28 Filed 07125/23 Page 2 oft +What is Human Trafficking? +Human trafficking is the recruitment, transportation, provision, or +obtaining of a person for labor or services, through the use of force +of coercion for the purpose of subjection to involuntary servitude, +peonage, debt bondage or slavery. Human trafficking has become +the second largest criminal enterprise and is currently the fastest +growing criminal industry in the world. +The Victims +Human trafficking does not discriminate. Per the Global Slavery +Index Report, it is estimated that 45.6 million people are currently +enslaved worldwide. Victims include men, women, boys, girls, and +transgender individuals lured by false promises of love or +opportunity. Statistics from the National Center for Missing and +Exploited Children estimate about 100,000 children per year, are +caught up in the web of child prostitution. +facebook +Key indicators/Red flags of potential Human Trafficking activity: +Customer Behavior +• Excessive number of individual accounts +abbies +• No deposits from an employer + +8 +• Reports of identity theft +• Hiring of immigration attorneys or ties to other labor intermediaries to handle visa paperwork +• Business industries with links to human trafficking (e.g. modeling, travel & transportation) + +3/29/2: +JPM-SDNYLIT-00151917 + + +Case 1122 CV-10904 JS Documen 238°28 Filed 07125/23 Page 3 or7 +Key indicators/Red flags of potential Human Trafficking activity (cont'd): +Source of Funds +• Round- dollar deposits via wires, ACH or cash +• Excessive interstate or intrastate cash deposits less than $1,000 (round dollar), using multiple +branches +• Cash deposits below the CTR threshold deposited at several branches & ATMs +• Structured transactions, particularly those conducted via MSBs +• Incoming wires or personal checks deposited into business accounts with no clear purpose +Use of Funds +> High volume of debit card/ credit card transactions with the following types of merchants: +• Airline and/or rental car companies in multiple cities or states +• Hotel or casino charges and purchases made at high end merchants (jewelry, accessories, +apparel) +• Online advertisement providers (see list of known sites) +› Excessive payments to property management companies, utility companies, and cell phone +companies +• Purchase of money orders to pay bills instead of using personal checks +• Wire transfers to countries with high migrant populations, following unusual cash deposits +• Wire activity inconsistent with business, particularly international or round dollar wires (e.g. nail +salon operating in Queens, NY receives large value wire transfers from South America or Southeast +Asia, or wires in even thousand-dollar increments.) + +JPM-SDNYLIT-00151918 + + +case L22-CV-10904 SR Document 238-28 Filed 07/25/23 Page 4 017 +NOTE: As of April 6, 2018, backpage.com and affiliated websites have been seized +by U.S. enforcement agencies... +backpage.com +backpage +Califor +backpage.com and affiliated +websites have been seized +as part of an enforcement action by the Federal Bureau of Investigation, the +U.S. Postal Inspection Service, and the Internal Revenue Service Criminal +Investigation Division, with analytical assistance from the Joint Regional +intelligence Center, +Other agencies participating in and supporting the enforcement action +include the U.S. Attarney's Office for the District of Arizona, the U.S. +Department of Justice's Child Exploitation and Obscenity Section, the U.S. +Attorney's Office for the Central District of California, the office of the +California Attorney General, and the office of the Texas Attorney General. +Additional information will be provided at around 6:00 pm EST on Friday. +April 6, by the U.S. Department of Justice, and all media inquiries should be +directed to the U.S. Department of Justice's Office of Public Affairs at +202-514-2007 and press@lundoiaoy. +April 6, 2018 +starburs + +JPM-SDNYLIT-00151919 + + +Case ILL-cv-10904 05R Document 238-26 Filed 0712523 Page 50f7 +...law enforcement has identified at least 30 sites that have taken its place, including: +• www.bedpage.com +• www.thebqe.com +• www.onebackpase.com +• www.theeroticreview.com - must turn on VPN and "locate" to another +country +• switter.at and listing.switter.at +• SafeOffice (sex workers only): https://www.safeoffice.com/ +• Discord (sex workers only): https://discord.gg/UJK2TKH/ [Requires +additional confirmation that you're a sex worker.] +• Telegram: httos://t.me/joinchat/FMw30xB-bdEM4gi6fw3A6w +• TER boards: https://www.theeroticreview.com/ [Forums up, not +accepting ads.] +• Stripperweb: https://www.stripperweb.com +• Eroticmonkey: https://www.eroticmonkey.com/ [Down as of 2018-04- +06] +• Eros.com: https://www.eros.com/ +• P411: https://preferred411.com/ +• Eccie: https://eccie.net/ (Down as of 2018-04-07] +• Slixa: https://www.slixa.com/ +• TNA: https://www.tnaboard.com/ +• SA Sex Guide: http://www.usasexguide.info +* Plenty of Fish: https://www.pof.com/ (Not SW-friendly, but SWers +have used it] +• Skipthegames:https://skiptherames.com +• City of Love:http://www.cityoflove.com/ +• Open Adult Directory: https://openadultdirectory.com/escorts/ +• Mature Sensual: https://maturesensual.com/ +• Escort Ads: https://www.escort-ads.com/ +• Humaniplex: http://www.humaniplex.com +• Cityxguide: https://www.cityxguide.com +• The Other Board: https://www.theotherboard.com +• RentMen: https://rent.men/ +• Onebackpage: https://onebackpage.com +• Rent.love: https://www.rent.love +• Doublelist.com: https://www.doublelist.com +• Hubzilla: https://gerzilla.de/channel/sexworkers +• Dread (Tor-only): http://dreadecomdopooda.onion/d/sexworkers +• Minds.com Sex Workers Forum - +https://www.minds.com/groups/profile/825386597235675136 +• Riot.im: https://riot.im/app/#/room/#sw.matrix.org +Be on the lookout for any of the above websites during your investigation! It may +indicate potential human trafficking activity is occurring. + +JPM-SDNYLIT-00151920 + + +Case 1:22-CV-10904-USR Document 238-28 Filed 07125123 Page b oг7 +AML Investigations promotes cases involving possible Human Trafficking. But first, your +investigation must support why you believe the activity is related to HT. Below are additional tips to +assist you in determining whether HT may be present in your investigation. +Negative Media +Search an entity or customer name via +open source or strategic corporate +tools. Searches may yield negative +news, arrests for prostitution/ human +trafficking or other crimes which raise +risk profile of an alert/ customer. +Demographic Links to Online Adult +Advertising and Services +Searches of phone numbers, +addresses, and email addresses may +yield nexus to online advertising. +Previous AML History +Previous AML History, +not +necessarily HT related, may be +associated with an investigation +related to suspicious activity such as +interstate, excessive or structured cash +activity. +Additionally, if a SAR is being filed on activity +relating to potential human trafficking, don't forget +to select "Box 38h - Human trafficking" in the +Suspicious Activity Info section of the SAR form. +38 Other Suspicious Activities +h +• Human trafficking +What are potential quality +concerns related to +Human Trafficking? +• Are the reasons you suspect the activity is related to human trafficking +adequately explained in the SAR narrative? +• +Is Box 38h appropriately selected? +Has the SAR been flagged as Significant, with the Significant SAR +procedures appropriately followed? + +JPM-SDNYLIT-00151921 + + +Case 1:22-cv-10904-JSR Document 238-28 Filed 07/25/23 Page 7 of 7 \ No newline at end of file diff --git a/vision-fixhub/court-05/50ef9433c303df710cdbc4f453eefcce0451391d86aa4d0a135be3cbd9c5184f.receipt.json b/vision-fixhub/court-05/50ef9433c303df710cdbc4f453eefcce0451391d86aa4d0a135be3cbd9c5184f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..78f62dc89743f6360e7c74687e1bae4abf55ec83 --- /dev/null +++ b/vision-fixhub/court-05/50ef9433c303df710cdbc4f453eefcce0451391d86aa4d0a135be3cbd9c5184f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -252, + "dataset": "marble-joined", + "doc_id": "50ef9433c303df710cdbc4f453eefcce0451391d86aa4d0a135be3cbd9c5184f", + "engine": "marble-apple-vision", + "event_count": 15, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "dd8953cfd091cb383f7164bcbcafe22cf8446d8d85e2d6fd794147cdabada76a", + "output_sha256": "7533f8edbc4e609921c2cb278b22d0e17c9d8ec68235346504e6ec9b6d017d7c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/511580004a5567e16884a5e6856017b4582dad0742206aaa255abaa73ad38b6a.md b/vision-fixhub/court-05/511580004a5567e16884a5e6856017b4582dad0742206aaa255abaa73ad38b6a.md new file mode 100644 index 0000000000000000000000000000000000000000..3f4b6ff03c1819618a6e7fa4d9f78cec24733fa8 --- /dev/null +++ b/vision-fixhub/court-05/511580004a5567e16884a5e6856017b4582dad0742206aaa255abaa73ad38b6a.md @@ -0,0 +1,195 @@ +Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 1 of 8 + + + +Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 2 of 8 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +JANE DOE, individually and on behalf of +all others similarly situated, +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS. +v. +Plaintiff, +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +Case Number: 1:22-cv-10019-JSR +Case Number: 1:22-cv-10904-JSR +v. +JAMES EDWARD STALEY +Third-Party Defendant. +THIRD-PARTY DEFENDANT JAMES E. STALEY'S RESPONSES +AND OBJECTIONS TO UNITED STATES VIRGIN ISLANDS' FIRST +SET OF REQUESTS FOR ADMISSIONS +Pursuant to Rules 26 and 36 of the Federal Rules of Civil Procedure, Third-Party +Defendant James E. Staley, through undersigned counsel, hereby responds and objects to the +United States Virgin Island's First Requests for Admissions in the above-captioned matters. +1 + + +Case 1:22-cv-10904-JSR Document 238-23 Filed 07/25/23 Page 3 of 8 +9. Staley objects to each Request to the extent that it improperly "seek[s] information as to +fundamental disagreement at the heart of the lawsuit." Republic of Turkey v. Christie's, +Inc., 326 F.R.D. 394, 400 (S.D.N.Y. 2018) (citing +& +Fed. Prac. & P. § +2252; Tamas v. Fam. Video Movie Club, Inc., 301 F.R.D. 346, 347 (N.D. III. 2014)). +10. Staley objects to each Request to the extent that it amounts to an improper use of Requests +for Admission as a discovery device. Pasternak v. Dow +1. 2011 WL 4552389, at *5 +(S.D.N.Y. Sept. 28, 2011) (requests for admission "presuppose|] that the party proceeding +under [Rule 36] knows the facts" and "merely wishes its opponent to concede their +genuineness." (citations omitted)); L +v. De Niro, 2022 WL 101909, at *2 +(S.D.N.Y. Jan. 11, 2022) ("[RJequests for admission are used to establish admission of +facts about which there is no real dispute," not to obtain new information). +11. Staley objects to each Request to the extent that it is vague because it uses terms that are +susceptible to more than one meaning, ambiguous, overly broad, or unduly burdensome. +Fed. R. Civ. P. 26(b)(1). +12. Staley objects to each Request to the extent that it requests an admission not "relevant to +any party's claim or defense" and therefore, not "proportional to the needs of the case." +Fed. R. Civ. P. 26(b)(1). +II. +REQUESTS FOR ADMISSION +REQUEST FOR ADMISSION NO. 1: +Admit that You were CEO of JPMorgan Asset Management between 2001-2009. +RESPONSE TO REQUEST FOR ADMISSION NO. 1: +Subject to and without waiving the General Objections, and reserving the right to amend or +supplement his response as further information is discovered, Staley denies this Request. He admits +4 + + +Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 4 of 8 +that he was the CEO of JPMorgan Asset and Wealth Management. +REQUEST FOR ADMISSION NO. 2: +Admit that You were CEO of JPMorgan Investment Bank between 2009-2012. +RESPONSE TO REQUEST FOR ADMISSION NO. 2: +Subject to and without waiving the General Objections, and reserving the right to amend or +supplement his response as further information is discovered, Staley admits this Request. +REQUEST FOR ADMISSION NO. 3: +Admit that You signed a written affirmation each year between 2006-2012 where You pledged to +remain in compliance with JPMorgan's Code of Conduct. +RESPONSE TO REQUEST FOR ADMISSION NO. 3: +In addition to and specifically incorporating his foregoing General Objections, Staley +objects to Request No. 3 because it inappropriately incorporates documents by reference. +Subject to and without waiving the foregoing objections, and reserving the right to amend +or supplement his response as further information is discovered, Staley admits that he signed +certifications that speak for themselves. Otherwise the request is denied. +REQUEST FOR ADMISSION NO. 4: +Admit that You provided information to JPMorgan regarding Your friendship with Epstein. +RESPONSE TO REQUEST FOR ADMISSION NO. 4: +In addition to and specifically incorporating his foregoing General Objections, Staley +objects to Request No. 4 because the terms "information" and "friendship" are vague because they +are susceptible to more than one meaning. +Staley objects to Request No. 4 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +5 + + +Case 1:22-cv-10904-JSR Document 238-23 Filed 07/25/23 Page 5 of 8 +Staley objects to Request No. 16 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley denies this Request. +REQUEST FOR ADMISSION NO. 17: +Admit that Epstein referred or otherwise introduced JPMorgan to other ultra-high net worth +individuals as clients or for additional activities or funds to JPMorgan Private Bank. +RESPONSE TO REQUEST FOR ADMISSION NO. 17: +In addition to and specifically incorporating its foregoing General Objections, Staley +objects to Request No. 17 because the terms "ultra-high net worth individuals," "clients," +"additional activities or funds" are vague because they are susceptible to more than one meaning. +Staley objects to Request No. 17 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +Staley objects to Request No. 17 to the extent it is directed at JPMC's knowledge or actions +because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to +the extent the Request seeks information based on his personal knowledge. +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley admits this Request. +REQUEST FOR ADMISSION NO. 18: +Admit that JPMorgan obtained fees, revenue, and business referrals in connection with JPMorgan's +banking relationship with Epstein. +RESPONSE TO REQUEST FOR ADMISSION NO. 18: +12 + + +Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 6 of 8 +"reporting," "allegations," and "human trafficking" are vague because they are susceptible to more +than one meaning and call for improper legal conclusions. Carver, 2018 WL 4579831, at *2. +Staley objects to Request No. 110 to the extent that it assumes or implies that Staley knew +about, had reason to know, or should have known of Epstein's actions and because it seeks a legal +conclusion and thus seeks admissions outside the scope of the Federal and Local Rules. Id. +Staley objects to Request No. 110 because it "seek[s] information as to fundamental +disagreement at the heart of the lawsuit." Republic of Turkey, 326 F.R.D. at 40. +Staley objects to Request No. 110 because it abuses Requests for Admission as a discovery +device. See Pasternak, 2011 WL 4552389, at *5; De Niro, 2022 WL 101909, at *2. +Staley objects to Request No. 110 to the extent that it is improperly compound, conjunctive, +or disjunctive. Fed. R. Civ. P. 36(a)(2). +Staley objects to Request No. 110 as improperly incorporating a document or documents by +reference without an opportunity to test their veracity and authenticity. As such, Staley further +objects to Request No. 110 to the extent it assumes that a person who read what was "report[ed]" in +the "newspaper or other media articles" had to assume the report to be a full, true, complete, and +accurate account of the people, actions, or events it described. +Subject to and without waiving the foregoing objections, and reserving the right to amend +or supplement his response as further information is discovered, Staley admits that he received and +reviewed articles about Epstein. Otherwise the request is denied. +REQUEST FOR ADMISSION NO. 111: +Admit that in 2006 Jamie Dimon communicated with You regarding Epstein's arrest on charges of +procuring a minor for prostitution and solicitation of a prostitute. +RESPONSE TO REQUEST FOR ADMISSION NO. 111: +In addition to and specifically incorporating his foregoing General Objections, Staley +76 + + +Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 7 of 8 +objects to Request No. 111 because the terms "communicated," "regarding," "arrest," "charges of +procuring a minor for prostitution," and "solicitation of a prostitute" are vague because they are +susceptible to more than one meaning and call for improper legal conclusions. Carver, 2018 WL +4579831, at *2. +Staley objects to Request No. 111 to the extent that it assumes or implies that Staley knew +about, had reason to know, or should have known of Epstein's actions and because it seeks a legal +conclusion and thus seeks admissions outside the scope of the Federal and Local Rules. Id. +Staley objects to Request No. 111 because it "seek[s] information as to fundamental +disagreement at the heart of the lawsuit." Republic of Turkey, 326 F.R.D. at 40. +Staley objects to Request No. 111 because it abuses Requests for Admission as a discovery +device. See Pasternak, 2011 WL 4552389, at *5; De Niro, 2022 WL 101909, at *2. +Subject to and without waiving the foregoing objections, and reserving the right to amend +or supplement his response as further information is discovered, Staley admits this Request. +REQUEST FOR ADMISSION NO. 112: +Admit that in 2006 Mary Erdoes communicated with You regarding Epstein's arrest on charges of +procuring a minor for prostitution and solicitation of a prostitute. +RESPONSE TO REQUEST FOR ADMISSION NO. 112: +In addition to and specifically incorporating his foregoing General Objections, Staley +objects to Request No. 112 because the terms "communicated," "regarding," "arrest," "charges of +procuring a minor for prostitution," and "solicitation of a prostitute" are vague because they are +susceptible to more than one meaning and call for improper legal conclusions. Carver, 2018 WL +4579831, at *2. +Staley objects to Request No. 112 to the extent that it assumes or implies that Staley knew +about, had reason to know, or should have known of Epstein's actions and because it seeks a legal +77 + + +Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 8 of 8 +May 22, 2023 +By: /s/ Brendan V. | +1. Jr. +Brendan V. L +Zachary K. +Stephen L. Wohlgemuth +& CONNOLLY LLP +680 Maine Avenue SW +Washington, DC 20024 +Tel: (202) 434-5252 +Fax: (202) 434-5029 +zwarren@wc.com +Counsel for Third-Party Defendant +James Edward Staley +5 diff --git a/vision-fixhub/court-05/511580004a5567e16884a5e6856017b4582dad0742206aaa255abaa73ad38b6a.receipt.json b/vision-fixhub/court-05/511580004a5567e16884a5e6856017b4582dad0742206aaa255abaa73ad38b6a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..287934d568a8698ec489146e59bb1e63b02c236c --- /dev/null +++ b/vision-fixhub/court-05/511580004a5567e16884a5e6856017b4582dad0742206aaa255abaa73ad38b6a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -106, + "dataset": "marble-joined", + "doc_id": "511580004a5567e16884a5e6856017b4582dad0742206aaa255abaa73ad38b6a", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "7d7f2855f8599f728da22d0564579c346ffba0b0be4b51a193830a826b21bf66", + "output_sha256": "a459c96957c827c98001dc32bf866cb4b905830a5d910a8cbe9e0e24e8d4ab38", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/51219913cc7a1d7f5aebf3f9c2b1379f735d205d01fd81c4191207b99ddb7f5c.md b/vision-fixhub/court-05/51219913cc7a1d7f5aebf3f9c2b1379f735d205d01fd81c4191207b99ddb7f5c.md new file mode 100644 index 0000000000000000000000000000000000000000..e5d8ecbbee35c7a1818b4519d7efada4c08749e5 --- /dev/null +++ b/vision-fixhub/court-05/51219913cc7a1d7f5aebf3f9c2b1379f735d205d01fd81c4191207b99ddb7f5c.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 297-3 Filed 08/18/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/51219913cc7a1d7f5aebf3f9c2b1379f735d205d01fd81c4191207b99ddb7f5c.receipt.json b/vision-fixhub/court-05/51219913cc7a1d7f5aebf3f9c2b1379f735d205d01fd81c4191207b99ddb7f5c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..78d887935dd14bbad838fa8ac6601ef64634792a --- /dev/null +++ b/vision-fixhub/court-05/51219913cc7a1d7f5aebf3f9c2b1379f735d205d01fd81c4191207b99ddb7f5c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "51219913cc7a1d7f5aebf3f9c2b1379f735d205d01fd81c4191207b99ddb7f5c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "509c05f63eb56252d1bf98bccbc043efb2b74febb2fddef6a98caba92556fcdd", + "output_sha256": "6a27526164f9c157a1d2a005c0c5223eef1253db31ef428af9b37145ac20cfa7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/513bd40db153439b58bebf5dfc633759661aae573907126e3f338e9f3fb78006.md b/vision-fixhub/court-05/513bd40db153439b58bebf5dfc633759661aae573907126e3f338e9f3fb78006.md new file mode 100644 index 0000000000000000000000000000000000000000..00cc94d8722d1604b0842d5cda83c96004ad0c1f --- /dev/null +++ b/vision-fixhub/court-05/513bd40db153439b58bebf5dfc633759661aae573907126e3f338e9f3fb78006.md @@ -0,0 +1,38 @@ +Case 1:22-cV-10904-JSR Document 285-82 Filed 08/15/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 285-82 Filed 08/15/23 Page 2 of 2 +From: +Sent: +To: +Subject: +Lesley Groff +2/11/2019 2:49:25 PM +Erdoes, Mary E [mary.erdoes@jpmorgan.com] +Re: Jeffrey Epstein +...Mary, Jeffrey just thought that kathy is one of the most powerful women in washington and thought you two +would bond.. +Sent from my iPhone +On Feb 11, 2019, at 8:03 AM, Erdoes, Mary E wrote: +Thanks so much, Lesley. +I dont handle accounts myself but we will definitley get her in the right hands. +I will reach out to her. +Thanks for sharing. +Mary +From: Lesley Groff +Date: Thursday, Feb 07, 2019, 2:08 PM +To: Erdoes, Mary E +Subject: Jeffrey Epstein +Hello Mary. Hope you are well. Jeffrey wanted me to reach out to you re his very good friend and former +House counsel to Pres. Barak Obama, Kathy Ruemmler. She would like to open an account with JPM. Jeffrey +requests she deal with you personally. Might this be possible? +Lesley +Assistant to Jeffrey Epstein +This message is confidential and subject to terms at: https://www.jpmorgan.com/emaildisclaimer +including on confidentiality, legal privilege, viruses and monitoring of electronic messages. If +you are not the intended recipient, please delete this message and notify the sender immediately. +Any unauthorized use is strictly prohibited. + +JPM-SDNYLIT-00233394 +6898ZH \ No newline at end of file diff --git a/vision-fixhub/court-05/513bd40db153439b58bebf5dfc633759661aae573907126e3f338e9f3fb78006.receipt.json b/vision-fixhub/court-05/513bd40db153439b58bebf5dfc633759661aae573907126e3f338e9f3fb78006.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..eba16a45daf47f552e028dc2683dcd807dc1dfb7 --- /dev/null +++ b/vision-fixhub/court-05/513bd40db153439b58bebf5dfc633759661aae573907126e3f338e9f3fb78006.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -35, + "dataset": "marble-joined", + "doc_id": "513bd40db153439b58bebf5dfc633759661aae573907126e3f338e9f3fb78006", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "1ee61454421d67987a9a71e2ae73e350101bc39217b7c276cbae14ff588127de", + "output_sha256": "a32df1b692dcd93d0fe42c73acacf4f317f7ac59848428c7e9f000ceaa4000f2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/515a1e5cc4c14d80be449f84e5056a3c5924cf4054f656941380886983101b2c.md b/vision-fixhub/court-05/515a1e5cc4c14d80be449f84e5056a3c5924cf4054f656941380886983101b2c.md new file mode 100644 index 0000000000000000000000000000000000000000..4091b55e7a0fada34d7835074d397180154e736c --- /dev/null +++ b/vision-fixhub/court-05/515a1e5cc4c14d80be449f84e5056a3c5924cf4054f656941380886983101b2c.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 158-15 Filed 05/23/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/515a1e5cc4c14d80be449f84e5056a3c5924cf4054f656941380886983101b2c.receipt.json b/vision-fixhub/court-05/515a1e5cc4c14d80be449f84e5056a3c5924cf4054f656941380886983101b2c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3686d3a83e4f0e678f99befea485f4b8d049f1ba --- /dev/null +++ b/vision-fixhub/court-05/515a1e5cc4c14d80be449f84e5056a3c5924cf4054f656941380886983101b2c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "515a1e5cc4c14d80be449f84e5056a3c5924cf4054f656941380886983101b2c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "5746e2ba14c4878f981dc79c4d3ec0251153ab3e6fe39e1030df524de117b813", + "output_sha256": "60d1512ac802cc2ad0101d941edc36902bdf630e65b7eb8accd7e2a518eae35f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5179e906a3196ce02dce8a4b3ccf83ea5083119f50d4d8bfd744a11c836c7668.md b/vision-fixhub/court-05/5179e906a3196ce02dce8a4b3ccf83ea5083119f50d4d8bfd744a11c836c7668.md new file mode 100644 index 0000000000000000000000000000000000000000..e87e5a0aa29dd739350f0e3ed1cb60154997660a --- /dev/null +++ b/vision-fixhub/court-05/5179e906a3196ce02dce8a4b3ccf83ea5083119f50d4d8bfd744a11c836c7668.md @@ -0,0 +1,85 @@ +Case 1:19-cr-00830-AT Document 20 Filed 01/27/20 Page 1 of 2 +[EsIll FOX & SEPLOWITZ- +attorneys +105 MAIN STREET +HACKENSACK, NJ 07601 +TEL: 201-457-0071 +FAX: 201-457-0072 +30 WALL STREET +8TH FLOOR +NEW YORK. NY 10005 +TEL: 212-709-8230 +WWW.FOYSEPLOWITZ.COM +January 27, 2020 +FILED VIA ECF +Honorable Analisa +United States District Court Judge +Southern District of New York +500 Pearl Street +New York, NY 10007 +Re: +US v. Tova Noel, et al +Docket # 19 cr. 830 (AT) +Request to Adjourn Trial Date +Dear Judge +On November 25, 2019, during the initial status conference the Court scheduled the +above referenced criminal action for trial to commence on April 20, 2020. 1 am +requesting that the trial date be postponed to sometime in October or a date +thereafter that is convenient for the Court. +The adjournment is necessary to ensure that Ms. Noel receives adequate and effective +assistance of counsel. The postponement of the trial will allow for the defense to +review voluminous discovery and conduct a defense investigation of the case. +On November 22, 2019, I informed the Government that I would provide them with +a hard drive during the November 25, 2019 initial status conference. On November +25, 2019, I provided the Government with a hard drive for discovery and the +Government informed the Court that they would produce discovery in 30 days. The +Government forwarded discovery on the hard drive to my office on December 31, +2019. The discovery was received by my office on January 2, 2020. On January 4, +2020, I attempted to review the discovery and I could not access it because the +Government provided the incorrect password to get access. On January 6, 2020, I +was provided with the correct password and gained my first access to the discovery. +The discovery contained in the initial production is 877GB of materials. The 877GB +of materials contains up to 8118 +of global discovery and up to 20,853 | +of +individual discovery. In folder marked SDNY_00000001, there is video surveillance +capturing 3 separate cameras from July 5, 2019 thru August 12, 2019. Each date +allegedly contains the 24-hour period for each day, from each camera, and in 1-hour +increments per individual file. Note, that there is video surveillance in the +Government's possession that has not been turned over, however, the Government + + +Case 1:19-cr-00830-AT Document 20 Filed 01/27/20 Page 2 of 2 +FOY & SEPLOWITZ uc +ATTORNEYS AT LAW +PAGE 2 +indicated that those video surveillance files will be turned over upon request. +Furthermore, SDNY_7549-8118 contains the interviews of approximately 29 +employees and 14 inmates. It will be necessary to interview many, if not all the +witnesses previously interviewed by the Government. +A review of the video surveillance turned over reveals that most of the videos are not +date or time stamped. After discussions with the Government, on January 21, 2020, +1 provided the Government with a flash drive to reproduce the same video +surveillance contained in SDNY_00000001 with the date and time stamps. On +January 22, 2020, the Government received the flash drive and advised my office that +the flash drive was not functioning properly. On January 23, 2020, I forwarded a +1TB hard drive to the Government to provide the requested materials. Based upon +representations made by the Government, I expect to receive the hard drive back by +January 27, 2020. +On January 24, 2020, my office received additional discovery from the Government. +The additional discovery increased the global discovery +number to 8132. +Based upon the volume of discovery received to date, defendant Noel is not able to +determine what motions or legal issues she will raise. I anticipate making additional +requests for discovery or information, however, I will need significant time to review +and digest the discovery to have an appreciation of what materials we do have and +what materials we do not have that we are entitled to. +I will be prepared to discuss this issue in further detail during our upcoming status +conference on January 30, 2020 at 11:00am. Thank you for your thoughtful +consideration. +Sincerely, +FOY & SEPLOWITZ LLC +Jason E. Fay +JASON E. FOY +ifoy@foyseplowitz.com +encl. diff --git a/vision-fixhub/court-05/5179e906a3196ce02dce8a4b3ccf83ea5083119f50d4d8bfd744a11c836c7668.receipt.json b/vision-fixhub/court-05/5179e906a3196ce02dce8a4b3ccf83ea5083119f50d4d8bfd744a11c836c7668.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..17aeb8f1b8df117aa1f39b7c8ac51c418ffa2032 --- /dev/null +++ b/vision-fixhub/court-05/5179e906a3196ce02dce8a4b3ccf83ea5083119f50d4d8bfd744a11c836c7668.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "5179e906a3196ce02dce8a4b3ccf83ea5083119f50d4d8bfd744a11c836c7668", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "47a90980365535bf1978fbc7303c09adc60694545555ae636f4611d4532eda8d", + "output_sha256": "5bb6562da481510f6609ab1c08a05e646256c771f7cfc87843b8d8af7d940d9d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/518e96d9ec443ef40760abc003f4326c91761db235e4fea3bd4343215ef28c03.md b/vision-fixhub/court-05/518e96d9ec443ef40760abc003f4326c91761db235e4fea3bd4343215ef28c03.md new file mode 100644 index 0000000000000000000000000000000000000000..b28915b763bb8c441628e8fc712c4b9d911252cd --- /dev/null +++ b/vision-fixhub/court-05/518e96d9ec443ef40760abc003f4326c91761db235e4fea3bd4343215ef28c03.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 263-34 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/518e96d9ec443ef40760abc003f4326c91761db235e4fea3bd4343215ef28c03.receipt.json b/vision-fixhub/court-05/518e96d9ec443ef40760abc003f4326c91761db235e4fea3bd4343215ef28c03.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..30bec7cef2cbeb5df4e4e3e4997356e5ed6dc701 --- /dev/null +++ b/vision-fixhub/court-05/518e96d9ec443ef40760abc003f4326c91761db235e4fea3bd4343215ef28c03.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "518e96d9ec443ef40760abc003f4326c91761db235e4fea3bd4343215ef28c03", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "119b35bb5c7488cc2350918fc3ef52e042aefff819fbd95e039b7f638f3f20ae", + "output_sha256": "866c4a00024935dfa44430992eb607f4cd5ac297e61158f67d7241606c000d15", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/51b5063f3dd38d9e9b576fa3e4562d296e915b81d3fb96ac4371600a9c9d7bef.md b/vision-fixhub/court-05/51b5063f3dd38d9e9b576fa3e4562d296e915b81d3fb96ac4371600a9c9d7bef.md new file mode 100644 index 0000000000000000000000000000000000000000..d31a2220563b7af2e9b4bb0dccbc08c279c3d550 --- /dev/null +++ b/vision-fixhub/court-05/51b5063f3dd38d9e9b576fa3e4562d296e915b81d3fb96ac4371600a9c9d7bef.md @@ -0,0 +1,167 @@ +Case 1:22-cv-10904-JSR Document 226-41 Filed 07/24/23 +_Page 1 of 4 + + + +Case 1:22-cv-10904-JSR Document 226-41 Filed 07/24/23 Page 2 of 4 +From: +Sent: +To: +Subject: +Ryan, Maryanne X [/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MARYANNE.X.RYAN] +1/10/20115:09:25 PM +Langford, William D [william.d.langford@jpmchase.com]; DeLuca, Phillip A [phillip.a.deluca@jpmchase.com]; +Nichols, Nina A [nina.a.nichols@jpmchase.com] +RE: Jeffrey Epstein +05-08. Seems JPMC never was served a subpoena, +Bear got one in 07. +Rich is getting me the AUSA correspondence and we will compare their ask of Bear +(something about $1000 and S100,000 transactions were of interest to them) +How it came up again was his account alerted in Fortent for cash activity which it does for time to time +and we went to Jim and he again said PB is comfortable with him and that Steve Cutler +I spoke to Phil and given the HT project thought that Steve Cutler may feel differently about +pstein, given the exposure the bank has received on the HT project. +I circled back with PB and that was +the reason for the RR meeting on Friday. Seems PB was not so thrilled with retaining him, it was all due +Digging will take a few days, I'1l get back to you when I am done. The guy likes cash so the paper trail +could be hard. +Regards, +Maryanne Ryan, +Department | | 194 +Vice Presenue south, Frat 4, Isen, a 08830-27ko A V: 1321452. Compliance +Avenue South, Floor 4, Iselin, NJ +----Original Messagerom: Langford, William I +Sent: Monday, +2011 11:55 AM +To: Deluca, Phillip A; Nichols, Nina A +Cc: Ryan, Maryanne X +Subject: RE: Jeffrey Epstein +what do we have todihas ties +noted below that he +"thes forde modesing Tency, stethat really tells us and bad activity? yo +o the modeling agency +Also, how again did this come up recently? was it the negative media this summer? +- W +•----Original Message----- +From: DeLuca, Phillip A +Sent: Monday, January 10, 2011 11:29 AM +To: Nichols, Nina A; Langford, William D +Cc: Ryan, Maryanne X +Subject: FW: Jeffrey Epstein +several other eat 15 as we 1 but for ed most part the attachments above may be the bulk or walt you are +Phil +--Original Message-- +From: Ryan, Maryanne X +Sent: Monday, January 10, 2011 11:03 AM +DeLuca, +Phillip A +Subject: RÉ: Jeffrey Epstein +tere is the RR memo which includes I think everything you would want, or W would want. Let me know afte +ou read it if there is more you would like to see +Regards, +Maryanne Ryan, +Department] | 194 +ice Presidene Sout eror 4 Ise a 03830-27k N.A V 992. 452. Complianc +venue south. Floor 4. Iselin. i +--Original Message- +From: DeLuca, Phillip A +Sent: Monday, January 10, 2011 10:42 AM +To: Ryan, Maryanne X +JPM-SDNYLIT-W-00031038 + + +Case 1:22-cv-10904-JSR Document 226-41 Filed 07/24/23 Page 3 of 4 +Subject: FW: Jeffrey Epstein +Maryanne, +Can you please begin to gather his info? +Thanks, +Phil +--Original Message-. +From: Langford, William D +Sent: Monday, January 10, 2011 9:18 A +To: +Phillip A; Nichols, Nina A +Subject: +Ok. Can you all assemble prior email on the facts and include any relevant press reports so we can get +a11 the facts asap in advance is any meeting with Jest +Thanks. +W +Sent with Good (www.good.com) +-----Original Message----- +From: Deluca, Phillip A +Sent: Monday, January 10, 2011 07:50 AM Eastern Standard Time +To: +CC: +Langford, 1111 am D +Subiect: +FW: Jeffrey Epstein +Nina, +here prose one color around this matter: rais fits into the never a an dent categor with wi171 am +he'1l provide sone color around this matter. +Please see below. I can also fill you in with additional details when we speak. In essence: +JPMC maintains the Private Banking (PB) relationship for this individual, Jeffrey Epstein. +e is alleged to be involved in the human trafficking of young girls and law enforcement 1 +1so allegedly investigating his involvement in this activity +He is also an alleged personal associate of the CEO of the Investment Bank (Jes Staley) +AML Operations went to a PB risk meeting late last week requesting that we exit this +relationship. +and PE management of pus Sash taney tating) dupreet used (ee erdon) suggest that within +'m copying william as we have discussed this individual in the past and you may not have email set l +it. Maryanne Ryan's email below discusses the request as well as additional detail related to Epstei +Please let me know when you have a few moments to discuss. +Thanks, +Phil +-----Original Message-.-- +JPM-SDNYLIT-W-00031039 + + +Case 1:22-cv-10904-JSR Document 226-41 Filed 07/24/23 Page 4 of 4 +From: Ryan, Maryanne X +Sent: Friday, +January 07, 2011 7:33 PM +To: Deluca, Phillip A +Cc: Middlemiss, Arthur +Subject: Jeffrey Epstein +Philemail is a summary of the Rapid Response meeting regarding Jeffrey Epstein. It involves an ask of +William +so I am sending to you first. +The RR +Bonnie +meeting attended by Catherine Keating, Ann Verdon, the current and former banker, Kevin, Jim and +from Risk and Art and I. +leffrey Epstein is a friend of Jes Ș and Catherine feels that PB along with william should meet with hin +o explain the HT project and explain the banks recognition on the project and whether Epstein if furthe +exposed could have a potential serious impact. +Epstein was released in July from house +arrest and the Palm Beach Post carried two articles saying DOJ +be investigating +for child trafficking via a modeling agency he is part owner_in. +believes that after the briefing on HT that Jes would need to point blank ask Jeffrey the status of any +criminal investigations. +crimined tim as a client. Sets it ama is due to kes personal relationayip all he has about 212 mil +in the bank and some in JPMS (old Bear PCS) +I asked legal and asked on the call about if we were ever +subpoened and seems it is No which I find very +ercepter she pered scone i a songered by Ate in my were her love transactiong en tightng as +palm beach and in st +pomp bed to and iness stories mes places of resideades: Plus iots of video +lingerie shops, drug stores ny +| (his places of residence). +like girls gone +other shops not fit for my good catholic upbringing! +The transactions are old 05 to 08. Besides frequent +frequent spa like charges it has died down . +Surprised she was never subpoened. +The one new concerning +is the one article about the DOJ investigation is saying they brought under +age girls to the US +said today we extended Epstein a +via a modeling agency M2 that is owned by a guy named Brunel. Turns out the banker +in relation to this modeling agency. +It appears to be a legit +modeling agency. If girls were expolited via their contract or arrangement it would be hard for us to +tell. +Bottom line we need W to meet with Jes to explain HT and then Jes could decide the next steps. +Typed on my bb so sorry for typos. I do have a PB rapid response memo I can forward as well. +JPM-SDNYLIT-W-00031040 diff --git a/vision-fixhub/court-05/51b5063f3dd38d9e9b576fa3e4562d296e915b81d3fb96ac4371600a9c9d7bef.receipt.json b/vision-fixhub/court-05/51b5063f3dd38d9e9b576fa3e4562d296e915b81d3fb96ac4371600a9c9d7bef.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6b38586bb5d030d9fdbc961631ecee888947cfd2 --- /dev/null +++ b/vision-fixhub/court-05/51b5063f3dd38d9e9b576fa3e4562d296e915b81d3fb96ac4371600a9c9d7bef.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -62, + "dataset": "marble-joined", + "doc_id": "51b5063f3dd38d9e9b576fa3e4562d296e915b81d3fb96ac4371600a9c9d7bef", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "3db13195107adc99e93080e7ad821a47670ae94a243b52c76c698b2b78065420", + "output_sha256": "bae77747e66b187f484318483546f1668b2bc16a4dd2636728dcb1b06637cf09", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/520b4e262d2ec19a4a99c795674e9ab3068ff8a49b1d9ee1e6bd77cb0f5d5689.md b/vision-fixhub/court-05/520b4e262d2ec19a4a99c795674e9ab3068ff8a49b1d9ee1e6bd77cb0f5d5689.md new file mode 100644 index 0000000000000000000000000000000000000000..e29d7aba814393c2baed5c9b6df20d576d4f7c4b --- /dev/null +++ b/vision-fixhub/court-05/520b4e262d2ec19a4a99c795674e9ab3068ff8a49b1d9ee1e6bd77cb0f5d5689.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 267-32 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/520b4e262d2ec19a4a99c795674e9ab3068ff8a49b1d9ee1e6bd77cb0f5d5689.receipt.json b/vision-fixhub/court-05/520b4e262d2ec19a4a99c795674e9ab3068ff8a49b1d9ee1e6bd77cb0f5d5689.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0547cef76710ee914aa6c53017219aa53a52fcc2 --- /dev/null +++ b/vision-fixhub/court-05/520b4e262d2ec19a4a99c795674e9ab3068ff8a49b1d9ee1e6bd77cb0f5d5689.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "520b4e262d2ec19a4a99c795674e9ab3068ff8a49b1d9ee1e6bd77cb0f5d5689", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "9f139c21b7d2aa404981c8726dfd671bfb6003d509f422fc9f7faed9ba15bb3c", + "output_sha256": "5d6682da46f3444ea7859daa89452b0b1f8309c923901b68e31e5dd6d31d6152", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/521c9ba5f64065bb716536f0132ebc9dfcdc020fed1e13a39d6fb3aa47dd4112.md b/vision-fixhub/court-05/521c9ba5f64065bb716536f0132ebc9dfcdc020fed1e13a39d6fb3aa47dd4112.md new file mode 100644 index 0000000000000000000000000000000000000000..9514832de36cf1c84bb8d0125011797dc3de5d0b --- /dev/null +++ b/vision-fixhub/court-05/521c9ba5f64065bb716536f0132ebc9dfcdc020fed1e13a39d6fb3aa47dd4112.md @@ -0,0 +1,40 @@ +Case 1:22-cV-10904-JSR Document 186-41 Filed 06/14/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 186-41 Filed 06/14/23 Page 2 of 2 +ST. CROIX 116 +Street, Frederiksted, VI 00840 (340) 773-6499 FAX (340) 773-7701 +8000 Misky Shapping Center, Suite 620, St. +L V1 00802 (340) 714-1700 FAX (340) 715-2753 +WWW.USVIEDA.ORG +UNITED STATES VIRGIN ISLANDS +Economic Development Authority +January 7, 2015 +VIA Certified Mail +Jeffrey Epstein +Financial Trust Company, Inc. +6100 Red Hook Quarter B3 +St. +VI 00802 +RE: Southern Trust Company, Inc. +Dear Mr. Epstein: +Given the current media discussions surrounding a principal of Southern Trust Company, Inc., the +USVI Economic Development Authority (VIEDA) requests that no later than January 9, 2015, an +assessment of the potential impact, if any, on the business activities of Southern Trust Company, Inc., +as approved by the USVI Economic Development Commission, be provided to the VIEDA. +Regards, +berry +Stephanie J. Berry +Director, Compliance +CC: +Cecile de Jongh, Office Manager STC (via email only) +Erika Kellerhals, Attorney for STC (via email only) +Clouden, Chief Executive Officer +Jennifer Nugent- +, ACEO/Chief Operating Office +Tracy I +Bhola, Legal Counse +Sandra Bess, Compliance Officer + +ESTATE_JPM018432 diff --git a/vision-fixhub/court-05/521c9ba5f64065bb716536f0132ebc9dfcdc020fed1e13a39d6fb3aa47dd4112.receipt.json b/vision-fixhub/court-05/521c9ba5f64065bb716536f0132ebc9dfcdc020fed1e13a39d6fb3aa47dd4112.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..977725e0d338e1c06bed24c0e6bf0c4bff3a4d6d --- /dev/null +++ b/vision-fixhub/court-05/521c9ba5f64065bb716536f0132ebc9dfcdc020fed1e13a39d6fb3aa47dd4112.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -46, + "dataset": "marble-joined", + "doc_id": "521c9ba5f64065bb716536f0132ebc9dfcdc020fed1e13a39d6fb3aa47dd4112", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "08bed5e02b22f1e3bd4eca1e84f389c1ab42086a96da6ce936854250a092b9db", + "output_sha256": "eac47395447ac9a97ff6330b01c0b29b1cfbc2229fb560ec06239d63b53f7bda", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5269566fef19d509c836c74440fc13a0eea18f108ffd2fd361b0898c6e0b269b.md b/vision-fixhub/court-05/5269566fef19d509c836c74440fc13a0eea18f108ffd2fd361b0898c6e0b269b.md new file mode 100644 index 0000000000000000000000000000000000000000..0b3de6d1d14964e236caff154d500177dccbab30 --- /dev/null +++ b/vision-fixhub/court-05/5269566fef19d509c836c74440fc13a0eea18f108ffd2fd361b0898c6e0b269b.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 311-24 Filed 08/25/23 + + +Filed Under Seal diff --git a/vision-fixhub/court-05/5269566fef19d509c836c74440fc13a0eea18f108ffd2fd361b0898c6e0b269b.receipt.json b/vision-fixhub/court-05/5269566fef19d509c836c74440fc13a0eea18f108ffd2fd361b0898c6e0b269b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..02092aa2ed2b49bb212a599b28d5dadc5090b0a3 --- /dev/null +++ b/vision-fixhub/court-05/5269566fef19d509c836c74440fc13a0eea18f108ffd2fd361b0898c6e0b269b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "5269566fef19d509c836c74440fc13a0eea18f108ffd2fd361b0898c6e0b269b", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "e6f170c3b92d5d89dc7ec59b072fd601677bb897bb48b7d0c1e6c7dceb14076d", + "output_sha256": "be16d9e8823c218ddded8af8a60e55256fbfacf5710fd35b5d58efba1fecb871", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/527ea16a40ebd08f30054a979671b272a7c942b0a01ed51baa0c6b887b95ad6e.md b/vision-fixhub/court-05/527ea16a40ebd08f30054a979671b272a7c942b0a01ed51baa0c6b887b95ad6e.md new file mode 100644 index 0000000000000000000000000000000000000000..0c5a06423f3646b918d63419402ed95c5ec0b713 --- /dev/null +++ b/vision-fixhub/court-05/527ea16a40ebd08f30054a979671b272a7c942b0a01ed51baa0c6b887b95ad6e.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 243-34 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/527ea16a40ebd08f30054a979671b272a7c942b0a01ed51baa0c6b887b95ad6e.receipt.json b/vision-fixhub/court-05/527ea16a40ebd08f30054a979671b272a7c942b0a01ed51baa0c6b887b95ad6e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ed0f95efcaad68439ba693cbb108eb397d9f85ab --- /dev/null +++ b/vision-fixhub/court-05/527ea16a40ebd08f30054a979671b272a7c942b0a01ed51baa0c6b887b95ad6e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "527ea16a40ebd08f30054a979671b272a7c942b0a01ed51baa0c6b887b95ad6e", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "3a70797dfe5ec749f28e11f7cde848485ff902db860d549d4a7996c6b19cbbb7", + "output_sha256": "ae33ead15d3b425a019f215629d35c17a5001d8917190d794601ed6a9a6f3fca", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/529259ddfda05a17e4051926d7dd9ae005b8a65cebc8fc84bf9c0c7b63933cac.md b/vision-fixhub/court-05/529259ddfda05a17e4051926d7dd9ae005b8a65cebc8fc84bf9c0c7b63933cac.md new file mode 100644 index 0000000000000000000000000000000000000000..957ca5f047e401518f0f3a269b530360c4345e41 --- /dev/null +++ b/vision-fixhub/court-05/529259ddfda05a17e4051926d7dd9ae005b8a65cebc8fc84bf9c0c7b63933cac.md @@ -0,0 +1,36 @@ +Cassel1222e0v1D9904JSFR Documeet 7833 FfléelD33098233 Feagel10622 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiffs, +Case No. 22-cv-10904-JSR +[PROPOSED| ORDER FOR +ADMISSION PRO HAC VICE +V. +JPMORGAN CHASE BANK, N.A., +Defendant. +The motion of Bruce W. Doughty for admission to practice pro hac vice in the abovecaptioned action is granted. +Applicant has declared that he is a member in good standing of the bar of the state of +Illinois, and that his contact information is as follows: +Massey & Gail LLP +50 East Washington Street, Suite 400 +Chicago, IL 60602 +Tel.: (312) 283-1590 +bdoughty@masseygail.com +Applicant having requested admission pro hac vice to appear for all purposes as counsel +for Defendant JPMorgan Chase Bank, N.A. in the above-captioned action, +IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the +above-captioned case in the United States District Court for the Southern District of New +York. + + +Casse11222e0v1D990415FR Documeet 7833 FfleekD33098233 Faage220622 +All attorneys appearing before this Court are subject to the Local Rules of this Court, +including the Rules governing discipline of attorneys. +Dated: March 9 +New York, NY +-, 2023 +The Hom ed S. Rakoff +United States District Judge +2 diff --git a/vision-fixhub/court-05/529259ddfda05a17e4051926d7dd9ae005b8a65cebc8fc84bf9c0c7b63933cac.receipt.json b/vision-fixhub/court-05/529259ddfda05a17e4051926d7dd9ae005b8a65cebc8fc84bf9c0c7b63933cac.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a110d5f38a598a8d52dd01730b247fd17eea4ddf --- /dev/null +++ b/vision-fixhub/court-05/529259ddfda05a17e4051926d7dd9ae005b8a65cebc8fc84bf9c0c7b63933cac.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "529259ddfda05a17e4051926d7dd9ae005b8a65cebc8fc84bf9c0c7b63933cac", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "951e463340d306862e27c2b3937a7ed5c727dc229606acd91e763467106664bd", + "output_sha256": "182d8daba44096e94223e513d1ccb57e80c2da401532fec3581b889c5fad99da", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/529dd1659fd07299b6ec4b3826f84512f75de19dbf57840b4dea1d2843131966.md b/vision-fixhub/court-05/529dd1659fd07299b6ec4b3826f84512f75de19dbf57840b4dea1d2843131966.md new file mode 100644 index 0000000000000000000000000000000000000000..906fda685dfee2342e1c93c110a946d8857f61b8 --- /dev/null +++ b/vision-fixhub/court-05/529dd1659fd07299b6ec4b3826f84512f75de19dbf57840b4dea1d2843131966.md @@ -0,0 +1,31 @@ +Case 1:20-cr-00330-PAE l +Document 768 +Filed 08/10/22 Page 1 of 1 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AM +USA / Plaintiffs) +Case No.: 20-cr-330 +GHISLAINE MAXWELL, +Defendant(s) +) +NOTICE OF FILING OF OFFICIAL TRANSCRIPT +INFERENC +Notice is hereby given that an official transcript of a +held on +has been filed by the court reporter/transcriber in the above-captioned matter. +12/20/21 +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting +the transcript is a judge or a member of the public or media. +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court +any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also +be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically +available to the public without redaction after ninety (90) calendar days. +This process may only be used to redact the following personal data identifiers: Social Security +numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure +5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information +may proceed by motion. +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. +speer +Court Reporter/Transcriber +Date diff --git a/vision-fixhub/court-05/529dd1659fd07299b6ec4b3826f84512f75de19dbf57840b4dea1d2843131966.receipt.json b/vision-fixhub/court-05/529dd1659fd07299b6ec4b3826f84512f75de19dbf57840b4dea1d2843131966.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b04aadc4db4217d36b2beb52806b9d04c51f65b8 --- /dev/null +++ b/vision-fixhub/court-05/529dd1659fd07299b6ec4b3826f84512f75de19dbf57840b4dea1d2843131966.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -14, + "dataset": "marble-joined", + "doc_id": "529dd1659fd07299b6ec4b3826f84512f75de19dbf57840b4dea1d2843131966", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "7e932937178141bd3af4a9e47acfe1b6fe94fc2bbeb22f789402c5cb68eda755", + "output_sha256": "40cf86bf0501a748602859e7385b3800836cf252d4fabc2b4b5173327af1e2b8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/52c018dfc4e6dae522f9e7ae6e7a4fdc8401a3dfdce007aceecd94b8e45e22cd.md b/vision-fixhub/court-05/52c018dfc4e6dae522f9e7ae6e7a4fdc8401a3dfdce007aceecd94b8e45e22cd.md new file mode 100644 index 0000000000000000000000000000000000000000..bd20ad8563ae586dcfd8d24c7b0483410414b01b --- /dev/null +++ b/vision-fixhub/court-05/52c018dfc4e6dae522f9e7ae6e7a4fdc8401a3dfdce007aceecd94b8e45e22cd.md @@ -0,0 +1,522 @@ +Case 1:22-cv-10904-JSR Document 315-2 Filed 08/31/23 Page 1 of 10 + + + +Decisions +Case 1:22-cv-10904H6® Treogmenta 15r Bentited: @8/31/BacisiRag@ediafy10 +DecisionsCE +• Course Library +&+ New User +& Existing User +© Help +Miscellaneous +Latest CE Courses +Human Trafficking: Red Flags for Dental Professionals +Dentists and dental hygienists should look for the subtle signs of victimization so they can offer appropriate +treatment, resources and referrals. +By Sheryl L. Syme, RDH, MS, Susan Camardese, RDH, MS and Kimberly Mehlman-Orozco, PhD On Aug 4, 2017 +Dentists and dental hygienists should look for the subtle signs of victimization so they can offer appropriate treatment, resources +and referrals +PURCHASE COURSE +This course was published in the August 2017 issue and expires August 2020. The authors have no commercial conflicts of +interest to disclose. This 2 credit hour self-study activity is electronically mediated. +OBJECTIVES +After reading this course, the participant should be able to: +1. Discuss trends in human trafficking, and oral health professionals role in identifying, treating and helping victims. +2. Explain the types of individuals that human traffickers target, and tactics for manipulating victims. +3. Describe common oral injuries that trafficking victims present with, as well as reasons why victims typically underreport +abuse. +This website uses cookies to improve your experience. We'll assume you're ok with this, but you can opt-out if you wish. +https://decisionsindentistry.com/article/human-trafficking-red-flags-dental-professionals/ +1/9 + + +8/28/23, 12:50 PM Case 1:22-CV-10904+6® TrIcorenta16- Bentited 08/21/Daisibag @eatiaty10 +Human trafficking is a rampant global health problem affecting a growing number of childrepraadedolisk@s Rokeyrldwide basis, +traffickers use fraud, coercion, threats and deception to manipulate victims into various forms of exploitation, including domestic +servitude, sex trafficking, sham marriages, forced labor and criminal activity. Trafficking is identified as a form of slavery and a +major, yet often hidden, crime involving the control of victims for the traffickers' economic gain. Targeting potential victims who +appear lost, disenfranchised or in desperate situations, traffickers are adept at isolating victims from social support systems and +creating dependency, limiting victims' movement to work settings, and hiding the red flags and signs of victimization. Victims +are often lured by promises of lucrative employment, stability, ability to obtain an education, a steady income to send home to +support their families, or a loving relationship — some or all of which represent opportunities absent in the victim's life. +While the stories of trafficked survivors often include accounts of trying to improve their lives or that of their families, and desires +to migrate to areas that promise a better future, these individuals are not always migrants. Although transportation may be a +control tactic to keep human trafficking victims in unfamiliar places, the defining characteristic is exploitation for profit, rather +than being moved from one region to another. Given the extent of the problem and fact that trafficked individuals may seek +dental treatment, oral health professionals have a responsibility to recognize the signs that may indicate victimization, and be +prepared to provide appropriate treatment, resources and referrals (Table 1). +The United States is a key source, site of transport and destination for trafficked individuals. Reports of trafficking to the National +Human Trafficking Hotline and Polaris BeFree Textline have been increasing in all 50 states and Washington, D.C. The National +Human Trafficking Hotline is partially funded by the U.S. Department of Health and Human Services and is operated by Polaris, a +nonprofit, nongovernmental anti-trafficking organization. While a lack of uniformity in reporting +and tracking victims in a +universal database, as well as the clandestine nature of this criminal activity, creates challenges in identifying victims, the U.S +Department of State estimates more than 26 million individuals are subjected to human trafficking worldwide. As regional and +global markets increase for human trafficking, so, too, does the need to identify trafficked individuals. Considering that health +care providers may be among the few professionals to come in contact with these individuals, it behooves clinicians to be +prepared to identify possible victims. +TABLE 1. Resources for Seeking Help or Reporting Human Trafficking +Resources +Purpose +National Human Trafficking Hotline +24/7 toll-free national anti-trafficking hotline and resource center +888-373-7888 +providing assistance with service providers and placement +resources; operated by the nongovernmental Polaris organization +that's funded by the federal government +Local Police Department +Call for immediate safety, advising and protection concerns +911 or local contact number +Department of Homeland Security +Blue Campaign to End Human Trafficking +dhs. gow/blue-campaign/victim-centered +Polaris Project website and Resource Center +polarisproject.org +U.S. Immigration and Customs Enforcement (ICE) +Homeland Security Investigations (HS) +866-347-2423 (866-DHS-2-ICE) or report online +using the HSl Tip Form ice.gowwebform/his-tip-form +Provides legal assistance, special -Visa authorization for victims of +human trafficking and victim support; provides immigration relief +to non-U.S. citizens of human trafficking +Nonprofit, nongovernmental organization working directly with +victims, Polaris hosts the National Human Resource Center crisis +hotline and BeFree Textline: text HELP or INFO to BeFree (233733) +U.S. Immigration and Customs Enforcement/Homeland Security +Investigations investigates human trafficking and arrests traffickers. +Call if clinicians notice suspicious activity in the practice or +community +TRAFFICKING TARGETS +Labor trafficking victims are most often recruited through a job offer and represent approximately 11% percent of our nation's +victims, while sex trafficking accounts for 82% of victims in the U.S.; of the latter, most are trafficked by their intimate partners. In +2016, an estimated one out of six of the 18,500 runaway children reported to the National Center for Missing and Exploited +Children were likely sex trafficking victims. Children are often targeted through social networking and escort websites, and at +bus and truck stops, train stations, youth centers, homeless shelters, schools and malls - often within hours of displacement +from their homes. +278 Youth entrapment and enmeshment schemes are frequently used in sex trafficking of minors and +resemble power and control techniques observed in other exploitive relationships, such as intimate partner violence (IPV), in +whichstbere era sim dasities to ithendriyaand erretatoe desiesyou're ok with this, but you can opt-out if you wish. Accept +https://decisionsindentistry.com/article/human-trafficking-red-flags-dental-professionals/ +2/9 + + +Case 1:22-cv-10904нlSR TrDoogrent 1 6rBenFilade08/31/28cisiDag@ehtefy10 +• In both child sex trafficking and IP\ tbarafüobelegrotigetrator gain +TABLE 2. Human Trafficking Assessment Questions* +Clinicians should identity their +interest in helping and avoid sounding +judgmental when asking the following screening questions: +1. +Are you living and working in a safe place? Where and when do you sleep? +2. Have you ever been pressured to do something that you didn't want to do or +were uncomfortable doing? +3. Have you ever been threatened or intimated by someone? If so, what did this +4. +person say would happen to you? +Are you able to come and go freely at home and work? +5. +What happens if you leave or talk of leaving home or work? +6. +Do you have access to any money or the money you eam? Has anyone taken +some or all of your money, or held your money with promises to keep it safe? +7. Do you owe money to someone? Are you in debt to someone and how are +you paying off the debt? +8. +Does someone control, supervise and/or monitor you and your work? +9. Her youd a phone or compute that hapese te orse i oft? Have you +10. Do you have days off from work and what do you do on your days off? Are +you allowed to take breaks at work? If you are not feeling well, are you able +to take time off from work? +11. Has someone ever controlled your access to food and drink, health care +and/or medications? +12. Has someone ever taken your identification papers, passport or other +personal documents? +* Adapted from The Polaris Project. Human Trafficking, Recognize the Signs. 2017. +Available at polarisproject.org/recognize-signs. +control by isolating victims from outside social support and terrorize +victims through the use of emotional blackmail and/or physical and +sexual violence. Glamorizing and normalizing commercial sex are +additional ways adolescents are enticed into sex trafficking, often by +traffickers' use of peers for recruiting. This may include peer recruiters +who appear to be living the good life. Pervasive themes in the +literature indicate that a female's age is her greatest vulnerability to +being sex trafficked as a minor. Vulnerable populations include +children in the child welfare system and +care, runaways, +homeless individuals, individuals living in impoverished communities +seeking work, migrant workers, persons with limited English skills, +persons with disabilities, socially marginalized individuals, persons +rooted in vulnerability to gender inequality situations, and persons +1-4,8,10-15 +who identify as lesbian, gay, bisexual, transgender or intersex. +Increasingly, reports indicate that traffickers are preying on those with +intellectual or other disabilities and using drugs or withholding +medication and health care to manipulate victims into commercial +,?!' Branding and tattooing are common, and mark the trafficked person as property, enabling the trafficker to claim +ownership of the victim and signal other pimps to stay away. +CHALLENGES IN IDENTIFYING VICTIMS +Identifying victims poses a significant challenge to researchers and professionals who provide medical or dental care, +interventions and refer resources because trafficked children and adults rarely self-identify. Trafficked victims may underreport +because they:" +• Lack access to legal or support services +• Fear retaliation from their traffickers against them or their family +• Have been conditioned to fear and distrust anyone other than their captors, including law enforcement or other authorities +• Fear the consequences of being identified as illegal immigrants or criminals, instead of victims +• Feel ashamed of their activities and how their families and communities will receive them if they return +• Feel a sense of hopelessness in escaping their captor, and the emotional or financial indebtedness employed by their +controlling trafficker +• Do not identify that they are being trafficked +PSYCHOLOGICAL AND PHYSICAL COSTS +Traffickers use intimidation and emotional entrapment to control victims, including violence against the individual or their family +and friends, threats of deportation, confiscation of identification documents, shaming or guilt, and trauma-bonding (in which +the trafficked person fears the trafficker, yet feels relieved to be taken care of, offered employment and allowed to live). Trafficked +individuals are routinely exposed to "seasoning"6 +tactics, such as withholding food, water, sleep or social contact, and +psychological trauma that enabled the trafficker to achieve submission, increase dependence and reduce resistance. +Psychological entrapment often prevents victims from escaping, even when opportunities arise." Victims and survivors may +experience multiple psychological conditions, including severe post-traumatic stress disorder, rape trauma syndrome (the series +of emotional, physical and behavioral reactions experienced by rape victims), and child sexual abuse accommodation syndrome +(in which children go through five stages of response to ongoing abuse, including secrecy, helplessness, accommodation, +delayed disclosure and retraction). In addition, victims may have anxiety and/or nervous disorders, psychosomatic syndromes, +eating disorders, personality disorders, depression, coping substance abuse (and subsequent addiction), and thoughts of self- +3,8,11,18 +harm or suicide. +Victims of human trafficking frequently present to medical and dental facilities with a variety of physical health needs, including +injuries from violence, head and neck trauma, sexually transmitted diseases (STDs), dental or orofacial conditions, and +19,20 +https://decisionsindentistry.com/article/human-trafficking-red-flags-dental-professionals/ +3/9 + + +8/28/23, 12:50 PM Case 1:22-cv-109046R TrDoogrenta15r Bentilade 08/31/28cisiRage Gefy10 +multiple pregnancies and forced abortions. Physical injuries to trafficked individuals are ofterpinflickedodhesheidyand face, +3,11,21 +including teeth and jaw fractures and mandibular dislocations; +consequently, demand for dental care is one of many +22,23 +common needs of trafficked victims. +Neglected health conditions - such as uncontrolled asthma, hypertension, diabetes, +nourishment, obesity, addiction, +untreated skin infections/lesions, untreated caries and periodontal disease - and withholding medication or noncompliance +with recommended therapies may be signs that trafficked individuals are being prevented from accessing care. +ORAL HEALTH PROFESSIONALS' ROLE +HUMAN TRAFFICKING CASE SCENARIOS +Victims may present for dental services as a result of restricted access to +dental hygiene products or deleterious effects on oral health from sex or +labor work, as well as for cosmetic purposes. Additionally, a sex trafficker's +interest in seeking cosmetic dental services would most likely stem from +a desire to make the victim more attractive to clients. Thus, the +responsibility of identification relies on the provider's ability to recognize +the sometimes subtle signs of victimization and follow up with focused +questions to assess immediate treatment and referral needs. That said, +the role of oral health professionals in assisting victims of human +20,24,25 +trafficking has not been extensively discussed in the literature. +In +some cases, dentists and dental hygienists may be the first responders in +rendering care to trafficked individuals. +** A survey of U.S.-based survivors +of human trafficking shows that while being trafficked, 26.5% were seen +by a dentist, along with other health care providers, but few victims were +26 +identified by these clinicians. +The following examples represent scenarios of human +trafficking that oral health professionals may +encounter. They also reflect individuals and +relationships that do not necessarily fit stereotypic +profiles of victims and perpetrators, which makes +identification difficult. +Scenario 1: "B," a 15-year-old girl, is brought into a +dental office as a new patient; she is accompanied by a +woman who says she is her aunt and caring for her +because B's mother and father died recently. Initially, B +is seen by the dental hygienist to start the medical +history and assessments. The aunt reports that she +doesn't know details of B's medical history, except that +she had an abortion this year, a sexually transmitted +disease, and has some broken front teeth from falling +down steps. The aunt also reports that B dropped out +of school this year and has been difficult to manage. +The girl appears shy and afraid of the aunt, and asks +to use the restroom. The aunt appears nervous when B +Signs of abuse or other indicators of human trafficking warrant follow-up +and a one-on-one conversation without the presence of the victim's +attendant. The online version of this article provides examples of +questions that can be used to assess whether a patient has been a victim +of human trafficking; while this is neither an exhaustive nor cumulative +list, it may prove helpful in the assessment process. +leaves with the dental hygienist, who has offered to +show her to the restroom. The aunt follows them and +yells at B to hurry up and repeatedly asks the dental +hygienist what can be done to fix B's teeth so they can +get back to work soon. After exiting the restroom, the +dental hygienist asks B if she is OK or in need of +assistance, but B is apprehensive and seems afraid of +receiving help. +Scenario 2: "T," a 25-year-old petite woman, is +brought into a dental office by a husband and wife +In recognition of the suspected frequency with which (as yet +unidentified) trafficking victims are being seen in health care facilities. +efforts to educate clinicians about human trafficking have increased in +3,13.21,27 +the last 10 years. +At the same time, documentation of the health +consequences and risks of human trafficking is improving, as is science's +understanding of the gas 2 health care providers knowledge about +this growing problem. +Dentists, +2024 mental health workers, +emergency room professionals, +gynecologists or other specialty +physicians,1.21 +16,19 +and nurses and midwives +would all benefit from +training designed to increase recognition of trafficking victims so an +interdisciplinary response can be initiated. +who are among the longest tenured families in the +practice. They report that T is an undocumented +migrant and does not have any medical records, +passport or identification documents. She recently +became a nanny for their twin 18-month-old sons, and +the family explains they are willing to foot the bill to +get her decayed teeth restored because she is such a +wonderful help with their sons and "good child care +is hard to find." The couple says that T's appearance +frightens the children and embarrasses them in front +of friends and family. She does not make eye contact +and appears to have multiple faint bruises on her +face, neck and forearms. She appears to be unable to +sit with her back against the dental chair. The couple +reports the twin boys are quite rambunctious and a +little rough on T. The couple states that they can +speak for T in decisions made about her teeth. +CLINICAL STRATEGIES +Increasingly, it is recognized that dental providers +may routinely encounter, but inadvertently overlook, +Separating the patient from the third party accompanying the individual +individuals who are presently (or previously) victims +to the health visit is a crucial first step in conducting screening questions +of human trafficking. With this in mind, it is prudent +about human trafficking. A third party's refusal to allow the patient to be +for clinicians to watch for signs of abuse and/or +human trafficking, and offer the appropriate +alone with the provider may indicate that he or she is not concerned with +treatment, counseling, resources and referrals. +obtaining the best care for the patient, but instead fears being divulged +as a trafficker. The patient can be asked if he or she requires an +interpreter or prefers a male or female clinician. It is also up to the clinician's judgment to enlist interpreter services if the +promidas eusee cise ireesires tcompsuaigatioex iseffecting shesibilita feurovide teen aot yealtan ap-Ebeinenial shinterpteter +services by the person accompanying the patient may be apshe med flag indicating victimization. +https://decisionsindentistry.com/article/human-trafficking-red-flags-dental-professionals/ +4/9 + + +8/28/23, 12:50 PM Case 1:22-cv-10904+6® Troorenta16-Bentilad 08/21/Daisibag@ Giaty10 +Clinicians should not inquire about trafficking-specific details, but should know their state-møridated Gpattingoliys for children +and adults, as well as vulnerable adults, and when weapons are involved. Oral health professionals are mandated to report their +suspicions of abuse and neglect perpetrated against children under 18, regardless of consent. Detailed documentation of +craniofacial injuries and other injuries identified during the dental examination should include descriptions, locations, duration +and information pertaining to the cause. +If a patient divulges that he or she is a victim, it is imperative to establish rapport, acknowledge the presence of trauma +symptoms, respect an adult victim's decision on whether he or she is ready and able to self-report, and attend to the individual's +immediate needs and safety. Clinicians should not divulge personal addresses or contact information, or attempt to harbor the +trafficked person. Unless legally mandated, providers should not contact authorities without consent of an adult trafficking +victim; instead, oral health professionals are advised to encourage self-reporting and refer the patient to the appropriate support +If the victim's personal decision is in contrast with the health care provider's, a trauma-informed approach enables the trafficked +individual to feel in control and respected, perhaps for the first time. Establishing this level of trust may provide an opportunity +for the victim to potentially return when he or she is ready to escape the trafficking situation. +REFERRALS AND RESOURCES +Compared to other victimized groups, there are relatively few resources and long-term sustainable services for individuals +identified as victims of human trafficking.' +?.' Trauma-informed programming is essential to the recovery and reintegration of +survivors, and requires an approach that effectively focuses on the physical and mental health consequences of human +trafficking 31732 As noted, Table 1 provides resources for those who seek help or wish to report suspected cases of human +trafficking. It is imperative for dental teams to familiarize themselves with local resources, such as housing, legal assistance and +trauma-informed care providers, as well as their intake requirements (e.g., residency, gender or age). +This website uses cookies to improve your experience. We'll assume you're ok with this, but you can opt-out if you wish. +https://decisionsindentistry.com/article/human-trafficking-red-flags-dental-professionals/ +5/9 + + +Case 1:22-cv-109046R TDoorenta15r Bentited 08131/ DacisiBag@ ehaty10 +TABLE 3. Red Flags for Identifying Human Trafficking* +Indicators for Individual(:) in Question +• Is restricted in coming and going places as he/she wishes +• Is under age 18 and providing commercial sex acts +• Is in the commercial sex industry and has a handler/manager or pimp +• Wages are low or non-existent or paid only through tips +• Works excessively long hours with little or no breaks +• Experiences strict rules or works under severe restrictions +• Was recruited with false promises regarding the work he/she would be involved in and +promises for a better life, education, higher paying job, or exciting opportunities +• Works all the time but is unable to pay off debt to trafficker +• Works or lives in settings marked by high security measures (cameras, boarded or opaque +windows, bars on window and doors) +Psychological Signs +• Fearful, anxious, depressed or nervous/paranoid (looking around before talking) +• Extreme startle response +• Exhibits combative behaviors as a defense mechanism +• Become anxious and appears distrustful of law enforcement when brought up in conversation +• Doesn't make eye contact and appears very submissive or overly emotionally attached to 3rd party +• Extreme dependence on the 3rd party for living arrangements, drugs, affection +• Emotionless, withdrawn posture +• Unmet health and dental care needs +• Appears malnourished and dehydrated +• By anither patioing in highly visible areas of body to show other pimps that heshe is owned +• Appears to have been physically and/or sexually abused, physically restrained, confined or tortured +• Reports an unusually high number of sexual partners +• Self-inflicted injuries +• Chronic medical conditions +• Multiple, new or recurrent sexually transmitted diseases +• Presents with injuries from inadequate personal protective equipment in the workplace +Lack of Autonomy and Self-Determination +• Has few or no personal belongings +• Doesn't control own money, finances and doesn't have a financial/bank account +• Lack of passport, immigration or identification documents; turned them over to his/er +handler, trafficker, employer or another person +• Is not permitted to speak or must seek permission to speak from 3rd party attending +the conversation with needs for cosmetic treatment and not overall health care needs +• Has been renamed to show ownership by trafficker or to attract more buyers +Lack of Connectedness, Social Outlets and Long-Range Plans +• Claims to be just visiting and unable to convey where he'she is living +• States an unverifiable residential address +• Doesn't know where they are; lack of knowledge of what city, town or even state he/she b in +• Loss of sense of time +• Lacking social contacts outside of handler/trafficker; out of touch with family and friends +• Doesn't express long-range goals or plans for future +• Difficulty in explaining what he/she does for fun or socially +• Doesn't discuss inviting friends over to place of residence +Other +• Age appears falsified or discrepancy between reported and suspected age +• A large discrepancy in age of victim to trafficker +• Accompanied by controlling and demanding person +• Aprove wied by aped areas in entratien obtai and nome ed a long em +treatment plan or preventive care +• Accompanied by third party who offers to pay for all dental work in cash +* Adapted from The Polaris Project. Human Trafficking. Recognize the Signs. 2017. Available at: +polarisproject.org/recognize-signs. +CONCLUSION +Human trafficking is a global public health problem, and dental professionals have the opportunity to play an important role in +identifying and lending support to victims. Given the likelihood that dental teams will encounter victims who are seeking +treatment under a variety of circumstance, they should be prepared to identify, respond and refer for intervention. Clinicians +should utilize the red flag indicators, screening questions, and specific general and oral health presentations commonly +associated with trafficking-related injuries as triggers for interventions. Oral health care is an important component of the +interdisciplinary care necessary for addressing trafficking victims' psychological and physical needs. +This website uses cookies to improve your experience. We'll assume you're ok with this, but you can opt-out if you wish. +https://decisionsindentistry.com/article/human-trafficking-red-flags-dental-professionals/ +6/9 + + +8/28/23, 12:50 PM Case 1:22-CV-10904+6® TDoorenta16- Bentilad 08/31/Daisibage Biaty10 +REFERENCES +1. U.S. Department of State. Trafficking In Persons Report June 2016. Available at: +https://www.state.gov/documents/organization/258876.pdf. Accessed July 17, 2017. +2. U.S. Department of Justice. National Strategy to Combat Human Trafficking January 2017. Available at: +https://www.justice.gov/humantrafficking/page/file/922791/download. Accessed July 17,2017. +3. -Perrin C, Wurtele SK. Sex trafficking and the commercial sexual exploitation of children. Women & Therapy. +2017;40:123-151. +4. JE, +K, Rizo CF. Domestic minor sex trafficking among child welfare-involved youth: an exploratory study of +correlates. Child Maltreat. 2017;22:256-274. +5. Polaris Project. Human Trafficking. The Victims and Traffickers. Available at: polarisproject.org/victims-traffickers. Accessed +July 17, 2017. +6. National Center for Missing and Exploited Children. Child Sex Trafficking. Available at: missingkids.org/lin6. Accessed July 17. +2017. +7. U.S. Department of Justice. The National Strategy for Child Exploitation Prevention and Interdiction. A Report to Congress +- April 2016. Available at: https://www.justice.gov/psc/file/842411/download. Accessed July 17, 2017. +8. +J, Sprang G. Sex trafficking of minors in metropolitan, micropolitan, and rural communities. Child Abuse Neg/. +2015;40:113-123. +9. Reid JA. Entrapment and enmeshment schemes used by sex traffickers. Sex Abuse. 2016;28:491-511. +10. National Human Trafficking Resource Center. 2015 National Human Trafficking Resource Center (NHTRC) Data Breakdown +United States Report 1/1/2015-12/31/2015. Available at: +https://humantraffickinghotline.org/sites/default/files/NHTRC%202015%20United%20States%20Report%20-%20USA%20- +%2001.01.15%20-%2012.31.15_OTIP_Edited_06-09-16.pdf. Accessed July 17, 2017. +11. Macias-Konstantopoulos W. Human trafficking: the role of medicine in interrupting the cycle of abuse and violence. Ann +Intern Med. 2016;165:582-588. +12. +J, Sprang G, Lee R, +J. The trauma of commercial sexual exploitation of youth: a comparison of CSE victims to +sexual abuse in a clinical sample. J Interpers Violence. 2016;31:122-146. +13. Jimenez M, +AM, Deye K. Aspects of abuse: commercial sexual exploitation of children. Curr Probi Pediatr Adolesc +Health Care. 2015;45:80-85. +14. Varma S, Gillespie S, McCracken C, Greenbaum VJ. Characteristics of child commercial sexual exploitation and sex +trafficking victims presenting for medical care in the United States. Child Abuse Negl. 2015;44:98-105. +15. Gibbs DA, Hardison Walters JL, Lutnick A, | +S, Kluckman M. Sevices to domestic minor victims of sex trafficking: +Opportunities for engagement and support. Child Youth Serv Rev. 2015;54:1-7. +16. Hachey LM. Identification and management of human trafficking in the emergency department. Adv Emerg Nurs J. +2017;39:31-51. +17. Logan TK, +R, Hunt G. Understanding human trafficking in the United States. Trauma Violence Abuse. 2009;10:3-30. +18. U.S. Department of State. United States Advisory Council on Human Trafficking Annual Report 2016. Available at: +state.gov/j/tip/263114.htm. Accessed July 17, 2017. +19. Dovydaitis T. Human trafficking: the role of the health care provider. J Midwifery Womens Health. 2010;55:462-467. +20. Nuzzolese E. Human trafficking: role of oral health care providers. J Forensic Odontostomatol. 2014;32:1-8. +21. Lederer L, Wetzel C. The health consequences of sex trafficking and their implications for identifying victims in healthcare +facilities. Annals of Health Law. 2014;23:61-91. +22. Greenbaum VJ. Commercial sexual exploitation and sex trafficking of children in the United States. Curr Prob/ Pediatr +Adolesc Health Care. 2014;44:245-269. +23. Chaffee T, English A. Sex trafficking of adolescents and young adults in the United States: Healthcare provider's role. Curr +Opin Obstet Gynecol. 2015;27:339-344. +24. O'Callaghan MG. Human trafficking and the dental professional. J Am Dent Assoc. 2012;143:498-504. +25. Blackiston L. Saving a life: Recognizing the signs of human trafficking, abuse, and neglect. RDH. 2011;31:1-8. +26. Chisolm-Straker M, Baldwin S, Gaigbé-Togbé B, Ndukwe N. L +PN, | +LD. Health care and human trafficking: +we are seeing the unseen. I Health Care Poor Underserved. 2016;27:1220-1233. +27. Baldwin SB, Eisenman DP, Sayles JN, Ryan G, Chuang KS. Identification of human trafficking victims in health care settings. +Health Hum Rights. 2011;13:1-14. +Med Educ Online. 2017;22:1267980 +https://decisionsindentistry.com/article/human-trafficking-red-flags-dental-professionals/ +7/9 + + +29. +LAM, Lippert S, +Case 1:22-cv-109046R TDoorenta16r Bentited 08191/ DacisiBage Austy10 +K, et al. Educating health care professionals on human traffickingyReciatiEnnelig Care. +2014;30:856-861. +30. Schwarz C, Unruh E, Cronin K, l +-Simpson S, Britton HE, Ramaswamy M. Human trafficking identification and service +provision in the medical and social service sectors. Health Hum Rights. 2016;18:181-192. +31. Hemmings 5, Jakobowitz S, Abas M, et al. Responding to the health needs of survivors of human trafficking: a systematic +review. BMC Health Serv Res. 2016:16:320. +32. Hopper E. Trauma-informed psychological assessment of human trafficking survivors. Women & Therapy. 2017;40:12-30 +Featured Image by STEVANOVICIGOR/ISTOCK/GETTY IMAGES PLUS +From Decisions in Dentistry. August 2017;3(8):30-33. +Sheryl L. Syme, RDH, MS +Sheryl L. Syme, RDH, MS, is an associate professor, director of the Bachelor of Science Degree Completion Program, and director of +curriculum management in the Division of Dental Hygiene of the Department of Endodontics, Prosthodontics, and Periodontology at the +University of Maryland School of Dentistry in Baltimore. She is also the education director for the Mid-Atlantic PANDA (Prevent Abuse and +Neglect through Dental Awareness) Coalition and coauthor of the Abuse and Neglect chapter in Darby's and Walsh's Dental Hygiene +Theory and Practice, 4th edition. She can be reached at ssyme@umaryland.edu. +Susan Camardese, RDH, MS +Susan Camardese, RDH, MS, is cofounder and president of the Mid-Atlantic PANDA Coalition. She is a public health dental hygienist at +Chase Brexton Health Services in Columbia, Maryland, and coauthored the Abuse and Neglect chapter in Darby's and Walsh's Dental +Hygiene Theory and Practice, 4th edition. +Kimberly Mehlman-Orozco, PhD +Kimberly Mehlman-Orozco, PhD, is a founding partner and human trafficking expert witness for Mahn, Mehlman and Associates in +Alexandria, Virginia. She is also an adjunct professor in the Department of Criminology, Law and Society at +Mason University in +Fairfax, Virginia. She has trained both federal and local level law enforcement agents on methodology for identifying geographic patterns +of human trafficking prevalence. +This site uses Akismet to reduce spam. Learn how your comment data is processed. +This website uses cookies to improve your experience. We'll assume you're ok with this, but you can opt-out if you wish. +https://decisionsindentistry.com/article/human-trafficking-red-flags-dental-professionals/ +8/9 + + +Load More +@ Follow on Instagram +Home +Issue Archive +© 2023 - Decisions in Dentistry - All Rights Reserved. +Advertising Opportunities +ISSN 2380-1999 +This website uses cookies to improve your experience. Well assume you're ok with this, but you can opt-out if you wish. +https://decisionsindentistry.com/article/human-trafficking-red-flags-dental-professionals/ +9/9 \ No newline at end of file diff --git a/vision-fixhub/court-05/52c018dfc4e6dae522f9e7ae6e7a4fdc8401a3dfdce007aceecd94b8e45e22cd.receipt.json b/vision-fixhub/court-05/52c018dfc4e6dae522f9e7ae6e7a4fdc8401a3dfdce007aceecd94b8e45e22cd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c9308ac332e73b3c4a33716eef87de0d85c33f1d --- /dev/null +++ b/vision-fixhub/court-05/52c018dfc4e6dae522f9e7ae6e7a4fdc8401a3dfdce007aceecd94b8e45e22cd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -411, + "dataset": "marble-joined", + "doc_id": "52c018dfc4e6dae522f9e7ae6e7a4fdc8401a3dfdce007aceecd94b8e45e22cd", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "c60f880c3513be83f145fb1286cefac61b13009579fe42121aebdb7ba145905a", + "output_sha256": "acf7f6bfb3a656dd9b9038fe9be9f64952ed3f6a388e4f93d6f420cadf7f1944", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/52c3303b2f88c9ee5aabee96e7680a3cc678f1619216598d3b9a0d8380646440.md b/vision-fixhub/court-05/52c3303b2f88c9ee5aabee96e7680a3cc678f1619216598d3b9a0d8380646440.md new file mode 100644 index 0000000000000000000000000000000000000000..cf8f6d5031cc820614e23dde7cd0475795a1d03b --- /dev/null +++ b/vision-fixhub/court-05/52c3303b2f88c9ee5aabee96e7680a3cc678f1619216598d3b9a0d8380646440.md @@ -0,0 +1,185 @@ +Case 1:22-cV-10904-JSR Document 238-18 Filed 07/25/23 Page 1 of 6 + + + +Case 1:22-cv-10904-JSR Document 238-18 Filed 07/25/23 Page 2 of 6 +From: +Sent: +To: +CC: +Subject: +8/14/2006 5:01:37 PM +maria.a.hornak@jpmorgan.com +csg_ao_de_fm2@jpmchase.com; +kimberly.a.upham@jpmorgan.com +Re: Article of J Epstein's Arrest +natalka.palczynski@jpmorgan.com; piers.a.cornelius@jpmorgan.com; +http://www.nypost.com/news/regionalnews/mystery moguls_teen sex secret bared in probe regionalnews_ dan mangan.htm +Doreen L.. Hewitt +Assistant to: Tad C. +&: Piers A. Cornelius +JPMorgan Private Bank | 345 Park Avenuc, 7th Floor, New York, NY 10154 +W: 212.464.2089 | F: 212.464.1108 | email: +* Maria A Hornak/JPMCHASE +Maria A Hornak/JPMCHASE +08/14/2006 12:29 PM +ToMary C1 +/JPMCHASE@JPMCHASE +ceDoreen X Hewitt-Dunn/JPMCHASE@JPMCHASE, CSG AO DE FM2, Natalka X +Palezynski/JPMCHASE@JPMCHASE, Piers A Cornelius/JPMCHASE@JPMCHASE +SubjectArticle of J Epstein's Arrest +http://www.palmbeachpost.com/pbewest/content/local_news/epaper/2006/08/14/mla_EPSTEIN_0814.html +EXHIBIT 1/ +WIT: Casus +DATE: +· T23 +RDR CRR CSR #13921 + +JPM-SDNYLIT-00105859 + + +Case 1:22-cV-10904-JSR Document 238-18 Filed 07/25/23 Page 3 of 6 +NEW YORK POST +LOG IN +NJ girl, 11, +found dead +by suicide ... +Alabama +cop fatally +shot... +pol +blasted for +"inappropria... +Idaho man +arrested for +alleged... +Read the +unsealed +indictment... +Video shows +pro-Putin +blogger... +Idaho couple +convicted of +starving--. +Trum +atton +indic +NEWS +MYSTERY MOGUL'S TEEN-SEX SECRET BARED IN +PROBE +By Dan Mangan +August 14, 2006 4:00am +For years, a media-dodging financial adviser who owns Manhattan's largest pad has +cultivated his mysterious image, suggesting he creates big investment profits for billionaire +clients without revealing how he does it or whose portfolios he handles. +But now investment whiz Jeffrey Epstein's darkest personal secrets have allegedly been +bared in an explosive, seamy prostitution case involving underage girls. +Instead of marveling at his +-market acumen, Epstein's celebrity friends are now hearing +sordid stories about his alleged obsession with getting massages in his Florida mansion +from young girls - one allegedly just 14 years old. +The tawdry tale came to light when Epstein, 53, was busted in Florida on July 23 after a +grand jury indicted him on a single felony charge of solicitation of prostitution. The grand jury +declined to indict the silver-haired moneyman on charges of sexual contact with minors. +But a bitter rift between Palm Beach cops and prosecutors over how to handle the case has +put Epstein at risk of more serious charges. The FBI is weighing whether to investigate his +alleged contacts with underage girls. +https://nypost.com/2006/08/14/mystery-moguls-teen-sex-secret-bared-in-probe/ +1/8 + + +Case 1:22-cV-10904-JSR Document 238-18 Filed 07/25/23 Page 4 of 6 +Gerald Lefcourt, one of Epstein's high-powered lawyers, says his client is innocent and that +his polygraph test helps prove it. +"There was no sexual contact with anyone underage," Lefcourt said, arguing that that has +been "proved beyond a reasonable doubt" by evidence lawyers gave authorities. +Epstein owns what reportedly is Manhattan's largest home - a 51,000-square-foot Upper +East Side house - plus a sprawling New Mexico ranch and a 100-acre private island in the +U.S. Virgin Islands. +He also owns a two-story pink mansion in Palm Beach, which became the focus of a nearly +yearlong police investigation. +Palm Beach police records show that on March 15, 2005, a 14-year-old girl alleged she had +visited Epstein's house a month before at the behest of an older friend. The girl said that +while at Epstein's pad, she partially stripped and gave Epstein a massage. +At one point, "Epstein then pulled out a purple vibrator" and used it on her, police records +claim. +Epstein eventually paid the girl $300, and she left, the records allege. +The allegation ignited a probe that ultimately led to five young women who said Epstein had +masturbated and touched their genitals during massages, the records state. Some girls +initially were recruited by a woman named +documents say. +https://nypost.com/2006/08/14/mystery-moguls-teen-sex-secret-bared-in-probe/ +2/8 + + +Case 1:22-cV-10904-JSR Document 238-18 Filed 07/25/23 Page 5 of 6 +When cops confronted the 20-year-old +the records show, she admitted that she had +been recruited at age 17 by a friend to give Epstein a massage while she was naked. +"He tried to touch me, and I stopped him," +alleged. +Epstein allegedly paid her $200 for the rubdown. +After the massage, Epstein told her that he understood she wasn't comfortable but that "he +would pay her if she brought over some girls," the police records state. +"He told her the younger the better," the records claim. +- who described herself as "like a Heidi Fleiss" - alleges that, over time, she +brought six girls who were between 14 and 16 to Epstein's house, the police records state. +Police allege that Epstein's comely blond assistant, +helped arrange the +sessions. +Several girls allege that +26, led them to Epstein's +set up a massage table and give them oils to rub on Epstein. +bedroom, where she would +Cops wanted to charge +jury did not indict either women. +not be reached for comment. +and +for their roles in procuring the girls, but the grand +declined to comment for this story, and +could +According to one girl, "Epstein asked for her real age, [and she] stated she was 16. Epstein +advised her not to tell anyone her real age," the records say. +The girl alleged that Epstein paid her to have sex with his girlfriend +police records state. +Epstein would then watch the women have sex and take photos of their trysts to display at +home, the records claim. +declined to comment. +The teen told cops she always refused to have intercourse with Epstein, the report states. +But one time, she told cops, Epstein allegedly grabbed her and forced himself on her. +https://nypost.com/2006/08/14/mystery-moguls-teen-sex-secret-bared-in-probe/ +3/8 + + +Case 1:22-cV-10904-JSR Document 238-18 Filed 07/25/23 Page 6 of 6 +When the girl became upset and screamed, "No!" Epstein apologized, and he later paid her +$1,000 for the visit, the records allege. +Palm Beach cops prepared an arrest-warrant request proposing that Epstein be charged +with unlawful sexual activity with certain minors and with lewd and lascivious molestation. +Instead, in a rare move, prosecutors brought the evidence to a grand jury, which indicted +Epstein only on the prostitution charge. +The frustrated police now have given their evidence to the FBl's Miami division, which is +considering whether to investigate Epstein for possible federal crimes involving underage +girls, said Special Agent Judy Orihuela. +READ NEXT +WTC SICK MONITOR TO FOCUS ON CANCER +SPONSORED STORIES +* +What Was Eating Tom Lee? +The tragic suicide of L.B.O. pioneer +Lee rattled the cloistered world of finance. +Puck +H. +South Carolina Launches New +Guidelines For Cars Used Less Than 50 +Miles/Day +BindRight +DUGH +The Scandal at the +Center of Sergey Brin's... +"The first words out of this person's... +Puck +Unsold Electric Cars +https://nypost.com/2006/08/14/mystery-moguls-teen-sex-secret-bared-in-probe/ +4/8 \ No newline at end of file diff --git a/vision-fixhub/court-05/52c3303b2f88c9ee5aabee96e7680a3cc678f1619216598d3b9a0d8380646440.receipt.json b/vision-fixhub/court-05/52c3303b2f88c9ee5aabee96e7680a3cc678f1619216598d3b9a0d8380646440.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6b6a497b384d9ef23c3f16e034603cd037b399a9 --- /dev/null +++ b/vision-fixhub/court-05/52c3303b2f88c9ee5aabee96e7680a3cc678f1619216598d3b9a0d8380646440.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -347, + "dataset": "marble-joined", + "doc_id": "52c3303b2f88c9ee5aabee96e7680a3cc678f1619216598d3b9a0d8380646440", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "8d20381af4478cf591c9b838e1063dbd130544bfa55b35027c38c1b4d5f0112a", + "output_sha256": "30b5d8d4ab43ee337412e529643cd6fd78ffa940bbafa9fe31bc9a1b8cd668d5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/52f16b9ca0e0238f7a5673eba5f28379812c1290f3be7f28e7275877d14530b5.md b/vision-fixhub/court-05/52f16b9ca0e0238f7a5673eba5f28379812c1290f3be7f28e7275877d14530b5.md new file mode 100644 index 0000000000000000000000000000000000000000..25b9e513155c1cef1780e8e8639dde79a3a9a8e9 --- /dev/null +++ b/vision-fixhub/court-05/52f16b9ca0e0238f7a5673eba5f28379812c1290f3be7f28e7275877d14530b5.md @@ -0,0 +1,31 @@ +Case 1:20-cr-00330-PAE l +Document 744 +Filed 08/10/22 Page 1 of 1 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AM +USA / Plaintiffs) +Case No.: 20-cr-330 +GHISLAINE MAXWELL, +Defendant(s) +) +NOTICE OF FILING OF OFFICIAL TRANSCRIPT +INFERENC +Notice is hereby given that an official transcript of a +held on +has been filed by the court reporter/transcriber in the above-captioned matter. +11/30/21 +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting +the transcript is a judge or a member of the public or media. +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court +any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also +be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically +available to the public without redaction after ninety (90) calendar days. +This process may only be used to redact the following personal data identifiers: Social Security +numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure +5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information +may proceed by motion. +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. +speer +Court Reporter/Transcriber +Date diff --git a/vision-fixhub/court-05/52f16b9ca0e0238f7a5673eba5f28379812c1290f3be7f28e7275877d14530b5.receipt.json b/vision-fixhub/court-05/52f16b9ca0e0238f7a5673eba5f28379812c1290f3be7f28e7275877d14530b5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..55329c5692fa13c557be5b62b713e8094437bc51 --- /dev/null +++ b/vision-fixhub/court-05/52f16b9ca0e0238f7a5673eba5f28379812c1290f3be7f28e7275877d14530b5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -14, + "dataset": "marble-joined", + "doc_id": "52f16b9ca0e0238f7a5673eba5f28379812c1290f3be7f28e7275877d14530b5", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "1e0ef5b6639fd04bf4cae1e3599b03e8da6697a88e617eaf3efc3a89ee29a62d", + "output_sha256": "b98456b4ef9e10b2cc4b759855e26b227f4604aefbca8e0238e6f39333c7cc42", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/530ed1f853a2076f12f1dbf5aba1090aca86965ab4babf239d4a4de8085381cd.md b/vision-fixhub/court-05/530ed1f853a2076f12f1dbf5aba1090aca86965ab4babf239d4a4de8085381cd.md new file mode 100644 index 0000000000000000000000000000000000000000..90f809f949b7c9fb6b1cfe6c2f46f058ff0ec9d9 --- /dev/null +++ b/vision-fixhub/court-05/530ed1f853a2076f12f1dbf5aba1090aca86965ab4babf239d4a4de8085381cd.md @@ -0,0 +1,23 @@ +Case 1:22-cV-10904-JSR Document 285-91 Filed 08/15/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 285-91 Filed 08/15/23 Page 2 of 2 +From: +Sent: +To: +Subject: +Erdoes, Mary E [/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MARY.ERDOES] +7/26/2011 11:59:36 PM +"jeevacation@gmail.com' [jeevacation@gmail.com] +This message has been archived. +I tried calling you yesterday buy no mail on your cell. +Onwards and upwards, on so many fronts. +ME +From: Jeffrey Epstein +To: Erdoes, Mary E +Sent: Tue Jul 26 19:06:49 2011 +Subject: +thank you for your attention . I appreciate the effort.- lets move on, and make some real money +************ diff --git a/vision-fixhub/court-05/530ed1f853a2076f12f1dbf5aba1090aca86965ab4babf239d4a4de8085381cd.receipt.json b/vision-fixhub/court-05/530ed1f853a2076f12f1dbf5aba1090aca86965ab4babf239d4a4de8085381cd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8708b7de17552955819d7948d7e4a496edf338e0 --- /dev/null +++ b/vision-fixhub/court-05/530ed1f853a2076f12f1dbf5aba1090aca86965ab4babf239d4a4de8085381cd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -35, + "dataset": "marble-joined", + "doc_id": "530ed1f853a2076f12f1dbf5aba1090aca86965ab4babf239d4a4de8085381cd", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "a2ab66685fed604063de64a8d3de46e081518100a67a6c36a0c3f17e160816a1", + "output_sha256": "5495ae93c5a78b72b5d6d3164ddb2e54fe694deb5767671f853bcfcf744bdf03", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/53171e90e29b77d70aa526c20d9d5708b1e1ec7587ebf86816ad0e8dc5726f2e.md b/vision-fixhub/court-05/53171e90e29b77d70aa526c20d9d5708b1e1ec7587ebf86816ad0e8dc5726f2e.md new file mode 100644 index 0000000000000000000000000000000000000000..aa58bbc475599e52546465bb2899201224bf7e23 --- /dev/null +++ b/vision-fixhub/court-05/53171e90e29b77d70aa526c20d9d5708b1e1ec7587ebf86816ad0e8dc5726f2e.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 270-5 Filed 08/07/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/53171e90e29b77d70aa526c20d9d5708b1e1ec7587ebf86816ad0e8dc5726f2e.receipt.json b/vision-fixhub/court-05/53171e90e29b77d70aa526c20d9d5708b1e1ec7587ebf86816ad0e8dc5726f2e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2f7281e686fc7815c0222fbbc72868e54f03a7d6 --- /dev/null +++ b/vision-fixhub/court-05/53171e90e29b77d70aa526c20d9d5708b1e1ec7587ebf86816ad0e8dc5726f2e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "53171e90e29b77d70aa526c20d9d5708b1e1ec7587ebf86816ad0e8dc5726f2e", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "be06465f5d8befc3a92bebd4a05fe60fc7200fd013466ad09dc65ececcf966bc", + "output_sha256": "3f561a9e47fead80f0e5cb2fb76701948dfb22a2c21f0b740b1de542a4023057", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/532ad962e228cadb4132c8562e61eac2f99cdadb3983e34f7af3cee659a7c3c2.md b/vision-fixhub/court-05/532ad962e228cadb4132c8562e61eac2f99cdadb3983e34f7af3cee659a7c3c2.md new file mode 100644 index 0000000000000000000000000000000000000000..6ea1bf12841383fe1d0fe159bc560c4410d4cfe3 --- /dev/null +++ b/vision-fixhub/court-05/532ad962e228cadb4132c8562e61eac2f99cdadb3983e34f7af3cee659a7c3c2.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 158-24 Filed 05/23/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/532ad962e228cadb4132c8562e61eac2f99cdadb3983e34f7af3cee659a7c3c2.receipt.json b/vision-fixhub/court-05/532ad962e228cadb4132c8562e61eac2f99cdadb3983e34f7af3cee659a7c3c2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9e0238d984ae39e50da269ead6470f39e0e4019c --- /dev/null +++ b/vision-fixhub/court-05/532ad962e228cadb4132c8562e61eac2f99cdadb3983e34f7af3cee659a7c3c2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "532ad962e228cadb4132c8562e61eac2f99cdadb3983e34f7af3cee659a7c3c2", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "1998b78597e726bebdfd8f00b6949903293b67c2514fc93ef3803737fac18fe4", + "output_sha256": "ef7cd6395ac4ae975ae039193ad5eb29f70c80bf6ff246eca0825ae0f67a6e41", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5331b9cc3f1e36ddafb9271389d4146316cab662ff5cff2519dc278506bcefed.md b/vision-fixhub/court-05/5331b9cc3f1e36ddafb9271389d4146316cab662ff5cff2519dc278506bcefed.md new file mode 100644 index 0000000000000000000000000000000000000000..3c5804a61128df49cd563cca893dd54eddad7f67 --- /dev/null +++ b/vision-fixhub/court-05/5331b9cc3f1e36ddafb9271389d4146316cab662ff5cff2519dc278506bcefed.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 267-36 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/5331b9cc3f1e36ddafb9271389d4146316cab662ff5cff2519dc278506bcefed.receipt.json b/vision-fixhub/court-05/5331b9cc3f1e36ddafb9271389d4146316cab662ff5cff2519dc278506bcefed.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..682123df7f34582ceabdbe0e78fa371aff24580d --- /dev/null +++ b/vision-fixhub/court-05/5331b9cc3f1e36ddafb9271389d4146316cab662ff5cff2519dc278506bcefed.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "5331b9cc3f1e36ddafb9271389d4146316cab662ff5cff2519dc278506bcefed", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "cff03dc93bb6761ed2b567a7f9ed12cf94c195c5e492fe13a18a77aab399fdf8", + "output_sha256": "4f62913ff4cebe2acd52ffc862a5920dc241c11d9c57cc03dffa4dcdf5b990cf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/533c6efec368b8218690f34bccc601617255e869e703b77a0ee0664d9a4fbfa0.md b/vision-fixhub/court-05/533c6efec368b8218690f34bccc601617255e869e703b77a0ee0664d9a4fbfa0.md new file mode 100644 index 0000000000000000000000000000000000000000..681597f2ae3bbf755e29e26e27b89cf3fab17f0f --- /dev/null +++ b/vision-fixhub/court-05/533c6efec368b8218690f34bccc601617255e869e703b77a0ee0664d9a4fbfa0.md @@ -0,0 +1,43 @@ +Case 1:19-cr-00830-AT Document 37 +Filed 09/01/20 Page 1 of 1 +The Law Offices of +MONTEL I FIGGINS... +17 Academy Street, Suite 305 +Newark, New Jersey 07102 +Phone: (973) 242-4700 +Fax: (973) 242-4701 +www.figginslaw.com +BRANCH OFFICES: +0 East Ridgewood Aven +ramus. NJ 076- +Reply to Newark Office [X] +Of Counsel +Douglas Mitchell, Esq. +Linda Childs, Esq +30 Wall Street 8* Floor +New York, NY 1005 +September 1, 2020 +SENT VIA ECE +Honorable Analisa | +U.S. Southern District of NY +500 Pearl Street +New York, NY 10007 +Re: State of NY v Michael +, et al. +Reques to Appear Remotely +Dear Hon. Judge +1. in the abovecaptioned matter. We are scheduled for a hearing on September 9, 2020. Given the current +andemic, I am not sure if the Court is allowing in-person hearings; however, I am requesting to +appear remotely due to the circumstances surrounding COVID-19. Due to my health, I am +unfortunately high risk and believe that it is in my best interest to appear remotely. +In light of the foregoing, I respectfully request the Court to allow my appearance via +video or telephone. +Respectfully yours, +/s/ Montell Figgins +Montell Figgins, Esq. +Attorney for Defendant Michael L +cc: +Nicolas Roos, Esq., Counsel for Plaintiff +Rebekah Donaleski, Esq., Counsel for Plaintiff +Jessica Lonergan, Esq., Counsel for Plaintiff +Jason Erroy Foy, Esq. Counsel for Defendant Noel diff --git a/vision-fixhub/court-05/533c6efec368b8218690f34bccc601617255e869e703b77a0ee0664d9a4fbfa0.receipt.json b/vision-fixhub/court-05/533c6efec368b8218690f34bccc601617255e869e703b77a0ee0664d9a4fbfa0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..893ad4a1b374b2756d9f45dd00cb254c4c792db5 --- /dev/null +++ b/vision-fixhub/court-05/533c6efec368b8218690f34bccc601617255e869e703b77a0ee0664d9a4fbfa0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -14, + "dataset": "marble-joined", + "doc_id": "533c6efec368b8218690f34bccc601617255e869e703b77a0ee0664d9a4fbfa0", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "8049853e65cca53508b7c873621e812540dc5cd46049570e06076991725b80f9", + "output_sha256": "ed767ff967d38dbc8ebe6684d9803a40debe81da05ad67cd243bab53c08e4448", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/53ae48ba6bedc51928efd557f59f41cbd1295d703232b5197e212c2bd4f79c7d.md b/vision-fixhub/court-05/53ae48ba6bedc51928efd557f59f41cbd1295d703232b5197e212c2bd4f79c7d.md new file mode 100644 index 0000000000000000000000000000000000000000..a1e2b3fcb575eefe505a3dc811297fc463f0ebcd --- /dev/null +++ b/vision-fixhub/court-05/53ae48ba6bedc51928efd557f59f41cbd1295d703232b5197e212c2bd4f79c7d.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 226-53 Filed 07/24/23 + + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/53ae48ba6bedc51928efd557f59f41cbd1295d703232b5197e212c2bd4f79c7d.receipt.json b/vision-fixhub/court-05/53ae48ba6bedc51928efd557f59f41cbd1295d703232b5197e212c2bd4f79c7d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..131768ecb8cbf030f5049cd55f8db17c82beddc0 --- /dev/null +++ b/vision-fixhub/court-05/53ae48ba6bedc51928efd557f59f41cbd1295d703232b5197e212c2bd4f79c7d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "53ae48ba6bedc51928efd557f59f41cbd1295d703232b5197e212c2bd4f79c7d", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "aa2df2d08d890edd49ce3735b1e05f66bea02dc813d237845d62e32e3e6795ca", + "output_sha256": "fa3b4d2c2a516062344e1d59afd2a11cccb5ba347e18ea52c4763664eae5e741", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/53b08df919e87057c61de8e622e1a1d0e7a65e3a6bec29d422cb6fd1cc8523e5.md b/vision-fixhub/court-05/53b08df919e87057c61de8e622e1a1d0e7a65e3a6bec29d422cb6fd1cc8523e5.md new file mode 100644 index 0000000000000000000000000000000000000000..a3523bcbdf16388cf5f0532b0861bc36ce63502f --- /dev/null +++ b/vision-fixhub/court-05/53b08df919e87057c61de8e622e1a1d0e7a65e3a6bec29d422cb6fd1cc8523e5.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 245-1 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/53b08df919e87057c61de8e622e1a1d0e7a65e3a6bec29d422cb6fd1cc8523e5.receipt.json b/vision-fixhub/court-05/53b08df919e87057c61de8e622e1a1d0e7a65e3a6bec29d422cb6fd1cc8523e5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8b32c7dc65fa65b8e0add6727ed5f2024e9b55ad --- /dev/null +++ b/vision-fixhub/court-05/53b08df919e87057c61de8e622e1a1d0e7a65e3a6bec29d422cb6fd1cc8523e5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "53b08df919e87057c61de8e622e1a1d0e7a65e3a6bec29d422cb6fd1cc8523e5", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "12bde364459926e70e4b61f398ee9e2e3c18904a61e90a8be6bc68f584b094f0", + "output_sha256": "5aed656c3d93467f60e2a2ac77478adae94dda72134e2dbcb92c9880ca7068b3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/53c3b2ba47a1864302727238bd32f702761e8d0d6db00fa9c8a419c53bde4cb9.md b/vision-fixhub/court-05/53c3b2ba47a1864302727238bd32f702761e8d0d6db00fa9c8a419c53bde4cb9.md new file mode 100644 index 0000000000000000000000000000000000000000..69dd99313c2d16c31458c2edcc094c6d288f7eda --- /dev/null +++ b/vision-fixhub/court-05/53c3b2ba47a1864302727238bd32f702761e8d0d6db00fa9c8a419c53bde4cb9.md @@ -0,0 +1,137 @@ +Case 1:22-cV-10904-JSR Document 226-30 Filed 07/24/23 Page 1 of 6 + + + +Case 1:22-cV-10904-JSR Document 226-30 Filed 07/24/23 Page 2 of 6 +FORBES +BILLIONAIRES +EDITORS' PICK +Exclusive: +Billionaire +Investor Buys +Jeffrey +Epstein's +Private Islands +For $60 +Million +Richard J. Chang Forbes Staff +May 3, 2023, 12:40pm EDT +Follow + + +Case 1:22-cV-10904-JSR Document 226-30 Filed 07/24/23 Page 3 of 6 +Private equity mogul Stephen Deckoff, who moved to the U.S. +Virgin Islands in 2011, has purchased two islands formerly owned +by Jeffrey Epstein. COURTESY BLACK DIAMOND CAPITAL MANAGEMENT; +EMILY MICHOT/NEWSCOM +A private equity mogul, who says he +never met Epstein, plans to develop a +luxury resort on the infamous property. +fter more than a year on the market, +A +Jeffrey Epstein's infamous Caribbean +islands have finally found a buyer: +Stephen Deckoff, founder of private equity firm +Black Diamond Capital Management, has +purchased the two islands for $60 million, less +than half of their initial asking price of $125 +million. +Deckoff plans to develop a 25-room luxury resort +on the property, he said Wednesday, adding that +he never met Epstein and never set foot on the +islands until they were marketed following +Epstein's 2019 death. +"I've been proud to call the U.S. Virgin Islands +home for more than a decade and am + + +Case 1:22-cV-10904-JSR Document 226-30 Filed 07/24/23 Page 4 of 6 +tremendously pleased to be able to bring the area +a world-class destination benefitting its natural +and beauty," Deckoff tells Forbes. "I very +much look forward to working with the U.S. +Virgin Islands to make this dream a reality." +The property, which spans the 70-plus-acre Little +St. James and 160-plus-acre Great St. James +islands, is located just off the shores of tourism +hub St. +and already boasts a helipad, +multiple pools and several guest villas. Deckoff is +in the process of recruiting architects and +engineers to work on developing the resort, which +he plans to open in about two years. +Epstein's ownership has cast a dark shadow over +the islands, despite the natural beauty of their +palm tree-dotted beaches and crystal clear water. +The disgraced financier purchased Little St. +James in 1998 for a reported $8 million. He lived +in a large mansion there and constructed several +bizarre structures on the property, which has been +dubbed "pedophile island" for its role in Epstein's +sex trafficking ring. Alleged victim +has claimed that Prince Andrew, of +York, raped her on Little St. James (a claim +Buckingham Palace has denied). Epstein bought +the neighboring Great St. James, which is largely +undeveloped, in 2016 for a reported $22.5 +million. +He died in a Manhattan jail cell in 2019 while +facing federal charges for trafficking minors in + + +Case 1:22-cV-10904-JSR Document 226-30 Filed 07/24/23 Page 5 of 6 +Florida and New York. His associate, Ghislaine +Maxwell, was found guilty of child sex trafficking +in December 2021 for her role in helping Epstein +procure underage girls and was sentenced to 20 +years in prison. +Epstein's estate agreed to pay $105 million to the +U.S. Virgin Islands, including the repayment of +$80 million in tax benefits, after the territory's +attorney general sued in 2020, claiming the +Virgin Islands were duped into granting Epstein's +company, Southern Trust Company, tax benefits +that allowed Epstein to use his residence there to +abuse girls and women. The settlement grants the +U.S. Virgin Islands government half the proceeds +from the sale of the islands-some $30 millionto be put into a trust to provide counseling and +other services for victims of sexual abuse. +Deckoff-who has a net worth of $3 billion, +according to Forbes' estimates-built a fortune in +private equity, working his way up at several +firms, including Drexel Burnham Lambert, Bear +Stearns and Kidder, Peabody & Co., before +striking out on his own in 1995 with Black +Diamond Capital. Today, the Stamford, +Connecticut-based company manages some $9 +billion in assets and specializes in high-yield debt, +distressed debt, restructuring and business +turnarounds. +A native of New York City, Deckoff moved to the +U.S. Virgin Islands in 2011. He has given more + + +Case 1:22-cV-10904-JSR Document 226-30 Filed 07/24/23 Page 6 of 6 +than $1.2 million to nonprofits there, mostly to +private schools and nature preservation +organizations. +The islands are still recovering from two category +5 hurricanes, Irma and Maria, that tore through +in September 2017. Deckoff's plan is to construct +a "state-of-the-art, five-star, world-class luxury +25-room resort" on the property, according to a +press release Wednesday, to help boost tourism +and economic development "while respecting and +preserving the important environment of the +islands." +Follow me on Twitter or LinkedIn. Send me a +secure tip. +Richard J. Chang +Follow +I am a general assignment reporter on the wealth team. I +previously interned at CNN Politics, Linkedin News, and +The MetroWest Daily News in Framingham, Mass. For +three years, I... Read More +Editorial Standards +Reprints & Permissions +ADVERTISEMENT diff --git a/vision-fixhub/court-05/53c3b2ba47a1864302727238bd32f702761e8d0d6db00fa9c8a419c53bde4cb9.receipt.json b/vision-fixhub/court-05/53c3b2ba47a1864302727238bd32f702761e8d0d6db00fa9c8a419c53bde4cb9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bcd2d8304e3a2d5ff4bc5f10bf7f57d54a6c72fb --- /dev/null +++ b/vision-fixhub/court-05/53c3b2ba47a1864302727238bd32f702761e8d0d6db00fa9c8a419c53bde4cb9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -84, + "dataset": "marble-joined", + "doc_id": "53c3b2ba47a1864302727238bd32f702761e8d0d6db00fa9c8a419c53bde4cb9", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "6c195153c6a54f2a48adb836ba964edcfebcf3191bcd18b9f107e813f2b83d73", + "output_sha256": "08196a000708a36114731aa710c7f7bb645fc561c87821de4d96b61015d3255b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/53c4840b023e1ab4b2ab9ffaa4a46f4e98d12d06dd4dfd31f162e48cd2b74e26.md b/vision-fixhub/court-05/53c4840b023e1ab4b2ab9ffaa4a46f4e98d12d06dd4dfd31f162e48cd2b74e26.md new file mode 100644 index 0000000000000000000000000000000000000000..17a8ee090dfcc0e72141f3da91bffca28b12daea --- /dev/null +++ b/vision-fixhub/court-05/53c4840b023e1ab4b2ab9ffaa4a46f4e98d12d06dd4dfd31f162e48cd2b74e26.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 311-42 Filed 08/25/23 + + +Filed Under Seal diff --git a/vision-fixhub/court-05/53c4840b023e1ab4b2ab9ffaa4a46f4e98d12d06dd4dfd31f162e48cd2b74e26.receipt.json b/vision-fixhub/court-05/53c4840b023e1ab4b2ab9ffaa4a46f4e98d12d06dd4dfd31f162e48cd2b74e26.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5db9c36cebbe481d7e88f7d1eca022e8cb7facc8 --- /dev/null +++ b/vision-fixhub/court-05/53c4840b023e1ab4b2ab9ffaa4a46f4e98d12d06dd4dfd31f162e48cd2b74e26.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "53c4840b023e1ab4b2ab9ffaa4a46f4e98d12d06dd4dfd31f162e48cd2b74e26", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "e64b07af1aecb8af807d8cdd962eccfca3c9fd7da26c0bea03d99b24389815b6", + "output_sha256": "3efe4f0bd4a1b5214974ac14dd293b2649223ecfad614114a39503685bc76ec6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/540184be58552bbf5541b0ae848843dc08fdd878df8b7813d6fe96f0ade97012.md b/vision-fixhub/court-05/540184be58552bbf5541b0ae848843dc08fdd878df8b7813d6fe96f0ade97012.md new file mode 100644 index 0000000000000000000000000000000000000000..6685c4019194fe4d0aadf8ccd1d97c55fc88e1dc --- /dev/null +++ b/vision-fixhub/court-05/540184be58552bbf5541b0ae848843dc08fdd878df8b7813d6fe96f0ade97012.md @@ -0,0 +1,385 @@ +Case 1:22-cV-10904-JSR Document 285-16 Filed 08/15/23 Page 1 of 6 + + + +Case 1:22-cV-10904-JSR Document 285-16 Filed 08/15/23 Page 2 of 6 +USCG Due Diligence Report - Individual +JPMorgan Private Bank +DDR Name: +DDR Status: Process Completed +Banker Information +Banker: +Paul V Morris/JPMCHASE +LE/OU: ( +Banker SID: +Banker BAC: +Banker FNEN: +102/29338 +N256838 +8634--CHBG +01 +Banker History: +03/04/2010 11:02:15 PM - CRD / Notrix changed: Banker from Mary C +/JPMCHASE to Paul V Morris/JPMCHASE. +07/28/2006 11:00:04 PM - CRD / Notrix changed: Banker from Jeffrey M Matusow/JPMCHASE to Mary C +/JPMCHASE. +07/13/2006 11:00:44 PM - CRD / Notrix changed: Banker from Mary CL +/JPMCHASE to Jeffrey M +Matusow/JPMCHASE. +07/07/2006 11:00:21 PM - CRD / Notrix changed: Banker from Many Bayard/ASS to Mert Canard/SPCHASE. +07/07/2006 11:00:21 PM - CRD / Notrix changed: Banker from Mary C +01/19/2006 11:00:30 PM - CRD / Notrix changed: Banker from Mary Rieth/JPMCHASE to Mary C +04/22/2005 10:10:28 PM - CRD / Notrix changed: Banker GID from 00000043917 to U043917. +DM ID Link Information +The DM for this DDR is DM Name -JEFFREY E EPSTEIN CAS ID - 9710670708. +The following DDR's are associated with this Decision Maker. +DDR Name +Banker +116 East 65th St., LLC +Morris, Paul V +Darren K. Indyke PLLC +Morris, Paul V +Morris, Paul V +EMMCAC, LLC +Epstein, Jeffrey +Financial Trust Company, Inc. +Financial Trust Company, Inc. +Freedom Air International, Inc. +HBRK Associates Inc. +Hyperion Air, Inc. +I-Correct.com LLC +Indyke, Darren K +Jege, Inc. +LYN & JOJO LLC +Morris, Paul V +Morris, Paul V +Morris, Paul V +Morris, Paul V +Morris, Paul V +Morris, Paul V +Morris, Paul V +Morris, Paul V +Morris, Paul V +Morris, Paul V +Morris, Paul V +Morris, Paul V +MAX Foundation +Morris, Paul V +New York Strategy Group, LLC +Morris, Paul V +Plan D, Inc. +Morris, Paul V +The 2007 Jeffrey E Epstein Insurance Trust Morris, Paul V +#2 - November 1, 2007 +Morris, Paul V +The 2007 Jeffrey E Epstein Insurance Trust Morris, Paul V +#3 dtd November 1, 2007 +Morris, Paul V +The 2007 Jeffrey E. Epstein Insurance +Morris, Paul V +Trust #1 Dtd November 1, 2007 +The C.O.U.Q. Foundation, Inc. +The Haze Trust +Security Services Search Date +02/02/2009 +10/17/2008 +02/08/2004 +08/06/2004 +03/07/2011 +0B/11/1999 +05/21/2003 +03/11/2010 +10/17/2008 +02/03/2009 +01/30/2009 +01/15/2010 +02/03/2009 +07/31/2006 +02/08/2004 +12/10/2009 +04/16/2003 +01/30/2009 +12/01/2008 +12/02/2008 +11/25/2008 +01/28/2004 +Name/Contact Information +i New Client (No Decision Maker/UCAS/PCN Exists) +C Existing Client (Decision Maker/UCAS/PCN Exists) +C Prospect (must be converted to a client prior to the account opening.) +Г Backlog Client +JPMC Internal Use Only + +JPM-SDNYLIT-00149696 + +Is this DDR beinfiaseral 220veb6904-JSR Document 285-48 Filed 08/15/23 Page 3 of 6 +Last Name: +First Name: +Middle Name/Initial: +Previous Last Name(s): +Title: +Business Name: +(To Record Individual's Ownership Or Employer) +Primary Address +Business Address +Addresses +(Legal address on account) +(Other than Primary Address) +Name: +Attention: +Address Line 1: +Address Line 2: +City: +State: +Province: +Postal/Zip Code: +Country: +USA +UNITED STATES +Legal Entity: +Individual / Joint +Industry Code: +NAIC Code: +Citizenship: +Date of Birth: +USA +(Use 4-digit year) +Gender: +Female +Tax ID # : +Remember to collect W-B's or other applicable tax forms for each jurisdiction. +Passport/Drivers +License #: +Home Phone: +(212)-000-0000 +Introduction Information +Introduction Type: +Specific Information: +Related Client A/C +Jeffrey Epstein +Met With Principal? +C Yes G No +If you did not meet the Principal, give an indication of why you haven't met the individual and when you will. +Mary will meet with them as soon as possible +What form of goverment issued identification document did you obtain for the files? +Other +If Other Please Describe: +Financial Information +not yet supplied +Occupation, Business or Employer Model +of the Client: +Net Worth of Client: +Documentation/ Information +obtained to confirm stated net +worth of the Client: +personal information provided by Epstein advisor, Eric Ganey + +JPM-SDNYLIT-00149697 + + +Source Of WealtCase 1:22-cvel6004-JSR Document 285-16 Filed 08/15/23 Page 4 of 6 +Please Describe: +through modelling assignments +Transaction Profile/Expected Account Activity +What is the +purpose/intended use of +this account? +What is the expected +source of account +funding ? +Approximate $ amount +to fund the account : +Please check the types of account and expected activity for this legal entity +(inflows and outflows of securities and cash) - check ALL that apply: +Activity Level: +Account +Low (1-5 transactions/month) +Medium (6-12 trs/month) +High (over 12 trs/month) +DDA/MMIA: +" Low +C Medium C High +SDI: +CLow +C Medium C High +Investment Management: +C Low C Medium f High +Funds: +C Low C Medium C High +Other: +CLow +C Medium T High +Transaction Profile/Expected Account Activity +Checking Account +Required Security Services Checks +Security Search Type: +Note for Security Services: +Please list any specific search +requests/instructions to Security +Services here +Full +Security Services Information +A Security Services Check is REQUIRED for New Clients and Prospects +This section to be completed by the Security Services Group: +List Individuals and Corporate Entities Investigated: +was fully researched in New York and California only. +Please Note: All research is subject to the availability of electronic database resources. +Attachment: +DDR # 059504 (no attachment) +Search Type +Is +Security Service Details: +Further +Review +by +Banker +Require +d? +No +No +No records were found. +No records were found. +response +Company Information +Corporate Records +ther Database Searchi +RDC/CDC/MIS +Civil Court Action +Federal & State Court +Action +Personal Particulars +No +Yes +No records were found. +No records were found. +Socing security numberl +however the social securt administration +Satisfactory + +JPM-SDNYLIT-00149698 + + +Case 1:22-cv+10904solSReaDocumter| 285-16 | 464lee) 08 15/2Bia Page 5 of 6 +between +As of May 2003, +last reported address used +by +was +Publications +Regulatory Sanctions +OFAC/Control List Search +No +No +Nothing derogatory was found +No records were found. +Has this been identified as a Red Dot DDR? : +C Yes +C No +Expense No.: +Total Costs: +Signed by: +99/137001 +$0.00 +Vanessa A Budhu +Dated: +02/08/2004 09:40:19 AM +Individual Checks +Background Check +Comments +(Required If Check Carried Out) +Network +01/28/2004 +Jeffrey Epstein knows the model personally and asked for +our assistance in opening an account for her. Mr. Epstein is +a longstanding client of JPMPB. +Г TRW/CIC +Г. Lexis Nexis +Г. Dun_Bradstreet +Г Bank References +Г Directories +Г Bus Social Contacts +Г Other +Summary +Summary Of Findings: +Anticipated Products) +Let ravo stein often a hearing dels in the early stages of the is green. He a and +and he is guaranteeing her credit +ard application +Deposits +Number Assignments +Standalone Entity? +• Yes C No +If this legal entity is or will be a Client (PCN) or +Prospect answer YES. +If this legal entity is or will be part of an Existing +PCN relationship answer NO +f "No" above, then indicate the Client (PCN) +Itimate Customer Number (UCN) +ptionally, you mi +dicate the Affiliation Numbe +SPN Required? +CAS ID: + +@ Yes T No + +JPM-SDNYLIT-00149699 + + +Client Service TeGase 1:22-cv-10904-JSR Documento285el6io/PHee08M5/23_ Page 6 of 6 +Hornak/JPMCHASE, Ethan J Hornbecker/JPMCHASE +Please type in the name of the CSS person/persons +that supports your region. +Approval Information +Public/High Profile Figure +High Risk Jurisdiction +High Risk Business +Banker: +LE/OU: +Senior Manager: +No +No +No +Paul V Morris/JPMCHASE +102/29338 +Tad C +Annual / Periodic Review Information +Annual/Periodic Review +36 months +Due in: +Periodic Review Comments : +This annual/periodic review is for DMID # 9710670708 - DMID Name: JEFFREY E EPSTEIN +The actual review is being conducted within the Ranch Lake III, Inc. DDR. +Banker Approval Information +Bared on my due diligence and the infarmation provided, I approve the acceptance of I +02/09/2004 08:13:26 AM +Senior Manager Approval Information +Based on the information provided and the approval granted by Mary Rieth, I approve the acceptance of +a Client. +Tad C +02/09/2004 09:23:55 AM +Admin Comments +Admin Comments: +By: +Date: +Admin Comments History : +Document History +Created: 01/28/2004 +Last Modified: 02/09/2004 09:24:12 AM +Submitted: 01/28/2004 +Audit History +By: Doreen X +By: Tad CL +By: Doreen X +-Dunn +-Dunn +Converted Tracking Document History: +1. Awaiting Security Services Research by: Doreen X +-Dunn on 01/28/2004 06:05:23 PM. +2. Client Manager Approval by: Mary Rieth on 02/09/2004 08:13:26 AM. +3. Senior Manager Approval by: Tad C| +on 02/09/2004 09:24:01 AM. +4. Security Services Sign-Off by: Vanessa A Budhu on 02/08/2004 09:40:23 AM. +as a Client. +~ as + +JPM-SDNYLIT-00149700 diff --git a/vision-fixhub/court-05/540184be58552bbf5541b0ae848843dc08fdd878df8b7813d6fe96f0ade97012.receipt.json b/vision-fixhub/court-05/540184be58552bbf5541b0ae848843dc08fdd878df8b7813d6fe96f0ade97012.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b59807b8fdba88670ce6011822380361428beb76 --- /dev/null +++ b/vision-fixhub/court-05/540184be58552bbf5541b0ae848843dc08fdd878df8b7813d6fe96f0ade97012.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -137, + "dataset": "marble-joined", + "doc_id": "540184be58552bbf5541b0ae848843dc08fdd878df8b7813d6fe96f0ade97012", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "0bf2dd8d5758785d1ba30592ab6b296e589ff0021e6362dd5d6246703f7d176c", + "output_sha256": "4dd31575491475ec1ec02302b8ab424349d93da4e76c94b420f1986d650ef627", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/54253e37ebde90178c388651e3b17a40edbe00aeec52d0e02bac695e360f91d3.md b/vision-fixhub/court-05/54253e37ebde90178c388651e3b17a40edbe00aeec52d0e02bac695e360f91d3.md new file mode 100644 index 0000000000000000000000000000000000000000..49fc187a1014027af0ecb79ae52dcda0f42b1b94 --- /dev/null +++ b/vision-fixhub/court-05/54253e37ebde90178c388651e3b17a40edbe00aeec52d0e02bac695e360f91d3.md @@ -0,0 +1,54 @@ +Case 1:22-cv-10904-JSR Document 267-5 Filed 08/07/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 267-5 Filed 08/07/23 Page 2 of 3 +From: +Sent: +To: +Subject: +Cecile de Jongh +12/27/20172:45:30 PM +Richard Kahn| +Re: Fwd: +@yahoo.com] +@gmail.com];jeffrey E. [jeevacation@gmail.com] +Importance: +High +I'll cut the check today. +With warm regards, +Cecile de Jongh +On Wednesday, December 27, 2017 10:37:05 AM AST, jeffrey E. wrote: +rich have stc makee a 25 k check to DPNR for the public library . +- Forwarded message - +From: Dawn Henry +All public libraries are under DPNR. I was thinking either the Charles Wesley Turbull Library on St. +Sprauve Library on St. John since you live in this district. If you preter to donate to school libranes I can connect you with +the Commissioner for Education. Either way the Territory wins. +Dawn +From: jeffrey E. [mailto:jeevacation@gmail.com| +Sent: Wednesday, December 27, 2017 4:15 AM +To: Dawn Henry +Wednesday, May 29, 2013 9:30 PM +Cecile de Jongh +Re: Fw: ESL course @ UVI +f1 and +On Wed, May 29, 2013 at 5:00 PM, Cecile de Jongh +@yahoo.com> wrote: +Jeffrey, +What kind visas do these ladies currently have? Ms. Todman said that the I-20 is only +for persons in a degree program (seeking a dregee) or an exchange student (getting a +degree in their country and just doing a semester here). She said that they will not +need an I-20 if they already have a work visa and they can take the ESL class without +the I-20. She was clear that no I-20 would be sought for them by UVI if they are not in +a degree program. Perhaps they can enroll and take at least 12 credits towards a +degree? What would you like to do? +With warm regards, +Cecile +DISCLAIMER: The information contained in this e-mail may be privileged, confidential, and protected from +disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, +distribution or duplication of this communication is strictly prohibited. If you have received this +communication in error, please notify the sender immediately and delete all copies. +"Nearly all men can stand adversity, but if you want to test a man's character, give him power." ~ +Lincoln +• Please consider the environment before printing this e-mail. +-- Forwarded Message --- +From: ann rodriquez < +@yahoo.com> +To: Dionne + +1 +@yahoo.com> + +ESTATE_JPM020206 + + +Case 1:22-cV-10904-JSR Document 186-53 Filed 06/14/23 Page 3 of 5 +Sent: Wednesday, May 29, 2013 3:18 PM +Subject: Re: ESL course @ UVI +Hi Ms. Todman, +Please see attached registration forms for +Thank You, +Ann R. +& Ms. +DISCLAIMER: The information contained in this e-mail may be privileged, confidential, and +protected from disclosure. If you are not the intended recipient, you are hereby notified that any +dissemination, distribution or duplication of this communication is strictly prohibited. If you have +recelved this communication in error, please notify the sender immediately and delete all +copies. +From: Dionne + +To: Cecile de Jongh < +@yahoo.com> +Cc: Violeta Donovan < ydonova@live.uvi.edu>; Ann Rodriquez ≤ +Sent: Wednesday, May 29, 2013 2:09 PM +Subject: RE: ESL course @ UVI +@yahoo.com> +My pleasure, Cecile. +Good luck! +My best, +Dionne +From: Cecile de Jongh [mailto: +@yahoo.com| +Sent: Wednesday. May 29, 2013 2:38 PM +To: Dionne +Cc: Violeta Donovan; Ann Rodriquez +Subject: Re: ESL course a UVI +Thanks Dionne, I will have Anna coordinate. +With warm regards, +Cecile +DISCLAIMER: The information contained in this e-mail may be privileged, confidential, and protected from disclosure. If +you are not the intended recipient, you are hereby notified that any dissemination, distribution or duplication of this +2 + +ESTATE_JPMO20207 + + +Case 1:22-cv-10904-JSR Document 186-53 Filed 06/14/23 Page 4 of 5 +communication is strictly prohibited. If you have received this communication in error, please notify the sender +immediately and delete all copies. +"Nearly all men can stand adversity, but if you want to test a man's character, give him power." ~ +Lincoln +( Please consider the environment before printing this e-mail. +From: Dionne + +To: Cecile de Jongh < +zivahoo.com> +Ce: Violeta Donovan +Sent: Wednesday, May 29, 2013 1:54 PM +Subject: RE: ESL course a UVI +Hello Cecile, +I believe applications should go to Barbara Todman; she is well acquainted with the +procedures for international students. +She can be reached as follows: phone: 340-693-1150 or email: btodman@live.uvi.edu. +Please let me know how things go. +My best, +Dionne V. +Dionne V. +Vice-President for Institutional Advancement & +Executive Director, Foundation for Reichhold Center for the Arts +University of the Virgin Islands +#2 John +St. +Bay +_ USVI 00802 +p: 340-693-1040 +m: 340-514-7480 +f: 340-693-1015 +e: djackso @uvi.edu +w: http://www.uvi.edu/ +From: Cecile de Jongh [mailto +Sent: Wednesday. May 29, 2013 12:58 PM +To: Dionne +Cc: Violeta Donovan +Subject: Re: ESL course a UVI +Good afternoon Dionne, +@yahoo.coml +3 + +ESTATE_JPM020208 + + +Case 1:22-cv-10904-JSR Document 186-53 Filed 06/14/23 Page 5 of 5 +Thank you forthis information. From what you sent me, it looks like the total +cost for the course (for up to 10 students) is $8,868 which we will pay. We have +two students to enroll. To whom should we send the applications? Once UVI +receives the applications, the two students will need to get an 1-20. +With warm regards, +Cecile +DISCLAIMER: The information contained in this e-mail may be privileged, confidential, and protected from +disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, distribution or +duplication of this communication is strictly prohibited. If you have received this communication in error, please +notify the sender immediately and delete all copies. +"Nearly all men can stand adversity, but if you want to test a man's character, give him power." ~ +Lincoln +Please consider the environment before printing this e-mail. +......**** +.............* +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved +..***** +4 + +ESTATE_JPM020209 diff --git a/vision-fixhub/court-05/5452e459ffe38b5123abcf9f99e1a452f6ff5e8f09a08324c274dcb316562da6.receipt.json b/vision-fixhub/court-05/5452e459ffe38b5123abcf9f99e1a452f6ff5e8f09a08324c274dcb316562da6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a1a6b6eb7d76074d9db5633e9706dc6c37c1a601 --- /dev/null +++ b/vision-fixhub/court-05/5452e459ffe38b5123abcf9f99e1a452f6ff5e8f09a08324c274dcb316562da6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -118, + "dataset": "marble-joined", + "doc_id": "5452e459ffe38b5123abcf9f99e1a452f6ff5e8f09a08324c274dcb316562da6", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "3c3325a2e31664ce2576ca7bf8c5908c9223864410c1f5de88ea512f7b86cd25", + "output_sha256": "e9369b49d300a044fa875e1d0a7d0acf9df016243ccbdd8d86c2105d1afcf50e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5489d404c4bf1af9caf2a43f6359de877534ddab8f3ec7ebba9b8300593785ea.md b/vision-fixhub/court-05/5489d404c4bf1af9caf2a43f6359de877534ddab8f3ec7ebba9b8300593785ea.md new file mode 100644 index 0000000000000000000000000000000000000000..f3e2c2b18d03ade32f0b1bd4024d7c1a222e33d4 --- /dev/null +++ b/vision-fixhub/court-05/5489d404c4bf1af9caf2a43f6359de877534ddab8f3ec7ebba9b8300593785ea.md @@ -0,0 +1,2708 @@ +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 1 of 50 +1 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-x +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiffs +V. +JPMORGAN CHASE BANK N.A., +22 Civ. 10904 (JSR) +et +al, +Defendants +- x +ORAL ARGUMENT +New York, N.I. +August 31, 2023 +4:00 p.m. +Before: +HON. JED S. RAKOFF +District Judge +APPEARANCES +OFFICE OF THE ATTORNEY GENERAL +Attorneys for Plaintiff USVI +MIMI LIU +DAVID I. ACKERMAN +LINDA +WILMER CUTLER PICKERING HALE & DORR LLP +Attorneys for Defendant JPMorgan Chase Bank NA +FELICIA ELLSWORTH +ALAN SCHOENFELD +JOHN BUTTS + + +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 2 of 50 +2 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Case called) +THE DEPUTY CLERK: +Will the parties please identify +themselves for the record. +MS. LIU: Mimi Liu on behalf of plaintiff, the +Government of the United States Virgin Islands. +: Linda +• for the Virgin Islands. +MR. ACKERMAN: David Ackerman for the Virgin Islands. +MS. ELLSWORTH: Good afternoon, your Honor. Felicia +Ellsworth for JPMorgan Chase. +MR. SCHOENFELD: Alan Schoenfeld for JPMorgan Chase. +MR. BUTTS: John Butts for the JPMorgan Chase. +THE COURT: Welcome. And I'm ready to hear argument +on the cross-motions for summary judgment. Now to some extent +they are two sides of the same coin, in some of the aspects, +but not in all. Nevertheless, to maintain some sort of order, +why don't we start with the Virgin Islands's motion, and then +we'll turn shortly thereafter to JPMorgan's motions. I don't +want anyone to recite at any great length what's in your +briefs. +I thank you for their excellent briefs, but it was 80 +pages and I did manage to read them all without falling asleep. +And so really this is your opportunity to address matters and +issues that were not fully addressed in your brief, either +because they were raised in someone's else reply papers or for +whatever reason. Let me hear first from moving counsel. + + +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 3 of 50 +3 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +it please the Court. Mimi Liu on behalf +of plaintiff, Government of the US virgin Islands. I will be +arguing our motion for summary judgment on the Trafficking +Victims Protection Act claims, and my colleague Mr. Ackerman +will be arguing our motion on the affirmative defenses, your +Honor. +THE COURT: Okay. +MS. LIU: In its order on the motion to dismiss, the +Court said that the plaintiffs adequately allege knowledge, +participation and benefit to show JPMorgan participated in +Epstein's sex trafficking venture in violation of 1591(a) (2). +THE COURT: So they dispute, among other things, +knowledge and intent, and almost always those are jury +questions. Why can they be disposed of on summary judgment +here? +MS. LIU: Your Honor, no reasonable juror could find +that JPMorgan did not know or did not recklessly disregard that +its client Jeffrey Epstein was engaged in sex trafficking. In +your motion to dismiss order, you said that it is sufficient +that JPMorgan was aware of Epstein's convictions for sex crimes +and ignored numerous red flags associated with Epstein's +accounts. +The undisputed facts show that JPMorgan knew, not only +at the time of his convictions in 2008, but two years earlier +in 2006, that Epstein had engaged in sex crimes involving + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 4 of 50 +4 +minors. The evidence shows that Epstein confessed all but the +ages to Jes Staley, and Jes Staley turned around and reported +it to Mary Erdoes, and that is corroborated in a written email. +The ages were undeniable from the reports that were +based on police documents that JPMorgan reviewed in 2006. +Compliance staff later +acknowledged that Epstein was "known to +pay cash for his massages, and minors aren't the issue," which +is precisely what was reported in the news in 2006. And then +when we get to the question of JPMorgan ignoring numerous red +flags, they did more than that, your Honor. +In 2019, the filing with the department of treasury +after Jeffrey Epstein was dead identifies more than $1 billion +in transactions for Epstein that the bank says are related to +human trafficking dating back to 2003, $1 billion in +transactions related to human trafficking dating back to 2003. +By 2006, the bank thus had reams of financial information +related to Jeffrey Epstein that corroborated his sex crimes +involving children. +THE COURT: So what about the argument that your +adversary makes that, that doesn't preclude them from offering +ordinary banking services? Even convicted felons are entitled +to avail themselves of ordinary business. They could buy +groceries. They could buy land. And in this case, they can +have bank accounts, so why isn't that preclude summary +judgment? + + +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 5 of 50 +5 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MS. LIU: Well, again, in your motion to dismiss +order, your Honor, you identified a number of categories where +the Court said, these are sufficient to show that JPMorgan +engaged in active non-routine or non-ordinary banking services. +THE COURT: Yes, and that was on motion to dismiss +taking everything in your favor. But the question now is +whether you have established that through undisputed evidence +that no reasonable juror could find to the contrary. +MS. LIU: Yes. In addition, the New York banking +regulator looked at a number of categories as well, and the New +York banking regulator said vis-a-vis Deutsche Bank that these +are examples of activity that fall outside ordinary banking +services. And we have proven on summary judgment starting with +the fact that JPMorgan has admitted that it handled more than +$1 billion in suspicious transactions, again related to human +trafficking for Epstein over a 16-year period from 2003 to +2019. +And just to put that $1 billion number in context, +your Honor, in their counterstatement of undisputed material +facts at paragraph 19, JPMorgan argues that $900 million of +funds flowed through Epstein's accounts at JPMorgan from 2003 +to 2013. This means that Epstein's entire business with +JPMorgan and JPMorgan's entire business with Jeffrey Epstein +was human trafficking. +JPMorgan was a full service bank for Jeffrey Epstein's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 6 of 50 +6 +sex trafficking. If you look at the Canosa case that we +discussed at the motion to dismiss stage, it talks about +facilitating sex trafficking on the front-end and then covering +it up the back-end, which allows ongoing sex trafficking, that +is precisely this case. On the front-end, JPMorgan after +knowing that Jeffrey Epstein had engaged in felony sex crimes +with children handled $4 million in payments to girls and +women, many with Eastern European names, and over $5 million in +cash withdrawals which it repeatedly tied to his felony sex +crimes. +That's $9 million in transactions which JPMorgan +argues on reply is a drop in the bucket relative to the $900 +million in funds that flowed through Epstein's accounts at +JPMorgan. +But if you take that $9 million -- and this is a bank, +and this is a bank reviewing as part of their due diligence all +of the news reports and the police documents -- if you take +that $9 million, your Honor, and you divide it by the couple of +hundred dollars that Epstein was known to pay a victim, and the +couple of hundred dollars that Epstein was known to pay the +young women who recruited that victim, you get more than 20,000 +unlawful sex acts facilitated by JPMorgan. +Again, I would submit, no reasonable juror could find +that JPMorgan did not participate in Jeffrey Epstein's sex +trafficking venture. + + +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 7 of 50 +7 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: Okay. Let me interrupt you. We're going +to sort of go back and forth just to try to keep aspects of +these motions completed. So let me, just on what you've argued +so far, let me hear from defense counsel, then we'll come right +back to you. +MS. ELLSWORTH: Thank you, your Honor, Felicia +Ellsworth for JPMorgan. I'll start where the Court did, +knowledge is a key element of the US Virgin Islands claim here. +Knowledge is almost never susceptible to disposition on summary +judgment, and it certainly is not here. There's sworn +testimony from multiple JPMorgan current employees and former +employees that the US Virgin Islands took testimony from, each +of whom to a person testified they did not have knowledge. +THE COURT: Let me raise an issue that I don't think +was raised clearly by your adversary, but that won't stop me. +So if we look at section 1595(a) for lawsuits not brought by +the state, but by individuals, civil lawsuits, the knowledge +requirement there is knew or should have known, as opposed to +the criminal section, which it's knew or recklessly +disregarded. Should have known sounds awfully much like +negligence. So if all they have to show is negligence, are +they not entitled to summary judgment? +MS. ELLSWORTH: That's not all they have to show, your +Honor. Parens patriae plaintiff under 1595(d) -- and I don't +think the US Virgin Islands has disputed this fact -- + + +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 8 of 50 +8 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: No, they haven't. You're correct in that, +but -- +MS. ELLSWORTH: It's knowledge or reckless -- +THE COURT: — but I'm infamously activist judge, so +I'm raising it independently. +MS. ELLSWORTH: When you 1ook at 1595 (d), it +incorporates only the section 1591, the criminal provision. +So +what the 1595(d), which is the parens patriae action, it says +that a state has reason to believe that an interest of the +residents of the state is threatened or adversely effected by +any person who violates section 1591, and that's the criminal +provision. +THE COURT: Yeah, but the question would be -- and you +may well be right on that. I'm not suggesting necessarily to +the contrary. But since this is a civil action, why shouldn't +section (d) be read in the context of the primary civil action +requirement set forth in (a)? +MS. ELLSWORTH: I don't think it should be because I +don't think that's what Congress set out. Congress set out and +incorporated. Congress could have chosen to add a parens +patriae cause of action to 1595(a), for example; but instead it +quite explicitly added this section (d) separately and +incorporated only the criminal underlying conduct which would +be knowledge or reckless disregard. I think the statutory +structure is fairly clear. I also don't think it particularly + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 9 of 50 +9 +matters in purpose of your Honor deciding today's motion. +THE COURT: The statute is clear? This is the +Congress of the United States, they never write clear statutes. +We know that. +MS. ELLSWORTH: I think the construction that your +Honor can make of the statute should not be difficult to +understand that what Congress +THE COURT: Let's assume you're right about that. I +just wanted to flag that issue. Go back to the point you +wanted to make. +MS. ELLSWORTH: If I could raise one more point on the +scienter standard. I just want to make clear. We point this out +in our affirmative motion. I'm happy to address it then. But +prior to 2008, the standard has to be just knowledge, not even +reckless disregard given the timing when that was added to the +statute. But in any event, I come back to the question that +the Court ask my adversary to begin with, which is this is +simply not an issue that is susceptible to determination on +summary judgment. It is not the case that no reasonable juror +could find that there wasn't knowledge or reckless disregard +depending on the timing here. +There is hotly disputed testimony and evidence. There +is, as I said, testimony from JPMorgan current and former +employees disclaiming knowledge. That testimony would be +subject to a credibility determination by the jury as to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 10 of 50 +10 +whether or not in fact the information that the US Virgin +Islands has pointed to and that Ms. Liu pointed you to today +was information that JPMorgan considered and found that there +was some reason to even suspect that there was something that +would be an actual violation of the TVPA. +THE COURT: Okay. Let me go back to plaintiff's +counsel. We're going to go back and forth with apologies. +Anything further before we turn to the other prong of your +motion that your colleague is going to address, anything +further you wanted to say on this prong? +MS. LIU: Only, Judge, to clarify in terms of your +question about constructive knowledge in 1595. We did argue at +the motion to dismiss stage at footnote one in our opposition +brief, which is docket 49, that a constructive knowledge +standard applies also to the government's civil case under +1595. +THE COURT: This is not a question of constructive +knowledge. That's a different issue. +MS. LIU: Or knew or should have known. +THE COURT: Okay. So in your view you haven't waived +that argument? +MS. LIU: We have not waived that argument. And, in +fact, the point that we made there is that if you 1ook at the +legislative history of 1595(d), it's clear that Congress wanted +to give extra litigation leverage to individuals and more + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 11 of 50 +11 +resources to pursue civil prosecution against sex trafficking. +So obviously Congress did not intend to apply a higher +scienter standard to a parens patriae action than it did to the +original civil action. +THE COURT: That may or may not be, why shouldn't +Congress or why couldn't Congress have rationally decided, if +it's an individual is a victim, we're going to make it a +negligent standard; but if it's a state with all the force that +a state brings and with assertion by the state that it's +bringing a, if you will, quasi-criminal case, we're not going +to apply that lower standard. Why wouldn't that be a possible +interpretation of what Congress did? +MS. LIU: I just don't think that there's anything +including the legislative history would be to the contrary in +1595(d) to suggest that Congress wanted to apply a criminal +scienter standard to a civil action by the government. +And if I could just clarify one point. Ms. Ellsworth +mentioned the knowledge or reckless disregard pre-2008. That +goes to a different point. That knowledge or reckless +disregard goes to knowledge or reckless disregard of sex +trafficking. This particular knew or should have known +standard goes to the participation in the venture. These are +two different scienter standards. +THE COURT: Let me hear from your colleague then on +the next prong. + + +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 12 of 50 +12 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. ACKERMAN: Thank you, your Honor. May it please +the Court. +David Ackerman for the Virgin Islands. The Court +expressed skepticism in denying JPMorgan's motion to strike +these affirmative defenses, and those concerns were +well-founded. +Despite having taken expansive discovery of the +Virgin +Islands, including the depositions of three current or +former governors and three former Attorneys General and +receiving nearly a hundred thousand pages in discovery, +JPMorgan's attempts to blame the USVI have no merit in law or +in fact. The Court received voluminous briefing, but nowhere +-- +THE COURT: You needn't remind me of that. +MR. ACKERMAN: I thought using the word "voluminous" +may have triggered a memory, your Honor. But nowhere in these +reams of documents are there facts that show any knowledge of +human trafficking or red flags by any USVI government official. +Your Honor, this is an important moment for both this +case and more fundamentally for the development of TVPA +enforcement law. As the Court is aware, this is the first +civil attorney general, civil enforcement action brought under +the IVPA. The government of the Virgin Islands, not Florida, +not New York, has stepped up to challenge the biggest bank in +the world over its enforcement practices. And it has permitted +through significant discovery calculated to test the +government's resolve and shift attention away from the bank's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 13 of 50 +13 +own failings. +And the case law establishes, your Honor, that these +affirmative defenses are not cognizable at law and JPMorgan's +briefing barely disputes that fact. The facts that JPMorgan +attempt to stitch together lack any fact tying government +action to Epstein's trafficking. +THE COURT: Well, are you saying that even if JPMorgan +is able to prove that the Virgin Islands were culpable +initially in letting Mr. Epstein's misconduct go forward to a +certain point in time, that that is completely irrelevant to +any of the issues in this case? +MR. ACKERMAN: What I'm saying, your Honor, is that +the affirmative defenses that JPMorgan has asserted are not +cognizable at law. Whether they may be relevant at some other +stage could be a question, we don't think they are. But the +issue before the Court now is simply the affirmative defenses, +and these affirmative defenses have no basis. +THE COURT: All right. Let me hear from again, with +apologies for interrupting, let me hear from defendant's +counsel. +MR. SCHOENFELD: Thank you, your Honor. Alan +Schoenfeld for JPMorgan Chase. +USVI's lead argument I think is +one that the Court has already rejected cause the Court found +in the bottom line order in the motion to strike that those +claims were available, or those affirmative defenses were + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 14 of 50 +14 +available as a matter of law. And the Court did express +skepticism -- and I'm happy to allay the Court's skepticism +today. But as a matter of law, in pari delicto and unclean +hands are clearly available to JPMorgan Chase to assert its +affirmative defenses to USVI's two TVPA claims. That's +consistent with the Court's holding in Google and Facebook, +which USVI never addresses, and both of which make clear that a +state government suing parens patriae under a federal statute +is a private actor susceptible to equitable defenses. +So the only question on this motion for summary +judgment is whether there's any issue of disputed fact as to +whether USVI's misconduct precludes its claims that JPMC +knowingly benefited from participation or obstructed a federal +investigation into Epstein. And a jury could reasonably +conclude that USVI's decades-long entanglement with Epstein +precludes judgment in USVI's favor. I'm happy to start with +knowledge. USVI claims that unlike JPMC, "There's no evidence +that any government official or employee had knowledge of what +was occurring on Epstein's private Island." But in 2007 -- +THE COURT: I guess what I'm having a little trouble +is, it's one thing to say that their alleged involved in +complicity if you will, it effects the timeframe involved, it +effects perhaps the extent of the relief they're entitled to; +but I'm not sure I've seen any case on facts similar to this +where it's a total bar of their bringing an action at all. + + +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 15 of 50 +15 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. SCHOENFELD: We've asked two sets of affirmative +defenses. The first is in pari delicto and unclean hands, +which I think would defeat the claims as a matter of law. And +those are both well-established affirmative defenses that go to +liability. +THE COURT: I'm just putting this in the context of a +state as opposed to an individual. A state fails to prosecute +or take action against someone who's committing a crime within +their state, and they do that even though they knew or +recklessly disregarded that that person was committing that +misconduct. And then they wake up and they say, you know, this +is really too much too far, and so they say we're going to +prosecute. I don't know of any cases that says they can't +prosecute in that situation. +MR. SCHOENFELD: This is a critical distinction, and +I'm glad your Honor raised it. And this is exactly what the +Court held in both UPS and FedEx to mark the distinction +between the enforcement actions that the City of New York was +bringing under the CCTA, which is the something, something +Tobacco Act, and RICO. And under the CCTA, the City had been +delegated enforcement authority by Congress to bring these +actions as a law enforcement authority. +And in those circumstances, the Court held that +unclean hands was not available as an affirmative defense, +including because the defendant couldn't challenge the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 16 of 50 +16 +government's discretionary law enforcement decision making. +That would apply if what we were talking about is +USVI's enforcement of the IVPA, but that's not why they're +here. They have no authority to enforce the TVPA. They have +the ability under 1595(d), which is what you were just +discussing with Ms. Ellsworth, to bring a claim parens patriae +to seek civil relief for injuries done to residents of the +US Virgin Islands. That is not a law enforcement authority. +That is a private claim brought parens patriae, and that's +precisely what the Court says in Google and Facebook. +In both of those cases, states were coming in to +enforce the Clayton Act to stop a merger. And the Court +said -- it's the SDNY in Google and the District of Columbia in +Facebook -- the Court said in both of those cases, Congress +chose not to give enforcement authority under the United States +Antitrust Laws to states and municipalities. It did decide to +supplement the ability of private parties to enforce those laws +through the Clayton Act. And in those cases, the states were +bringing those actions parens patriae to enjoin mergers and to +defeat other sorts of allegedly anti-competitive activity. +And the Court said, in those capacities where they are +not enforcing the anti-trust law, but instead seeking civil +relief against a merger, they are just as susceptible to a +Laches defense as any private actor. So the distinction you're +drawing is absolutely right. You can't bring a Laches claim, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 17 of 50 +17 +especially when there's an applicable statute of limitations +against the government to challenge its failure to prosecute, +its selection among discretionary prosecutorial options. That +is not why we're here. That is not what the USVI is doing in +this case. They are a private litigant, regardless of the fact +that they are suing parens patriae. +There are special standing rules that apply under +Article 3, and that's the Snapp line of case law. But as far +as the role that they are occupying here, it's not a law +enforcement role. So using UPS and FedEx as our models, the +actions brought under the CCTA are not the relevant actions. +It's the actions brought under RICO that are the relevant +actions, where they were suing as an aggrieved essentially +private party, parens patriae, and there they were susceptible. +The City in both cases were susceptible to the unclean hands +and in pari delicto defenses that FedEx and UPS had advanced. +THE COURT: All right. Let me go back to plaintiff's +counsel to respond, and then we'll go to the next issue. +MR. ACKERMAN: Couple of responses, your Honor. First +of all with respect to UPS. What the UPS case says about +enforcing statutes is, they initially quote the UPS case +correctly. It says the case law in the area of executive +discretion generally relates to a party's attempt to require +particular enforcement or hold a public entity responsible for +lack of an adequate enforcement. But the case then observes + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 18 of 50 +courts have in numerous other instances declined to probe into +government actor's decision making in circumstances where the +government +was acting in the sphere of enforcing public rights +in the public interest, and that is exactly what's happening +here. +18 +THE COURT: They just said it again here, they don't +think you, in this situation, are really enforcing public +rights. You are enforcing the private rights of your citizens +that may not be enforceable by those citizens, and we'll get +later to the question of whether the settlement bears on that. +But what is the public right you are enforcing by your action? +MR. ACKERMAN: This is a civil enforcement action, +your Honor. And what Congress has given the USVI and all other +states is the authority to enforce this statute specifically. +And in these types of cases, such as Phillip Morris, when +states are proceeding as a civil enforcement authority -- and +Phillip Morris I think is very instructive because the +defendant in that case, the tobacco company, argued in pari +delicto defenses because the government failed to communicate +to the public its knowledge of the properties of nicotine; or +they relied on the conduct of government scientists; or the +department of defense was subsidizing cigarette sales. +It relied on regulatory decisions concerning the +creation of so-called safer cigarettes. And the Court rejected +the unclean hands defense. It held, When as here, the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 19 of 50 +19 +government acts in the public interest, the unclean hands +doctrine is unavailable as a matter of law. +THE COURT: So I understand that point, but I'm +looking at subsection (d) of 1595, the section under which you +sue "In any case in which the Attorney General of the state has +reason +to believe that an +interest of the residents of that +state has been or is threatened or adversely affected by any +person who violates section 1591, the Attorney General of the +state is parens patriae, may bring a civil action against such +person on behalf of the residents of the state in an +appropriate district court of the United States to obtain +appropriate relief." +So the statute seems to contemplate that you're not +acting in the same way, for example, that the SEC might in a +civil action brought by the SEC; but rather more as, at least +so far as compensatory damages and the like are concerned, as +the representative of residence who for whatever reasons cannot +or have not brought their own actions. Now it might be +different to the extent that you're seeking injunctive relief. +But with respect to -- and this unfortunately gets into the +next motion -- but as I said they are intertwined -- with +respect to the relief that is geared to compensating victims, +in this case residents of the state, why aren't you in that +respect at least acting as the equivalent of a private +representative? + + +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 20 of 50 +20 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. ACKERMAN: Your Honor, you have hit the nail on +the head, which is that there is overlap between these motions, +and I believe Ms. Liu was handling this point. So what I would +say is that for certain UPS -- +THE COURT: Take a guess at what she would have said. +MR. ACKERMAN: That's fair, your Honor. +THE COURT: Go ahead. +MR. ACKERMAN: I believe that was -- and with respect +to -- +THE COURT: I'1l tell you what, I won't put you on the +hook. Ms. Liu, what did you want to say in that regard? +MS. LIU: So, Judge, you've already held at the motion +to dismiss stage in the challenge to our parens patriae +authority that the Virgin Islands has a quasi-sovereign +interest in assuring its residents it will act to protect them +from the harmful effects of criminal sex trafficking +enterprises flourishing in the islands. +THE COURT: You correctly quoted me, and I thought it +was a brilliant statement, but now we're getting -- and we are +getting now into the next series of motions while we're there, +but that may have to be distinguished depending on which kind +of relief you're seeking. +I think there's a strong argument that if you're +seeking injunctive and declaratory relief, you're acting in the +public interest, as well as in the interest of the residents + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 21 of 50| +21 +individually. But when you're seeking compensatory damages, +I'm not sure why that's so. +MS. LIU: So the case law, Judge, on this issue, +including in the Second Circuit in the Purdue Pharma v. +Kentucky case that is cited in I think both parties' papers +specifically says, If the Attorney General as parens patriae is +the real party in interest, which is determined by assessing +whether or not they have a quasi-sovereign interest, as this +Court has held the Attorney General here does, then the +question of what specific relief they're seeking does not +necessarily negate that parens patriae authority or interest. +So, for example, the Purdue Pharma v. Kentucky case, +injunctive relief was sought, civil penalties were sought, and +also damages to individual victims was sought. And the Court +specifically said the fact that the primary purpose of this +case is to pursue the public interest or to act in the public +interest means that the add-on of additional request for +compensatory damages does not negate the overall parens patriae +nature of this matter. +That is a consistent holding in numerous cases that we +cite in our papers, including the AU Optronics case, the +Balderas case and other cases. +THE COURT: What about the argument - now we really +are getting into the other motion, but I think I have no choice +cause it logically follows. +What about if you're not entitled + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 22 of 50| +22 +to compensatory damages cause they're duplicative of the class +action. +Assuming for the sake of argument that I approve the +class action settlement, what about that? +MS. LIU: I would submit, Judge, that Congress -- so +the Seneci case, the Second Circuit case in Seneci, what that +case +says is if all you're seeking in an AG case, all you're +seeking. And the only thing sought there was compensatory +damages for individuals. If that's all the AG is seeking, +we're going to have to question parens patriae standing. And +that's not all we're seeking. And our primary purpose is the +quasi-sovereign interest of assuring residents that sex +trafficking will not continue to flourish in the US virgin +Islands. But even the Seneci case says —- +THE COURT: Specifically -- I hear what you're saying, +but tell me exactly specifically what relief you are seeking +assuming for the sake of argument you're entitled to any and +all appropriate relief? +MS. LIU: We are seeking injunctive and declaratory +relief. +THE COURT: Injunctive against who? +MS. LIU: We are seeking injunctive relief against +JeMorgan. +THE COURT: Io not do anymore banking with +Mr. Epstein. +MS. LIU: No, Judge. Just as in the Snapp case where + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 23 of 50 +23 +the action, the discriminate conduct occurred in 1978 ended. +The case was brought a year later in 1979. The Supreme Court +said you can seek injunctive relief against this actor to +conform their conduct with the law. So our injunctive relief +that we're seeking is requiring that JPMorgan conform its +conduct to the protections of the Trafficking Victims +Protection Act, which is precisely what the Supreme Court +occurred in the Alfred Snapp case. +THE COURT: I know what you say they didn't do in the +past, but then, for example, they have subsequently filed SARs +and so forth. What is it you're saying they're not doing now +that they need to be ordered to do? +MS. LIU: Well, exactly like in the Snapp case where +the conduct had ended where the Court said, yes, but, in the +future we are going to enjoin you from violating the statute. +That is the same thing we are seeking here. There is nothing +to suggest that short of Jeffrey Epstein's death in 2019, +JPMorgan would act in conformance with the Trafficking Victims +Protection Act. Not vis-a-vis Jeffrey Epstein. Obviously he's +dead, but vis-a-vis other clients going forward in the future. +The only reason that JPMorgan finally after 16 years +reported the billion dollars in suspicious transactions for +Jeffrey Epstein is because he was arrested, and then he was +dead. This was a CYA reporting after 16 years of all of the +monies flowing in his JPMorgan accounts after he was dead. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 24 of 50 +24 +There is nothing -- and JPMorgan, as we've argued to the Court +in our letter brief, is a repeat offender. They have been +fined countless times for violating the law. There is nothing +to suggest that on its own JPMorgan is going to conform with +the law absent an injunction from this Court, which is +precisely what Alfred Snapp authorizes in terms of ongoing on +future conduct. +In terms of past harm, which the statute clearly +recognizes, the only forms of relief available are compensatory +and punitive damages for individuals and civil penalties. +Civil penalties is no doubt a traditional law enforcement +remedy. And civil penalties was in fact, your Honor, a remedy +at common law. +So I would submit that whether or not you read the +statute to authorize civil penalties, which we believe it +plainly does, civil penalties is a remedy at common law for +civil law enforcement. And thus to the extent they say the +statute merely codifies the common law parens patriae +principles outlined in Alfred Snapp, it certainly codifies the +common law authority of Attorneys General in civil law +enforcement actions to seek civil penalties as we do here. +THE COURT: I know there's more you want to say, and +you will have that opportunity, but let me turn to defense +counsel. And at this point, you're free to get into your +motions as well, because I think we can't avoid the interplay + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 25 of 50 +25 +of those motions. +MS. ELLSWORTH: Thank you, your Honor. Let me start +where Ms. Liu just ended. This is not a law enforcement +action. This is not the US Virgin Islands proceeding as a law +enforcement entity enforcing its own law. If they were trying +to enforce one of its territorial laws, then it could be a law +enforcement action. It did try and bring such a case, and the +Court dismissed it. +THE COURT: But the statute doesn't limit them to +that. The statute says that they can, when they have reason to +believe that the interest of the residents of their state has +been or is threatened, they can bring a civil action. +MS. ELLSWORTH: A parens patriae civil action, which +means they need to show injury, and the Court found that at the +motion to dismiss stage, they could survive a motion to dismiss +based on the articulation of injury that Ms. Liu read to you, +or maybe it was Mr. Ackerman, which was injury to the residents +of the US Virgin Islands. +But what we come to the Court with a motion for +summary judgment on the damages that they're seeking. Let me +put the injunction relief to the side for a moment, but I'd +like to come back to it. The damages that US Virgin Islands +purports to seek in this case are not damages that are tied to +that injury that they asserted in the motion to dismiss. +THE COURT: What about your adversary mentioned what + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 26 of 50| +26 +she called civil penalties. In some of the briefing it's +referred to as punitive damages, but what about that? In other +words, can't they -- even if they, for the sake of argument, +the victims were all totally compensated by the settlements +that are before me, their argument is, civil penalties still +need to be imposed. Those have a quasi-punitive purpose that +is not +served by mere compensatory damages. +You say, among other things in your papers, well, +there's a lot of law that says that if you can't show +compensatory damages, you can't get punitive damages; but I +wonder if that's really analogous to a situation where it's the +state suing parens patriae. +MS. ELLSWORTH: I think it is. On the compensatory +damages, just briefly, the compensatory damages that the US +Virgin Islands now seeks are the very type of damages that they +cannot seek as parens patriae. They are individual victim +damages. They call them victim damages. It's simply not +cognizable under the parens patriae law, and that's Seneci and +that's the Vacco case. I didn't hear Ms. Liu argue it. It +really is not available to them under Snapp or under any parens +patriae doctrine. +Under civil penalties, again, Ms. Liu just said, civil +penalties are a traditional law enforcement mechanism, but this +is not law enforcement. The IVPA section 1595(d) allows them +to bring a civil action, parens patriae, and allows them to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 27 of 50 +27 +seek appropriate relief. That's not defined in the statute. +THE COURT: I must say, I think that's -- of all the +questions, very interesting questions that you folks have +presented me with, one of the most interesting is, there's not +much indication, as near as I can tell from your briefs, as to +what Congress meant by appropriate relief. +MS. ELLSWORTH: I'm not sure Congress elucidated at +much beyond putting those words into the statute, so that's the +job for the Court. But I do think what the Court can look at +are a few different things. The first is, parens patriae is +different than law enforcement. And Mr. Schoenfeld spoke about +the UPS and the FedEx cases that draw the distinction between +the state acting as an enforcement agency when it is delegated +that authority by a federal statute, versus a state acting as +essentially a civil plaintiff when the only right of action +that it's given by a federal statute is as a civil plaintiff. +The TVPA does not delegate enforcement authority to +any state attorney general or the USVI. What the TVPA allows +is a civil action that allows them to try and seek some from of +relief, whether it's injunctive or damages if they could show +them. They have not articulated any damages that map onto the +interest to the territory that was articulated at the motion to +dismiss. +THE COURT: Maybe I misunderstood their argument, but +I think the argument goes, at least in part, we want injunctive + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 28 of 50| +28 +relief to make sure the bank doesn't undertake this alleged +misconduct in the future. And we think under their +interpretation of the statute and the law that we can add on to +that civil penalties for the prior misconduct. What about +that? +MS. ELLSWORTH: Again, it's not contemplated by the +statute that they would have civil penalties. +THE COURT: The question is, what is meant by +appropriate? +MS. ELLSWORTH: Well, then I think appropriate relief +could be injunctive relief. It could be some form of damages if +there were damages that actually mapped onto the parens patriae +interest. To allow them, particularly in the facts in this +case, to assert civil penalties or to award civil penalties +would be, as you just indicated, those are essentially like +punitive damages, that would be a retroactive application of +some sort of penalty to a provision that was added in 2018. +And the conduct of course that the US Virgin Islands challenges +here is conduct that dates back to the late '90s. +So I don't think that -- putting aside whether that's +actually even contemplated in the IVPA sort of writ large in +this case. To have civil penalties applied for conduct that +predates the right of action under which the US Virgin Islands +precedes would be an improper retroactive penalty. +But I also think it's not sort of what the statute set + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 29 of 50 +29 +out. +What the statute set out was to allow an Attorney General +to try and bring some form of civil action to the extent that +they had some separate form of damage to the territory, to the +quasi-sovereign interest. +And the US Virgin Islands could have tried to prove +that form of damage. And they had at various different points +theories and dollar amounts that were disclosed as being those +potential damages. They have withdrawn all that. They are not +seeking relief for the actual injury that allowed them to bring +this suit as parens patriae, and that's why no form of monetary +damages is available to them in this case. +I talked about compensatory damages briefly. We +talked about civil penalties. I do want to just note the US +Virgin Islands suggest that even if they can't get compensatory +damages, somehow maybe punitive damages would still be +appropriate. That's frankly just incorrect, under both the +common law availability of punitive damages, which are only +when there is something compensatory, and under the +constitutional sort of ratio due process clause. So I don't +think punitive damages could possibly be on the table either. +Restitution and discouragement are two other forms of +damages that they have articulated. Restitution would have to +be for some harm to the US Virgin Islands. That's what +restitution is. Of course they have not articulated that. And +discouragement is only available to victims, and they don't + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 30 of 50| +30 +claim to be a victim of anything either. They claim to proceed +on behalf of the interest of the territory to try and vindicate +this quasi-sovereign interest. +Let me turn to the injunctive relief request because +you discussed that at some length with Ms. Liu. I think the +Court's questions are the right ones which is, What is the US +Virgin Islands seeking to enjoin? And what basis does it have +to believe that there is a need to enjoin anything? The US +Virgin Islands has listed no evidence that sitting here today +JPMorgan Chase is not conducting itself in compliance with the +IVPA or with any of the federal anti-money laundering statutes +or any of the other sort of bank regulations that have form the +basis of some of their claims. +There's not a scintilla of evidence in the record that +suggest that there is lack of compliance today -- and I would +argue lack of compliance historically, but putting that to the +side. There's no suggestion that there would be any need that +they could possibly make out the showing required for +injunctive relief, either balance of harms for some of the +reasons Mr. Schoenfeld was discussing relating to some of the +affirmative defense. +But more importantly, there is no suggestion that +there is a need to have an injunction from a court that says +follow the law when they haven't elucidated any evidence that +JPMorgan is not following the law. + + +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 31 of 50| +31 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: I think their argument at least in part as +I understood from what Ms. Liu just had to say was, you didn't +file SARs in her view purposely because you were accommodating +Mr. Epstein's misconduct, because it was lucrative for you to +do so. +Then when finally things just got impossibly out of +hand, the publicity was too bad or whatever, you, in her view, +belatedly filed those SARs almost -- she would argue -- +admitting thereby that you should have filed them sooner. And +that that shows a pattern of behavior that needs to be enjoined +going forward. Those are not the Court's arguments one way or +the other. I'm just trying to articulate what I understood her +to be saying. +MS. ELLSWORTH: I think that that argument as +articulated by US Virgin Islands is simply contravened by the +facts. There are six filings made with the treasury department +during the course of the relationship between JPMorgan and +Jeffrey Epstein that predate that final post-death filing that +Ms. Liu was talking about. +So the suggestion that there were no filings at all is +imply incorrect. And the suggestion that there is a need to +have some kind of follow the law injunction from this Court for +the bank to have an adequate compliance program, again there +have been no facts adduced to suggest that sitting here today +in 2023, the compliance program is not squeaky clean. + + +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 32 of 50 +32 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So I don't think that you can just say, well, I think +you did something not as well as you should have 20 years ago, +and so today the Court's going to enter an injunction without +knowing that you're not doing things perfectly appropriately +today. The time for facts is now, and they have not elucidated +them. If I could just be heard briefly, we also moved on the +obstruction claim. +THE COURT: Yes, and we need to hear from your +adversary on that as well, but go ahead. +MS. ELLSWORTH: Indeed, but since I have the +microphone, I'll start. We moved that summary judgment should +enter in JPMorgan's favor on the obstruction claim. Let me +give a few different reasons why I think that is. +THE COURT: Possession of the microphone is a weapon +not to be lightly disregarded. +MS. ELLSWORTH: And not to be abused, so I'll be +brief. The US Virgin Islands does not have standing for an +obstruction claim. The Court allowed the Doe class obstruction +claim to proceed pass the motion to dismiss stage because the +Doe class claim to be victims of the alleged obstruction of a +federal TVPA investigation. Virgin Islands hasn't claim nor +could it that it was a victim of an alleged obstruction of a +TVPA investigation. +It hasn't argued any harm, but more importantly it +hasn't suggested that somehow it was a victim. And it's only a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 33 of 50 +33 +victim of obstruction that can in fact bring a claim under the +TVPA for that obstruction. The harm, to the extent that there +was a harm beyond the individual victims, it would be to the +federal government to the extent there was an obstruction. So +I think there's sort of threshold standing problem with the US +Virgin Islands obstruction claim. +The second point I would make is, they have not put +forth any evidence that there was in fact a federal +investigation to obstruct. They have not identified, , there +was an investigation in 2010, and somehow that was obstructed +or impeded by conduct or lack of conduct by JPMorgan Chase. +They haven't met that second predicate act. +And then even more easily on the summary judgment +standard, they have not and cannot -- +THE COURT: What about the arguments -- this goes back +to the SARs -- that there would or a reasonable jury could +conclude that there would have been an investigation had they +timely filed the SARs that she says you didn't file in a timely +fashion; and that therefore the effect of the failure to make +timely filings was an obstruction in the same way that, say, +destroying evidence before the government knows about the +underlying crime constitutes obstruction. +MS. ELLSWORTH: Again, it's a counterfactual argument, +and that's the problem with the argument. There were failings +made with the treasury department, and there was no response or + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 34 of 50 +34 +action taken by the federal government in response to filings +made in 2002, 2003, 2008, 2013, 2015 and 2016. So the +suggestion that filing more than those particular reports would +have somehow spurred an investigation is I think contravened by +the fact that the things that were filed did not spur an +investigation. +I would also point out that the obstruction count +requires an intentional act. It requires an intent to impede +an investigation. We again have the opposite here. What the +testimony and the evidence in the record before you shows is +that JPMorgan Chase employees made inquiries of the federal +government about whether or not an investigation was ongoing +against Mr. Epstein. +And they were either told Can't confirm or deny, or +they were told by lawyers for Epstein that no investigation was +ongoing. So inquiring about the existence of an investigation +is the polar opposite of trying to obstruct. +THE COURT: I'm not sure that I need to or should give +any weight to the inquiries of Epstein's lawyers. When you say +the bank says to a crook, Are you under investigation, +Mr. Crook. Not me. The inquiries of the government are +typically responded to as you indicated with, We're not going +to comment one way or the other. +MS. ELLSWORTH: But again, what this all goes to is +whether there was intentional conduct. It doesn't matter + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 35 of 50 +whether it was right or wrong if an investigation was ongoing +or not. +35 +THE COURT: My point is couldn't a reasonable jury +determine that the inquiries of Mr. Epstein's lawyers in that +regard was simply, to use plaintiff's counsel colorful phrase, +as CYA -- +MS. ELLSWORTH: With apologies, your Honor. +THE COURT: -- approach as opposed to a sincere +approach. +MS. ELLSWORTH: I don't think sincerity matters for +purposes of obstruction. They need to show an intentional +attempt to impede an investigation, and the conduct that I've +just described is the opposite of that. It's an attempt to +determine if there's an investigation ongoing, as opposed to an +attempt to hide evidence, destroy evidence, sort of all the +typical obstruction type conduct. +The last point I would make on the obstruction claim +is just to point out that again we have a 2008 retroactivity +problem. So the obstruction cause of action was added to the +IVPA in December of 2008, so any conduct that predates that on +which the US Virgin Islands would seek to rely cannot be a +basis for a liability under obstruction. Anything after 2008, +that could potentially be a basis, but pre-2008 conduct is off +the table for that purpose. +THE COURT: Thank you very much. Let me hear now + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 36 of 50 +again from the Virgin Islands. +MS. LIU: Thank you, your Honor. I just want to be +clear on this issue about parens patriae being essentially the +government acting as a private actor is completely contrary to +all of the case law and the common law as it relates to parens +patriae authority which is specifically the language used in +1595 (d) . +36 +Parens patriae means parent of the country or parent +of the state. The Attorney General is the one who can act as +parens patriae because they can act in a law enforcement +capacity to prosecute crimes civilly and criminally, but +civilly here including crimes as heinous as child sex +trafficking. +The very nature of parens patriae is the state acting +as a civil law enforcer. Otherwise, it is not the real party +and interest for purposes of a parens patriae's action, and +that's where you get into a number of these -- +THE COURT: Well, that may be true as to parens +patriae actions generally, but here of course the statute +speaks of the interest of the residents, not the interest of +the state independent of the interest of the residents. So I'm +not totally sure whether there's +: a distinction to be made there +or not. +MS. LIU: There absolutely is because if you look at +Alfred Snapp, it distinguishes between three layers. One, the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 37 of 50 +37 +state acting in its pure sovereign capacity while the parens +patriae case. The state acting in its quasi-sovereign capacity +protecting the general interest of a substantial segment of its +population, that is the interest of its residents. And here +the Court has said, assuring its residents that it will be +protected from ongoing sex trafficking flourishing in the +Virgin Islands is exactly a quasi-sovereign interest of the +residents. +THE COURT: If that's so, accepting that for the +moment, that gets you to injunctive relief. It doesn't get you +to damages. +MS. LIU: That gets us, we submit, your Honor, not +only to injunctive relief under the common law, but also +declaratory relief and civil penalties. +Now when you get to the question of, Can you also +authorize in a parens patriae case compensatory and punitive +damages to individuals, the answer is yes. The Second Circuit +in Seneci said under common law parens patriae, we are not +going to determine their standing when you're seeking merely +damages on behalf of individuals. But, the Court said, citing +to the Frito Lay case, the legislature can authorize under +parens patriae authority the additional remedy of pursuing +compensatory or punitive damages. +THE COURT: But here we have all the injured members +of the class settled. They of course could have sought -- and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 38 of 50 +38 +undoubtedly would have sought if the case had gone forward -- +punitive damages. +They accepted a settlement that, if I +approve it, will very fully compensate the whole class of +victims. +So what's left for you to seek in that regard? +MS. LIU: Before I answer that question, Judge, just +two more quick points on the parens patriae issue. I would +submit to the Court in the AU Optronics case. In that case the +Court I think summarized it nicely by saying parens patriae +representation is analogous to, for example, the role of the +EEOC. I think you asked about the SEC. +But what the Court says and what many of these cases +say is parens patriae authority is the state Attorney General +or state law enforcer acting in the role of a civil law +enforcement agency. And in fact in that case the Court said, +or other regulator, when it brings a case on behalf of a +segment of the public or in the interest of its residents. +So parens patriae is recognized as a civil law +enforcement or regulatory action, and we thus submit, for +example, as the New York banking regulator issued $150 million +civil penalty against Deutsche Bank for its relationship with +Epstein, such a similar civil penalty can be awarded here. +But to answer your question, Judge, as to individual +victim damages. First of all, Congress has in numerous +examples that we cite, and also cited by defendants, authorized +under parens patriae authority for State Attorneys General the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 39 of 50| +39 +ability to seek money damages for individuals, in addition to +injunctive relief civil penalties and other forms of relief. +As far as I know, not a single one of those statutes +has been struck down as improperly allowing the Attorney +General in its parens patriae authority to seek civil damages +on behalf of individuals. +Going back to the Seneci case, citing to Frito Lay. +What Frito Lay says -- and this is the Second Circuit in Seneci +citing to the Ninth Circuit. What Frito Lay says is, State +legislatures or Congress can use its legislative power and +determine that within parens patriae authority one form of +relief that can be sought is compensatory or punitive damages +for victims. And that is one of form of relief we are seeking +here under the statute. +In terms of your questions about double recovery or +duplicative relief, that does not go to the question of whether +or not in the first instance Attorneys General under 1595 (d) +have the authority to seek that relief. That is what happened +in this particular case. What happens in any particular case +cannot determine whether or not the authority existed. So +these are two different questions. +And in fact in their reply brief, JPMorgan argues the +question of parens patriae authority is analytically distinct +from what relief can be sought in a particular action. So I +would submit, we can seek it. The plain language of the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 40 of 50| +40 +statute allows it. The legislative history supports it. And +then when it comes before your Honor in the situation that's +present here, which may not be present in every case, there +could be an example where the Doe victims did not come forward. +They did not seek their own relief. And then what would the +Court say. You can't interpret 1595(d) differently in terms of +authority based on what happens in any particular case. +So the only question becomes, Can you seek it? Yes, +you can. And to what extent would a jury after a trial, if +there is a trial in this case, award in terms of compensatory +and punitive damages. They may award $280 million, in which +case it then falls to the Court -- you can look at EEOC v. +Waffle House before the Supreme Court to decide what's the +offset. +THE COURT: Again, just for the sake of argument, if +the only relief you can seek is injunctive relief, declaratory +relief and civil penalties, is it a jury trial? +MS. LIU: I believe that civil penalties, your Honor, +as I mentioned -- and there's a Supreme Court case from 1987 +called Tull. I think it's Tull v. United States. I think what +that case says is that a civil penalty was a remedy at common +law. And because it's a remedy at common law, I believe +liability can be determined by a jury. I don't want to get +ahead of myself here, but I think it's the case that perhaps +the judge can determine the amount of the civil penalty, but + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 41 of 50 +that a jury can hear the case and assess liability in that +context. +41 +THE COURT: All right. Well, we don't need to reach +perhaps that issue on these motions. Only in my nightmares do +I see this as a bench trial. So, anyway, let me hear from +defense counsel. +MS. ELLSWORTH: So, your Honor, just to make a few +points in response to Ms. Liu's argument. The first is that +the cases where parens patriae actions were viewed more akin to +law enforcement actions that Ms. Liu was citing to, the Purdue +case, the AU Optronics. Those are all cases where there were +states pursuing under their own state laws. +THE COURT: You made that point before, and I think +it's an important point, but I understand that point. +MS. ELLSWORTH: So when they're enforcing their own +state law, it's just a different in kind. On the question of +injunctive relief -- and I do think the Court needs to think +about, again, what is the interest that is being articulated +here. And in particular, Does the US Virgin Islands even have +standing to seen an injunction here. +So the interest that's been articulated is protecting +the residents from the harm of potential sex trafficking. They +have not identified any actual concrete or particularized +injury that such future harm might befall the residents of the +US Virgin Islands or any territory; nor that that potential + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 42 of 50 | +42 +harm might be redressed by the injunction that apparently they +would be seeking. And although I don't think it's before you +on summary judgment as to the form of injunctive relief, if +any, of course liability would need to be established first. +But what I've heard articulated is, comply with the +law. Comply with the IVPA. And there's no suggestion that +that would redress whatever harm it is that they articulated at +the motion to dismiss stage, and they purport to continue to +articulate here. +I do want to go back to the civil penalties point +because I think it's important, and I hear the Court sort of +grappling with whether or not that's available here. It is a +traditional law enforcement penalty. It's called a civil +penalty, right, or a fine. That's by its nature punitive. +I'll point out the retroactivity point again, but +again that is not what Congress authorized State Attorneys +General to do here, didn't authorize State Attorney General to +enforce the TVPA as some law enforcement entity. +Congress knows how to do that. It has done that in +other federal statutes where it delegates some enforcement +authority to a State Attorney General. That is not what +Congress did in the TVPA. It knows how to do it, and it didn't +do it here. And so for the Court to interpret the 1595(d) to +allow that type of punitive action by a non-law enforcement +entity would, I think, be both improper under the TVPA, but + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 43 of 50| +43 +would also be impermissibly retroactive for any conduct that +predates 2018. +On the question of compensatory damages to victims. +That's just flatly unavailable to a parens patriae plaintiff. +It cannot be individual damages. And Ms. Liu has said a few +different times that Seneci said, well, if that's all you're +seeking, then that's the problem. But whether or not that's +all that the US Virgin Islands is seeking, it is still +unavailable as a form of relief under parens patriae. +And the Court said it itself in the motion to dismiss +ruling, which is that the interest that allows the US Virginia +Islands to proceed forward here is an interest that cannot be +redressed by an individual plaintiff, and that's not what the +compensatory damages that they purport to seek here would be. +And again I point out as the Court has, to the extent +that they had some right to seek those damages, which they do +not, those victims have been fully compensated by the two +settlements. +THE COURT: Although theoretically, I doubt this will +occur, theoretically if 50 people opted out on those +settlements, and they were all residents of the Virgin Islands, +we might have an interesting issue, but I think that's an +unlikely scenario. +MS. ELLSWORTH: I think it is too, your Honor. I +think that is an entirely theoretical question, but the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 44 of 50 | +44 +question did embed an important point, which is residents of +the Virgin Islands would be the only types of potential victims +that the US Virgin Islands might be able to seek compensatory +damages for. +Again, those damages aren't available, but even if +they were. And they have not articulated or identified who +those individuals might be. +But more importantly, it's both categorically +unavailable released by the settlement if it is ultimately +approved and unnecessary. Those damages have been fully +compensated by the settlements reached that the Court is +currently considering. +THE COURT: Okay. I want to hear both from +plaintiff's counsel on what we've just been discussing, but +also on anything else you want to raise because in a moment of +foolishness I scheduled another matter to follow this matter, +and I don't want to keep the lawyers in that matter waiting too +long. +Let me hear from plaintiff's counsel, and then we'll +give defense counsel a final say as well. +MS. LIU: Thank you, your Honor, just a few points. +If you look at the legislative history of 1595(d), it's clear +that Congress was contemplating that State Attorneys General +would act as civil law enforcement in this case. +The language in one section allege history that we + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 45 of 50 +45 +cite in the briefing, We have begun to change the issue of +resources to go after the perpetrators of these heinous crimes +in a much better way by allowing State Attorneys General to +actually prosecute these crimes. +"Prosecute" that is not a +word that is used, except when you are referring to the State +Attorneys General's law enforcement powers. +We are doing +something in the law that says we need more prosecutes. +We +need more investigators. +Again, those are terms used when Congress is intending +that Attorneys General are acting in their civil law +enforcement capacity. "Let's unleash those in the states to +help us address this growing problem throughout our country. A +problem that they previously referred to as these heinous +crimes." +Clearly the intent of Congress was to have State +Attorneys General, the law enforcement entities in state -- +THE COURT: You're saying that, as to your adversary's +argument, that this would only apply if they were enforcing +state laws, that the statute on its face in effect says they +are enforcing federal law? +MS. LIU: Right. And Congress has done this numerous +times where they've invoked State Attorneys General parens +patriae authority to enforce a federal law civilly, and for +this precise reason, to allow more prosecutes to go after these +type of crimes. + + +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 46 of 50| +46 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And in the briefing we talk about other congressional +enactments that protect children; for example, where Congress +has specifically sought the help of state law enforcement to +enforce and prosecute these type of heinous crimes against +perpetrators like JPMorgan. +I will also provide to you, your Honor -- +THE COURT: And you might along the same lines say or +argue perhaps that this made special sense in a situation where +victims who are residents of a particular state or territory +are often, by the nature of these crimes, people who are +hesitant to come forward have many impediments to bearing their +souls so to speak; and so that it would be particularly +appropriate to have the state as a quasi-prosecutor through +civil action in those situations. +MS. LIU: Absolutely, Judge. And that's precisely +what has happened here. If you look at the statements of +undisputed facts, I believe it's in JPMorgan's facts, it is +noted by one of the parties that the EDCP identified, for +example, a certain number of victims that it could identify. +Of course it's very hard to ensure that you've +identified all of the victims in this kind of case, +particularly as you said, where Jeffrey Epstein really was able +to hide out on these two Islands that were miles off the shore +of St. +But the EDCP identified a certain number of victims. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 47 of 50| +47 +And, in fact, not all those victims came forward. There may be +a number of absent class members who did not fall within the +class period whose claims are released. And that is precisely, +even in this particular case, the reason that state AGs are +here. +We can get those damages for those victims, put them in +a fund. And if at some point years down the road those victims +come forward, they can still claim those funds as opposed to +having them released. +I would also note that there is a long line of cases, +Judge, where the situation that's happened here has happened in +cases involving government enforcement actions; namely, private +party settlements seeking to release government claims. And +the Third Circuit, the Eighth Circuit, the Seventh Circuit, the +Eleventh Circuit, have all said that is not permitted. +In the Kwasny case, 853 F.3d 87; the Kratville case, +796 F.3d 873; the Hartigan case, 816 F.2d, 1177. Those cases +say -- and I'm quoting, That private settlements cannot +preclude the government "From later seeking additional or more +full restitution or any other remedy. Private settlements +cannot release the claims of government." +Again, your Honor can determine at a later stage, if +there's an offset merited here. We are not arguing for double +recovery. But to the extent, again, there are absent class +members, or a jury decides that punitive damages should be +awarded, which are not included in the proposed settlement, why + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 48 of 50 +48 +shouldn't the victims benefit from those awards? Why should +JPMorgan get the windfall of not having to pay those punitive +damages or those absent class members or those additional +compensatory damages that a jury decides is properly awarded to +the hundreds of victims at issue in this case particular case? +THE COURT: Okay. Thank you so much. Let me hear +from defense counsel. +MS. ELLSWORTH: Just a few things, and I'll bring that +last point up first. The claims the government is asserting +here are not the claims of victims for their own damages. What +the government is trying to assert here is a quasi-sovereign +interest in protecting the residents of the territory, so +nothing that would be released by the settlement should effect +the government's claims. +The government has different claims, and I think +that's some of what the Court and the parties have been +grappling with here is trying to define what in fact is the +government claiming, and is there any injury in fact that they +can claim based on that articulation. +As to whether the IVPA should be read to infer some +power for a state Attorney General to actually act as a +prosecutor, as an enforcing entry. Congress knows how to do +that explicitly. +When it wants to do that, it does so explicitly using +that language. That is not what it did in the TVPA. And I + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 319 Filed 09/08/23 Page 49 of 50 +don't think that a snippet of either a floor statement or a +Senate report can change the plain language of the statute +which does not delegate any enforcement authority. It doesn't +amend the criminal provision of the TVPA that only the federal +government can enforce. It adds a civil parens patriae right +of action for State Attorneys General, and that's it. +49 +And the last point I would make is that, the governor +of the Virgin Islands here has to identify what interest it is +that it's trying to vindicate. And it identified that interest +as the harm to residents from sex trafficking. +Now before the Court it needs to come forward with +some evidence that there is in fact harm in the future to +residents from sex trafficking, or that there is some +cognizable compensatory harm in the past to its residents, its +quasi-sovereign interest. And it's come forth with neither at +this last stage in the litigation, and that's what I think is +the important factual point for the Court to focus on. +THE COURT: All right. So I thank all counsel for +this excellent and very helpful argument. I remind everyone +that if the case goes forward to trial, he trial is set for +October 23rd, and that is a firm fixed final and unmoveable +date, so you need to know the results of these motions +substantially before that. +I will undertake worst case to get you my rulings on + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 319 Filed 09/08/23 Page 50 of 50| +50 +these motions by the end of September, but I'm going to try to +do much better than that. At least maybe I'll get you a bottom +line order to be followed by an opinion. Meanwhile, I'll take +everything under advisement, and my thanks again to the +excellent counsel in this case. That concludes this +proceeding. +(Adjourned) \ No newline at end of file diff --git a/vision-fixhub/court-05/5489d404c4bf1af9caf2a43f6359de877534ddab8f3ec7ebba9b8300593785ea.receipt.json b/vision-fixhub/court-05/5489d404c4bf1af9caf2a43f6359de877534ddab8f3ec7ebba9b8300593785ea.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..057b677ee860e0e0b16d652d856824a49d6854c0 --- /dev/null +++ b/vision-fixhub/court-05/5489d404c4bf1af9caf2a43f6359de877534ddab8f3ec7ebba9b8300593785ea.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -3501, + "dataset": "marble-joined", + "doc_id": "5489d404c4bf1af9caf2a43f6359de877534ddab8f3ec7ebba9b8300593785ea", + "engine": "marble-apple-vision", + "event_count": 51, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "f96d17007e072fbddc4f726025fba16e009ba2b4ad942956e76024e0eb3cc5e5", + "output_sha256": "7bc5306c09d8281bb9eaf0a6984bc869103481c011b726adf3cc0bc153422711", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5494fcc2db30390ca13e224dd13c08c1726ecdfff355d4c0a3e480a05ea35492.md b/vision-fixhub/court-05/5494fcc2db30390ca13e224dd13c08c1726ecdfff355d4c0a3e480a05ea35492.md new file mode 100644 index 0000000000000000000000000000000000000000..572c6edcd8a1012942968caef35d4dddfedf8d7a --- /dev/null +++ b/vision-fixhub/court-05/5494fcc2db30390ca13e224dd13c08c1726ecdfff355d4c0a3e480a05ea35492.md @@ -0,0 +1,33 @@ +Case 1:19-cr-00830-AT +Document 15 +Filed 12/16/19 + +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AM +USA / Plaintiff(s) +19CR830 +Case No.: +TOVA NOEL ET AL., +Defendant(s) +) +NOTICE OF FILING OF OFFICIAL TRANSCRIPT +Notice is hereby given that an official transcript of a +INFERENC +held on +11/19/19 +has been filed by the court reporter/transcriber in the above-captioned matter. +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting +the transcript is a judge or a member of the public or media. +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court +any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also +be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically +available to the public without redaction after ninety (90) calendar days. +This process may only be used to redact the following personal data identifiers: Social Security +numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure +5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information +may proceed by motion. +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. +Is ANDREW WA +Court Reporter/Transcriber +Date diff --git a/vision-fixhub/court-05/5494fcc2db30390ca13e224dd13c08c1726ecdfff355d4c0a3e480a05ea35492.receipt.json b/vision-fixhub/court-05/5494fcc2db30390ca13e224dd13c08c1726ecdfff355d4c0a3e480a05ea35492.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c0dea3fc1cd86b062e40cdeeb0b98aac51c8d38f --- /dev/null +++ b/vision-fixhub/court-05/5494fcc2db30390ca13e224dd13c08c1726ecdfff355d4c0a3e480a05ea35492.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -25, + "dataset": "marble-joined", + "doc_id": "5494fcc2db30390ca13e224dd13c08c1726ecdfff355d4c0a3e480a05ea35492", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "2d1fa84c24b082fcd61407566a59c9919d2daf153203953a50340605e5ac6eb9", + "output_sha256": "4306e5de02a64eb90083074e226d240e8ba26c7620ebb7dd83f5ce6a640f02b7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/54a62f1c960084504536b4dea0f93a9953fb927617303cb8cd44de338b687ab4.md b/vision-fixhub/court-05/54a62f1c960084504536b4dea0f93a9953fb927617303cb8cd44de338b687ab4.md new file mode 100644 index 0000000000000000000000000000000000000000..8bc6c2e9468e6ce00ac76cee93870764733be2d1 --- /dev/null +++ b/vision-fixhub/court-05/54a62f1c960084504536b4dea0f93a9953fb927617303cb8cd44de338b687ab4.md @@ -0,0 +1,85 @@ +Case 1:19-cr-00830-AT +Document 65 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +Filed 0T03/2Z +Page TUl 3 +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC#: +DATE FILED: 1/3/2022 +- x +: +UNITED STATES OF AMERICA +NOLLE PROSEQUI +-V. - +19 CI. 830 (AT) +TOVA NOEL and +MICHAEL +Defendants. +: +: +- x +1. The filing of this nolle prosequi will dispose of +this case with respect to TOVA NOEL and MICHAEL +the +defendants. +2. On or about November 19, 2019, a grand jury sitting +in this District returned Indictment 19 Cr. 830 (AT) , which charged +TOVA NOEL and MICHAEL +, the defendants, with committing +offenses against the United States, to wit, conspiring to knowingly +defraud the United States and to knowingly make and use a false +writing or document, in violation of 18 U.S.C. S 371, and knowingly +making and using a false writing or document, in violation of 18 +U.S.C. § 1001. +3. On or about May 20, 2021, TOVA NOEL and MICHAEL +the defendants, entered into deferred prosecution +agreements with the Government. Under the agreements, prosecution +was deferred for a period of six months during the term of NOEL's +and +good behavior, completion of community service, and + + +Case 1:19-cr-00830-AT Document 65 +Filed 01/03/22 Page 2 of 3 +satisfactory compliance with the terms of the agreement. The United +States Pretrial Services Office has informed the Government that +NOEL and +have complied with the terms of the agreement +during the period of deferral, which expired on November 20, 2021. +4. In light of the +foregoing, the Government +recommends that an order of nolle prosegui be filed as to TOVA +NOEL and MICHAEL +, the defendants, with respect to Indictment +19 CI. 830 (AT). +lund +Nicolas Roos +Assistant United States Attorney +(212) 637-2421 +Dated: +New York, New York +December 13, 2021 +2 + + +Case 1:19-Cr-00830-AT Document 65 Filed 01/03/22 Page 3 of 3 +Upon the foregoing recommendation, I hereby direct, with +leave of the Court, that an order of nolle prosequi be filed as to +defendants TOVA NOEL and MICHAEL +with respect to Indictment +19 Cr. 830 (AT). +Damian +United States Attorney +Southern District of New York +Dated: +New York, New York +December 13, 2021 +SO ORDERED. +Dated: January 3, 2022 +New York, New York +ANALISA +United States District Judge +3 diff --git a/vision-fixhub/court-05/54a62f1c960084504536b4dea0f93a9953fb927617303cb8cd44de338b687ab4.receipt.json b/vision-fixhub/court-05/54a62f1c960084504536b4dea0f93a9953fb927617303cb8cd44de338b687ab4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2337e0e66eb3fc12ba05bd3d87d7c755f576c7ef --- /dev/null +++ b/vision-fixhub/court-05/54a62f1c960084504536b4dea0f93a9953fb927617303cb8cd44de338b687ab4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "54a62f1c960084504536b4dea0f93a9953fb927617303cb8cd44de338b687ab4", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "413ca893074dfb9a735096ba4413a454744a834f0b5b204d6ea0feef09477f3b", + "output_sha256": "6ab160ab92cc8edc30012b6605a127307c0b65bc295758b046c8f3a74b3f0d7c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/54a6ada797aa9995cc89114f227780df40dc76f09a659a3d3bc371e07693c578.md b/vision-fixhub/court-05/54a6ada797aa9995cc89114f227780df40dc76f09a659a3d3bc371e07693c578.md new file mode 100644 index 0000000000000000000000000000000000000000..65247fdae78e75d24bef97d0dabc9e26dfa2f371 --- /dev/null +++ b/vision-fixhub/court-05/54a6ada797aa9995cc89114f227780df40dc76f09a659a3d3bc371e07693c578.md @@ -0,0 +1,37 @@ +Case 1:22-cV-10904-JSR Document 326-95 Filed 09/08/23 Page 1 of 2 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-95 Filed 09/08/23 Page 2 of 2 +Staley, Jes +"jeevacation@gmail.com' +1/22/2011 11:08:59 PM +Re: +Terrific. Lots of workers. +What a paradise. When I retire, I'm going to put a mooring in front of your dock for my boat +Amazing place. +I think Larry is sad.... +Jes +From: Jeffrey Epstein +To: Staley, Jes +Sent: Sat Jan 22 13:33:25 2011 +Subject: +did you like the kitchen +$$$********* +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved + diff --git a/vision-fixhub/court-05/54a6ada797aa9995cc89114f227780df40dc76f09a659a3d3bc371e07693c578.receipt.json b/vision-fixhub/court-05/54a6ada797aa9995cc89114f227780df40dc76f09a659a3d3bc371e07693c578.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..85d703d31d24e994287c0e08968d5b801d507849 --- /dev/null +++ b/vision-fixhub/court-05/54a6ada797aa9995cc89114f227780df40dc76f09a659a3d3bc371e07693c578.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -41, + "dataset": "marble-joined", + "doc_id": "54a6ada797aa9995cc89114f227780df40dc76f09a659a3d3bc371e07693c578", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "dbe9e4af1e3eded32d9e78f1f422788c0e81dc49a00322b2d5a2bdea2ef80f31", + "output_sha256": "cd4047a8ca523f7103c4ae519ddae0028d05bfbab11ea2021338f2cecd3405fa", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/54b06e85683cd49d23ddfff4975ba53e1c1138d8a13d1c4d595f49d00645edaa.md b/vision-fixhub/court-05/54b06e85683cd49d23ddfff4975ba53e1c1138d8a13d1c4d595f49d00645edaa.md new file mode 100644 index 0000000000000000000000000000000000000000..eb0ec2f8b884517dde8945d0370d70296935c6a2 --- /dev/null +++ b/vision-fixhub/court-05/54b06e85683cd49d23ddfff4975ba53e1c1138d8a13d1c4d595f49d00645edaa.md @@ -0,0 +1,58 @@ +Case 1:22-cv-10904-JSR Document 284-17 Filed 08/14/23 + + +FILED UNDER SEAL + + +Case 1:22-cV-10904-JSR Document 284-17 Filed 08/14/23 Page 2 of 3 +Date : 10/26/2018 9:31:57 PM +From: "Cecile de Jongh" +To: "Richard Kahn" +Ce : "Una Pascal" +Subject: Re: +Ok +With warmregards, +Cecile +Sent from my iPhone and mispelings courtesy of iPhone +On Oct 26, 2018, at 3:54 PM, Richard Kahn +use your office +Richard Kahn +wrotc: +fix/ +cell +On Oct 26, 2018, at 451 PM, Una Pascal +Rich +They ako need a telephone. +On Fri, Oct 26, 2018 at 3:44 PM Richard Kahn +my address is ok as long as donation fromjee +Richard Kahn +HBRK Associates Ine. +wrote: +Wote: +tel +tax +cell +> On Oct 26, 2018, at 3:33 PM, Cecile de Jongh +> +> Rich +wrote: +> What email address should we use on the DCCC website? Una is trying to pay the $10,000. +> With warm regards, +> Cecile +> +> Sent from my iPhone and misspellings courtesy of iPhone. + +ESTATE_JPM060696 + + +Case 1:22-cV-10904-JSR Document 284-17 Filed 08/14/23 Page 3 of 3 +> On Oct 26, 2018, at 104 PM, Una Pascal +wrote: +> +> Hi Cecile, +> I am processing the donation right now. It is asking for a email address +> and a phone number. What information would like me to use? +> Thanks, +> Una + +ESTATE_JPM060697 diff --git a/vision-fixhub/court-05/54b06e85683cd49d23ddfff4975ba53e1c1138d8a13d1c4d595f49d00645edaa.receipt.json b/vision-fixhub/court-05/54b06e85683cd49d23ddfff4975ba53e1c1138d8a13d1c4d595f49d00645edaa.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0f056fb64fafb9124e72c26d8b74371fc69a8b50 --- /dev/null +++ b/vision-fixhub/court-05/54b06e85683cd49d23ddfff4975ba53e1c1138d8a13d1c4d595f49d00645edaa.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -82, + "dataset": "marble-joined", + "doc_id": "54b06e85683cd49d23ddfff4975ba53e1c1138d8a13d1c4d595f49d00645edaa", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "1ead2ad70d2bcd7452f269c6e4884bf9ab35c3705ad4d09b32388bf6f1445f60", + "output_sha256": "cb412a63143078e294717ec1af06908d8be7ff779d1baf4438721ecc1aa03103", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/54b4dc02f35fe82cb9a7dcd9bc050ef69316d24551e4e5f49d43cdb33e0c89bf.md b/vision-fixhub/court-05/54b4dc02f35fe82cb9a7dcd9bc050ef69316d24551e4e5f49d43cdb33e0c89bf.md new file mode 100644 index 0000000000000000000000000000000000000000..1af3076aa7a6b32732f670ae28888035bcb052c5 --- /dev/null +++ b/vision-fixhub/court-05/54b4dc02f35fe82cb9a7dcd9bc050ef69316d24551e4e5f49d43cdb33e0c89bf.md @@ -0,0 +1,648 @@ +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 1 of 14 + + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 2 of 14 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +JANE DOE 1, individually and on behalf of all +others similarly situated, +Plaintiff, +Case No. 22-cv-10019-JSR +V. +JPMORGAN CHASE BANK, N.A., +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +JAMES EDWARD STALEY, +Third-Party Defendant. +JPMORGAN CHASE BANK, N.A.'S +FOURTH SUPPLEMENTAL INITIAL DISCLOSURES +Pursuant to Federal Rule of Civil Procedure 26(a)(1) and the Civil Case Management +Plan, Dkt. 16, Defendant/Third-Party Plaintiff JPMorgan Chase Bank, N.A. ("JPMorgan") +makes the following fourth supplemental initial disclosures to Plaintiff Jane Doe 1 ("Doe" or +"Plaintiff") and Third-Party Defendant James Edward Staley ("Staley" or "Third-Party +Defendant"). +The disclosures made herein are based upon information reasonably available to +JPMorgan at the present stage of this litigation and the issues as currently defined by the +complaint. JPMorgan reserves the right to supplement, revise, or otherwise amend the + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 3 of 14 +information contained herein as discovery continues. +By making these disclosures, JPMorgan does not represent that it is identifying every +document, tangible thing, or witness that may be relevant to the issues in this action, or on +which JPMorgan may rely in support of its claims or defenses. Nor does JPMorgan waive +its rights to object to production of any document or tangible thing disclosed on the basis of +any valid objection (including but not limited to any privilege, the work-product doctrine, +relevancy, hearsay, undue burden, or any other proper ground) or its rights to object to the +use of any information disclosed for any purpose, in whole or in part, in any subsequent +proceeding in this action or in any other action. JPMorgan also reserves the right to object +on any and all proper grounds to any other discovery request or proceeding involving or +relating to the subject matter of these disclosures consistent with the Federal Rules of Civil +Procedure and the Local Rules for the United States District Court for the Southern District +of New York. +JPMorgan's disclosures represent its good faith effort to identify information it +reasonably believes is required by Fed. R. Civ. P. 26(a)(I). The disclosures set forth below +are made subject to the above objections and qualifications. +I. +INDIVIDUALS WITH KNOWLEDGE +Based on information reasonably available at this time, JPMorgan identifies the +following individuals who may be likely to have discoverable information that JPMorgan may +use to support its claims or defenses, unless such use is solely for impeachment. In making +these disclosures, JPMorgan does not waive its right to object, pursuant to any applicable +Federal Rule of Civil Procedure or Local Rule, to the deposition or trial testimony of any of +the individuals listed below. +JPMorgan does not consent to or authorize communication by the Plaintiff with the +individuals identified below. Each of the individuals identified below can be reached +- 2- + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 4 of 14 +through counsel for JPMorgan. +Because discovery, investigation, and analysis of these matters is ongoing, JPMorgan +reserves the right to supplement this information if additional information later becomes +known and to designate and/or call further witnesses at trial. JPMorgan also reserves the +right to seck discovery from, and relating to, other persons that may subsequently become +known as persons likely to have discoverable information relevant to the disputed facts. +Name +Corporate representative of JPMorgan +Chase Bank, N.A. +Subject Matter +Corporate representative of JPMorgan +Chase Bank, N.A. +Corporate representative of JPMorgan +Chase Bank, N.A. +Corporate representative of JPMorgan +Chase Bank, N.A. +Mary Erdoes (CEO Asset & Wealth +Management) +William Langford* (former Director +(Global Anti-Money Laundering); Global +Head (Compliance); Head (Enterprise +Financial Crimes Compliance); and +General Counsel (Global Compliance and +Regulatory Management)) +McHugh (Executive Director, +JPMorgan Private Bank) +to Jeffiey Epstein. +JPMorgan's policies and procedures relating to +the private bank's recruitment, onboarding, and +retention of clients. +JPMorgan's policies and procedures relating to +monitoring and reporting account activity of +private banking clients. +JPMorgan's Anti-Money Laundering ("AML") +Compliance program and AML Compliance +policies and procedures. +JPMorgan's private banking client relationship +with Jeffrey Epstein. +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein.' +AML compliance work that JPMorgan +performed relating to Jeffrey Epstein's accounts +and accounts related to Jeffrey Epstein. +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +Transaction information relating to Jeffrey +Epstein's account activity at JPMorgan and +accounts related to Jeffrey Epstein. +' JPMorgan has identified those individuals who, at this point in the litigation, may have information uniquely +related to its breach of fiduciary duty and faithless servant claims against Mr. Staley. All witnesses may have +information related to the underlying claims of Doe for which JPMorgan seeks contribution or indemnity. +JPMorgan does not waive its rights to further amend or supplement these disclosures through discovery. +- 3- + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 5 of 14 +Name +Paul Morris* (former Banker (Private +Bank)) +James Edward Staley* (former CEO +(Private Bank); CEO (Investment Bank); +CEO (Asset Management); Global Head +(Asset & Wealth Management); Head +(Private Bank)) +Stephen Cutler* (former Executive Vice +President, General Counsel) +Mary +Bank) +(Managing Director, Private +Subject Matter +JPMorgan's private banking client relationship +with Jeffrey Epstein. +JPMorgan's private banking client relationship +with Jeffrey Epstein. +Jeffrey Epstein's involvement in recruiting other +private banking clients for JPMorgan. +Mr. Staley's involvement in JPMorgan's banking +relationship with Jeffrey Epstein. +Knowledge of Jeffrey Epstein's activities as +alleged by Plaintiff Jane Doe 1 and the United +States Virgin Islands (in Case No. 22-cv-10904). +Third-Party Defendant. +JPMorgan's private banking relationship with +Epstein. +JPMorgan's retention and exit of Jeffrey +Epstein's accounts and accounts related to +Jeffrey Epstein. +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +JPMorgan's private banking client relationship +Justin Nelson (Managing Director and +Head of Asset Management and Financial +Principals Coverage, Private Bank) +Jonathan +* (Former General +Counsel, Investment Bank) +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +JPMorgan's private banking client relationship +with Jeffrey Epstein. +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +Mr. Staley's involvement in JPMorgan's +anking relationship with Jeffrey Epstein +These individuals no longer work at JPMorgan and may be separately represented. To the extent these individual +re separately represented, JPMorgan will provide contact information for their counsel when availabl +- 4- + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 6 of 14 +Catherine Keating* (former CEO, Private +Bank) +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +John Duffy* (former CEO, Private Bank) +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +Anne Verdon (former General Counsel, +Private Bank) +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +Jane Doe 1 (Plaintiff) +Mr. Staley's alleged sexual abuse of Jane Doe 1 +and others through his relationship with Jeffrey +Epstein. +Jane Doe 1 (Plaintiff in Case No. 22-cv- +10018) +Mr. Staley's alleged sexual abuse of Jane Doe 1 +and others through his relationship with Jeffrey +Epstein. +U.S. Customs and Border Protection +Federal Bureau Of Investigation +United States Attorney's Office For The +Southern District Of New York +United States Attorney's Office For The +Southern District Of Florida +Palm Beach Sheriff's Office +Palm Beach Police Department +Virgin Islands Department Of Justice +Information concerning passengers on Jeffrey +Epstein's aircraft and visitors to his residence +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +Information concerning law enforcement actions +and investigations into Epstein and related +entities. +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +- 5- + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 7 of 14 +Santa Fe County Sherriff's Office +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +New York Police Department +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +Manhattan District Attorney's Office +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +The Epstein Estate +Information concerning Epstein and related +entities. +The Epstein Victims Compensation Program Information concerning claims made by victims +against Epstein and their resolution. +In addition to the above-named individuals, all persons deposed in this case and other +persons identified in the documents described in Section II below may have discoverable +information that JPMorgan may use to support its claims or defenses. JPMorgan reserves the +right to modify and supplement the foregoing list and to identify and call as witnesses +additional persons if, during the course of discovery and investigation relating to this case, +JPMorgan learns that such additional persons have knowledge or information that JPMorgan +may use to support its claims or defenses. +Further, JPMorgan also reserves the right to call as witnesses individuals in addition to +those identified herein to the extent such witnesses are required to authenticate an exhibit +offered into evidence or to establish chain of custody of an exhibit offered into evidence. +JPMorgan also may rely on expert witnesses, to be disclosed in accordance with Federal Rule of +Civil Procedure 26(a)(2) and the Civil Case Management Plan, Dkt. 16, to support its +claims or defenses. JPMorgan specifically reserves the right to call any deponent or declarant +in this action as a trial witness to testify regarding matters covered in his/her deposition or +declaration and/or to rely on any such testimony in support of its claims or defenses in this +case. JPMorgan further specifically reserves the right to call any individual(s) identified in the +Plaintiff's disclosures, including as amended. +- 6- + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 8 of 14 +II. CATEGORIES OF RELEVANT DOCUMENTS +At present, JPMorgan believes that the following documents, electronically stored +information, and tangible things may be used to support JPMorgan's claims or defenses, +unless such use is solely for impeachment. This disclosure does not include documents solely +within the Plaintiff's or the Third-Party Defendant's possession, custody, or control. This +disclosure does not include expert materials that may be or have been developed, which will +be disclosed pursuant to Federal Rule of Civil Procedure 26(a)(2). This disclosure does not +constitute an admission as to the existence, relevance, or admissibility of the identified +materials or a waiver of any attorney- client privilege, work product protection, or other +applicable privilege or immunity. +1) Documents, communications, and electronically stored information relating to +JPMorgan's AML compliance program and other policies and practices. +2) Documents, communications, and electronically stored information relating +to Jeffrey Epstein's accounts and accounts related to Jeffrey Epstein at +JPMorgan. +3) Documents, communications, and electronically stored information relating +to James Staley's employment, compensation, and duties at JPMorgan, +including JPMorgan policies and codes of conduct. +4) Documents, communications, and electronically stored information relating +to James Staley's communications with or about Jeffrey Epstein. +JPMorgan will make the foregoing documents available for inspection or copying at a time and +place to be mutually agreed upon by the parties, subject to any applicable privacy or +other restrictions and to the extent they are non-privileged and in JPMorgan's possession, +custody, and control. JPMorgan has produced Mr. Staley's personnel file which includes Mr. +Staley's Code of Conduct affirmations and information regarding Mr. Staley's compensation, +- 7- + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 9 of 14 +and points Mr. Staley to the following documents in support of its claims: +JPM-SDNYLIT-00178143-JPM-SDNYLIT-00178494 +JPM-SDNYLIT-00202227-JPM-SDNYLIT-00204753 +JPM-SDNYLIT-00204821-JPM-SDNYLIT-00204836 +In addition to the above-described documents, JPMorgan expects that, during the +course of discovery, experts will identify documents used to support their opinions pertaining +to the issues in this case. +Further, JPMorgan may rely upon publicly available documents +and documents that have been identified in the initial disclosures of any other party or may be +obtained through discovery or are otherwise produced by the Plaintiff and/or third parties. +Because discovery, investigation, and analysis of these matters are ongoing, +JPMorgan expects to discover additional documents and/or tangible things upon which it may +rely to support its claims or defenses, including documents from the Third-Party Defendant. +JPMorgan therefore reserves the right to supplement this information accordingly. +Notwithstanding this identification of these categories of documents, JPMorgan reserves +the right to object to any of the Plaintiff's discovery requests on related topics to the extent such +requests are overly broad, unduly burdensome, and/or call for documents beyond the scope of +JPMorgan's discovery obligations under the Federal Rules of Civil Procedure or the Local +Rules, and/or any other applicable basis for objection. +III. +CALCULATION OF DAMAGES +Doe v. JPMorgan: +Not applicable. +JPMorgan v. Staley: +As stated in its Third-Party Complaint, JPMorgan seeks the following damages from +Staley: +1) All damages awarded to Plaintiff or any member of the purported class (together, +- 8- + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 10 of 14 +"Plaintiffs"), as discussed in Section C of Plaintiff's Initial Disclosures dated +December 22, 2022, and the amount JPMorgan will pay to the Plaintiffs to settle +this action, in the amount of $290,000,000.00. +2) Damages for breach of fiduciary duty, including the amount JPMorgan will pay to +the Plaintiffs to settle this action, in the amount of $290,000,000.00, and all costs of +defending the Jane Doe 1 v. JPMorgan Chase Bank, N.A. litigation.? +3) All compensation paid by JPMorgan to Staley from 2006 through 2013, which +JPMorgan has calculated at this time based on the documents it has produced +(see supra) to be approximately not less than $140,000,000.00. +4) Punitive damages in an amount to be determined at trial. +IV. +INSURANCE +Insurance agreements under which an insurance business may be liable to satisfy all +or part of a possible judgment in this action or to indemnify or reimburse for payments made +to satisfy any judgment in this action have been made available for inspection and copying +and can be found at the following +numbers: +2 JPMorgan is currently determining the damages it has suffered and will suffer as a result of this litigation and will +amend these disclosures when it has a reasonable calculation of those damages. +- 9 - + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 + +JPM-SDNYLIT-00762790 +JPM-SDNYLIT-00762803 +JPM-SDNYLIT-00762885 +JPM-SDNYLIT-00762920 +JPM-SDNYLIT-00762932 +JPM-SDNYLIT-00762944 +JPM-SDNYLIT-00762958 +JPM-SDNYLIT-00762974 +JPM-SDNYLIT-00763005 +JPM-SDNYLIT-00763064 +JPM-SDNYLIT-00763075 +JPM-SDNYLIT-00763086 +JPM-SDNYLIT-00763104 +JPM-SDNYLIT-00763127 +JPM-SDNYLIT-00763149 +JPM-SDNYLIT-00763184 +JPM-SDNYLIT-00763199 +JPM-SDNYLIT-00763222 +JPM-SDNYLIT-00763224 +JPM-SDNYLIT-00763225 +JPM-SDNYLIT-00763231 +JPM-SDNYLIT-00763244 +JPM-SDNYLIT-00763257 +JPM-SDNYLIT-00763288 +JPM-SDNYLIT-00763326 +JPM-SDNYLIT-00763337 +JPM-SDNYLIT-00763352 +JPM-SDNYLIT-00763353 +JPM-SDNYLIT-00763357 +JPM-SDNYLIT-00763373 +JPM-SDNYLIT-00763375 +JPM-SDNYLIT-00763388 +JPM-SDNYLIT-00763395 +JPM-SDNYLIT-00763408 +JPM-SDNYLIT-00763526 +JPM-SDNYLIT-00763564 +JPM-SDNYLIT-00763565 +JPM-SDNYLIT-00763566 +JPM-SDNYLIT-00763596 +JPM-SDNYLIT-00763599 +JPM-SDNYLIT-00763608 +JPM-SDNYLIT-00763615 +JPM-SDNYLIT-00763632 +JPM-SDNYLIT-00763652 +JPM-SDNYLIT-00763672 +JPM-SDNYLIT-00763693 +JPM-SDNYLIT-00763718 +JPM-SDNYLIT-00763729 +JPM-SDNYLIT-00763736 +JPM-SDNYLIT-00763749 +JPM-SDNYLIT-00763750 +JPM-SDNYLIT-00763751 +JPM-SDNYLIT-00763752 +JPM-SDNYLIT-00763782 +JPM-SDNYLIT-00763823 +JPM-SDNYLIT-00763942 +JPM-SDNYLIT-00763945 +JPM-SDNYLIT-00763970 +JPM-SDNYLIT-00763997 +JPM-SDNYLIT-00764006 +JPM-SDNYLIT-00764013 +JPM-SDNYLIT-00764043 +JPM-SDNYLIT-00764046 +JPM-SDNYLIT-00764063 +JPM-SDNYLIT-00764100 +JPM-SDNYLIT-00764101 +JPM-SDNYLIT-00764102 +JPM-SDNYLIT-00764103 +JPM-SDNYLIT-00764104 +JPM-SDNYLIT-00764105 +JPM-SDNYLIT-00764106 +JPM-SDNYLIT-00764133 +JPM-SDNYLIT-00764156 +JPM-SDNYLIT-00764188 +JPM-SDNYLIT-00764308 +JPM-SDNYLIT-00764332 +JPM-SDNYLIT-00764341 +JPM-SDNYLIT-00764366 +JPM-SDNYLIT-00764397 +JPM-SDNYLIT-00764414 +JPM-SDNYLIT-00764440 +JPM-SDNYLIT-00764443 +JPM-SDNYLIT-00764444 +JPM-SDNYLIT-00764451 +JPM-SDNYLIT-00764452 +JPM-SDNYLIT-00764453 +JPM-SDNYLIT-00764454 +JPM-SDNYLIT-00764455 +JPM-SDNYLIT-00764462 +JPM-SDNYLIT-00764463 +JPM-SDNYLIT-00764464 +JPM-SDNYLIT-00764465 +JPM-SDNYLIT-00764466 +JPM-SDNYLIT-00764467 +JPM-SDNYLIT-00764468 +JPM-SDNYLIT-00764470 +JPM-SDNYLIT-00764496 +JPM-SDNYLIT-00764511 +JPM-SDNYLIT-00764521 +JPM-SDNYLIT-00764536 +JPM-SDNYLIT-00764548 +JPM-SDNYLIT-00764561 +JPM-SDNYLIT-00764575 +JPM-SDNYLIT-00764582 +JPM-SDNYLIT-00764587 +JPM-SDNYLIT-00764593 +JPM-SDNYLIT-00764713 +JPM-SDNYLIT-00764832 +JPM-SDNYLIT-00764950 +JPM-SDNYLIT-00765068 +JPM-SDNYLIT-00765186 +JPM-SDNYLIT-00765305 +JPM-SDNYLIT-00765434 +JPM-SDNYLIT-00765587 +JPM-SDNYLIT-00765588 +JPM-SDNYLIT-00765721 +JPM-SDNYLIT-00765735 +JPM-SDNYLIT-00765864 +JPM-SDNYLIT-00765871 +JPM-SDNYLIT-00765876 +JPM-SDNYLIT-00765880 +JPM-SDNYLIT-00765886 +JPM-SDNYLIT-00766054 +JPM-SDNYLIT-00766187 +JPM-SDNYLIT-00766193 +JPM-SDNYLIT-00766336 +JPM-SDNYLIT-00766362 +JPM-SDNYLIT-00766379 +JPM-SDNYLIT-00766403 +JPM-SDNYLIT-00766410 +JPM-SDNYLIT-00766484 +JPM-SDNYLIT-00766569 +- 10 - + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 12 of 14 +JPM-SDNYLIT-00766574 +JPM-SDNYLIT-00766657 +JPM-SDNYLIT-00766798 +JPM-SDNYLIT-00766805 +JPM-SDNYLIT-00766857 +JPM-SDNYLIT-00766877 +JPM-SDNYLIT-00767011 +JPM-SDNYLIT-00767145 +JPM-SDNYLIT-00767281 +JPM-SDNYLIT-00767424 +JPM-SDNYLIT-00767446 +JPM-SDNYLIT-00767464 +JPM-SDNYLIT-00767472 +JPM-SDNYLIT-00767486 +JPM-SDNYLIT-00767508 +JPM-SDNYLIT-00767597 +JPM-SDNYLIT-00767621 +JPM-SDNYLIT-00767626 +JPM-SDNYLIT-00767686 +JPM-SDNYLIT-00767844 +JPM-SDNYLIT-00767963 +JPM-SDNYLIT-00768057 +JPM-SDNYLIT-00768136 +JPM-SDNYLIT-00768203 +JPM-SDNYLIT-00768362 +JPM-SDNYLIT-00768503 +JPM-SDNYLIT-00768533 +JPM-SDNYLIT-00768648 +JPM-SDNYLIT-00768664 +JPM-SDNYLIT-00768690 +JPM-SDNYLIT-00768721 +JPM-SDNYLIT-00768744 +JPM-SDNYLIT-00768769 +JPM-SDNYLIT-00768793 +JPM-SDNYLIT-00768815 +JPM-SDNYLIT-00768842 +JPM-SDNYLIT-00768856 +JPM-SDNYLIT-00768868 +JPM-SDNYLIT-00768892 +JPM-SDNYLIT-00768963 +JPM-SDNYLIT-00769341 +JPM-SDNYLIT-00769423 +JPM-SDNYLIT-00769443 +JPM-SDNYLIT-00769474 +JPM-SDNYLIT-00769634 +JPM-SDNYLIT-00769750 +JPM-SDNYLIT-00769911 +JPM-SDNYLIT-00769946 +JPM-SDNYLIT-00770041 +JPM-SDNYLIT-00770190 +JPM-SDNYLIT-00770200 +JPM-SDNYLIT-00770348 +JPM-SDNYLIT-00770482 +JPM-SDNYLIT-00770502 +JPM-SDNYLIT-00770562 +JPM-SDNYLIT-00770662 +JPM-SDNYLIT-00770692 +JPM-SDNYLIT-00770725 +JPM-SDNYLIT-00770757 +JPM-SDNYLIT-00770782 +JPM-SDNYLIT-00770805 +JPM-SDNYLIT-00770827 +JPM-SDNYLIT-00771149 +JPM-SDNYLIT-00773075 +JPM-SDNYLIT-00773204 +JPM-SDNYLIT-00773207 +JPM-SDNYLIT-00773209 +JPM-SDNYLIT-00773215 +JPM-SDNYLIT-00773224 +JPM-SDNYLIT-00773240 +JPM-SDNYLIT-00773263 +JPM-SDNYLIT-00773275 +JPM-SDNYLIT-00773293 +JPM-SDNYLIT-00773318 +JPM-SDNYLIT-00773337 +JPM-SDNYLIT-00773340 +JPM-SDNYLIT-00773356 +JPM-SDNYLIT-00773476 +JPM-SDNYLIT-00773595 +JPM-SDNYLIT-00773713 +JPM-SDNYLIT-00773831 +JPM-SDNYLIT-00773949 +JPM-SDNYLIT-00774068 +JPM-SDNYLIT-00774204 +JPM-SDNYLIT-00774307 +JPM-SDNYLIT-00774461 +JPM-SDNYLIT-00774626 +JPM-SDNYLIT-00774909 +JPM-SDNYLIT-00774933 +JPM-SDNYLIT-00774953 +JPM-SDNYLIT-00774973 +JPM-SDNYLIT-00774992 +JPM-SDNYLIT-00775011 +JPM-SDNYLIT-00775041 +JPM-SDNYLIT-00775081 +JPM-SDNYLIT-00775111 +JPM-SDNYLIT-00775118 +JPM-SDNYLIT-00775137 +JPM-SDNYLIT-00775172 +JPM-SDNYLIT-00775187 +JPM-SDNYLIT-00775219 +JPM-SDNYLIT-00775248 +JPM-SDNYLIT-00775278 +JPM-SDNYLIT-00775304 +JPM-SDNYLIT-00775311 +JPM-SDNYLIT-00775338 +JPM-SDNYLIT-00775352 +JPM-SDNYLIT-00775376 +JPM-SDNYLIT-00775404 +JPM-SDNYLIT-00787742 +- 11- + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 13 of 14 +Dated: July 18, 2023 +Respectfully submitted, +MASSEY & GAIL LLP +Is/ Leonard A. Gail +Leonard A. Gail (pro hac vice) +Rachel Morse (pro hac vice) +50 East Washington Street, Suite 400 +Chicago, IL 60602 +(t) (312) 283-1590 +lgail@masseygail.com +rmorse@masseygail.com +WILMER CUTLER PICKERING +HALE AND DORR LLP +Is/ Felicia H. Ellsworth +Felicia H. Ellsworth +John J. Butts +60 State Street +Boston, +02109 +(t) (617) 526-6000 +(f (617) 526-5000 +felicia.ellsworth@wilmerhale.com +john.butts@wilmerhale.com +M. +HII +Robert L. Boone +7 World Trade Center +250 Greenwich Street +New York, NY 10007 +(1) (212) 230-8800 +(f (212) 230-8888 +robert.boone@wilmerhale.com +Ronald C. Machen +2100 Pennsylvania Avenue NW +Washington, DC 20037 +(1) (202) 663-6000 +(f) (202) 663-6363 +ronald.machen@wilmerhale.com +Attorneys for JPMorgan Chase Bank, N.A. + + +Case 1:22-cv-10904-JSR Document 326-55 Filed 09/08/23 Page 14 of 14 +CERTIFICATE OF SERVICE +I hereby certify that on July 18, 2023, the foregoing document, entitled "JPMorgan +Chase Bank, N.A.'s Fourth Supplemental Initial Disclosures," was served in accordance with +the Federal Rules of Civil Procedure and/or the Local Rules of the United States District Court +for the Southern District of New York upon the attorneys for the Plaintiff and the Third-Party +Defendant in the above-entitled action by electronic mail. +DATED: +July 18, 2023 +Boston, +By: Is/ Felicia H. Ellsworth diff --git a/vision-fixhub/court-05/54b4dc02f35fe82cb9a7dcd9bc050ef69316d24551e4e5f49d43cdb33e0c89bf.receipt.json b/vision-fixhub/court-05/54b4dc02f35fe82cb9a7dcd9bc050ef69316d24551e4e5f49d43cdb33e0c89bf.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7ff745c94f0ea1983419f965407550f44a38d95a --- /dev/null +++ b/vision-fixhub/court-05/54b4dc02f35fe82cb9a7dcd9bc050ef69316d24551e4e5f49d43cdb33e0c89bf.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -191, + "dataset": "marble-joined", + "doc_id": "54b4dc02f35fe82cb9a7dcd9bc050ef69316d24551e4e5f49d43cdb33e0c89bf", + "engine": "marble-apple-vision", + "event_count": 16, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "aac99bd57be3c948664c565d6aa1610bd4b6050f42413fd0dba23beaf3b9502f", + "output_sha256": "f330c095a8f976b1320683fd463e639dbedf78a18eed52cf95858c62d61e63c1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/54c8c25c027d89c533d58f21876eb825d0c9858331bcc753e41991cb7436e7ee.md b/vision-fixhub/court-05/54c8c25c027d89c533d58f21876eb825d0c9858331bcc753e41991cb7436e7ee.md new file mode 100644 index 0000000000000000000000000000000000000000..9cfd86df3149284a0692e1affcb84d23ea79d379 --- /dev/null +++ b/vision-fixhub/court-05/54c8c25c027d89c533d58f21876eb825d0c9858331bcc753e41991cb7436e7ee.md @@ -0,0 +1,153 @@ +Case 1:22-cv-10904-JSR Document 237-6 Filed 07/25/23 Page 1 of 6 + + + +Case 1:22-cv-10904#d$RsteD 06ament:237+6. stiled 67/25/28 NRage Bat 6 +The New Work Cimes +https://www.nytimes.com/2019/08/10/nyregion/jeffrey-epstein-suicide.html +Jeffrey Epstein Dead in Suicide at Jail, Spurring Inquiries +Mr. Epstein, the financier accused of sex trafficking, was not under suicide watch at the Manhattan jail at the time of his death. +By William K. Rashbaum, +Weiser and Michael Gold +Aug. 10, 2019 +(The latest: Mr. Epstein was left alone and not closely monitored before his suicide.] +Jeffrey Epstein, the financier who was long dogged by accusations of sexual abuse of girls and who was able to cultivate an array of high-profile friends despite his lurid lifestyle, killed +himself in his Manhattan jail cell, officials said on Saturday. +Mr. Epstein's death quickly reverberated from New York to Washington to Florida, spurring federal inquiries into why he was not being more closely monitored and angering his +accusers, who said they had hoped to have his crimes aired in open court. +Mr. Epstein hanged himself, and was found at around 6:30 a.m. Saturday at the Metropolitan Correctional Center, officials said. +Last month, after being denied bail on federal sex trafficking charges, Mr. Epstein was found unconscious in his jail cell with marks on his neck. Prison officials had been investigating +the incident as a possible suicide attempt. +Mr. Epstein was placed on suicide watch after the incident on July 23 and received a daily psychiatric evaluation, according to a person familiar with his detention. He was removed +from suicide watch on July 29 and returned to the special housing unit, a segregated area of the prison with extra security, this person said. +The authorities did not immediately explain why he was taken off suicide watch. The F.B.I. said it was investigating, and Attorney General William P. Barr said in a statement that a +special inquiry would be opened into what happened. +"I was appalled to learn that Jeffrey Epstein was found dead early this morning from an apparent suicide while in federal custody," Mr. Barr said. "Mr. Epstein's death raises serious +questions that must be answered." +In addition to the F.B.I., the Inspector General, the Justice Department's internal watchdog, will open an investigation into Mr. Epstein's death, Mr. Barr said. The Metropolitan +Correctional Center is run by the federal Bureau of Prisons. +[Read more: Why wasn't Mr. Epstein on suicide watch when he died?] +Federal prosecutors in Manhattan last month charged Mr. Epstein, 66, with sex trafficking of girls as young as 14 and sex trafficking conspiracy. The indictment renewed attention on +how Mr. Epstein - who had opulent homes, a private jet and access to elite circles — had escaped severe punishment in an earlier investigation of sexual abuse more than a decade +ago in Florida. +He had avoided federal criminal charges in 2008 after prosecutors brokered a widely criticized deal that allowed him to plead guilty to state charges of solicitation of prostitution from a +minor and serve 13 months in jail. Even while in custody, Mr. Epstein was able to leave the jail for 12 hours a day, six days a week, to work at his office in Florida. +The new federal indictment also focused scrutiny on luminaries in government, politics, business, academia, science and fashion with whom Mr. Epstein had associated over the years, +including Donald J. Trump, Bill Clinton, Prince Andrew of Britain and the retail billionaire Leslie H. Wexner. +https://www.nytimes.com/2019/08/10/nyregion/jeffrey-epstein-suicide.html +1/5 + + +Case 1:22-cv-10904fSRosteD DEamenti23T+6, Spied 60425/28 nBage Bret 6 +The Southern District of New York announced charges against Jeffrey Epstein last month. +Jefferson Siegel for The New York Times +Mr. Epstein's defense team — the lawyers Reid Weingarten, Marty Weinberg and Michael/ +- declined to comment on the circumstances of death. "We are enormously sorry to +learn of today's news. No one should die in jail," they said in a statement. +A fourth member of Mr. Epstein's legal team, Marc Fernich, blamed a host of actors — from prosecutors to victims' lawyers to the media — for bearing "some responsibility for this +calamity:" +Mr. Epstein's suicide derailed a prosecution that his accusers had hoped would finally show how he had been allowed to commit what they said was a string of depraved crimes for so +many years — and what role his wealth, privilege and connections played. +, who said she had been raped by Mr. Epstein after being recruited into his circle in 2001 outside her Manhattan high school, said she was angry that he would not have +to face his accusers in court. +"We have to live with the scars of his actions for the rest of our lives, while he will never face the consequences of the crimes he committed — the pain and trauma he caused so many +people, +said. She said she hoped investigators would pursue charges against people who had aided and protected Mr. Epstein. +[Read more: Mr. Epstein's accusers called for investigators to continue an inquiry into his confidants.] +The United States attorney in Manhattan, Geoffrey S. Berman, said in a statement that the investigation into Mr. Epstein's misconduct would continue, pointing specifically to the +conspiracy charge, which suggested Mr. Epstein was assisted by others who helped facilitate his illegal acts. +"Today's events are disturbing, and we are deeply aware of their potential to present yet another hurdle to giving Epstein's many victims their day in court," Mr. Berman said. +The apparent demise of the new federal prosecution also led to widespread airing of unfounded conspiracy theories online on Saturday, with people questioning who would benefit from +Mr. Epstein's death. President Trump, who has a history of promoting unfounded conspiracy theories, retweeted one of those posts without comment, fueling the +speculation. +Until last year, it seemed that Mr. Epstein had largely been able to avoid further scandal over his dealings with young women and girls. +But then new questions were raised about the earlier plea agreement in an investigative report published by The Miami Herald in November 2018 which quoted four of Mr. Epstein's +victims, who are now adults, on the record for the first time. +In February, the Justice Department said it had opened an investigation into the nonprosecution agreement. The inquiry is reviewing whether prosecutors committed professional +misconduct in their handling of the earlier Epstein case. +At the same time, federal prosecutors in Manhattan, apparently spurred by The Miami Herald investigation, opened their own inquiry into accusations of sex trafficking by Mr. +Epstein. +https://www.nytimes.com/2019/08/10/nyregion/jeffrey-epstein-suicide.html +2/5 + + +Case 1:22-cv-10904кđ$RsteD 0€amenti237+6. stiled 67/25/28e NRage Anal 6 +The United States attorney in Florida who handled the 2008 case was R. Alexander Acosta, who was President Trump's labor secretary, After the new charges were announced against +Mr. Epstein in July, Mr. Acosta's work on the earlier case came under intense criticism, and he resigned. +(Read more: How Mr. Epstein become a symbol of wealth, privilege and depravity.] +Mr. Epstein was arrested on July 6 at Teterboro Airport in New Jersey after his private plane landed on a flight from Paris. +He was accused of hiring dozens of girls as young as 14 to perform nude massages on him, at which point he would masturbate and touch their genitals with his hands or with sex toys. +The abuse was said to have occurred at both his Upper East Side mansion and his palatial waterfront home in Palm Beach, Fla., between 2002 and 2005. +The girls were paid hundreds of dollars in cash for the encounters and, once recruited, were asked to return to his homes several times, where they were abused again, the indictment +against him said. +Prosecutors said Mr. Epstein asked some of the girls to recruit other girls, creating a network of vulnerable victims. +He pleaded not guilty to the charges. If convicted, he would have faced up to 45 years in prison. +Mr. Epstein had initially sought home detention at his Upper East Side mansion while he awaited trial. His lawyers had proposed allowing Mr. Epstein to post a substantial bond and +stay in his luxurious seven-story townhouse, watched by 24-hour security guards, at his expense. +But a federal judge denied the request, concluding that Mr. Epstein was a flight risk and citing his "vast wealth," which prosecutors have placed at more than $500 million. +Mr. Epstein's body was found at around 6:30 Saturday morning at the Metropolitan +Correctional Center, officials said. Yana Paskova for The New York Times +Mr. Epstein's younger brother, Mark, was his "only living immediate family member," according to a memo filed in federal court last month by Mr. Epstein's lawyers. The memo +described the pair as close. +Mr. Epstein, a former money manager with Wall Street experience, had long depicted himself as a wealthy financier with stellar investment savvy. +In addition to his homes in Florida and New York, he owned a private island in the United States Virgin Islands, a massive ranch in New Mexico and a residence in Paris. He had +numerous luxury vehicles and access to private planes and helicopters. +Even after he served time in a Florida jail and became a registered sex offender, Mr. Epstein successfully maintained a reputation as a billionaire investor and philanthropist. +https://www.nytimes.com/2019/08/10/nyregion/jeffrey-epstein-suicide.html +3/5 + + +Case 1:22-cv-10904кđ$RsteD 0€ameati237+6, stiled 67/25/28e NBage 5nat 6 +Still, since Mr. Epstein's arrest last month, evidence has emerged that the former money manager's business acumen was more myth than fact. His client list was not as extensive as +believed, and the services he offered were less remarkable than once portrayed. +Earlier this week, perhaps Mr. Epstein's most notable client, Mr. Wexner, the retail executive behind Victoria's Secret and Bath & Body Works, accused Mr. Epstein of misappropriating +"vast sums of money" from him and his family. +After Mr. Epstein's arrest in July, some Wall Street titans found themselves forced to answer questions as to why they had continued to socialize or do business with him after his 2008 +conviction. They included the private equity billionaire | +Black, the longtime banking executive Jes Staley and the hedge fund manager Glenn +The executives all said they had no knowledge he had engaged in sex trafficking, and had sought to minimize their contacts with Mr. Epstein in recent years. +Also drawing attention were a number of major universities — including Harvard University and the Massachusetts Institute of Technology - that had accepted large contributions +from foundations established by Mr. Epstein even after his 2008 conviction. +The contributions to the universities and to scientists at those schools were part of a campaign by Mr. Epstein to polish his image and get himself back into the good graces of the +academic and corporate elite. +But even as Mr. Epstein was trying to rebrand himself, he continued to peddle dubious ideas. +A number of scientists said he had showed an interest in biogenetic engineering and had discussed a plan to seed the human race with his DNA by having young women impregnated +at his Zorro Ranch in New Mexico. +There is no indication that Mr. Epstein ever took steps toward carrying out those plans, but some in the scientific world continued to meet with him and take his money. +Long before he generated the riches that facilitated those interactions, Mr. Epstein came from modest beginnings. He was born in Brooklyn in 1953 and grew up in Coney Island; his +father worked for the city +Department. +Mr. Epstein was something of a prodigy, playing the piano at 5, skipping two grades in school and graduating from Lafayette High School in Brooklyn when he was 16. +Though Mr. Epstein took college classes, he never received a degree. Instead, he landed a job as a math and physics teacher at the Dalton School, an elite private school in Manhattan +in 1974. His time there was brief, but some students recalled that Mr. Epstein was willing to violate norms in his encounters with girls. +An administrator told The Times that he was dismissed from Dalton for poor performance. +But it was through Dalton, a prestigious school with well-heeled parents and alumni, that Mr. Epstein came into closer contact with New York's rich and powerful. After leaving the +school, he eventually took a job at the Wall Street investment bank Bear Stearns. +In 1981, Mr. Epstein left Bear Stearns to start his own advisory firm and in 1988, he formed J. Epstein & Company, the investment firm that would help him build his network of +connections to wealthy Wall Street executives. +The exact details of Mr. Epstein's money management operation were shrouded in secrecy, as was his client list. +Mr. Epstein claimed to be handling finances for a number of billionaires, but his only prominent known investor was Mr. Wexner. +In 1991, Mr. Wexner gave Mr. Epstein unfettered authority to handle his personal fortune for roughly 16 years. That enabled Mr. Epstein to become hugely wealthy himself and supplied +him with the Wall Street bona fides he needed to seek business from other executives. +Along the way, Mr. Epstein would acquire a mansion on Manhattan's Upper East Side that had once belonged to Mr. Wexner, as well as a Boeing 727 jet from Mr. Wexner's company. +The money he made working for Mr. Wexner enabled Mr. Epstein to buy his own island in the United States Virgin Islands, where he relocated much of his financial advisory business +in 1999. +https://www.nytimes.com/2019/08/10/nyregion/jeffrey-epstein-suicide.html +4/5 + + +Case 1:22-cv-1090AfASRsteD DEamentiZaT+, spled 625/28 nBage fret 6 +Mr. Wexner, now 81, has said he had severed all ties to Mr. Epstein in late 2007. Just this week, he wrote in a letter to his charitable foundation that he had learned that year that Mr. +Epstein had misappropriated vast sums from him. +But Mr. Wexner apparently never notified authorities of the suspected misappropriation — even though Mr. Epstein was, at the time, being investigated in Florida for engaging in sex +with underage girls. +Katie Benner, Matthew +Daniel E. Slotnik and Emily Steel contributed reporting. +William K. Rashbaum is a senior writer on the Metro desk, where he covers political and municipal corruption, courts, terrorism and broader law enforcement topics. He was a part of the team awarded the 2009 Pulitzer Prize for +breaking news. More about William K. Rashbaum +Weiser is a reporter covering the Manhattan federal courts. He has long covered criminal justice, both as a beat and investigative reporter. Before joining The Times in 1997, he worked at The Washington Post. More about +Weiser +Michael Gold is a general assignment reporter on the Metro desk covering news in the New York City region. More about Michael Gold +A version of this article appears in print on, Section A, Page 1 of the New York edition with the headline: Epstein Is Dead; Found in His Cell In New York Jail +https://www.nytimes.com/2019/08/10/nyregion/jeffrey-epstein-suicide.html +5/5 \ No newline at end of file diff --git a/vision-fixhub/court-05/54c8c25c027d89c533d58f21876eb825d0c9858331bcc753e41991cb7436e7ee.receipt.json b/vision-fixhub/court-05/54c8c25c027d89c533d58f21876eb825d0c9858331bcc753e41991cb7436e7ee.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5592209c0c48bbe293bf9bee3c4360e1325cb630 --- /dev/null +++ b/vision-fixhub/court-05/54c8c25c027d89c533d58f21876eb825d0c9858331bcc753e41991cb7436e7ee.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -167, + "dataset": "marble-joined", + "doc_id": "54c8c25c027d89c533d58f21876eb825d0c9858331bcc753e41991cb7436e7ee", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "61c62648fde55c8fe95eb706bc1f9c3f951b22845c3dfa3a965ffba343bc9d65", + "output_sha256": "64af63576543ce651fe1b18c73186ee13cf1fe9177cde7ceaa2355fd84742d9e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/54cb4e661b1908a23ab93f44727181e30e1d18d8f4c073ce7ce2429297a1461a.md b/vision-fixhub/court-05/54cb4e661b1908a23ab93f44727181e30e1d18d8f4c073ce7ce2429297a1461a.md new file mode 100644 index 0000000000000000000000000000000000000000..8e91bd8f056ec09bf3a597e2b726e199d0ee940b --- /dev/null +++ b/vision-fixhub/court-05/54cb4e661b1908a23ab93f44727181e30e1d18d8f4c073ce7ce2429297a1461a.md @@ -0,0 +1,618 @@ +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 1 of 10 + + + +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 2 of 10 +GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential +Gov. U.S. Virgin Islands vs JPMorgan Chase +July 07, 2023 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +CASE NO. 22-CV-10904 +GOVERNMENT OF THE UNITED STATES V.I., +Plaintiff, +VS. +JPMORGAN CHASE BANK, N.A., +Defendant. +----X +***CONFIDENTIAL*** +July 7, 2023 +Confidential Remote Video-Recorded +30 (b) (6) Deposition of +GVI BY JEAN-PIERRE ORIOL +Stenographically Reported By: +Mark Richman, CSR, CCR, RPR, CM +Job No. J9913116 +→ ESQUIRE +DEPOSITION SOLUTIONS + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 3 of 10 +GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential +Gov. U.S. Virgin Islands vs JPMorgan Chase +JP ORIOL - 7.7.23 - CONFIDENTIAL +July 07, 2023 +11 +page. +MR. ACKERMAN: Okay. +A. +No, nothing privileged. +Q. Okay. Could you read in that +half page of notes, just read it aloud, +please. +A. +01:13 +Sure. +The -- +MR. ACKERMAN: +Objection. You +can go ahead. +A. +Lieutenant +-Ann Cannonier, +she's currently the director of +investigations for VIPD for the last two +and a half years. She's been with the +VIPD for 26 years. If the complaint was +lodged with VIPD a case number would +have been developed and generated. VIPD +asserts that there have been +• no +complaints made. +And then for me, what my +understanding of this proceeding is, is +that I'm prepared to answer questions on +investigations and investigation +monitoring steps. +e. +Is that all the notes? +→ ESQUIRE +DEPOSITION SOLUTIONS +01:13 +01:13 +01:14 +01:14 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 4 of 10 +GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential +Gov. U.S. Virgin Islands vs JPMorgan Chase +July 07, 2023 +14 +JP ORIOL - 7.7.23 - CONFIDENTIAL +after the Easter season when there's +camping and there's people still living +in tents and coordinating with them +trying to move people off of the beaches +and such. +That's one example. +How regular is your contact with +the VIPD? +MR. ACKERMAN: Objection to form. +A. +Not regular at all. +e. +Have you gathered information +through your contact with VIPD that is +relevant in any way to this suit? +MR. ACKERMAN: Objection to form. +A. +I don't understand the question. +e. +So my question is you've done +some amount to prepare for this +testimony, for your testimony today by +talking to VIPD. Setting that aside, as +part of your regular work for DPNR, have +you gathered any information from VIPD +that is responsive to the topic you're +designated on today? +MR. ACKERMAN: +Objection to form. +→ ESQUIRE +DEPOSITION SOLUTIONS +01:16 +01:16 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 5 of 10 +GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential +Gov. U.S. Virgin Islands vs JPMorgan Chase +July 07, 2023 +15 +JP ORIOL - 7.7.23 - CONFIDENTIAL +A. +0. +I would say yes. +What sort of information? +A. +Well, we in preparation for today +asked them if they had any knowledge or +any information about any complaint +being made with respect to Mr. Epstein, +you know, from the, from either of the +islands, and the answer was no. +Q. +Okay. And aside from that +interview that you've done, have you +ever learned of any information from +VIPD that has to do with Epstein? +A. +No. +e. +A. +e. +A. +MR. ACKERMAN: Objection to form. +Have you been deposed before? +Yes. +And was that in this case? +One of them. +How many other depositions have +there been? +A. +e. +A. +Six or seven. +Can you describe them generally? +Similar to now, asking questions, +me answering yes, no, all of them +& ESQUIRE +DEPOSITION SOLUTIONS +01:18 +01:18 +01:18 +01:19 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 6 of 10 +GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential +Gov. U.S. Virgin Islands vs JPMorgan Chase +July 07, 2023 +21 +JP ORIOL - 7.7.23 - CONFIDENTIAL +A. +No. +What else did you ask her? +A. +We +asked if -- about any records, +any requests that were made about any +investigations. She indicated that she +had spoken +to the prior staff in the +office. +They were looking for if any +complaints were made and she did not +come across any complaints having been +filed for them to initiate an +investigation. +What else did you ask her? +A. +How long she had been in the +position, how long she had been with the +VIPD. +l. +What were the answers to each of +those questions? +A. +Again, she had been in the -- in +the division as the director for the +last two and a half years. She had been +with the VIPD now 26 years. And then we +asked about the process for if like what +typically happens when somebody reaches +out or files a complaint. So she +→ ESQUIRE +DEPOSITION SOLUTIONS +01:25 +01:25 +01:25 +01:25 +01:26 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 7 of 10 +GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential +Gov. U.S. Virgin Islands vs JPMorgan Chase +JP ORIOL - 7.7.23 - CONFIDENTIAL +indicated that the VIPD would, in +opening up an investigation from a +complaint, it's assigned a case number +and then there would be follow-up +investigations. +But that in her research, that +there had not been any complaint filed, +and therefore there was no, there was no +case number generated or anything of +that nature to suggest that there was +any investigation. +What other questions did you ask +July 07, 2023 +22 +01:26 +01:26 +her? +A. +That was really it. +e. +Beyond your conversation with +Lieutenant Cannonier, did you speak with +anyone else to prepare to testify on +this topic today? +A. +Only my attorneys. +e. +And what -- how often did you +meet with them? +A. +For this second deposition? +Once. +01:26 +01:27 +For how long? +→ ESQUIRE +DEPOSITION SOLUTIONS +01:27 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 8 of 10 +GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential +Gov. U.S. Virgin Islands vs JPMorgan Chase +July 07, 2023 +28 +JP ORIOL - 7.7.23 - CONFIDENTIAL +And no, during that 20 year span, +no complaints +were +received regarding +Epstein, correct? +A. +That's correct. +Beyond formal complaints, do you +know +if there were any interactions +between VIPD and Epstein during that +20-year period? +MR. ACKERMAN: +Objection. +A. +No -- +MR. ACKERMAN: Hold on, +Commissioner, let me just get my +objections in. Objection, scope, +form. Go ahead. +A. +No, I do not. +e. +Do you know if VIPD had any +interaction with Epstein's companies? +MR. ACKERMAN: Objection, scope, +form. +A. +No, I do not. +Let's pull up tab 40 and enter it +as exhibit 1. +(Exhibit 1, document produced to +JPMorgan by the USVI titled 2010 +2 ESQUIRE +DEPOSITION SOLUTIONS +01:32 +01:32 +01:32 +01:33 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 9 of 10 +GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential +Gov. U.S. Virgin Islands vs JPMorgan Chase +July 07, 2023 +51 +JP ORIOL - 7.7.23 - CONFIDENTIAL +VI-JPM-000079601 was marked for +identification.) +A. +Okay. +This is an email chain that +starts with a July 16, 2019 email from a +Curt +of CNN.com and it asks +certain questions of the VI Police +Department including "Has US Virgin +Islands Police Department participated +in lor been asked to participate in) any +investigation related to Mr. Jeffrey +Epstein?" +Do you see that? +A. +Yes. +e. +Do you know what the answer to +that question is? +A. +Has the US Virgin Islands Police +Department received any complaints? So, +again, from what was reported to me, +that there were no complaints. +Sorry, I was focused on the +second question which is has US Virgin +Islands police participated in or been +asked to participate in any +→ ESQUIRE +DEPOSITION SOLUTIONS +02:03 +02:03 +02:03 +02:03 +02:04 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 270-2 Filed 08/07/23 Page 10 of 10 +GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential +Gov. U.S. Virgin Islands vs JPMorgan Chase +July 07, 2023 +53 +JP ORIOL - 7.7.23 - CONFIDENTIAL +e. +So this is a response by Glenn +Dratte to the CNN reporter and he's +reporting, "I did a complete check with +the VIPD criminal investigations bureau +and no complaints has been filed against +MI. +Jeffrey Epstein with the Virgin +Islands Police Department. +If there's +anything further I can assist please +reach out to my office." +Do you see that? +A. +Yes. +So that is the answer as of July +18, 2019. +Do you know if subsequent to that +date there was any investigation? +MR. ACKERMAN: Objection, scope, +form. +A. +No, I do not know. Or at least +what was reported to me was that there +was no investigation. +There is no case +number that has been assigned with +anything related to Mr. Epstein, so -- +And that's -- that's -- +A. +So I would say no. +& ESQUIRE +DEPOSITION SOLUTIONS +02:06 +02:06 +02:06 +02:06 +02:07 \ No newline at end of file diff --git a/vision-fixhub/court-05/54cb4e661b1908a23ab93f44727181e30e1d18d8f4c073ce7ce2429297a1461a.receipt.json b/vision-fixhub/court-05/54cb4e661b1908a23ab93f44727181e30e1d18d8f4c073ce7ce2429297a1461a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b42eb184af1db21e9eac8b9f9154a9d15d407fc3 --- /dev/null +++ b/vision-fixhub/court-05/54cb4e661b1908a23ab93f44727181e30e1d18d8f4c073ce7ce2429297a1461a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -523, + "dataset": "marble-joined", + "doc_id": "54cb4e661b1908a23ab93f44727181e30e1d18d8f4c073ce7ce2429297a1461a", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "271aae658f5931ba80ac3348ac7620f3074ce25a9743a8643f187d09b2dd4299", + "output_sha256": "51a2da36319914c4ba251e4d0b55a9439e7919726f9edfcf45591f3a5f38437b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/550caf3f392ce646e874adeb69fc8ddb5c839b57a3da17e1b9997ad8e8807376.md b/vision-fixhub/court-05/550caf3f392ce646e874adeb69fc8ddb5c839b57a3da17e1b9997ad8e8807376.md new file mode 100644 index 0000000000000000000000000000000000000000..62d7376b7a75127044e3089830bf4f0a1d268c6f --- /dev/null +++ b/vision-fixhub/court-05/550caf3f392ce646e874adeb69fc8ddb5c839b57a3da17e1b9997ad8e8807376.md @@ -0,0 +1,1618 @@ +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 1 of 61 +ATTACHMENT B +PART 2 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 2 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +132. On October 25, 2007, +emails Mary +subject: "Re: Jeffrey +Epstein new LOC" and states in response 1o | +request to open a new line of credit for +Epstein: "we do still have an existing SIMM LC that we issued a few years ago... supporting the +Modeling Agency's loan to Mellon." Ex. 102 at -962-63. +JPMC Response: Disputed to the extent USVI misstates the document. The quoted +language states "we do still have an existing SIMM LC that we issued a few years ago.. +• supporting the Modelling Agency's loan to Mellon." USVI Ex. 102 at -962-63. +Disputed that the cited document establishes that Mary! +_ was requesting a new line +of credit for Epstein. In the cited document, it is clear | +is passing along the request +from Richard Kahn at Jeffrey Epstein's office and asking for advice on how to proceed. +USVI Ex. 102 at -962-63. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +133. +JPMC Response: Undisputed that the cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +134. In a July 31, 2010 email, Erdoes tells Staley, describing a July 31, 2010 NY Post article: +"The feds many not be quite done with (JE). Having just completed 13 months in a fl jail for +solicing/sic] prost [sic] from a minor, he now might be under investig [sic] for other possible +61 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 3 of 61 +crimes, inclduing [sic] whether there's any evidence of child trafficking. E has settled several +lawsuits by teens who say they were lured to his palm beach mansion for massages or sx [sic]. +The us AG in fl wouldn't comment. E's lawyer, jack goldberger, says he know nothing of any +probe, and they are not and should not be any pending criminal investigations. '' Ex. 104 at -251. +JPMC Response: Undisputed that the cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 19 +135. The July 31, 2010 NY Post article "Jeffrey Epstein may face child trafficking probe" states: +The Feds may not be quite done with Jeffrey Epstein. Having just +completed 13 months in a Florida jail for soliciting prostitution from +a minor, he now might be under investigation for other possible +crimes, including whether there's any evidence of child trafficking, +reports The Daily Beast. Epstein has settled several lawsuits by +teens who say they were lured to his Palm Beach mansion for +massages or sex. The US attorney general in Florida wouldn't +comment. Epstein's lawyer, Jack Goldberger, says he knew nothing +of any probe and, "There are not and should not be any pending +criminal investigations." +Ex. 90 at - 814. +JPMC Response: Disputed to the extent USVI misstates the document, the NY Post +article is titled "Epstein Probe". See USVI Ex. 90 at -814. Otherwise undisputed that the +cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +1-107. Further contended that the cited material cannot be presented at trial in admissible +form. +136. The July 29, 2010 Daily Beast article cited in the NY Post article states: "The Justice +Department is investigating Jeffrey Epstein for child trafficking ... and has widened the scope of +its probe to include a famous modeling agency. " "Federal investigators continue to investigate +Epstein's activities, to see whether there is evidence of child trafficking—a far more serious charge +62 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 4 of 61 +than the two in his non-prosecution agreement, the arrangement between Epstein and the +Department of Justice allowing him to plead guilty to lower level state crimes. Trafficking can +carry a 20-vear sentence." "The FBI is also investigating Epstein's friend Jean Luc Brunel, whose +MC2 modeling agency appears to have been a source of girls from overseas who ended up on +Epstein's private jets. " Ex. 105 at -902-903. +JPMC Response: Undisputed that the cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +1-107. Further contended that the cited material cannot be presented at trial in admissible +137. JPMorgan admits that in 2010, certain of its employees received, reviewed, or read a +Newstex Web Blog, Jezebel, article ("2010 Newstex article") identifying "MC2" as "the modeling +agency owned by Jean Luc Brunel. " Ex. 39 at Resp. 70. +JPMC Response: Undisputed that, in 2010, certain JPMC employees received. +reviewed, or read a Newstex Web Blog, Jezebel, article identifying "MC2" as "the +modeling agency owned by Jean Lue Brunel." +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11| +138. The 2010 Newstex article states: +"Jeffrey Epstein, the billionaire financier who the FBI believes molested around 40 +underaged girls" Ex. 106 at 596. +Buying a 14-year old Yugoslavian girl named +from her parents in +order to keep her as his "sex slave" Id. +C. +Paying women to bring him "economically desperate" teenagers to give him +massages "that often led to sexual contact" Id. +d. +Receiving two 12-year old +girls as a "birthday present" Id. +63 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 5 of 61 +e. +Flagging Epstein's relationship with Jean Luc Brunel, owner of MC2 Modeling, +and that Epstein, Maxwell, Brunel, Alfredo Rodriguez, and +used the +agency to "lure minor children ... mostly girls under the age of 17... to engage +in sexual play for money " Id. +f. References that the FBI is investigating MC2 and Brunel for "possibly engaging in +child sex trafficking" Id. +Mentions Epstein's plea of soliciting sex with a minor and settling a dozen civil +lawsuits from victims Id. +"These same civil complaints allege that young girls from South America, Europe, +and the former Soviet republics... were recruited for Epstein's sexual pleasure" +Id. +1. +"Brunel, along with numerous young models, was a frequent passenger on +Epstein's private jet, according to flight manifests" Id. +j. +"The agency owner also allegedly received S1 million from Epstein in 2005, when +he founded MC2 ... [but] denied any such payment from the billionaire pervert in +k. +2007, when rumors started swirling" Id. +"Whether the money was a secret investment in MC2, or a payment for Brunel's +service as a procurer, is unknown" Id. +JPMC Response: Disputed to the extent USVI misstates the cited document. The +sentence quoted in f 138(b) states, "buying a 14-year-old Yugoslavian named +from her parents in order to keep +as his "sex slave'[-]" USVI +Ex. 106 at -596. The sentence quoted in 9| 138(e) states, " luring minor children... +mostly girls under the age of 17... to engage in sexual play for money and the +sentence quoted in 9 138(k) states, "Whether the money was a secret investment in MC2, +or a payment for Brunel's services as a procurer, is unknown." See USVI Ex. 106 at - +596. Otherwise, undisputed that the cited document contains the quoted text. +64 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 6 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M1 +1-107. Further contended that the cited material cannot be presented at trial in admissible +form. +139. A DDR regarding Epstein approved by Morris (then banker), Sheridan (then overseeing +Morris); and Keating (then CEO U.S. Private Bank) stated: "As of 3/4/2011: Numerous articles +detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating +in child trafficking and molesting underage girls. Jeffrey Epstein is required to register as a sex +offender. Jeffrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding +solicitation for an undisclosed amount. MC2 Model Management received S1 million from Epstein +in 2005. It is unknown if the money was given as a secret investment or payment for services as a +procurer. Jean Luc Brunel, owner of MC2 Model Management and Jeffrey Epstein engaged in +racketeering that involved luring in minor children for sexual play for money. In addition, Brunel +was a frequent passenger on Epstein's private jet and often visited Epstein in jail. MC2 Model +Management was issued a citation by the Florida Business and Professional Regulation for acting +as a talent agent without a license. MC2 Model Management LLC has two outstanding federal +tax liens totaling $593,789 ($443,728 + $150,061)." Ex. 31 at -574. Global Security & +Investigations, Due Diligence Unit circulated "A Red Dot Memo for Jeffrey Epstein" containing +the same information that was circulated to Morris, +• Dalessio, and_ +, among others, in +early March 2011. Er. 107 at -499-500. +JPMC Response: Undisputed that Morris, Sheridan, and Keating approved the cited +DDR and that the cited DDR contains the quoted text. Undisputed that a Red Dot Memo +for Jeffrey Epstein was circulated to Morris, +1, Dalessio, and +, among others, +on March 7, 2011 containing the quoted language from the DDR. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +65 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 7 of 61 +140. +Ex. 9|| +206. +Id. 1206. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +1-107. Further contended that the cited material cannot be presented at trial in admissible +form. +141. JPMorgan's own due diligence process also required that it research and review civil and +other lawsuits that may be filed by or against clients. Ex. 32 at 42:20-24. +JPMC Response: Disputed. The cited testimony for this proposition does not support +the conclusion the JPMorgan's due diligence process required that employees research +and review civil lawsuits involving its clients. In response to questions about her +personal review of civil lawsuits that may be filed by or against a client, +. a JPMC +Private Banker and not a member of JPMC's compliance function, testified that "[t]hey +are included within the due diligence review." USVI Ex. 32 at 42:20-24. This testimony +relates only to L +understanding regarding the conducting of due diligence and does +not reflect an overall policy by JPMC to affirmatively require review of civil lawsuits. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 191 +142. In 2007, news reports stated Epstein was "bracing for a slew of lawsuits from as many as +40 young women who came to his Palm Beach mansion for massage sessions. " Ex. 63 at -652. +JPMC Response: Undisputed that the cited document, an October 15, 2007 article from +the New York Post's "Page Six" gossip column, contains the quoted text. +66 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 8 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +1-107. Further contended that the cited material cannot be presented at trial in admissible +form. +143. +Ex. 108 at -685. +USVI Ex. 108 at -685. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +144. +Ex. 109 at -686. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +145. The February 7, 2008 New York Post article stated that "the teen - identified only as 'Jane +Doe No. 2' - says she was lured to Epstein's Palm Beach mansion and then sexually assaulted in +his massage room .... He then paid her $200 ... " Ex. 110 at 1. The article further states: ".. +Jane Doe No. 1 ... says she was 14 when she went to Epstein's home to give him a massage and +wound up getting sexually assaulted by him" and that Epstein is "currently only facing criminal +charges related to Jane Doe No. 1." Id. at 1-2. +67 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 9 of 61 +JPMC Response: Disputed to the extent that USVI's citation for the quoted text in its +first quotation is only to page 1; the quoted text appears on pages 1 and 2. See USVI Ex. +110 at 1-2. Otherwise undisputed that the cited document contains the quoted language. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +1-107. Further contended that the cited material cannot be presented at trial in admissible +form. +146. On June 30, 2008, Epstein pled guilty to felony solicitation of prostitution and procurement +of a minor to engage in prostitution on June 30, 2008 and was "sentenced to 18 months in jail" +and "required to register as a sex offender. " Def. JPMorgan Chase Bank, N.A.'S Answer Second +Am. Compl. ("Answer") 1 38. +JPMC Response: Disputed to the extent the citation does not support the proposition +that Epstein plead guilty on June 30, 2008. Otherwise, undisputed. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 99 +147. +knew the victim was a 14-year-old girl. Ex. 109 at -686; Ex. 110 at 1-2. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 191 +68 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 10 of 61 +148. +Ex. 2 at -196; Ex. 3 at -523. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +149. In 2011, Langford commicated to Cutler "concern" about retaining Epstein as a client. +Cutler testified: "Those concerns are heightened, if you will, by the human trafficking initiative +that we're doing, given that he was convicted of these crimes. " Ex. 99 at 343:12-24. +JPMC Response: Disputed. In the cited testimony, Cutler testified that Langford +communicated to him "concern about the reputational issues". USVI Ex. 99 at 343:19- +21 (emphasis added). +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1l +150. +Ex. 55 at -475. +69 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 11 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +151. The August 5, 2008 AML Operations Human Trafficking Overview states that "nearly twothirds of the women trafficked for prostitution worldwide come from Eastern Europe" and "former +Eastern bloc countries such as Albania, Moldova, Romania, Bulgaria, Russia, Belarus and +Ukraine have been identified as major trafficking source countries for women and children." Ex. +44 at -053. +JPMC Response: Undisputed that the cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +152. In 2010, additional "news stories ... connects Jeffrey Epstein to human trafficking." Ex. +112 at - 262. +JPMC Response: Disputed to the extent USVI characterizes the news stories as +"additional". Undisputed that the cited document contains the quoted text and states that +these news stories appeared during 2010. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +153. On November 8, 2010, Dalessio emails Morris and | +with a ce to McCleerey, Subject: +Excerpt from recent articles. Dalessio writes: "See below new allegations of an investigation +related to child trafficking - are you still comfortable with this client who is now a registered sex +offender?'" Ex. 90 at-814. Dalessio attaches excerpts from four articles: +1. +The Palm Beach Post 8/1/10 "Epstein may be under new sex crime scrutiny +from feds": "Epstein... may be under investigation for other sex crimes, +including child trafficking ... According to the news website The Daily Beast, +70 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 12 of 61 +the feds are also checking whether a modeling agency run by a friend of the +Wall Street Investor Epstein fed his appetite for underage foreign girls. Epstein +was known to fly young women from Eastern Europe to Palm Beach, where +they'd massage him, among other services." Id. +2. NY Post 7/31/10 "Epstein Probe": "The Feds may not be quite done with +3. +4. +Jeffrey Epstein ... (HJe now might be under investigation for other possible +crimes, including whether there's any evidence of child trafficking, reports The +Daily Beast. Epstein has settled several lawsuits by teens who say they were +lured to his Palm Beach mansion for massages or sex. " Id. +Palm Beach Daily News 7/18/10 "House arrest nears home stretch for +Epstein": "Epstein has settled more than two dozen lawsuits and claims +against him by teenagers who say they were lured to his Palm Beach mansion +to give him sexually charged massages and/or sex in exchange for money ... A +secret deal with federal prosecutors revealed Epstein could have been charged +with multiple federal counts of sexual exploitation of minors, resulting in much +harsher penalties. But the feds deferred to two state charges that got him an +18-month sentence." Id. at -814-815. +Palm Beach Daily News 9/19/10 article "Woman sues Epstein for $50 M, +alleging abuse as teen": +"alleges repeated sexual abuse by Epstein" and +that "she was coerced into prostitution as a minor by Epstein, assisted by his +employee +alleges Epstein has transferred and is +transferring his assets overseas and elsewhere to conceal them from her and to +71 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 13 of 61 +prevent +from obtaining those assets in any judgment she may receive +against him." Id. at -815. +JPMC Response: Undisputed that Dalessio emailed Morris and | +, copying +McCleerey, on November 8, 2010, and the email contained the quoted language. +Disputed to the extent USVI misstates the document with respect to the inclusion of the +four article excerpts as attachments; the excerpts are copied into the body of McCleerey's +email. Otherwise, undisputed that the document contains the quoted excerpts of the listed +articles. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +1-107. Further contended that the cited material cannot be presented at trial in admissible +154. The JPMC Corporate AML Compliance Human Trafficking Finance: Nature, Scope and +Control Project, November 2010, states that one of the results achieved from the program was +that JPMorgan "Led effort to draw industry attention to human trafficking as an AML-related +issue" and notes multiple industry presentations given by JPMorgan related to human trafficking +issues and/or its human trafficking project findings. Ex. 71 at -975, -977-78. On December 21 +2010, Ryan writes to DeLuca : "My fear is will all our touting of good will on the HT work, if +anyone should ever say yet we bank Epstein, a known child sleaze. " DeLuca responds: "That is +what I was thinking when I read this. I'll call you." Ex. 113 at -018. +JPMC Response: Undisputed that the cited documents contain the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M1 +155. "HT" in Ryan's email refers to a project "within investigations related to human +trafficking and certain typology work that they were looking to dig through to identify human +trafficking." Ex. 36 at 56:14-57:6. +JPMC Response: Undisputed that Ryan testified that "the HT work" referred to in the +email cited as USVI Ex. 113 was "a project that was going on within investigations +72 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 14 of 61 +related to human trafficking and certain typology work that they were looking to dig +through to identify human trafficking." USVI Ex. 36 at 56:25-57:6. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +156. On December 22, 2010, DeLuca writes Langford again and states: "This will be raised to +the Rapid Response team (Catherine Keating) after the first of the year. McCleerey agrees this +customer should go. " Ex. 114 at -738. +JPMC Response: Undisputed that DeLuca emailed Langford on December 22, 2010 +and the cited email contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +157. On December 23, 2010, DeLuca writes Langford and states: "... I sent you an e-mail +yesterday on that scum Epstein. That looks good to. I reminded McCleerey that he listened to 2 +days of HT at the forum and this account could be problematic in several ways. " Langford +responds: "Good. Let me know if McCleerey waffles on Epstein. No patience for this. " Ex. 115 at +-777. +JPMC Response: Undisputed that DeLuca emailed Langford on December 23, 2010 +and the cited email contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +158. On January 4, 2011, Dalessio e-mails Morris, with a ce to | +1. and McCleerey, +Subject: Rapid Response meeting this Thursday, stating: "See attached draft document for the +Rapid Response meeting this Thursday (sic] We were asked by the firms AML Compliance +Director, William Langford, to re-evaluate our sponsorship of Epstein and request re-approval +from Steve Cutler if we wanted to retain. " Morris responds: "I thought we decided this was not +73 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 15 of 61 +necessary." Dalessio responds: "william langford requested that we responsor this client in light +of the new allegations of human trafficking which the firm has been actively assisting law +enforcement in uncovering others engaged in this practice." Ex. 116 at -967. +original email from Dalessio to Morris, copying +January 3, 2011. USVI Ex. 116 at -967. Otherwise, undisputed. +1. and McCleerey, is sent on +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +159. On January 5, 2011, Ryan wrote to DeLuca: "BTW, 4 tomorrow is the rapid response +meeting on Epstein, the sleazy PB client. " DeLuca responded the next day: "This is the guy who +likes young girls, correct? Hope they do not cave!"' Ex. 117 at -062; Ex. 36 at 68:11-69:18. +JPMC Response: Disputed to the extent USVI misstates the cited document. DeLuca's +response to Ryan's email on January 6, 2011 states, "This is the guy who likes young +girls, correct? Hope that they do not cave!!" USVI Ex. 117 at -062. Otherwise, +undisputed. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +160. By "sleazy PB client," Ryan was referring to the allegations against Epstein of sexual +misconduct with children. Ex. 36 at 68:11-19. +JPMC Response: Disputed. USVI mischaracterizes Ryan's testimony in which she +stated it was likely, but not definitive, that her use of "sleazy PB" client referred to the +allegations against Epstein of sexual misconduet with children. See USVI Ex. 36 at +68:11-15 (Q: When you say, the sleazy PB client, are you referring to the allegations of +sexual misconduct with children that you had referred to in a previous email? A: Likely, +yes.). +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +74 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 16 of 61 +161. On January 7, 2011, Ryan emails DeLuca, copying Middlemiss, writing, "Epstein was +released in July from house arrest and the Palm Beach Post carried two articles saying that DOJ +may be investigating for child trafficking via a modeling agency he is part owner in." Ex. 118 at +-066_R; Ex. 36 at 88:24-90:2. +JPMC Response: Disputed to the extent USVI misstates the cited document. The cited +text reads, "Epstein was released in July from house arrest and the Palm Beach Post +carried two articles saying DOJ may be investigating for child trafficking via a modeling +agency he is part owner in." USVI Ex. 118 at -066_R. Otherwise, undisputed. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +162. Ryan testified: "So, Phil was of the mindset, as was I, that (Epstein] had to go." Ex. 36 at +70:19-71:3. +JPMC Response: Undisputed that Ms. Ryan testified, "So, Phil was of the mindset, as +was I, that [Epstein] had to go." Disputed to the extent USVI contends that Ryan's +testimony establishes DeLuca's mindset with respect to Epstein's status as a client. The +cited testimony was provided in response to a question on what Ryan understood an +email from DeLuca to mean and is not supported by her personal knowledge of DeLuca's +views about Epstein. See USVI Ex. 36 at 70:19-71:3. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +163. Langford testified: "We were pushing it. I had asked for this to be redone, to push again, +to say it's time that we exit Epstein. " Ex. 119 at 278:17-21. +JPMC Response: Disputed to the extent USVI misstates Langford's testimony. +Langford testified, "We were pushing it. I had ask that this be redone, to push again, to +say it's time that we exit Epstein." USVI Ex. 119 at 278:17-21. Otherwise, undisputed. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +75 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 17 of 61 +164. Langford testified that by the end of 2010 or early 2011, it was his view that "we should +exit Jeffrey Epstein as a client." Ex. 119 at 58:18-59:11. +JPMC Response: Undisputed that Langford testified as such. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +165. DeLuca testified: "Maryanne [Ryan] was all over this, and like myself and William +(Langford], Maryanne wanted to see this client gone, the relationship terminated." Ex. 120 at +204:22-205:1. +JPMC Response: Undisputed that DeLuca testified as such. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +166. On January 10, 2011, DeLuca emails Nichols, copying Langford, regarding Jeffrey +Epstein: "He is alleged to be involved in human trafficking of young girls and law enforcement is +allegedly investigating his involvement in this activity. ... AML Operations went to a PB risk +meeting late last week requesting we exit this relationship." Ex. 70 at -748_R. +JPMC Response: Disputed to the extent USVI misstates the cited document. The cited +text reads, "He is alleged to be involved in the human trafficking of young girls and law +enforcement is also allegedly investigating his involvement in this activity... AML +Operations went to a PB risk meeting late last week requesting that we exit this +relationship." USVI Ex. 70 at -748_R. Otherwise, undisputed. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +167. On March 12, 2013, Ryan emails DeLuca, Subject: High Profile, telling him: "Here are +the ones [accounts] I think should be closed where the LOB has disagreed and signed off to keep. +76 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 18 of 61 +... PB customer Jeffrey Edward Epstein is an American financier and science and education +philanthropist, who is a convicted sex offender. " Ex. 121 at -272. +JPMC Response: Disputed to the extent USVI misstates the cited document. The +quoted text is emailed by Ryan to DeLuca on February 19, 2013. See USVI Ex. 121 at - +272. Otherwise, undisputed that the cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +168. JPMorgan admits that Erdoes was involved in decision making with respect to maintaining +Epstein as a customer of JPMorgan. Ex. 28 at Resp. 8. +JPMC Response: Undisputed that Erdoes was involved in decision making at certain +points with respect to maintaining Epstein as a customer of JPMorgan. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +169. In 2008, JPMorgan acquired Bear Stearns. Ex. 122 at 1; Ex. 123 at 285:8-286:2. +JPMC Response: Undisputed that the cited document states that JPMorgan acquired +Bear Stearns in 2008. See USVI Ex. 122 at 1. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or +Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. +See CSMF 11 1-107. +170. JPMorgan knew that Epstein conducted his brokerage business at Bear Stearns. Ex. 124 +at -175. +JPMC Response: Undisputed that the cited DDR for Jege, Inc. states that "Bear Stearns +will hold the brokerage relationship with Mr. Epstein." See USVI Ex. 124 at -175. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or +Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. +See CSMF 11 1-107. +171. +Ex. 125 at -076. +77 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 19 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or +Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. +See CSMF 11 1-107. +172. After Bear Stearns was acquired by JPMorgan, Arthur Middlemiss assumed a similar role +with JPMorgan AML compliance, working with Langford. Ex. 126 at 1; Ex. 120 at 155:21-158:6. +JPMC Response: Undisputed that the cited USVI Ex. 126 states that in June 2008 Mr. +Middlemiss transitioned from Managing Director at Bear Stearns to Managing Director at +Chase & Co. and that Mr. Langford testified that at some point Arthur +Middlemiss "was a direct report" of his. See USVI Ex. 120 at 155:21-22. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or +Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. +See CSMF 11 1-107. +173. While at Bear Stearns, Middlemiss was the AML Officer responsible for responding to a +2007 subpoena by the federal prosecutors investigating Epstein for federal sex crimes. Ex. 125 at +-076. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or +Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. +See CSMF M 1-107. +174. On January 10, 2011, Ryan e-mails Langford, DeLuca, and Nichols, Subject: Re: Jeffrey +Epstein: "Seems JPMC never was served a subpoena, which I find odd since we were his #1 bank +and actually Bear got one in 07. Rich is getting me the AUSA correspondence and we will compare +their ask of Bear (something about $1000 and $100,000 transactions were of interest to them)[J" +Ex. 127 at - 192. +JPMC Response: Undisputed that Ryan emailed Langford, DeLuca, and Nichols on +January 10, 2011 and the cited email contains the quoted text. +78 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 20 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or +Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. +See CSMF H 1-107. +175. +Ex. 128 at -247. +Ex. 129 at -248, -251-52; Ex. 125 at - +075. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or +Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. +See CSMF 11 1-107. +176. +Ex. 129 at - 251. +Id. +79 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 21 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or +Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. +See CSMF 11 1-107. +177. +Ex. 125 at -075. +la. at -076. +JPMC Response: Undisputed that the cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or +Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. +See CSMF 11 1-107. +178. In 2007, JPMorgan knew, as part of its investigation of Epstein at that time, that it had +made twenty transfers out of Epstein's accounts in the amount of $100,000 from January 2, 2007 +to October 12, 2007. Ex. 63 at - 655-60. +JPMC Response: Disputed that this email was part of any JPMC "investigation of +Epstein at that time" as unsupported by the cited document. Undisputed that on October +19, 2007 Dalessio emailed Verdon, copying MeCleerey, Waters, and Meisner, that +includes an attachment of a chart that shows transactions related to Epstein's accounts +from 2007. JPMC disputes, however, that the cited document establishes as a legal +conclusion that JPMC knew about the transfers in 2007. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +80 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 22 of 61 +179. On August 27, 2006, Staley emails Erdoes: "Last night went to the Huggy Bear concert. +The age difference between husbands and wifes [sic] would have fit in well with Jeffrey. What a +joke." Erdoes responds, "L. and what I meant to tell you about last night was they [sic] were a +few people laughing about Jeffrey. One of the guys ran a unit of +Apparently +has +8 assistants, one is more beautiful than the other (even though he's gay). Anyway, lots of +comparisons to JE. " Ex. 130 at -337. +JPMC Response: Disputed to the extent USVI misstates the quoted document. Erdoes' +response to Staley's email on August 27, 2006 states "jeffrey," not "Jeffiey." See USVI +Ex. 130 at -337. Otherwise, undisputed that the cited email contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +180. +Ex. 131 at -627. The article discussed "alleged financier-pery* billionaire Jeffrey Epstein, of +whom it is alleged that he retained a procurer of underage girls. " Ex. 132 at 1. +Undisputed that the cited article +contains the quoted language. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +181. In May 2008, Erdoes writes to l +"This has turned into a cheezy broker fest .. +• totally not cool, the only cool people are here at glen's table-same as bat mitzvah!" | +responds: "Epstein there with miley cyrus?" Ex. 133 at -475. +JPMC Response: Undisputed that the cited document contains the quoted text. +81 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 23 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +182. In May 2008, Miley Cyrus was 15 and starring in "Hannah Montana" on the Disney +Channel. Ex. 134 at 2. +JPMC Response: Undisputed +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M1 +183. On February 7, 2011, Ryan also said to Langford: "... wanted to catch up on Epstein as +he was featured ripped from the headline story on Law and Order SVU this week. " Ex. 135 at - +044; Ex. 36 at 145:21-148:2. +JPMC Response: Disputed to the extent USVI misstates USVI Ex. 135. The cited +quote reads, "Wanted to catch up on Epstein as he was the featured ripped from the +headlines story on Law and Order SVU this week." Otherwise, undisputed. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +184. Ryan testified, "That entire series [Law and Order SVU] was based on real life stories, +and it's never difficult to figure out, since I am a New Yorker, I knew exactly what this particular +episode was on, and so I sent it to William so that he could see.... I saw it - happened to see it, +made sure I told William that a customer might have been the implied story that was out in the +news." Ex. 36 at 147:4-148:2. +JPMC Response: Undisputed that Ryan testified as such. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +82 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 24 of 61 +185. Ryan testified that she wrote to Langford: "I typed SVU and his name and there is a +Gawker story, Law & Order commerates [sic] JE taste for teen hookers. " Ex. 135 at -044; Ex. 36 +at 148:21-149:2. +JPMC Response: Disputed to the extent USVI has misstated the Ryan's testimony. +Ryan did not testify that she wrote to Langford "I typed SVU and his name and there is a +Gawker story, Law & Order commerates [sic] JE taste for teen hookers." In the cited +portion of Ryan's testimony, the questioner states, "You write in the second sentence, I +typed SVU and his name and there is a Gawker story, Law and Order commerates [sic] +JE taste for teen hookers. Do you see that?" and Ms. Ryan responds "Yes", that she sees +that. See USVI Ex. 36 at 148:21-149:2. JPMC does not dispute that USVI Ex. 135 +states, "I typed svu and his name and there is a gawker story Law and Order commerates +JE taste for teen hookers." USVI Ex. 135 at -044. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +186. The Gawker story states: "Last night, for instance, Dick L +Law & Order: SVU aired +a 'ripped from the headlines' episode that seemed to be aimed directly at Epstein. The villain was +'Jordan Hayes,' a 'billionaire pervert flying in underage girls for ser' on his private jet. His +parties make the society page, he's friends with 'a former president,' and Hayes almost gets away +with the statutory rape of a young girl before our heroes uncover scores of underage girls he had +sexually abused." Ex. 136 at 1. +JPMC Response: Undisputed that the cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF MI +187. The Law & Order episode and the Gawker story made Ryan "more anxious to get Jeffrey +Epstein out of the bank. " Ex. 36 at 149:5-11. Ryan further testified "that all of these facts should +be escalated to the business to make an informed decision about getting Epstein out of the bank." +83 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 25 of 61 +Id. at 149:17-21. Ryan was of the opinion that Epstein should be out of the bank. Id. at 149:20- +21. +JPMC Response: Disputed to the extent USVI has misstated Ryan's testimony. With +respect to the first sentence, undisputed that Ryan testified that the Gawker story or the +Law and Order episode about Epstein made her more anxious to get Epstein out of the +bank. For the second sentence, USVI has misstated Ms. Ryan's testimony. Ryan +testified, "I thought that all of these facts had to be escalated to the business to make an +informed decision about getting him out of the bank. I was of the opinion that he should +be out of the bank." USVI Ex. 36 at 149:5-21. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +188. On November 29, 2011, Ryan e-mails DeLuca an article, "FBI Set to Reopen Epstein Case +Based on Testimony of +" The article states: "The FBI is reportedly preparing to +launch a new inquiry into Epstein after one of his under-age erotic masseuses, +made a string of disturbing allegations about her role. U.S. detectives are said to be furious that +Epstein, 58, escaped with only 13 months in jail for child sex offences [sic] after he struck a plea +bargain with prosecutors. The deal protected him from further prosecution for offences in Florida. +But the significance of +claims that under-age girls were moved abroad for sex is +that she paves the way for the FBI to prosecute him for offences /sic| committed outside Florida +under the Trafficking Victims Protection Act. " Ex. 137 at 689 (emphasis added). +JPMC Response: Undisputed that the cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +1-107. Further contended that the cited material cannot be presented at trial in admissible +form. +189. On June 17, 2013, in a "Lync" chat from DeLuca with Jessica Gomel, who reported to +DeLuca, DeLuca repeated the contents of the article, including that "the significance of +claims that under-age girls were moved abroad for sex is that she paves the way for +84 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 26 of 61 +the FBI to prosecute him for offences (sic] committed outside Florida under the Trafficking +Victims Protection Act." Ex. 138 at -936 (emphasis added). +JPMC Response: Disputed to the extent the cited document does not support the +assertion that Gomel reported to DeLuca or that DeLuca is repeating the contents of an +article. Otherwise, undisputed that the cited document contains the quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +190. In September 2012, David Brigstocke (then CFO of JPMorgan AWM) writes to Erdoes +regarding +house: "The size of the Union Club. In fact it used to be a club. +Reminded me of JE's house, except it was more tasteful, and fewer nymphettes. More like the +Frick. Art was fabulous. D." Erdoes responds: "Wow." Ex 139 at -203 (emphasis added). +JPMC Response: Disputed to the extent USVI misstates the quoted document. +Brigstocke's email states "Union club," not "Union Club." See USVI Ex. 139 at -203. +Otherwise, undisputed that the cited document contains the quoted text. Undisputed that +Brigstocke was the CFO of JPMorgan AWM in September 2012. Disputed as to +materiality. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +191. Staley was the senior person at JPMorgan with a business relationship with Epstein. Ex. +39 at Resp. 204. +JPMC Response: Undisputed that Staley was the senior person at JPMC with a +business relationship with Epstein. See JPMC Ex. 62 at Resp. 204. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 99 +192. JPMorgan admits that its employees consulted with Staley regarding Epstein's account +activities. Ex. 39 at Resp. 144. +85 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 27 of 61 +JPMC Response: Undisputed that JPMC employees consulted with Staley regarding +Epstein's' account activities. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +193. JPMorgan admits that Staley commumicated with Epstein through his JPMorgan email +account jes.staley@jpmorgan.com. Ex. 39 at Resps. 161, 162. +JPMC Response: Undisputed that Staley, at certain times, communicated with Epstein +through his JPMorgan email account jes.staley@jpmorgan.com. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +194. JPMorgan employees were instructed to only use their email accounts "for business +purposes." Ex. 39 at Resp. 163. +JPMC Response: Disputed that JPMorgan employees were instructed to only use their +email accounts for business purposes during the entirety of the relevant time period. +Undisputed that in 2009, JPMorgan employees were subject to a Code of Conduct which +included the instruction: "electronic mail (e-mail) systems and other electronic +communications devices provided by JPMorgan Chase, whether in the workplace or +elsewhere, are the property of the firm and should be used for business purposes; +however, limited incidental personal use is permitted, consistent with the Code and all +other policies of the firm." See USVI Ex. 39 at Resp. 163, JPMC Ex. 63 at -129. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +195. JPMorgan admits that Epstein sent Staley photographs of women on Staley's JPMorgan's +email address. Ex. 39 at Resp. 164. +JPMC Response: Undisputed that Epstein sent Staley photographs of women on +Staley's JPMorgan email address. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +86 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 28 of 61 +196. JPMorgan admits that more than 1,200 email messages were sent between Staley and +Epstein over Staley's work account. Ex. 39 at Resp. 165. +JPMC Response: Undisputed that more than 1,200 email messages list both +jes.staley@jpmorgan.com and jeevacation@gmail.com as either sender, receiver, or +carbon copy. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +197. JPMorgan admits that Staley sent an email from his work account that referenced "Snow +" Ex. 39 at Resp. 166. +JPMC Response: Undisputed that Staley sent an email from his JPMorgan email +account that referenced "Snow +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +198. On July 9, 2010, Staley e-mailed Epstein, "That was fun. Say hi to Snow | +"Epstein +responded, "what character would you like next." Staley responded, "Beauty and the Beast..." +Epstein responded, "well one side is available." Ex. 140 at - 669. +JPMC Response: Disputed to the extent USVI misstates the cited document. Epstein's +response to Staley's email states, "well one side is availble." See USVI Ex. 140 at - 669. +Otherwise, undisputed that cited document contains quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +199. On August 30, 2009, Epstein emailed Staley, "how long London? Do you need anything +there?" Staley responded, "Yep." Ex. 141 at -171. +JPMC Response: Disputed to the extent USVI misstates the quoted document. +Epstein's email states "london," not "London." See USVI Ex. 141 at -171. Otherwise, +undisputed that cited document contains quoted text. +87 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 29 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +200. On September 2, 2009, Epstein emailed +"jes staley is +staying at the berkeley hotel in London tonight." Ex. 142 at -773. +JPMC Response: Disputed to the extent USVI misstates the quoted document. +Epstein's email states "london," not "London." See USVI Ex. Ex. 142 at -773. Otherwise, +undisputed that cited document contains quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 99 +201. On December 20, 2009, Epstein emailed Staley a blank email with only an attachment, +which "appears to be a modeling photo": +Ex. 143 at -791-92; Ex. 144 at -005. +JPMC Response: Undisputed that cited document USVI Ex. 144 contains quoted text. +Disputed that the attachment in USVI Ex. 143 "appears to be a modeling photo," as the +email provides no context for the photograph. +88 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 30 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +202. On December 5, 2009, Epstein emailed Staley, "you were with larry, [sic] and I had to +put up with...." with the following attachment: +Ex. 145 at -715-16; Ex. 144 at -005. +Ex. 146 +at - 718. +JPMC Response: Disputed to the extent USVI misstates the quoted document. +See USVI Ex. 146 +at -718. Otherwise, undisputed that cited documents contain quoted text. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +89 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 31 of 61 +203. On June 16, 2010, Staley wrote to Epstein "is she free tonight?" Epstein replied, "call +me. " Staley replied, "I'm with A." Ex. 144 at -998. +JPMC Response: Undisputed that cited document contains quoted text. See USVI Ex. +144 at -005. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +204. +Staley testified he met +at Epstein's townhouse. Ex. 46 at 343:22-346:8. +JPMC Response: Undisputed that Staley testified he met +at Epstein's +townhouse. Disputed to the extent the underlying fact requires a credibility +determination. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +205. +Staley testified he met Lesley Groff at Epstein's townhouse. Ex. 46 at 343:22-346:8. +JPMC Response: Undisputed that Staley testified he met Groff at Epstein's townhouse. +Disputed to the extent the underlying fact requires a credibility determination. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 19 +206. Staley testified he met +at Epstein's townhouse. Ex. 46 at 343:22-346:8. +JPMC Response: Disputed that Staley testified he met +at Ep townhouse. +Staley testified that he met +" USVI Ex. 46 at 346:9-12. Disputed to the extent the underlying fact requires +a credibility determination. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +207. Staley testified +Ex. 46 at 433:9-440:8. +90 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 32 of 61 +JPMC Response: Undisputed that Staley testified +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11l +208. JPMorgan admits that Staley submitted, and JPMorgan reimbursed, the costs associated +with expense reports reflecting purported meetings with Epstein. Ex. 39 at Resps. 168, 169. +JPMC Response: Undisputed that Staley submitted, and JPMorgan reimbursed, the +costs associated with expenses reports reflecting meetings with, among others, Epstein. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M1 +209. JPMorgan admits that certain of its employees knew that Staley had visited Epstein while +he was incarcerated and still a JPMorgan client. Ex. 39 at Resp. 175. +JPMC Response: Undisputed that certain JPMorgan employees knew that Staley had +visited Epstein while he was incarcerated and still a JPMorgan client. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +210. JPMorgan admits that Staley visited Epstein at Epstein's New York property while Epstein +was a client of JPMorgan. Ex. 39 at Resp. 176. +JPMC Response: Undisputed that Staley visited Epstein at Epstein's New York +property while Epstein was a client of JPMorgan. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +211. JPMorgan admits that certain of its employees learned that Staley visited Little Saint James +while Epstein was a client of JPMorgan. Ex. 39 at Resp. 177. +91 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 33 of 61 +JPMC Response: Undisputed that certain of its employees learned that Staley visited +Little Saint James while Epstein was a client of JPMorgan. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +212. JPMorgan admits that it gave Staley a bonus every year between 2001 and 2012. Ex. 39 +at Resp. 197. +JPMC Response: Undisputed that Staley received a bonus every year between 2001 +and 2012. Disputed as to materiality with respect to USVI's claims in this litigation. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF M +213. JPMorgan admits that Staley's bonus was related to his performance and performance of +the business under his supervision, which may have included the revenue and business that they +generated. Ex. 39 at Resp. 198. +JPMC Response: Undisputed that Staley's bonus was related to his performance and +performance of the businesses under his supervision, which may have included the +revenue and business that they generated, among a broad range of additional quantitative +and qualitative considerations. Disputed as to materiality with respect to USVI's claims +in this litigation. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 11 +JPMorgan Participated in Epstein's alleged sex-trafficking venture +JPMC Response: This is a header to which no response is warranted. Disputed insofar +as USVI contends that the statements and documents cited below establish as a matter of +law that JPMorgan participated in Epstein's alleged sex-trafficking venture. +214. On July 6, 2020, the New York State Department of Financial Services entered into a +Consent Order with Deutsche Bank imposing a S150 million penalty in connection to Deutsche +Bank's relationship with Jeffrey Epstein. Ex. 147; Ex. 148; Ex. 99 at 457:10-466:2. Regarding +the Consent Order, Superintendent Lacewell said: "despite knowing Mr. Epstein's terrible +92 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 34 of 61 +criminal history, the Bank inexcusably failed to detect or prevent millions of dollars of suspicious +transactions." Ex. 147; Ex. 148; Ex. 99 at 457:10-466:2. The bank "processed hundreds of +transactions totaling millions of dollars " including: +• payments to individuals who were publicly alleged to have been Mr. Epstein's coconspirators in sexually abusing young women; +• settlement payments totaling over $7 million, as well as dozens of payments to law firms +totaling over $6 million for what appear to have been the legal expenses of Mr. Epstein +and his co-conspirators; +• payments to Russian models, payments for women's school tuition, hotel and rent +expenses, and (consistent with public allegations of prior wrongdoing) payments +directly to numerous women with Eastern European surnames; and +• periodic suspicious cash withdrawals — in total, more than $800,000 over +approximately four years. +Ex. 147; Ex. 148; Ex. 99 at 457:10-466:2. +JPMC Response: Undisputed that on July 6, 2020, the New York State Department of +Financial Services entered into a Consent Order with Deutsche Bank imposing a $150 +million penalty in connection to Deutsche Bank's relationship with Jeffrey Epstein. +Undisputed that cited documents contain quoted text. Disputed as to materiality of the +Deutsche Bank consent order in this matter. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 19 108-169. Further +contended that the cited material cannot be presented at trial in admissible form. +215. In 2005, JPMorgan made two separate $25,000 payments from Epstein's JPMorgan +accounts to +Ex. 56 at 34, 36 and Figure 9.3 (copied below). +Figure 9.3: Direct Payments to +2005 +$25,000 00 +$25,000 00 +2006 +2007 +2008 +2009 +2010 +2011 +2012 +2013 +Grand Total +$3,955.00 +$131,000 00 1 +14/2005 +1/5/2005 + +3/19/2008 +4/16/2009 +4/17/2000 +5/13/2009 +54/2009 +5/19/2009 +7/30/2009 +8/17/2009 +8/24/2009 +$500 00 +514,000 00 +54.000 00 +$6,000 00 +54,000 00 +$1,025 00 +$4.000 00 +55,000 00 +93 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 35 of 61 +9/16/2009 +10/1/2009 +11/18/2009 +12/4/2009 +14/2010 +24/2010 +3/4/2010 +15/2010 +4/7/2010 +54/2010 +5/4/2010 +8/31/2010 +3/10/2011 +3/24/2011 +8/16/2011 +11/16/2011 +3/16/2012 +10/4/2012 +48/2013 +8/21/2013 +Total +$4,000.00 +$13.000 00 +$4.000 00 +$4,000 00 +$4,000 00 +$1.000 00 +54,000 00 +$4,000 00 +52.604 62 +$4,000.00 +$4.000 00 +$2,104 17 +$6,000 00 +$300,000 00 +$12,252 60 +S6,105 75 +S3.294 43 +$9.800 00 +$100,000.00 +$15.000 00 +550,000.00 +$0.00 +$0.00 5134.055.00 | +S63,525.00 5334,708.79 $18,358.35 $13,094.43 S115,000.00 S728,741.57 +JPMC Response: Undisputed that cited document is a summary of transactions prepared +by USVI's proffered expert Jorge Amador. Disputed that this information was available +to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as +to materiality to the extent this summary fails to put Epstein's transactions in the +appropriate context. See JPMC Ex. 60 91 22, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 1T 108-169. +216. From August 2006 through August 2013, JPMorgan handled $678,741.57 in payments +from Epstein's JPMorgan accounts to +Ex. 56 at 34, 30 and Figure 9.3. +JPMC Response: Undisputed that cited document is a summary of transactions +prepared by USVI's proffered expert Jorge Amador. Disputed that this information was +available to JPMorgan in this format during the time Epstein was a client of JPMorgan. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex. 60 11 22, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 19 108-169. +217. In August 2013, JPMorgan handled a payment of $15,000 from Epstein's JPMorgan +account to +Ex. 56 at 34, 36 and Figure 9.3. +JPMC Response: Undisputed that cited document is a summary of transactions +prepared by USVI's proffered expert Jorge Amador. Disputed that this information was +available to JPMorgan in this format during the time Epstein was a client of JPMorgan. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex. 60 M 22, 92. +94 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 36 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 19 108-169. +218. From August 2006 through January 2013, JPMorgan handled $607,804.30 in payments +from Epstein's JPMorgan accounts to +Ex. 56 at 34-35 and Figure 9.2 (copied +below). +11/3/2003 +3/9/2004 +4/8/2004 +4/22/2004 +8728/2004 +5/1/2004 +8/5/2004 +10/19/2004 +11/22/2004 +12/1/2004 +1/4/2005 +1/19/2005 +4/12/2005 +126/2005 +7/19/2005 +8/15/2005 +8/25/2005 +10/11/2005 +10/24/2005 +14/2006 +23/2006 +3/2/2006 +4/10/2006 +4/28/2006 +7718/2006 +9/6/2006 +10/3/2006 +12/18/2006 +3/19/2007 +6/8/2007 +225/2007 +124/2008 +7/3/2008 +3/3/2008 +7/8/2009 +12/7/2009 +1/15/2010 +2/17/2010 +5/24/2010 +7/29/2010 +10/6/2010 +1/18/2011 +2/28/2011 +4/1/2011 +4/14/2011 +5/20/2012 +10/10/2012 +10/11/2012 +1/17/2013 +Total +2003 +$500 00 +Figure 9.2: Direct Payments to +2005 +2006 +2007 +2008 +2000 +2004 +51,166 00 +$2,000 00 +$1,51782 +$3,000 00 +$10.000 00 +$5.000 00 +510,000 00 +52,168 29 +$1,713 45 +2010 +2011 +2012 +2013 Grand Total +$25,000.00 +$3,155 56 +76 +$10,000 00 +$3,339 96 +$480 00 +$10,000 00 +$5,000 00 +$10,000 00 +$10,000 00 +$11,000 00 +$6,786 00 +$15,000 00 +57,362 50 +$5,000 00 +$25,000 00 +$1.025 00 +S1.724 30 +$25,000 00 +$50,000 00 +5100,000 00 +$3.055.00 +$2,000 00 +T$100,000 00 +$50,000 00 +$10,000 00 +$10.000 00 +$25,000 00 +[$20,000 00 +520,000 00 +525,000.00 +$10,000 00 +$25,000 00 +$30,000.00 +$25,000 00 +$20,000 00 +510,000 00 +$10,000 00 +$10,000 00 +$500.00 +536.565.56 +S67.754.28 $82.897.S0 S175.000.00| $105.055.00 $60.000.00| S100.000.00 S90.000.00| +$40,000.00 +S10.000.00 S767.772.64 +95 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 37 of 61 +JPMC Response: Undisputed that cited document is a summary of transactions +prepared by USVI's proffered expert Jorge Amador. Disputed that this information was +available to JPMorgan in this format during the time Epstein was a client of JPMorgan. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex. 60 11 22, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +219. In 2004, 2005, and 2006, JPMorgan handled $36,565.56, $67,754.28, and $82,897.80, +respectively, in payments from Epstein's JPMorgan accounts to +Ex. 56 at 34- +35 and Figure 9.2. +JPMC Response: Undisputed that cited document is a summary of transactions +prepared by USVI's proffered expert Jorge Amador. Disputed that this information was +available to JPMorgan in this format during the time Epstein was a client of JPMorgan. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex. 60 11 22, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +220. +Ex. 149 +JPMC Response: Undisputed that cited document is a summary of transactions +reflected in USVI Ex. 149. Disputed that this information was available to JPMorgan in +this format during the time Epstein was a client of JPMorgan. Disputed as to materiality +to the extent this summary fails to put Epstein's transactions in the appropriate context. +See JPMC Ex. 60 11 22, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +221. From October 1999 through July 2006, JPMorgan handled $25,146,955.30 in payments +from Epstein's JPMorgan accounts to Ghislaine Maxwell. Ex. 56 at 45-46 and Figure 15 (copied +below). +Figure 15: Direct Payments to Ghislaine Maxwell +96 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 38 of 61 +10/19/1999 +9/18/2002 +2/27/2003 +5/6/2003 +6/20/2003 +11/4/2004 +11/18/2004 +4/27/2005 +5/20/2005 +7/22/2005 +7/25/2005 +11/28/2006 +4/23/2009 +Total +1000 +$18,300,000 00 +2002 +$5,000,000 00) +2003 +$325,000 00 +$250.000 00 +593.037 971 +2004 +2005 +2006 +2009 +$225,000 0C +$34,867 33 +Grand Total +$18,3 00,000 00) +$5,000,000 00 +$325,000 00 +$250,000 DD +593.03792 +$225,000 D0 +$34.867 33 +$205,000 00 +$139,050 00 +5200,000 00 +$375,000 00) +$13.750 00 +$100,000 D0 +$25.260,705.30 +$205,000 00) +$139,050 00 +5200,000 00 +5375,000 00 +S18,300,000.00 +55,000,000.00 +5668.03797 +$259,867.33 +$919,050.00 +$13.750 00| +$13,750.00 +$100.000 00 +$100,000.00 +JPMC Response: Undisputed that cited document is a summary of transactions +prepared by USVT's proffered expert Jorge Amador. Disputed that this information was +available to JPMorgan in this format during the time Epstein was a client of JPMorgan. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex.60 11 22, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 19 108-169. +222. From August 2006 through April 2009, JPMorgan handled $113,750 in payments from +Epstein's JPMorgan accounts to Maxwell. Ex. 56 at 45-46 and Figure 15. +JPMC Response: Undisputed that cited document is a summary of transactions +prepared by USVI's proffered expert Jorge Amador. Disputed that this information was +available to JPMorgan in this format during the time Epstein was a client of JPMorgan. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex. 60 11 22, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 19 108-169. +223. In addition, JPMorgan received a $7.4 million wire from Epstein's Mellon Bank account +to Maxwell's JPMorgan account to purchase a helicopter. On June 15, 2007, JPMorgan received +a $7.4 million wire to Maxwell's JPMorgan account ending in 6312 from Epstein's Mellon Bank +account. Ex. 150 at -025 (June 2007 account statement from Ghislaine Maxwell's JPMorgan +account ending in #6312 showing a $7.4 million wire from Epstein's Mellon Bank account). On +the same day, Maxwell transferred those same funds to Air Ghislaine, Inc. 's JPMorgan account +ending in 4324. Ex. 151 at -878 (June 2007 account statement from Air Ghislaine, Inc. 's +97 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 39 of 61 +JPMorgan account ending in 4324). Then on June 18, 2007, $7,352,825.00 was transferred to +Sikorsky Aircraft as a down payment for the purchase of a l +_helicopter - Sikorsky S76C. Id. +According to the Aviation Database, as of June 27, 2007, the helicopter with tail number N908GM +was registered to Air Ghislaine, Inc. Ex. 56, Amador Exhibit G (aircraft registrations). +JPMC Response: Disputed as to date of transfer from Maxwell to Air Ghislaine, Inc.'s +JPMorgan account. The date provided in USVI Ex. 151 at -878 is June 18, not June 15. +Undisputed that other payments occurred to specified accounts. Undisputed that +helicopter with tail number N908GM was registered to Air Ghislaine, Inc. Disputed as to +the materiality of this transaction between Maxwell and Epstein to the claims in this +litigation. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +224. +Figure 9: Direct Payments to Women from the Epstein Accounts +Payee Name +Total Payment Amount +$15,000.00 +$5,000.00 +$13,656.00 +$5,000.00 +$7,026.00 +$3,000.00 +$64,599.86 +$5,000.00 +$8,468.00 +$2,400.00 +$400.00 +$500.00 +$4,000.00 +$58,000.00 +$8,000.00 +$30,000.00 +$5,000.00 +$20,000.00 +98 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 40 of 61 +Payee Name +Total Payment Amount +$19,000.00 +$36.049.30 +$22,500.00 +$113,500.00 +$5,007.13 +$1,000.00 +$396.44 +$500.00 +$3,675.00 +$12,110.00 +$550.00 +$200.00 +$4.901.00 +$3,341.68 +$116,399.86 +$500.00 +$1,550.00 +$750.00 +$12,500.00 +$9,000.00 +$211,441.25 +$5,000.00 +S12,528.67 +$728,741.57 +$7,750.00 +$5,000.00 +S80,550.00 +$115,000.00 +$50,000.00 +$8,073.75 +$108,500.00 +$767,772.64 +$1,000.00 +$1,495.00 +$500.00 +$2,700.00 +$30,000.00 +$15,000.00 +$5,000.00 +$1,100.00 +$79,773.51 +$10,000.00 +$1,540.00 +99 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 41 of 61 +Payee Name +Total +Total Payment Amount +$81,000.00 +$30,000.00 +$21,739.73 +$4,000.00 +$1,320.00 +$3,000.00 +$27,743.00 +$23,000.00 +$4,200.00 +$2,000.00 +$10,140.00 +$3,500.00 +$1,650000 +$8,000.00 +$300.00 +$5,000.00 +$38,031.49 +$500.00 +S3,132,070.88 +JPMC Response: Undisputed that cited document is a summary of transactions prepared +by USVI's proffered expert Jorge Amador. Disputed that this information was available +to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as +to whether the persons listed were minors when they received the payments as their age is +not provided in the cited source. Disputed as to materiality to the extent this summary fails +to put Epstein's transactions in the appropriate context. See JPMC Ex. 60 MMl 22, 23, 91, +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +225. +100 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 42 of 61 +101 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 43 of 61 +102 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 44 of 61 +103 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 45 of 61 +104 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 46 of 61 +JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. +Disputed that this information was available to JPMorgan in this format during the time +Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors +when they received the payments as their age is not provided in the cited source. +105 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 47 of 61 +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex. 60 MT 22, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +226. +106 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 48 of 61 +107 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 49 of 61 +108 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 50 of 61 +109 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 51 of 61 +110 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 52 of 61 +lll + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 53 of 61 +JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. +Disputed that this information was available to JPMorgan in this format during the time +Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors +when they received the payments as their age is not provided in the cited source. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex. 60 11 22, 23, 91, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +227. +112 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 54 of 61 +113 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 55 of 61 +114 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 56 of 61 +115 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 57 of 61 +116 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 58 of 61 +117 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 59 of 61 +JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. +Disputed that this information was available to JPMorgan in this format during the time +Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors +when they received the payments as their age is not provided in the cited source. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex. 60 11 22, 23, 91, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +228. +JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. +Disputed that this information was available to JPMorgan in this format during the time +Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors +when they received the payments as their age is not provided in the cited source. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropnate context. See JPMC Ex. 60 11 22, 23, 91, 92. +118 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 60 of 61 +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +229. +JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. +Disputed that this information was available to JPMorgan in this format during the time +Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors +when they received the payments as their age is not provided in the cited source. +Disputed as to materiality to the extent this summary fails to put Epstein's transactions in +the appropriate context. See JPMC Ex. 60 1l 22, 23, 91, 92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 11 108-169. +230. JPMorgan sent several of the payments by foreign wire to girls or women—including +located +in Belarus, Lithuania, and Russia. Ex. 56 at 37-38 and Figure 10 (copied below). +Figure 10: Foreign Wire Transactions from the Epstein Accounts +119 + + +Case 1:22-cv-10904-JSR Document 284-3 Filed 08/14/23 Page 61 of 61 +12/1/2008 +12/1/2008 +1/8/2009 +9/8/2009 +11/4/2010 +8/21/2012 +1/14/2013 +10/15/2013 +Beneficiary Bank +Location +Alfa Bank +Moscow, Russia +VTB Bank +Moscow, Russia +SEB Vilniaus Bankas Lithuania +VTB Bank +Moscow, Russia +ZAO +Raiffeisenbank +Moscow, Russia +ZAO +Raiffeisenbank +Moscow, Russia +Joint Stok Company +Minsky, Belarus +Joint Stok Company +Minsky, Belarus +Amount +$3,000.00 +$2,000.00 +$2,000.00 +$292.00 +$2,840.00 +$2,000.00 +$10,000.00 +$20,000.00 +JPMC Response: Undisputed that this is a summary of transactions prepared by +USVI's proffered expert Jorge Amador. Disputed that this information was available to +JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as +to whether the persons listed were minors when they received the payments as their age is +not provided in the cited source. Disputed as to materiality to the extent this summary +fails to put Epstein's transactions in the appropriate context. See JPMC Ex. 60 19 22, 23, +91,92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 19 108-169. +231. From 2004-2013, JPMorgan handled $211,411.25 in payments to +from +Epstein's JPMorgan accounts. Ex. 56, Amador Exhibit F (chart showing breakdown of each direct +payment Epstein made to girls or women from his JPMorgan accounts). +JPMC Response: Undisputed that this is a summary of transactions prepared by +USVI's proffered expert Jorge Amador. Disputed that this information was available to +JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as +to whether the persons listed were minors when they received the payments as their age is +not provided in the cited source. Disputed as to materiality to the extent this summary +fails to put Epstein's transactions in the appropriate context. See JPMC Ex. 60 T 22, 23, +91,92. +Disputed insofar as USVI contends that this fact supports an inference that JPMorgan +participated in Epstein's alleged sex-trafficking venture. See CSMF 19 108-169. +232. JPMorgan also handled $158,958.34 in indirect payments from Epstein's JPMorgan +accounts for the benefit of girls or women. 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b/vision-fixhub/court-05/5602052bb0c934f3393e1ae9fe9750d179436c7d0646e1b7005d67e84e76d8d9.md new file mode 100644 index 0000000000000000000000000000000000000000..fc4d9fc390c7bd4e74424fc7a51d2a1359ea9be0 --- /dev/null +++ b/vision-fixhub/court-05/5602052bb0c934f3393e1ae9fe9750d179436c7d0646e1b7005d67e84e76d8d9.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 158-13 Filed 05/23/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/5602052bb0c934f3393e1ae9fe9750d179436c7d0646e1b7005d67e84e76d8d9.receipt.json b/vision-fixhub/court-05/5602052bb0c934f3393e1ae9fe9750d179436c7d0646e1b7005d67e84e76d8d9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..17db8d4d53e32d5516f7b5f4313369f813915f29 --- /dev/null +++ b/vision-fixhub/court-05/5602052bb0c934f3393e1ae9fe9750d179436c7d0646e1b7005d67e84e76d8d9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "5602052bb0c934f3393e1ae9fe9750d179436c7d0646e1b7005d67e84e76d8d9", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "6078bacce3252d48f89011711feb16dbb15a1c9f11ab9e7a4ec646bc524961ee", + "output_sha256": "edf435e01457fd2d810bb8b868d7c9b5240c15b6b1904c6b1d124a2936f70bd7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/565582a84d9634c052c6b7daf514918e1bbf864bf3e66dbb5abb529199d91b72.md b/vision-fixhub/court-05/565582a84d9634c052c6b7daf514918e1bbf864bf3e66dbb5abb529199d91b72.md new file mode 100644 index 0000000000000000000000000000000000000000..21f7e0ba00c25b2f85ea64fca6279004fa033a04 --- /dev/null +++ b/vision-fixhub/court-05/565582a84d9634c052c6b7daf514918e1bbf864bf3e66dbb5abb529199d91b72.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 241-1 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/565582a84d9634c052c6b7daf514918e1bbf864bf3e66dbb5abb529199d91b72.receipt.json b/vision-fixhub/court-05/565582a84d9634c052c6b7daf514918e1bbf864bf3e66dbb5abb529199d91b72.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bb3977424d498081030ad9b7bb6bbc589958cccb --- /dev/null +++ b/vision-fixhub/court-05/565582a84d9634c052c6b7daf514918e1bbf864bf3e66dbb5abb529199d91b72.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "565582a84d9634c052c6b7daf514918e1bbf864bf3e66dbb5abb529199d91b72", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "2287cc368a887e2a789c8ade0a7bfe5a2acdf89b4e2e1bc82fa47e2b26efdc9b", + "output_sha256": "82d51f5d50ce19b141cc315e1b9e11c60857fd29a6b4c74ca59cbaaf7c5e0512", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/565ce34e4145a2d2c5b7df4c8cdc0ce1fe25c33415a818177ac3489de8ff6143.md b/vision-fixhub/court-05/565ce34e4145a2d2c5b7df4c8cdc0ce1fe25c33415a818177ac3489de8ff6143.md new file mode 100644 index 0000000000000000000000000000000000000000..ce6313e798d6e9dd65b1413952117f0785c347d3 --- /dev/null +++ b/vision-fixhub/court-05/565ce34e4145a2d2c5b7df4c8cdc0ce1fe25c33415a818177ac3489de8ff6143.md @@ -0,0 +1,22 @@ +Case 1:22-cV-10904-JSR Document 285-51 Filed 08/15/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 285-51 Filed 08/15/23 Page 2 of 2 +From: +Sent: +To: +Subject: +ann.borowiec@jpmorgan.com [ann.borowiec@jpmorgan.com] +10/24/20066:18:05 PM +patricia.lunka@jpmorgan.com; Barry Berger [barry.s.berger@jpmchase.com] +big new business oppy +Catherine called and Jes and she picked the NY based team to work with Jeffrey Epstein (advisor) on business +oppy associated with GRATS that are terminating for Google founders. It need to be NY. I need to tell you the +story here, and I will set up a call with West coast team that is handing this off. Can you two get together and +call me in NJ this afternoon and I will tell you story. We need to do homework with West coast team, probably +pick an investor and the next step will be meeting with Jeffrey. I will work to get call set up with west coast for +tomorrow. Thanks Ann + +98982vH +JPM-SDNYLIT-00390515 \ No newline at end of file diff --git a/vision-fixhub/court-05/565ce34e4145a2d2c5b7df4c8cdc0ce1fe25c33415a818177ac3489de8ff6143.receipt.json b/vision-fixhub/court-05/565ce34e4145a2d2c5b7df4c8cdc0ce1fe25c33415a818177ac3489de8ff6143.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9b188237b57b8f7814b7622f0f9f5d6362160ae2 --- /dev/null +++ b/vision-fixhub/court-05/565ce34e4145a2d2c5b7df4c8cdc0ce1fe25c33415a818177ac3489de8ff6143.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -35, + "dataset": "marble-joined", + "doc_id": "565ce34e4145a2d2c5b7df4c8cdc0ce1fe25c33415a818177ac3489de8ff6143", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "63df703558f5ba24247b4cb00de0795286fe19c877cb7cf57c00b032febd250b", + "output_sha256": "86ade1392efdbdd9d6d8de032ca67df76a14ec1b57b58c5e47f66613f8023528", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/567216beceab8753d9e9d8cf7d32cd242da6702464085d0f7f5c866d0f32ff49.md b/vision-fixhub/court-05/567216beceab8753d9e9d8cf7d32cd242da6702464085d0f7f5c866d0f32ff49.md new file mode 100644 index 0000000000000000000000000000000000000000..65df8e692b6de59b10acbd324a2709b51af89b49 --- /dev/null +++ b/vision-fixhub/court-05/567216beceab8753d9e9d8cf7d32cd242da6702464085d0f7f5c866d0f32ff49.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 311-17 Filed 08/25/23 + + +Filed Under Seal diff --git a/vision-fixhub/court-05/567216beceab8753d9e9d8cf7d32cd242da6702464085d0f7f5c866d0f32ff49.receipt.json b/vision-fixhub/court-05/567216beceab8753d9e9d8cf7d32cd242da6702464085d0f7f5c866d0f32ff49.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..983835c3a914c1e23fc27165e85243e87aeab1eb --- /dev/null +++ b/vision-fixhub/court-05/567216beceab8753d9e9d8cf7d32cd242da6702464085d0f7f5c866d0f32ff49.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "567216beceab8753d9e9d8cf7d32cd242da6702464085d0f7f5c866d0f32ff49", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "a516b90913c88b80889231825ce4ce0508b1b38e973f2b9c8c1be7d6bef0690a", + "output_sha256": "d17fe5ccd93c9194b2d1062db1118a7f9ba269cd23b5941160475339b2d745f1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/56734087143346e828a224cac02f7d75dfbdf4fcfee363bd06fd907be41aa05a.md b/vision-fixhub/court-05/56734087143346e828a224cac02f7d75dfbdf4fcfee363bd06fd907be41aa05a.md new file mode 100644 index 0000000000000000000000000000000000000000..c0e450bf6df63da4037a6c2ca8393a359aa34b76 --- /dev/null +++ b/vision-fixhub/court-05/56734087143346e828a224cac02f7d75dfbdf4fcfee363bd06fd907be41aa05a.md @@ -0,0 +1,36 @@ +Case 1:22-cv-10904-JSR Document 26-4 Filed 01/20/23 Page 1 of 2 +IN THE UNITED STATES DISTRICT COURT FOR +THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiffs, +Case No. 22-cv-10904-JSR +[PROPOSED| ORDER FOR +ADMISSION PRO HAC VICE +v. +JPMORGAN CHASE BANK, N.A., +Defendant. +The motion of Hillary Chutter-Ames for admission to practice pro hac vice in the abovecaptioned action is granted. +Applicant has declared that she is a member in good standing of the bar of the state of +Illinois and the state of New York, and that her contact information is as follows: +Wilmer Cutler Pickering +Hale and Dorr LLP +7 World Trade Center +250 Greenwich Street +New York, NY 10007 +Tel.: (212) 230-8848 +Hillary. Chutter-Ames@wilmerhale.com +Applicant having requested admission pro hac vice to appear for all purposes as counsel +for Defendant JPMorgan Chase Bank, N.A. in the above-captioned action, +IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the +above-captioned case in the United States District Court for the Southern District of New York. +All attorneys appearing before this Court are subject to the Local Rules of this Court, +including the Rules governing discipline of attorneys. + + +Case 1:22-cv-10904-JSR Document 26-4 Filed 01/20/23 Page 2 of 2 +Dated: +-, 2023 +New York, NY +The Honorable Jed S. Rakoff +United States District Judge diff --git a/vision-fixhub/court-05/56734087143346e828a224cac02f7d75dfbdf4fcfee363bd06fd907be41aa05a.receipt.json b/vision-fixhub/court-05/56734087143346e828a224cac02f7d75dfbdf4fcfee363bd06fd907be41aa05a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9bba67b890d0aaba719a5492680afb1d3dedced6 --- /dev/null +++ b/vision-fixhub/court-05/56734087143346e828a224cac02f7d75dfbdf4fcfee363bd06fd907be41aa05a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "56734087143346e828a224cac02f7d75dfbdf4fcfee363bd06fd907be41aa05a", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "ed73702450a7a4769aa4ffaa67c9ff3d95d746da3a479fb27920374fb31fe882", + "output_sha256": "45c14ae73cac8d03860d8b719b5f2fc00fda63d86d13927730bb9d632f12da3e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/56875639c107c73a90358a62945ea78a1ac7e123e2e77c24e9952f2dd36ea33d.md b/vision-fixhub/court-05/56875639c107c73a90358a62945ea78a1ac7e123e2e77c24e9952f2dd36ea33d.md new file mode 100644 index 0000000000000000000000000000000000000000..8ace28074246c49b8a660f90dfdfb23b7a5e406e --- /dev/null +++ b/vision-fixhub/court-05/56875639c107c73a90358a62945ea78a1ac7e123e2e77c24e9952f2dd36ea33d.md @@ -0,0 +1,105 @@ +Case 1:22-cv-10904-JSR Document 252 Filed 08/02/23 Page 1 of 3 +STEPHEN L. WOHLGEMUTH +(202) 434-5390 +swohlgemuth@@wc.com +LAW OFFICES +& CONNOLLY LP. +680 MAINE AVENUE SW +WASHINGTON, DC 20024 +(202) 434-5000 +WWW.Wc.com +August 2, 2023 +EDWARD BENNETT +1920-1988) +PAUL R. CONNOLLY (1922-1978) +Hon. Jed S. Rakoff +Re: +USVI v. JPMorgan Chase Bank, N.A.; Privilege Waiver Relating to Settlement +Discussions +Dear Judge Rakoff: +This Court has already held that JPMorgan put its subjective motivation for settling with +the Doe class at issue by seeking to hold Mr. Staley liable for the entirety of that settlement. That +is because JPMorgan bears the burden of proving that it paid $290 million because of Mr. Staley, +not for some other reason like its independent legal liability. JPMorgan refuses to produce the +privileged communications that would substantiateor refute +—its motive, claiming that it has not +waived privilege unless it affirmatively uses those communications to support its case. But that is +not the law, for the very good reason that it would leave Mr. Staley at the mercy of the bank's +exhibit list. Under Second Circuit and New York law, whether legal advice is placed "at issue" +turns on the factual contentions that a party makes, not the evidence that it chooses to offer in +support of those contentions. Here, given the bank's contention that it chose to pay $290 million +because of Mr. Staley's conduct, and not because of any other legal concerns such as weaknesses +in its case unrelated to Mr. Staley, this Court found that JPMorgan placed its internal legal motive +directly at issue. JPMorgan must now produce the only documents that can fairly prove or refute +JPMorgan's claimed motive. +JPMorgan asserts that Mr. Staley's argument for waiver is based on a mere-relevance +standard (which it attributes to Hearn v. Rhay), whereas, in the bank's view, the correct legal +standard is affirmative reliance, i.e., that unless the bank makes use of its own privileged +documents, there can be no waiver. JPM Ltr. 2. The bank is wrong on both points: Mr. Staley +does not claim that relevance is the standard, and—more to the point-cases post-dating (and even +discussing) the County of Erie and Deutsche Bank cases that JPMorgan cites explicitly state that +"waiver may be found even if the privilege holder does not attempt to make use of a privileged +communication," if the holder "makes factual assertions the truth of which can only be assessed +by examination of privileged communications." PRCM Advisers LLC v. Two Harbors Inv. Corp., +2022 WL 18027566, at *6 (S.D.N.Y. Dec. 30, 2022) (quotation marks omitted) (collecting +authority); accord MBIA Ins. Corp. v. Patriarch Partners VIII, LLC, 2012 WL 2568972, at *6 +(S.D.N.Y. July 3, 2012) ("use of the privileged materials ... [is not] the exclusive basis for at +issue' waiver", "rel[ying] upon" state of mind works waiver). These were the first two cases Mr. +Staley discussed in his opening letter, but JPMorgan ignores them entirely. + + +Case 1:22-cv-10904-JSR Document 252 Filed 08/02/23 Page 2 of 3 +& CONNOLLY u* +August 2, 2023 +Page 2 +The waiver-by-factual-assertion rule applies particularly where the factual assertion in +question concerns a purely subjective issue, such as state of mind, motive, or good faith. See, e.g., +Arista Records, LLC v. Lime Group, LLC, 2011 WL 1642434, at *2-3 (S.D.N.Y. Apr. 20, 2011) +(because "legal advice ... may well demonstrate the falsity of [the] claim of good faith belief; +waiver in these instances arises as a matter of fairness" (internal citation omitted)). This is clearly +the case here, as there is no more subjective issue than "motive." The particular motive in question +here, moreover, is not just any motive, but the motive in 2023 to settle a class-action lawsuit at a +nine-figure price. The idea that there will be non-privileged evidence of JPMorgan's actual motive +to settle in 2023—or that evidence of the bank's actual motive can be found in the contrived media +statements that it ginned up mid-litigation and then produced in discovery—is frivolous. +Remarkably, despite this Court's express ruling that JPMorgan put at issue its "motive for +settling" and "the motive behind [the settlement]," see July 7, 2023 minute entry, the word +"motive" appears nowhere in the bank's opposition. Instead, the bank treats the question as one +of "cause,' +," arguing that it will prove that Mr. Staley "caused" the settlement with "nonprivileged +documentary and testimonial evidence related to [his] tenure at the bank." JPM Ltr. 5. But that is +not the full extent of the bank's burden on causation. As the Court recognized when calling out +"motive" as an issue, the question at hand is not merely whether JPMorgan could have been liable +based on Mr. Staley's actions before 2013, but whether, in 2023, it decided to pay the full $290 +million because of those alleged actions or rather also for other reasons relating to itself alone, +such as concerns about direct liability, negative publicity, or enhanced regulatory scrutiny. That +question is the critical one, and it can be answered only through the communications that JPMorgan +had with its counsel over the course of deciding that a $290 million voluntary liability was its best +option. See PRCM Advisers, 2022 WL 18027566, at *6 (privileged communications are essential +to a fair assessment" of the "state of mind" of defendants); MBIA Ins., 2012 WL 2568972, at *6 +(waiver where "a party's state of mind ... is relied upon" in its claim). +The bank does not even broach this critical issue until the final substantive paragraph of its +response. There, JPMorgan acknowledges that its reasons for settling with the Doe class could +come up in this case, but nevertheless contends that they "cannot work a waiver" of privilege +because they amount merely to "a defense theory" that Mr. Staley "might raise"— in other words, +they are not an issue the bank itself injected into the case and thus placed "at issue." JPM Ltr. 5. +That is preposterous. JPMorgan made its motivation for the settlement part of this case when it +asserted that Mr. Staley's actions forced its hand into writing a check for $290 million. JPMorgan +bears the burden on the issue, and Mr. Staley is entitled to the evidence needed to counter +JPMorgan's (frankly absurd) causation theory. The bank cannot transform evidence that refutes +its affirmative case into a defense theory by its say-so. +For the foregoing reasons, and those stated in its opening letter, JPMorgan should +produce all communications between itself and its in-house and outside counsel as well as +attorney work-product relating to the reasonableness and causation of the settlement.? +' JPMorgan's letter claims that Mr. Staley previously "disclaimed" that he was seeking a waiver of privilege. Not +so. During the relevant Court call, Mr. Staley's counsel expressly stated that discovery into the bank's settlement +would raise privilege issues but that they were not presented by his first application. + + +Case 1:22-cv-10904-JSR Document 252 Filed 08/02/23 Page 3 of 3 +& CONNOLLYu* +August 2, 2023 +Page 3 +Respectfully submitted, +Is/ Stephen L. Wohlgemuth +Stephen L. Wohlgemuth diff --git a/vision-fixhub/court-05/56875639c107c73a90358a62945ea78a1ac7e123e2e77c24e9952f2dd36ea33d.receipt.json b/vision-fixhub/court-05/56875639c107c73a90358a62945ea78a1ac7e123e2e77c24e9952f2dd36ea33d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0c2bcae64457f9dff7f90610bc58fae8a289149c --- /dev/null +++ b/vision-fixhub/court-05/56875639c107c73a90358a62945ea78a1ac7e123e2e77c24e9952f2dd36ea33d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "56875639c107c73a90358a62945ea78a1ac7e123e2e77c24e9952f2dd36ea33d", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d873b99aae4bc86d892875b154daf0b9b3f0137abe8e3c71963b679563dd98a7", + "output_sha256": "67b5f3750e373bd45f74982e9a603911c9d8ca379d6523d4e87d7ddd17fddb0d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/56e0d6be6ba9f6937eced1adae40b036dbb26998b6c99333e142a5760b7678b0.md b/vision-fixhub/court-05/56e0d6be6ba9f6937eced1adae40b036dbb26998b6c99333e142a5760b7678b0.md new file mode 100644 index 0000000000000000000000000000000000000000..08ac564a754857ff6b327ecec3105f809e84fab0 --- /dev/null +++ b/vision-fixhub/court-05/56e0d6be6ba9f6937eced1adae40b036dbb26998b6c99333e142a5760b7678b0.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 265-53 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/56e0d6be6ba9f6937eced1adae40b036dbb26998b6c99333e142a5760b7678b0.receipt.json b/vision-fixhub/court-05/56e0d6be6ba9f6937eced1adae40b036dbb26998b6c99333e142a5760b7678b0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8914428f09287ac707287827735da50a5b94042b --- /dev/null +++ b/vision-fixhub/court-05/56e0d6be6ba9f6937eced1adae40b036dbb26998b6c99333e142a5760b7678b0.receipt.json @@ -0,0 +1,14 @@ 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"idempotent": true, + "input_sha256": "df9b9baffa7a75bdf16696f574e1a37650f450c3a2d1d2f650adf1d8b88ec2bc", + "output_sha256": "d9a8ea9384b05665158d6eb48b842d9e3fb79870d09392d172a8191b22812212", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/570f56557aae9e8aa59e44dabf986834b2b0489f4877f4e432a1736496624d03.md b/vision-fixhub/court-05/570f56557aae9e8aa59e44dabf986834b2b0489f4877f4e432a1736496624d03.md new file mode 100644 index 0000000000000000000000000000000000000000..c11c3c31f31b008d546ab3ee1ee46b381f0922ca --- /dev/null +++ b/vision-fixhub/court-05/570f56557aae9e8aa59e44dabf986834b2b0489f4877f4e432a1736496624d03.md @@ -0,0 +1,740 @@ +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 1 of 40 + +FILED UNDER SEAL + + +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 2 of 40 +Document Produced in +Native Format + +JPM-SDNYLIT-W-00026008 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 3 of 40 +1 +2 +B +C +Reason +D +Date +E +F +2 +Jeffrey Epstein +Several newspaper articles were found +that detail the indictment of Jeffrey +Epstein in Florida on felony charges of +soliciting underage prostitutes. +10/17/2006 +Retain +4 +After internal discussions with Jes Staley. +Mary Erdoes, Catherine Keating, John Duffy +and Mary +it was decided that we will +keep Mr. Epstein solely as a banking client +and on a 'reactive', client service basis. We +will not proactively solicit new investment +business from him +5 +6 + + +1 +8 +9 +10 +11 +12 +16 +17 +Case 1:22-cV-10904-JSR Document 265-1 Filed 08/07/23 Page 4 of 40 +5 +B +Reason +D +Date +F +8 +10 +== +13 +14 +5 +16 +17 +18 +19 +20 +2 + + +Case 1:22-cV-10904-JSR Document 265-1 Filed 08/07/23 Page 5 of 40 +Reason +Date + + +Case 1:22-cV-10904-JSR Document 265-1 Filed 08/07/23 Page 6 of 40 +Reason +Date + + +Case 1:22-cV-10904-JSR Document 265-1 Filed 08/07/23 Page 7 of 40 +Reason +Date + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 8 of 40 +Reason +Date + + +Case 1:22-cV-10904-JSR Document 265-1 Filed 08/07/23 Page 9 of 40 +Reason +Date +7 + + +Case 1:22-cv-10904-JSR Document 265-1 +2008 +Filed 08/07/23 Page 10 of 40 +1 +2 +B +C +Reason +D +Date +E +F +3 +4 +5 + + +Case 1:22-cv-10904-JSR Document 265-1 +Filed 08/07/23 Page 11 of 40 +2008 +B +C +Reason +D +Date +E +F +8 +9 +10 +11 +12 +13 + + +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 12 of 40 +2008 +B +C +Reason +D +Date +E +F +14 +15 +16 +17 +- +18 +10 + + +19 +20 +21 +22 +23 +24 +25 +21 +Jeffrey Epstein +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 13 of 40 +B +C +Reason +D +Date +mar +Epstein was sentanced to 12 +months in jail for solicitation of a +prostitute and six months for +procuring a person under the age +of 18 for prostitution followed by +12 months of house arrest. +7/15/2008 +Catherine will go back to JES to tell him +ve are uncomfortable with Epstein and +do not want to go to Cutler for approval +- +- +11 +F + + +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 14 of 40 +2008 +11/24/2008 +Not approved. +12 + + +35 +36 +37 +38 +39 +40 +41 +42 +34 +35 +36 +37 +38 +39 +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 15 of 40 +2008 +B +C +Reason +D +Date +E +F +13 + + +3 +6 +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 16 of 40 +1 +ClienuProspect +Reason +D +Date +E +G +Follow up +Y/N +Follow up +Complete +YN +F/U Action, due date +- +1 +14 + + +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 17 of 40 +Item #l +B +Reason +D +Date +G +Follow up +Y/N +Follow up +Complete +Y/N +[F/U Action, due date +10 +12 + + +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 18 of 40 +Item #l +B +Reason +D +Date +F +G +Follow up +Y/N +Follow up +Complete +Y/N +(FIU Action, due date +15 +16 +17 +16 + + +Case 1:22-CV-10904-JSR Document265-1 Filed 08/07/23 Page 19 of 40 +C +Client/Prospect Category +D +Reason +Date +H +Follow up +Y/N +Follow up +Complete +YIN +F/U Action, due date +1 +17 + + +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 20 of 40 +C +Client/Prospect Category +D +Reason +E +Date +H +Follow up +Y/N +Follow up +Complete +F/U Action, due date +10 +11 +12 +- +14 +18 + + +Case 1:22-CV-10904-JSR Document265-1 +Filed 08/07/23 Page 21 of 40 +Client/Prospect Category +Reason +Date +Ourcome +Follow up +YIN +Follow up +Complete +Ell Action, due date +15 +16 +19 + + +19 +20 +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 22 of 40 +C +Client/Prospect Category +D +Reason +E +Date +H +Follow up +Y/N +1 +Follow up +Complete +YIN +FIU Action, due date +20 + + +Case 1:22-CV-10904-JSR Document265-1 +Filed 08/07/23 Page 23 of 40 +21 +Client/Prospect Category +Reason +Date +Follow up +YIN +Follow up +Complete +YIN +FAl Action, due date +22 +23 +23 +1 +• +25 +21 + + +Case 1:22-CV-10904-JSR Documen2265-1 +Filed 08/07/23 Page 24 of 40 +C +Client/Prospect Category +Reason +E +Date +H +Follow up +Y/N +Follow up +Complete +Y/N +F/U Action, due date +26 +• +27 +28 +29 +30 +22 + + +Case 1:22-CV-10904-JSR Document265-1 Filed 08/07/23 Page 25 of 40 +- +30 +C +Client/Prospect Category +D +Reason +Date +F +H +Follow up +Y/N +1 +Follow up +Complete +J +FIU Action, due date +31 +32 +2788=88÷= +23 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 26 of 40 +- +Client/Prospect Category +Reason +Date +Follow up +YIN +Follow up +Complete +Y/N +Fill Action, due date +2 +2 +Jeffrey Epstein +Existing Client +The Firm's AML Director (William +Langford) has expressed concern +over the possibility that Mr. +Epstein is under investigation for +human trafficking +1/7/2011 +Discussions to be held with Will am and AML Ops has conducted +Nina to determine how to approach the +extensive research to root out +issue with Jes Stakey, who is friends with clients involved in human +Epstein. He needs to understand the +trafficking. William Langford is +potential backlash to the firm given all of requiring that if the business +the work done to root out chents +decides to proceed, then reinvolved in human trafficking. +approval by Steve Cutler will be +required. +Y +3 +1/28/11 - Follow up to +see if meeting with Jes +has taken place and +the LOB's decision for +re-approval. +3/15/2011: +Paul Morris spoke with +JE. The SBLC wil not +be renewed. +3 +1 +24 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 27 of 40 +Client/Prospect Category +Reason +Date +H +Follow up +Y/N +9 +8 +1 +Follow up +Complete +YIN +F/U Action, due date +10 +11 +12 +13 +1 +1 +25 + + +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 28 of 40 +Client/Prospect Category +Reason +Date +G +H +Follow up +YIN +Follow up +Complete +YIN +F/U Action, due date +17 +18 +19 +21 +26 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 29 of 40 +Client/Prospect Category +Reason +Date +G +H +Follow up +YIN +Follow up +Complete +YIN +F/U Action, due date +22 +23 +22 +Jeffrey Epstein +Existing Client - 4th follow-up +874/2011 +Review with John Duffy. +Duffy to reach out to Jes Staley and +advise that we exit while things are a bit +settled. +• +27 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 30 of 40 +Client/Prospect Category +Reason +Date +G +Follow up +YIN +Follow up +Complete +YIN +F/U Action, due date +28 +29 +- +30 +28 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 31 of 40 +Client/Prospect Category +Reason +Date +G +H +Follow up +YIN +Follow up +Complete +YIN +F/U Action, due date +35 +8=8235 +29 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 32 of 40 +Client Prospect +Category +ECI +Reason +Date +Follow up +YIN +Foles up +Complete FA Action, che date +Reputational Risk Cite. +Minutes Written +30 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 33 of 40 +Client Prospect +Category +Reason +Date +Follow up +Follow up +Complete +YIN +Reputational Risk Cite. +FAJ Action, due date +31 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 34 of 40 +Item $ +Client Prospect +Client Prospect +Category +Reason +Date +Aditions Comments +Follow up +YIN +Follow up +Complete +YIN +Reputational Risk Cite. +(FAJ Action, due date +Minutes Written +32 + + +Case 1:22-cV-10904-JSR Document 265-1 Filed 08/07/23 Page 35 of 40 +Client Prospect +Category +Reason +Date +Follow up +YN +- +Follow up +Complete +YIN +Reputational Risk Cite. +(FAJ Action, due date +Minutes Written +1 +33 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 36 of 40 +Client Prospect +Category +Reason +Actional Commenta +Follow up +YN +Folow up +Complete +YIN +Reputational Risk Cite. +| FAJ Action, due date Minutes Written +19 +20 +21 +1 +34 + + +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 37 of 40 +Item $ +27 +D +ECI +Category +Reason +F +Date +Follow up +YIN +Follow up +Complete +Reputational Risk Che. +|F/U Action, due date Minutes Written +27 +28 +29 +30 +31 +32 +33 +34 +35 +36 +37 +38 +39 +40 +41 +35 + + +Case 1:22-cv-10904-JSR Document, 265-1 Filed 08/07/23 Page 38 of 40 +Hern # +B +D +ECI +Client Prospect +Category +Reason +Date +G +Follow up +Y/N +Follow up +Complete +YIN +Reputational Risk Ctte. +F/U Action, due date Minutes Written +36 + + +Case 1:22-cv-10904-JSR Document 265-1 Filed 08/07/23 Page 39 of 40 +Hem # +Category +ECI +Reason +Date +1 +Follow up +Y/N +Follow up +Complete +Reputational Risk Ctte. +FIJ Action, due date +Minutes Written +1 +37 + + +14 +15 +Case 1:22-CV-10904-JSR Document 265-1 Filed 08/07/23 Page 40 of 40 +Client Prospect +Category +ECI +Reason +Date +G +Follow up +Y/N +Follow up +Complete +YIN +Reputational Risk Cite. +F/U Action, due date Minutes Written +• +38 \ No newline at end of file diff --git a/vision-fixhub/court-05/570f56557aae9e8aa59e44dabf986834b2b0489f4877f4e432a1736496624d03.receipt.json b/vision-fixhub/court-05/570f56557aae9e8aa59e44dabf986834b2b0489f4877f4e432a1736496624d03.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a3668eada0f880f6f41c887f1649589fb80d3f4a --- /dev/null +++ b/vision-fixhub/court-05/570f56557aae9e8aa59e44dabf986834b2b0489f4877f4e432a1736496624d03.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -3023, + "dataset": "marble-joined", + "doc_id": "570f56557aae9e8aa59e44dabf986834b2b0489f4877f4e432a1736496624d03", + "engine": "marble-apple-vision", + "event_count": 44, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "bbf70039cb3e1bdbdfa4e041e5d839b0073a9effeb78280efd5a420dfa28f5d9", + "output_sha256": "99bfa6a536b4c1fcdfecbcc99ae95c111696fbd2a41853e9cf5c4c5d11d37058", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/57112bdc9cb2163419e0fa728bb688919ecf229196c6694169c262d6233c17cf.md b/vision-fixhub/court-05/57112bdc9cb2163419e0fa728bb688919ecf229196c6694169c262d6233c17cf.md new file mode 100644 index 0000000000000000000000000000000000000000..cfbea706a2ae1767755dace741952555170e30bc --- /dev/null +++ b/vision-fixhub/court-05/57112bdc9cb2163419e0fa728bb688919ecf229196c6694169c262d6233c17cf.md @@ -0,0 +1,2403 @@ +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 1 of 77 + +to Government's Second Amended +Complaint against JPMorgan Chase +Bank, N.A. + + +IN THE SUPERIOR COURI +OF THE VIRGIN ISLANDS +FILED +November 30, 2022 12:02 PM +SI-2020-CV-00014 +TAMARA CHARLES +CLERK OF THE COURT +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 2 of 77 +IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS +DIVISION OF ST. +AND ST. JOHN +.. ... +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +PLAINTIFF, +Case No.: ST-20-CV-14 +ACTION FOR DAMAGES +JURY TRIAL DEMANDED +V. +DARREN K. INDYKE, in his individual capacity +and in his capacity as the EXECUTOR FOR THE +ESTATE OF JEFFREY E. EPSTEIN and +ADMINISTRATOR OF THE 1953 TRUST; +RICHARD D. KAHN, in his individual capacity and +in his capacity as the EXECUTOR FOR THE +ESTATE OF JEFFREY E. EPSTEIN, and +ADMINISTRATOR OF THE 1953 TRUST; +ESTATE OF JEFFREY E. EPSTEIN; THE 1953 +TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; +NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, +Inc.; SOUTHERN TRUST COMPANY, INC.; +CYPRESS, INC.; MAPLE, INC.; LAUREL, INC.; +AND JOHN AND JANE DOES, +DEFENDANTS. +SECOND AMENDED COMPLAINT +COMES NOW, the Government of the United States Virgin Islands ("Government") and +files this Second Amended Complaint containing information that has become known through +further investigation and third-party discovery and in support thereof, would show unto the Court +as follows: +JURISDICTION AND PARTIES +1. The Attorney General of the United States Virgin Islands (herein after "Virgin +Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 3 of 77 + +to 3 V.I.C. § 114 and 14 V.I.C. §607 and her statutory authority to enforce the laws of the Virgin +Islands, and advocate for the public interest, safety, health and well-being of persons in the +Virgin Islands. +2. +This Court has subject matter jurisdiction over this civil matter pursuant to 4 +V.I.C. § 76 and 14 V.I.C. § 607. +3. +This Court has personal jurisdiction over the parties pursuant to 5 V.I.C. § 4903. +4. +The Virgin Islands is an unincorporated territory of the United States. It consists +of St. +St. Croix, St. John, and Water Island, and more than 40 surrounding islands and +Cays, some of which are privately owned. Among these privately owned islands are Little St. +James and Great St. James. +Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he +maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also +purchased Great St. James. +6. +Epstein registered as a sex offender in the Virgin Islands in 2010. He was a Tier 1 +offender under Virgin Islands law based upon his Florida conviction of procuring a minor for +prostitution. As a Tier 1 offender, Epstein was required to register annually with the Virgin +Islands Department of Justice ("VIDOJ") and give advance notice of his travel to and from the +Virgin Islands. Epstein was also subject to random address verification by VIDOJ. +7. +Epstein was found dead on August 10, 2019 while in custody in New York for sex +crimes. +8. +Defendant Darren K. Indyke ("Defendant Indyke") is co-executor of the Estate of +Jeffrey E. Epstein and Administrator of The 1953 Trust and was and/or is a participant in the +activity of the "Epstein Enterprise," as set forth below. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 4 of 77 + +9. +Defendant Richard D. Kahn ("Defendant Kahn") is co-executor of The Estate of +Jeffrey E. Epstein and Administrator of The 1953 Trust and was and/or is a participant in the +activity of the "Epstein Enterprise," as set forth below. +10. +Defendants Indyke and Kahn, in addition to administering the Estate under the +laws of the Virgin Islands, engaged in conduct in the Virgin Islands through their participation in +businesses, financial transactions, and accounts registered, held, and operating in the Virgin +Islands, and by filing documents with the Government of the Virgin Islands. +11. +Defendant, the Estate of Jeffrey E. Epstein ("Estate"), created upon Epstein's death, +is domiciled in the Virgin Islands. On August 15, 2019, Defendants Indyke and Kahn filed a +Petition for Probate and Letters Testamentary which included Epstein's last will and testament +with the Probate Division of the Superior Court of the Virgin Islands. +12. The Petition reported the value of the real and personal property in The Estate +located in the Virgin Islands at $577,672,654.00 dollars. +13. According to the Petition, the assets in the Virgin Islands thus far included: +a. $56.5 million in cash; +b. $127 million in fixed income and equity investments; +c. $195 million in hedge fund and private equity investments; and +d. $18.5 million in planes, boats, and automobiles. +The Estate did not originally value his fine arts, antiques, and other valuables. +14. +The Estate also included shares of various corporate entities which hold residences +and real property used by Epstein, namely: +a. Brownstone in New York City valued at $56 million; +b. Ranch in New Mexico valued at $72 million; + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 5 of 77 + +c. Gated home in Palm Beach, Florida, valued at $12 million; +d. Seven units in an apartment building in Paris, valued at $8 million; and +e. Great St. James and Little St. James, collectively valued at $86 million. +15. +At the time of this Second Amended Complaint filing, the Estate's most recent +accounting, filed February 1, 2021, valued its total assets at $240,782,955.84, which is almost 60% +lower than the Estate's starting valuation less than 18 months earlier when Defendants Indyke and +Kahn began their Co-Executorship of the Estate. +16. The Estate is responsible to pay penalties and damages for the acts committed by +Epstein and the Epstein Enterprise described below. +17. +Defendant The 1953 Trust ("The Trust") was created by Epstein, who "amended +and restated" its terms only two days before his suicide. That same day, Epstein revised his Last +Will and Testament, transferring all of his "property, real and personal, wherever situated" to The +Trust. The Trust also contains Epstein's financial assets and is also responsible to pay damages +for the acts committed by Epstein and the Epstein Enterprise described below. Defendants +Indyke and Kahn, filed a Certificate of Trust in the Superior Court of the Virgin Islands for The +Trust on August 26, 2019. +18. +Epstein maintained a deliberately complex web of Virgin Islands corporations, +limited liability companies, foundations, and other entities, not all of which are yet known to the +Government of the Virgin Islands, through which he carried out and concealed his criminal +conduct. +19. +Epstein regularly created new entities in the territory and transferred properties +and funds between them in order to preserve and shield Epstein's assets and to facilitate and +conceal the unlawful acts described in this Complaint. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 6 of 77 + +20. These entities held properties, including Little St. James and Great St. James, at +which Epstein trafficked and sexually abused women and underage girls. Epstein owned and +arranged for private planes, helicopters, boat and automobiles to transport victims to, from, and +within the Virgin Islands, and provided money to pay these young women and underage girls. +21. +Epstein sat at the hub of this web, serving as president, member, manager, or +director of each of the entities and, upon information and belief, directing their activities. +22. +Defendant, Nautilus, Inc., is a corporation established and organized under the +laws of the Virgin Islands. It was incorporated on November 22, 2011. +23. +According to records of the Virgin Islands Recorder of Deeds, Nautilus, Inc. owns +Little St. James, a/k/a Parcel Number 109803010100, a parcel of 3.1 million square feet valued +at $3.2 million, with buildings and improvements valued at $4 million. +24. +Epstein was president and director of Nautilus, Inc., which corporate filings +describe as "holding property for personal use." Defendants Indyke and Kahn are the secretary +and treasurer of Nautilus, Inc., respectively. The Estate values Epstein's holdings of Nautilus, +Inc., which holds title to Little St. James at $63.9 million. +25. A deed recorded with the Virgin Islands Recorder of Deeds on December 30, +2011 reflects that the property was transferred from a Delaware entity, L.S.J., LLC, to Nautilus, +Inc. for "TEN DOLLARS ($10.00) and other good and valuable consideration." The quitclaim +deed lists Jeffrey Epstein as the sole member of L.S.J., LL.C, which it acquired Little Saint James +via a warranty deed dated April 27, 1998. +26. +As described below, Epstein engaged in a pattern and practice of trafficking and +sexually abusing young women and female children on this private, secluded island of Little St. +James where Epstein and his associates could avoid detection of their illegal activity from Virgin + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 7 of 77 + +Islands and federal law enforcement and prevent these young women and underage girls from +leaving freely and escaping the abuse. +27. +Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing +Epstein's crimes, hence Little St. James became an instrumentality of those crimes. +28. +Defendant, Great St. Jim, LLC, is a limited liability company established and +organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26, +2015. Great St. Jim, LLC, according to records of the Virgin Islands Recorder of Deeds, owns at +least three properties that make up Great St. James acquired on January 28, 2016: Parcel Number +109801010100, consisting of 3.5 million square feet and valued at $17.5 million; Parcel Number +109801010200, consisting of 450,000 square feet of land, valued at $2.8 million; and Parcel +Number 109801010300, 1.2 million square feet of land, valued at $2.7 million. According to a +warranty deed filed with the Virgin Islands Recorder of Deeds, Epstein, through Great St. Jim, +LLC, acquired the last two parcels for $5 million each. +29. +Epstein is listed as manager and a member of Great St. Jim, LLC and the nature of +its business is described as "holding assets." Upon information and belief, Epstein purchased +these Great St. James properties— the island with closest proximity to Little St. James to further +shield his conduct on Little St. James from view, prevent his detection by law enforcement or the +public, and allow him to continue and conceal his criminal enterprise. Epstein's significant +investment in the purchase of Great St. James demonstrates his intent to expand his illegal +operation in the Virgin Islands for years to come. Thus, Great St. Jim, LLC participated in +carrying out, concealing, facilitating and continuing Epstein's crimes, and Great St. James became +an instrumentality of those crimes. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 8 of 77 + +30. Defendant, Poplar, Inc., is a corporation established and organized under the laws +of the Virgin Islands. Poplar, Inc. was incorporated on November 22, 2011. Epstein was +president and director of Poplar, Inc., and its purpose was described in corporate filings as +"holding property for personal use." Defendants Indyke and Kahn are secretary and treasurer of +Poplar, Inc., respectively. +31. +A certificate of incumbency provided to the Department of Planning and Natural +Resources ("DPNR") also lists Epstein as president of Poplar, Inc. and expressly authorizes the +incorporators to conduct "transactions related to permitting matters submitted on behalf of Great +St. Jim, LLC." +32. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, +LLC, and the signature appears to be Epstein's. The Petition for Probate and Letters Testamentary +filed by The Estate lists Poplar, Inc. as holding title to Great St. James. Thus, Poplar, Inc. +participated in carrying out, concealing, facilitating and continuing Epstein's crimes. +33. Defendant, Plan D, LLC is a limited liability company established and organized +under the laws of the Virgin Islands. In its original Articles of Organization, filed October 19, +2012, and Annual Report filings, Epstein's pilot, Larry Visoski, was listed as Plan D, LLC's sole +manager/member. However, the July 31, 2019 Annual Report revealed Epstein as the principal +behind Plan D, LLC. +34. +Upon information and belief, Plan D, LLC owns one or more of the airplanes and +helicopters that Epstein used to transport young women and children to and from the Virgin +Islands to carry out the criminal pattern of activity described below. Among the airplanes owned +by Plan D, LLC is a Gulfstream with N-number N212JE. Flight logs and travel notices indicate + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 9 of 77 + +that Epstein used this plane to traffic and transport and young women and underage girls to the +Virgin Islands. +35. +Defendant, Hyperion Air, LLC is a limited liability company established and +organized under the laws of the Virgin Islands on October 19, 2012. Jeffrey Epstein is a +manager/member of Hyperion Air, LLC, along with his pilot, Larry Visoski. The purpose of +Hyperion Air, LLC is listed in its Annual Report as "holding assets." +36. +Hyperion Air, LLC is the registered owner of a Bell helicopter with N-number +N33IJE and a Keystone helicopter with N-number N722JE. Upon information and belief, +Epstein used these helicopters to transport young women and underage girls between St. +and Little St. James. +37. +Defendant Southern Trust Company, Inc. was originally incorporated in the Virgin +Islands on November 18, 2011 as Financial Informatics, Inc., but changed its name to Southern +Trust Company in September 2012. Southern Trust Company is a tenant at American Yacht +Harbor in Red Hook, St. +and Epstein is a "passive investor" in IGY-AYH, d/b/a +American Yacht Harbor. By the end of 2013, according to its corporate filings, Southern Trust +Company has assets of $198.5 million; four years later, its assets reached $391.3 million. From +2011 until at least 2018, Jeffrey Epstein was the President/Director of Southern Trust Company, +and Defendants Kahn and Indyke were Treasurer/Director and Secretary/Director, respectively. +Epstein was the sole owner of Southern Trust Company. +38. +Defendant Cypress, Inc. is a Virgin Islands corporation that was formed and first +licensed in or about November 2011. As of December 31, 2018, Epstein was listed as +President/Director and Defendants and Co-Executors Indyke and Kahn were listed, respectively, +as Vice President/Secretary/Director and Treasurer/Director of Cypress, Inc. Cypress, Inc. owns + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 10 of 77 + +the property 49 Zorro Ranch Road in Stanley, New Mexico, which was transferred to it in or +about December 2011, shortly after it was incorporated. +39. +Defendant Maple, Inc. is a Virgin Islands corporation that was formed and first +licensed in or about November 2011. As of December 31, 2018, Epstein was listed as +President/Director and Defendants and Co-Executors Indyke and Kahn were listed, respectively, +as Vice President/Secretary/Director and Treasurer/Director of Maple, Inc. Maple, Inc. owns the +property 9 East 71st Street in New York, New York, which was transferred to it on or about +December 23, 2011, shortly after it was incorporated. +40. +Defendant Laurel, Inc. is a Virgin Islands corporation that was formed and first +licensed in or about November 2011. As of December 31, 2018, Epstein was listed as President/ +Director and Defendants and Co-Executors Indyke and Kahn were listed, respectively, as Vice +President/Secretary/Director and Treasurer/Director of Laurel, Inc. Laurel, Inc. owns the +property 358 Brillo Way in Palm Beach, Florida, which was transferred to it in or about +December 2011, shortly after it was formed. +41. +John and Jane Does represent individuals and entities whose identities or +involvement with Epstein are currently unknown. The Government of the Virgin Islands will +amend the Complaint to add these individuals and entities when discovered. +42. +The Attorney General brings this action to seck all remedies available to the +Government of the Virgin Islands in enforcing its laws and protecting the public interest and +public safety. These claims are distinct from, and are not intended to supplant, the claims of +victims who were unconscionably harmed by Jeffrey Epstein and his associates. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 11 of 77 + +FACTUAL ALLEGATIONS +A. The Conduct of the "Epstein Enterprise" in the Virgin Islands +43. +Epstein and his associates, including Defendants, identified and recruited female +victims, including children, and transported them to the Virgin Islands where they were abused +and injured. Epstein, through and in association with Defendants, trafficked, raped, sexually +assaulted and held captive underage girls and young women at his properties in the Virgin Islands. +44. +Epstein created a network of companies and individuals who participated in and +conspired with him in a pattern of criminal activity related to the sex trafficking, forced labor, +sexual assault, child abuse, and sexual servitude of these young women and children. Epstein and +his associates trafficked underage girls to the Virgin Islands, held them captive, and sexually +abused them, causing them grave physical, mental, and emotional injury. +45. +To accomplish his illegal ends, Epstein formed an association in fact with +multiple Defendants and others (both companies and individuals) who were willing to +participate in, facilitate, and conceal Epstein's criminal activity in exchange for Epstein's +bestowal of financial and other benefits, including sexual services and forced labor from +victims. +46. +This illicit association of Epstein, Defendants, and his associates constitute what +is referred to herein as the "Epstein Enterprise." Epstein's associates in the Epstein Enterprise, +including, but not limited to, those named as Defendants knowingly facilitated, participated in, +and concealed Epstein's illegal conduct. +47. +Epstein used his wealth and power to create the Epstein Enterprise which +engaged in a pattern of criminal activity in the Virgin Islands by repeatedly procuring and + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 12 of 77 + +subjecting underage girls and young women to unlawful sexual conduct, sex trafficking, and +forced labor. +48. +The Epstein Enterprise engaged in a pattern of criminal activity in the Virgin +Islands (and elsewhere) with the criminal purpose and goal of placing a steady supply of +vulnerable female children and young women into sexual servitude in service of Epstein's +desires, and those of his associates. The Epstein Enterprise maintained and made available +young women and underage girls for the purpose of engaging them in forced labor and sexual +activities and used coercion and deception to procure, abuse, and harbor its victims. +49. +Flight logs and other sources establish that between 2001 and 2019 the Epstein +Enterprise transported underage girls and young women to the Virgin Islands, who were then taken +via helicopter or private vessel to Little St. James where they were then deceptively subjected to +sexual servitude, forced to engage in sexual acts and coerced into commercial sexual activity +and forced labor. +50. +In furtherance of its criminal activities, the Epstein Enterprise used its aircrafts +to transport the young women and underage girls to the Virgin Islands for purposes of sexual +abuse and exploitation. +51. +The Epstein Enterprise facilitated and participated in the sexual molestation and +exploitation of numerous girls between the age of 12 and 17 years old. +52. +On the pretext of providing modeling opportunities, careers and contracts, +associates of the Epstein Enterprise, funded by the Epstein Enterprise, lured and recruited young +women and underage girls to travel to locations including the Virgin Islands where, upon +information and belief, based on the pattern and practice of the Epstein Enterprise, they were +sexually abused and exploited. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 13 of 77 + +53. +Associates in the Epstein Enterprise recruited both victims and abusers into the +Epstein Enterprise, participated in sexual acts of rape and abuse of minors and witnessed +Epstein and others engage in sexual acts with children. +54. +As recent as 2018, air traffic controllers and other airport personnel reported +seeing Epstein leave his plane with young girls some of whom appeared to be between the age +of 11 and 18 years. +55. +Upon information and belief, based on Epstein's pattern of trafficking and +sexually abusing young girls, the Epstein Enterprise trafficked and abused these girls, and +others, in the Virgin Islands through 2018. +56. +When sued in civil court for committing sex trafficking and sex crimes, Epstein +never denied engaging in sexual acts with underage females and procuring underage females for +prostitution, but instead consistently invoked his Fifth Amendment privilege against selfincrimination. +57. +Upon information and belief, the Epstein Enterprise kept a computerized list of +underage girls who were in or proximate to the Virgin Islands, and able to be transported to +Epstein's residence at Little St. James in the Virgin Islands. +58. +The Epstein Enterprise engaged in a pattern of criminal conduct by trafficking +children and young women and placing them in sexual servitude and forced labor in the Virgin +Islands. The Epstein Enterprise repeatedly violated 14 V.I.C. §§ 133 to 138, which prohibit +trafficking and sexual abuse. The Epstein Enterprise also repeatedly violated laws against child +abuse and neglect, including 14 V.I.C. § 505, which defines the crime of child abuse as knowingly +or recklessly causing "a child to suffer physical, mental, or emotional injury," or causing a child to +be placed in a situation where such injury is foreseeable, and 14 V.I.C. § 506, which applies, as + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 14 of 77 + +here, where the child suffers serious physical, mental, or emotional injury as a result of that abuse. +The harm to Epstein's victims was both fully foreseeable and deeply damaging. +59. +The Epstein Enterprise knowingly recruited, transported, transferred, harbored, +received, procured, obtained, isolated, maintained, and enticed young women and girls to +engage in forced labor (such as providing massages) and, ultimately, sexual servitude at his little +St. James residence. +60. +A 15-year old victim was forced into sexual acts with Epstein and others and then +attempted to escape by swimming off the Little St. James Island. Epstein and others organized a +search party that located her and kept her captive by, among other things, confiscating her passport. +Another victim, who was first engaged in provide massages to Epstein, was then forced to +perform sexual acts at Little St. James in the Virgin Islands. When she attempted to escape the +"private island," Epstein and a search party found her, returned her to his house, and suggested +physical restraint or harm if she failed to cooperate. +61. +Another victim was flown by Epstein and his associates to New York or Palm +Beach and then to the Virgin Islands dozens of times from 2004, when she was age 20, to 2017. +She was repeatedly abused by Epstein and also was pressed to have sex with Epstein's business +colleagues. +62. +During the latter part of this period, she was forced into an arranged marriage to +another victim that was facilitated by Defendant/Co-Executor Indyke to prevent the other victim +from being deported. Indyke and a New York immigration lawyer retained by Epstein prepared +the victim for communications with U.S. immigration officials almost immediately after the +wedding. Defendant/Co-Executor Kahn provided a letter of reference for the immigration +proceeding. When the victim inquired about ending the marriage and leaving Epstein's circle, + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 15 of 77 + +Indyke repeatedly tried to talk her out of a divorce and threatened that she would lose Epstein's +and his associates' protection. +63. +The Epstein Enterprise forced at least three separate arranged marriages, in each +case requiring American female victims to marry foreign victims to avoid their deportation. The +victims were coerced into to participating in these arranged marriages, and understood that there +would be consequences, including serious reputational and bodily harm, if they refused to enter +a marriage or attempted to end it. In each instance, Indyke and Kahn knowingly facilitated the +fraudulent and coerced marriages, performing and securing the legal and accounting work +involved and enabling a fraud that would further bind Epstein's victims to him and enable +Epstein to continue to control and abuse these victims sexually. +64. +The Epstein Enterprise deceptively lured underage girls and women into its +sex trafficking ring with money and promises of employment, career opportunities and +school assistance. The Epstein Enterprise preyed on their financial and other vulnerabilities, +and promised victims money, shelter, gifts, employment, tuition and other items of value. +For example, participants in the Epstein Enterprise targeted young and underage females +under the pretext that they would be paid substantially merely to provide massages to him +and others. However, once drawn in, victims were then pressured and coerced to engage in +sexual acts. +65. +The Epstein Enterprise forced underage victims to recruit others to perform +services and engage in sexual acts—a trafficking pyramid scheme. +66. +The Epstein Enterprise paid girls for each "meeting," with additional money if +they brought additional girls. Epstein reportedly required three meetings per day. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 16 of 77 + +67. +The Epstein Enterprise used the term "work" as a code for sexual abuse, and, +upon information and belief, reportedly kept computer records of the contact information for the +victims. +68. +Consistent with his creation and use of a complex web of entities to carry out +and conceal the criminal trafficking enterprise in the Virgin Islands, the Epstein Enterprise +sometimes paid young women and underage girls he exploited and trafficked through his +charitable foundations. +69. +Once the girls and women were recruited, participants in the Epstein Enterprise +enforced their sexual servitude of victims by coercion, including but not limited to, confiscating +passports, controlling and extinguishing external communications, and threatening violence. +They also made fraudulent statements to family members of victims, claiming victims were +being well cared for and supported financially in college and other educational opportunities. +70. +One of the victims, who was flown by Epstein and his associates to the Virgin +Islands dozens of times up until as late as 2017, described how Epstein exercised strict control +over her and other victims' activity. The girls had to give notice if they left the main residence +and were kept to a rigid set of roles and rules. Epstein brought victims to business meetings, +where they were often required to massage his feet or run errands. Victims had to use Epsteinapproved doctors and sign consent forms for access to their medical records. Epstein also +required them to give him their email passwords. Each of these was a means of demonstrating +and reinforcing his control over the women and girls. +71. +During this time period through 2017, this vietim observed a succession of girls +and young women who were transported to Little St. James and while there were called into +Epstein's office or sauna to engage in sexual acts. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 17 of 77 + +72. +Another victim, who was brought to Little St. James more than 50 times during +the years 2000 to 2002, when she was 17 to 19 years old, was required to have sexual relations +with "guests" of Epstein, and was subjected to sexual abuse virtually every day, and on some +days, multiple times a day by Epstein or his guests. +73. +This victim, too, observed a large number of young women and girls around +Epstein at Little St. James. Many of them did not speak English, which was Epstein's preference +since they spoke less. +74. +Epstein sent these victims out to night clubs or on shopping trips to try to +identify and recruit other young women and girls, at times paying them a fee for each recruit. +75. +The Epstein Enterprise transported, held, sexually abused, trafficked, and +concealed women and children at his property in the Virgin Islands dozens of times over nearly +two decades. +B. Defendants and Co-Executors Indyke and Kahn were Instrumental to the +Epstein Enterprise's Human Trafficking and Financial Fraud. +76. +Defendants Kahn and Indyke organized, controlled, and directed almost every +aspect of the Epstein Enterprise. They were officers in virtually every corporate entity that +Epstein created to fund and conceal his activities. They were deeply involved in the financial +activities of the Epstein-owned entities, including those of Defendant Southern Trust Company, +which made clear that Southern Trust did not provide the services described to the Government +as the basis for tax incentives that allowed Epstein to fraudulently obtain more than $80 million +from the Government. +77. +Defendants Indyke and Kahn also directed, approved, enabled, and justified +millions of dollars in payments that fueled the Epstein Enterprise's sex trafficking, including + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 18 of 77 + +payments to women who were forced to have sex with Epstein and/or recruited others to be +victimized. Defendants Indyke and Kahn obtained large and frequent stocks of cash for Epstein +which, based on public knowledge, would have funded Epstein's cash payments for +"massages"-code for forced sex. +78. +Defendants Indyke and Kahn participated with Epstein in coercing his sex +trafficking victims, in at least three cases, to enter into arranged and forced marriages in order to +obtain immigration status for the foreign women so that they could continue to be available to +Epstein for his abuse - a doubly-deep assault on their will and dignity. Defendant Kahn +provided a letter of reference for at least one immigration application and tax services to the +spouses, and Defendant Indyke paid the immigration lawyer who applied for citizenship for the +women and threatened at least one who indicated that she would seek a divorce. They used +their professional skills and authority to carry out this abhorrent scheme. +79. +Indyke and Kahn were, in short, the indispensable captains of Epstein's criminal +enterprise, roles for which they were richly rewarded. +80. +Defendants Kahn and Indyke controlled and directed the activities of the other +entities and personal bank accounts of Epstein accounts after they were funded. One, and +frequently both, of them were officers or directors of Butterfly Trust; of companies holding +Epstein's real property (as laid out below); and of +FT Real Estate Inc.; Gratitude America, Inc.; +; J. Epstein Virgin +Islands Foundation, Inc.; Jeepers, Inc.; Mort, Inc.; Nautilus, Inc.; and Zorro Development +Corporation; among others. +81. +Along with their officer and director roles, Defendants Kahn and/or Indyke also +had signatory authority over virtually all of the accounts held by the Epstein Enterprise entities, + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 19 of 77 + +which allowed them to personally authorize and sign off on payments totaling hundreds of +thousands of dollars to the Enterprise's sex-trafficking and abuse victims, including those who +also acted as recruiters, and other expenses including legal fees, apartment rent, and tuition. +Further, they routinely withdrew cash in various ways, including ATMs, checks, or by +converting U.S. Dollars to Euros. In many instances, Kahn and/or Indyke structured these +transactions in order to evade the bank's reporting requirements. +82. +Defendant Kahn also oversaw the accounting and tax reporting for the other +entities in the Epstein Enterprise. As discussed below the "Tree entities," Laurel, Maple, and +Cypress, filed materially false and misleading financial statements by not including the +properties in other states they owned or related expenses. These financial statements were +submitted to the Office of Lieutenant Governor of the Virgin Islands and signed by Defendant +Kahn. In addition, in 2013, Defendant Kahn also directed the outside accountant not to report +the properties on their respective tax returns. +83. +The J. Epstein Virgin Islands Foundation, Inc. (the "Foundation") is a 501(c)(3) +tax-exempt private foundation that was founded in June 2000 and registered in the Virgin +Islands. +84. +As of October 23, 2007, Indyke was listed as President of the Foundation. • +85. +Between September 2015 and June 2019, Indyke +made +over a period of more than three and a half years until the middle of 2019. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 20 of 77 + +86. +In November 2017, Indyke +87. +These payments were inconsistent with the charitable purpose of the Foundation +and designed to serve the private benefit and criminal activities of Epstein and the Epstein +Enterprise. +88. +Earlier in 2017, Indyke signed a Foundation check for $160,000 to resolve a fine +Epstein had incurred for construction on Great St. James Island that violated Virgin Islands +environmental regulations and attempted to make the payment appear to be a charitable +donation. Over two years later, the Estate had to repay this amount to the Foundation after +questions were raised to Epstein's lawyer about the propriety of the Foundation payment. +89. +With help from Indyke and Kahn, Epstein established and operated separate +businesses through which he could pay victims and recruiters, and, upon information and belief, +which he used to maintain their immigration status. +90. +is a New York Limited Liability Company, the Articles of +Organization of which were filed in November 2014. The Articles list L +1. who was forced and +coerced to have sex with Epstein, +was manipulated, +exploited, and controlled by the Epstein Enterprise. +91. +According to +operating agreement, Kahn was to be the initial Manager of +the company, with full and complete authority, power, and discretion to do all things necessary +or convenient to manage, control, and carry out the business. Kahn also had signatory authority +for +bank accounts. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 21 of 77 + +92. +One of +bank accounts was funded entirely with money transferred from +Epstein's personal bank accounts. +93. +• payroll was paid to two persons, one of whom was the listed sole owner. +Kahn gave conflicting reports to +I bank about the second person on the company's payroll +and the reasons for its payments to her. Once, he described her as an +which +would justify the payments in light of +purported line of business, but which appears to +have been false. The other time, Kahn described this payroll recipient +which would +not justify +payments to her, but which appears to be true. +94. +LSJE, LLC is a Virgin Islands Limited Liability Company that was organized on +October 27, 2011. Defendants Indyke and Kahn were authorized signatories on the company's +checking account. +95. +Indyke and Kahn signed company checks for combined value of almost +$300,000 made out personally to young women or to, again, the immigration lawyer in New +York who was involved in one or more forced marriages arranged among Epstein's victims to +secure a victim's immigration status. +96. +Upon information and belief, after his guilty plea in Florida for soliciting +prostitution from a minor, Epstein began to focus on procuring and abusing women from +Eastern Europe. These women's immigration status and language barriers made them more +isolated, dependent, and vulnerable to Epstein's abuse and manipulation. +97. +The Butterfly Trust is a trust created for the benefit of numerous persons who +performed work for Epstein, including numerous young women with Eastern European +surnames and also including Indyke and Kahn themselves. Indyke and Kahn were authorized +signatories on the Trust's checking account. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 22 of 77 + +98. +Indyke and Kahn signed trust checks for combined value of over $1,000,000 +made out personally to young women, or their associated entities, who in some instances were +not beneficiaries of the trust. +99. +Defendants and Co-Executors Indyke and Kahn also were deeply involved with +transactions made in and out of Epstein's personal accounts, for which Indyke had signatory +authority, that were flagged by bank representatives and the New York Department of Financial +Services as potentially suspicious. +100. Indyke also engaged in repeated transactions that seem designed to have +provided Epstein with cash in small enough increments to avoid triggering financial reporting +requirements. It is well known that Epstein paid girls and women in cash for sexual encounters +that began as or were euphemistically described as massages, or for recruiting other girls to +provide such massages. +101. +On July 20, 2016, Indyke brought two checks to a branch teller window for +withdrawal, one for $7,500 drawn on Epstein's personal account and one for $4,000 drawn on +Indyke's business account. Indyke presented the $7,500 check for cashing and stated that he +would be cashing the other check the next business day to avoid all the paperwork. On July 21, +2016, Indyke returned to cash the $4,000 check. +102. +From June 2018 to February 2019, there was a series of 97 separate withdrawals +of $1,000 made from this account at an ATM that is a short walk from Indyke's law office. +103. +From this same account, Indyke wrote 11 checks, between April 2016 and April +2019, for the purpose of converting U.S. dollars to Euros totaling over $126,000. Some of the +checks contained the notation "Euros for safe." + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 23 of 77 + +104. +Also, Indyke withdrew large amounts of cash in single transactions. For +instance, on January 17, 2018, Indyke cashed a check for $100,000. Although Indyke cashed +the check, Kahn arranged with the Bank representative to have the cash ready for pickup. +105. Payments from this account, for which Indyke had signatory authority, totaling +over $2,500,000 were made to dozens of women with Eastern European surnames, purportedly +for hotel expenses, tuition, and rent, and to, again, the immigration lawyer in New York who was +involved in one or more forced marriages arranged among Epstein's victims to secure victims' +immigration status. +106. +For another of Epstein's personal accounts with the same bank, Indyke, from +2014 to 2016, made almost 45 separate check-cashing withdrawals at a pace of two to three per +month, each for the amount of $7,500, which was the bank's limit for third-party withdrawals. +107. From this same account, between June 2014 and September 2015, Indyke wrote +eight checks for the purpose of converting U.S. dollars to Euros. Each of the checks to +effectuate the conversion approximated $7,500, presumably in order to evade reporting +requirements, with some containing the notation "Euros for safe." +108. +Payments from this account totaling over $1,000,000 were made to dozens of +women with Eastern European surnames and to, again, the immigration lawyer in New York +who was involved in one or more forced marriages arranged among Epstein's victims to secure +a victim's immigration status. +109. +Indyke made wire transfers from another of Epstein's personal accounts with a +different bank totaling almost +between November 2016 and July 2019 (just before +Epstein's arrest) to + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 24 of 77 + +110. +which +From another of Epstein's personal accounts with another different bank, for +, someone acting on Epstein's behalf made a total of L +111. +Payments from this account totaling almost +112. +Upon information and belief, based on their authority for the accounts, their +interactions with the relevant banks, and records indicating that they made or approved the +transactions, these payments could have only been made with the knowledge and/or at the +direction of Indyke and Kahn. +113. +The sheer complexity of the infrastructure that Epstein set up and maintained +with the participation of Kahn and Indyke suggest their unlawful purpose. Based on the +Government's current knowledge, Epstein, with Kahn and Indyke, held and managed at least +140 different bank accounts for Epstein and Epstein-owned entities, many of which existed only +to transfer payments to other entities and accounts. +114. Kahn and Indyke profited substantially from their relationship with Epstein. +The amount of their payments is further evidence of the illicit nature of the work they +performed. +115. +From 2011 to 2019, Epstein and Epstein-owned entities paid over +• to Defendant/Co-Executor Indyke, and over +to Defendant/Co-Executor +Kahn. This includes +Based +on records obtained so far, + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 25 of 77 + +116. Indyke and Kahn were paid through multiple entities, including HBRK +Associates, Inc. (Kahn), Coatue Enterprises, LLC (Kahn), Birch Tree BR, LLC (Indyke) +Harlequin Dane, LLC (Indyke) and Darren K Indyke, PLLC, which functioned as shell +companies and engaged in no activities other than to coordinate the activities of Epstein's +Enterprise, including the receiving and sending money to other entities they held. +117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, +Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees +and costs of persons who-like the Co-Executors themselves—are alleged herein to have +participated in the criminal activity of the Epstein Enterprise. +C. The "Epstein Enterprise" Abused Privileges of Residency to Carry out its +Criminal Scheme +118. The Epstein Enterprise in 1998 acquired Little St. James in the Virgin Islands as +the perfect hideaway and haven for trafficking young women and underage girls for sexual +servitude, child abuse and sexual assault. Little St. James is a secluded, private island, nearly +two miles from St. +with no other residents. It can be visited only by private boat or +helicopter; no public or commercial transportation is available to carry persons on or off the +island, and no bridge connects the island to St. +1. Epstein had easy access to Little St. +James from the private airfield on St. +, only 10 minutes away by his private helicopter, +but the women and children he trafficked, abused, and held there were not able to leave without +his permission and assistance, as it was too far and dangerous to swim to St. +119. +In 2016, upon information and belief, using a straw purchaser to hide Epstein's +identity, the Epstein Enterprise acquired Great St. James the nearest island to Little St. James. By +then, Epstein was a convicted sex offender. Upon information and belief, the Epstein Enterprise + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 26 of 77 + +purchased the island for more than $20 million because its participants wanted to ensure that the +island did not become a base from which others could view their activities or visitors. By acquiring +ownership and control of Great St. James to the exclusion of others, the Epstein Enterprise created +additional barriers to prevent those held involuntarily on Little St. James from escaping or +obtaining help from others. +120. Great St. James and Little St. James are environmentally sensitive locations, with +native coral and wildlife protected by federal and territorial law and enforcement authorities. The +Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in +the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin +Islands. Under its authority, DPNR repeatedly issued citations and assessed thousands of dollars +of fines for violations of the Virgin Islands construction code and environmental protection laws +on both Little St. James and Great St. James-significant penalties to the agency and to the +average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had +little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its +activities to the law. +121. As a result of illegal construction activity of the Epstein Enterprise, the Virgin +Islands has incurred, and will incur, significant expenses to remove the illegal construction or +remediate its effects on natural resources in and around Little St. James and Great St. James. The +extent of the potential environmental damage is unknown at this time as the illegal construction +has not been removed or remediated +122. +The Epstein Enterprise continues to attempt to prevent or limit DPNR authorities +from conducting random inspections on the Little St. James and Great St. James necessary to +comply with Virgin Islands law. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 27 of 77 + +123. The Epstein Enterprise's violation of the construction and environmental laws was +part of a pattern of behavior in flouting the laws of the Virgin Islands and holding itself above the +law. Upon information and belief, as described above, the Epstein Enterprise undertook +construction at Great St. James after 2016 to continue the scheme to carry out and conceal his +trafficking and sexual abuse of young women and children in the Virgin Islands. These actions +are also indicative of the Epstein Enterprise's disregard for Virgin Islands' law. The Epstein +Enterprise used the Virgin Islands' land, resources, people, and laws for its illicit purposes. +Rather than participating lawfully in this community, the Epstein Enterprise took advantage of +the secluded nature of the islands in furtherance of its crimes. +124. As a result of its deplorable and unlawful conduct, the Epstein Enterprise has +subjected the Virgin Islands to public portrayals as a hiding place for human trafficking and sex +crimes. +D. The "Epstein Enterprise" Fraudulently Concealed its Conduct +125. The Epstein Enterprise fraudulently concealed its actions to prevent detection by +the Government of the Virgin Islands. +126. The secluded properties at Little St. James and Great St. James were repeatedly +used by the Epstein Enterprise as the locations for unlawfully soliciting, transporting, +transferring, harboring, receiving, providing, isolating, patronizing, maintaining, deceiving, +coercing, and sexually abusing young women and children and concealing these crimes. +127. The Epstein Enterprise was able to hide the trafficking ring from law +enforcement, despite the fact that Epstein was a registered sex offender. Given the isolation of +the Little St. James and Great St. James and the nature of the crimes and of the victims targeted +by the Epstein Enterprise, the activities of the Epstein Enterprise were not readily detectable. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 28 of 77 + +Moreover, Epstein's great wealth and power likely made witnesses reluctant to report their +observations to the local law enforcement. +128. +Upon information and belief, the Epstein Enterprise prevented its employees from +cooperating with law enforcement. Employees and others were required to sign confidentiality +agreements that prohibited them from speaking to or sharing information with law enforcement. +If they were contacted by law enforcement they were to notify the Epstein Enterprise and be +represented by Epstein's counsel. +129. The employees were directed not to communicate or interact with guests visiting +Little St. James and were also directed not to disclose to anyone events that occurred on the island. +130. Monitoring a sex offender with his own private islands and the resources to fly +victims in and out on private planes and helicopters presented unique challenges and allowed the +Epstein Enterprise to limit scrutiny by the Government of the Virgin Islands. +131. +Sexual Offender Registration and Community Protection Act ("SORCPA") 14 +V.I.C. § 1721, et. seq. requires sex offenders to register in their resident jurisdictions and to make +periodic in-person appearances to verify and update their registration information. +132. Epstein renewed his registration each year in the Virgin Islands. In addition, +beyond this statutory requirement, the Virgin Islands periodically visited or attempted to +visit-Little St. James to conduct additional address verifications. +133. At his last verification in July 2018, Epstein refused to permit Virgin Islands +Department of Justice Investigators, assisted by United States Marshals, to enter Little St. James +beyond its dock, claiming that the dock was his "front door." Instead, Epstein arranged to be met +at his office on St. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 29 of 77 + +134. +Epstein also misled the Government regarding his travel plans. On March 19, 2019, +the Virgin Islands was notified that Epstein would be traveling to France for 10 days on the private +plane owned by Plan D, LL.C. His notification form did not disclose travel to any other countries. It +was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco +during that trip. +135. +Similarly, the Epstein Enterprise sought to prevent DPNR from conducting +routine site visits to inspect unpermitted and potentially damaging construction activity on Great +St. James. The Epstein Enterprise repeatedly objected to DPNR's inspections referring to them as +"invasions" of Epstein's constitutional right to privacy in his home, which he described defined +as the entire island. These DPNR inspections are required for all construction and Virgin Islands +residents are required to cooperate with the inspections to assure compliance with the law +throughout the construction phases. +136. These efforts represent Epstein Enterprise's intent to conceal its unlawful activity +on Little St. James and Great St. James. +137. The Epstein Enterprise also created numerous corporations and limited liability +companies in the Virgin Islands to help conceal its unlawful activity. Most of these companies were +created in 2011 and 2012, soon after Epstein registered as a sex offender in the Virgin Islands. +138. +Epstein's pilot, Larry Visoski is identified as member or co-member in companies +that serviced and maintained the planes that the Epstein Enterprise used to traffick young women +and children — Freedom Air Petroleum, LLC (registered November 28, 2011 to hold assets); +and JEGE, LLC (registered October 19, 2012 to hold assets). + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 30 of 77 + +139. Other Epstein entities include LSJ Employees, LLC (registered October 27, 2011 +to provide services); Southern Financial, LLC (registered February 25, 2013 to provide services) +and LSJ Emergency, LLC (registered December 2, 2015 to provide services). +140. Some of these companies held considerable assets: Financial Informatics, Inc. +(incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of +approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November +6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012. +141. Though often absent in the original incorporation or registration documents or +annual filings, Epstein ultimately appeared as president, director, manager, or sole member of +each of these companies. Upon information and belief, the purpose of this complex array of +corporate entities- +-some of which may still be discovered —was to allow Epstein to shelter his +assets in order to fund, carry out, and conceal his identity and pattern of criminal conduct. +142. The Estate continues to engage in a course of conduct aimed at concealing the +criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an +Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior +Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to +be designed to "establish an independent and voluntary claims resolution program for purposes +of resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at 1). +143. +The program proposed by the Estate, whose executors are trustees of The 1953 +Trust and officers in at least two Epstein entities, imposes confidentiality requirements and +requires any claimant accepting an award under the program to sacrifice any other claims against +"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 31 of 77 + +conceal the criminal activities of the Epstein Enterprise and shield its participants from liability +and accountability for the injury they caused to the victims. +144. +The Estate also refused to agree to preserve documents or to release individuals +from the non-disclosure agreements. +145. +Two days before his death, Epstein amended The Trust and his Last Will and +Testament. Upon information and belief, he did so, as part of a pattern and ongoing effort to +conceal and shield his assets from potential recovery by claimants. +E. The "Epstein Enterprise" Violated Numerous Virgin Islands Laws +146. The pattern of criminal activity engaged in by Epstein and other participants in +the Epstein Enterprise violated 14 V.I.C. §§ 605 and 607 of the Criminally Influenced and +Corrupt Organizations Act ("CICO"). +147. +The Epstein Enterprise also violated Title 14, Chapter 3A, The Virgin Islands +Uniform Prevention of and Remedies for Human Trafficking Act relating to Trafficking of +Persons; Title 14, Chapter 24, relating to Child Protection and Child Abuse and Neglect; Title +14, Chapter 81, relating to Prostitution and Related Offenses; Title 18, Chapter 85, relating to +Rape and Sexual Assault and other related offenses, as well as other Virgin Islands laws. +148. +The Epstein Enterprise violated Virgin Islands laws by engaging in the human +trafficking of underage girls and young women and commercial sex with young women and +underage girls by force, fraud, enticement, or coercion, which serve as predicates to the Epstein +Enterprise's violations of CICO. +149. +Certain participants who recruited women and underage girls to be trafficked +and forced into sexual servitude themselves were sexually trafficked and abused by the Epstein +Enterprise and may be afforded the protections of 14 V.I.C. § 145. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 32 of 77 + +150. +Specifically, Plan D, LLC knowingly and intentionally facilitated the +trafficking scheme by flying underage girls and young women into the Virgin Islands to be +delivered into sexual servitude. Plan D LLC repeatedly made flights from the mainland to +St. +with Epstein and underage girls and young women for the purpose of engaging +in sexual activity on Little St. James. On some occasions, they would transport Epstein +and female children by helicopter to Little St. James. On other occasions, Epstein and the +young women and girls would be transported by boat. +151. +Great St. Jim, LIC and Nautilus, Inc. knowingly participated in the Epstein +Enterprise and facilitated the trafficking and sexual servitude of young women and underage +girls by providing the secluded properties at, from, or to which Epstein and his associates were +able to transport, transfer, receive, maintain, isolate, harbor, provide, entice, deceive, coerce, +and sexually abuse underage girls and young women. +152. +The Epstein Enterprise engaged in a continuing course of unlawful conduct. +153. +After Epstein's suicide, the Epstein Enterprise continued to exist as each of the +participants continued to conspire to prevent detection of the breadth and scope of the Epstein +Enterprise's criminal wrongdoing and to prevent accountability. These conspiratorial acts are +ongoing. +154. +The conduct of the Epstein Enterprise offends the core purpose of the Virgin +Islands Uniform Prevention of and Remedies for Human Trafficking Act, 14 V.I.C. §131 et seq, +and violates CICO, enacted to "curtail criminal activity and lessen its economic and political +power in the Territory of the Virgin Islands by establishing new penal prohibitions and +providing to law enforcement and the victims of criminal activity new civil sanctions and +remedies." 14 V.I.C. § 601. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 33 of 77 + +155. +The Epstein Enterprise is an illicit enterprise within the meaning of 14 V.I.C. §$ +604 and 605. +156. +The Government is entitled to recover civil penalties, damages and other +remedies and to extinguish and recoup from the Epstein Enterprise and its participants any and +all financial and other benefits, and any personal and real property that was used during the +course of, or intended for use in the Course of the conduct or criminal activity in violation of the +laws of the Virgin Islands. The Government is entitled to obtain through divestiture, forfeiture, +or other equitable relief all properties and instrumentalities used by the Epstein Enterprise in the +criminal pattern of trafficking and sexual abuse in the Virgin Islands, including but not limited +to Great St. James and Little St. James, and all other remedies and penalties permitted by law in +the interest of justice. +F. The Epstein Enterprise Used Corporate Entities to Defraud the Government +and Fund its Criminal Activities +1. Defendant Southern Trust Company, Inc. +157. +In October 2012, the Southern Trust Company applied for economic benefits +from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin +Islands Economic Development Authority ("EDA"), a semi-autonomous governmental +instrumentality created and governed pursuant to 29 VIC § 1101. +158. +In sworn testimony at a public hearing on the tax incentive application +conducted by the EDC on November 15, 2012, Epstein and his attorney, Ericka Kellerhals, +described Southern Trust Company as providing "cutting edge consulting services" in the area +of "biomedical and financial informatics." + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 34 of 77 + +159. The EDC granted Southern Trust Company a 10-year package of economic +incentives running from February 1, 2013 until January 31, 2023 that included a 90% +exemption from income taxes and 100% exemptions from gross receipts, excise, and +withholding taxes in the Virgin Islands. +160. Between 2013 and 2019, Southern Trust Company employed 13 different +individuals (not including Epstein). Of those 13 individuals, 11 served in administrative or +support roles: six as personal, administrative, or executive assistants, receptionists, or as a +driver/helper, one as an office manager, one as a clerk, and three in accounting or payroll +functions (though only one was licensed as a certified public accountant). There was one +network administrator/IT manager, and a second who was added in 2019. +161. +In fact, several of those individuals seemed to perform other personal services +for Jeffrey Epstein. Though he was reported by Southern Trust Company to be resident of the +Virgin Islands, the network administrator/IT manager was issued a Florida driver's license, +which listed an address in Miami. Further, he appears, in fact, to have served as Epstein's driver +and picked up luggage and cargo from Epstein's private planes on his behalf. +162. Another executive assistant lived at 301 E. 66th Street, Apartment 11B, New +York, New York. Epstein's address book lists various units in this building as providing "Apt. +for models" and she is publicly identified as a model. As noted above, the Epstein Enterprise +used modeling opportunities and contracts as a pretext for recruiting underage girls and young +women into its sex trafficking scheme. +163. +Financial records more recently obtained show that the employee described +above whom Kahn represented to be, alternatively, +• was also a + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 35 of 77 + +, which did not actually or even pretend to perform +either +1. in 2019. +164. +During several time periods, Southern Trust Company affirmed to EDC that it +had no employees who were non-residents, even though it employed non-residents. +165. +Southern Trust company does not appear to have had any clients and performed +no visible informatics services. According to financial records, it held no investments for others. +Instead, its employees performed tasks related to any number of other Epstein-owned companies +or properties, such as Little St. James. +166. +Despite having no visible clients and only one full-time employee working on +information technology during the bulk of the period, Southern Trust Company reportedly +generated net income of $50.3 million in 2013, $67.5 million in 2014, $52.8 million in 2015, and +$4.8 million in 2016 and $17.1 million in 2017, with aggregate income of $117.8 million in 2014, +$170.6 million in 2015, $175.3 million in 2016 and $192.4 million in 2017, or aggregate income +for the period of $656 million. +167. +Money received by Southern Trust was then funneled, frequently by Defendant +Indyke as authorized signatory, and often with copies given to Defendant Kahn, through other +Epstein-owned entities and accounts, funding payments to foreign women and for credit cards, +airplanes, and other instrumentalities of the Epstein Enterprise. +168. +In fact, the main source of funds for the Epstein Enterprise came from Southern +Trust. Between 2013 and 2017, Southern Trust reported approximately $184 million in +revenues. +169. +Defendants Kahn and Indyke directed and controlled the day-to-day activities of +Southern Trust in form and in substance, serving as members of its Board of Directors, along + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 36 of 77 + +with Epstein. Indyke was a signatory on Southern Trust's primary bank account to which funds +were wired, primarily from a single source, as described below. Kahn, as Southern Trust's +treasurer, oversaw its accounting, invoicing, and tax reporting. Indyke also authorized a +majority of the wire transfers from Southern Trust's bank account in order to fund the various +entities and personal bank accounts of Epstein, and had full inquiry capabilities over the +account. +170. +Bank records show that virtually all of Southern Trust Company's income came +from a single source (including related entities). +171. In all, the single source paid $158 million to Defendant Southern Trust Company +from 2013 to 2017, which constitutes 85% of the total revenues reported by Southern Trust +Company. These funds appear to have not been used to pay for informatics or datamining +services. +172. These payments to Southern Trust were the main source of funds for Epstein's +Enterprise. Indeed, no other entity in Epstein's Enterprise generated revenues. Funds received +from the single source were funneled, at the direction of Kahn and Indyke, to Epstein's personal +accounts, and other Epstein entities to fund his criminal activities. +173. +For the period between January 1, 2013 and December 31, 2017, Southern Trust +Company received tax exemptions totaling $73.6 million. +174. As of December 31, 2017, Southern Trust Company, Inc. elected to file its +income tax as an S-corporation, which elects to pass corporate income, losses, deductions and +credits through to its sole shareholder-Jeffrey Epstein +-for tax purposes. For this time period, +Epstein's income tax exemption was $71.3 million. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 37 of 77 + +175. +Including gross receipt taxes, the Government currently estimates that, as a +result of the EDC incentive, Epstein was able to avoid paying $80,576,236 in taxes. +176. +Based upon these facts, it is clear that Southern Trust Company did not perform +the "informatics" business represented to the EDC and could not have generated the business +income attributable to that business. Instead, upon information and belief, Southern Trust +Company existed to secure tax benefits for Epstein, to employ individuals associated with the +Epstein Enterprise, and to provide a source of income to support his criminal activities and +properties in the Virgin Islands. +2. +Defendants Cypress, Inc.; Maple, Inc.; and Laurel, Inc. +177. Epstein formed Cypress, Inc.; Maple, Inc.; and Laurel, Inc. as Virgin Islands +corporations in or about November 2011. +178. +As of December 31, 2018, Epstein was listed as President Director and +Defendants and Co-Executors Indyke and Kahn were listed, respectively, as Vice President/ +Secretary/Director and Treasurer/Director of each of Cypress, Inc.; Maple, Inc.; and Laurel, Inc. +179. +Defendant Cypress, Inc. acquired ownership of the property 49 Zorro Ranch +Road in Stanley, New Mexico in or about December 2011, shortly after Cypress was formed. +180. +Defendant Maple, Inc. acquired ownership of the property 9 East 7Ist Street in +New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple +acquired ownership of the property from Nine East 71st Street Corporation, which was owned by +Epstein. +181. +Defendant Laurel, Inc. acquired ownership of the property 358 Brillo Way in +Palm Beach, Florida in or about December 2011, shortly after Cyrpess was formed. Laurel +acquired ownership of the property from Epstein personally. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 38 of 77 + +182. +Epstein appears to have maintained divided ownership of these properties, +transferred ownership of them to the Virgin Islands, and then concealed this fact even from +Virgin Islands authorities in an attempt to shield the properties from any judgment in the states +where they are located. +183. +The financial statements submitted by each of these three Defendant corporations +to the Office of Lieutenant Governor of the Virgin Islands were false and misleading due to their +failure to include the above properties owned by each company or the related expenses incurred +by each company, such as property taxes. +184. +For instance, Cypress's Balance Sheet as of December 31, 2018 did not reflect +any assets other than cash of $18,824. Further, Cypress reported only $301 in expenses for the +year ended December 31, 2018, despite it paying +185. Similarly, in 2017, Cypress reported as its only asset cash in the amount of +$29,736 and expenses of $150, despite it paying +186. Similarly, for the tax years 2011 through 2016, Cypress did not include the value +of the New Mexico property in the total assets it reported and did not include any expenses +related to the New Mexico property in the total expenses it reported to the Government. +187. +Likewise, Maple's balance sheet as of December 31, 2018 did not reflect any +assets other than cash of $21,265. Further, Maple reported only $300 in expenses for the year +ended December 31, 2018, despite it paying + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 39 of 77 + +188. +Similarly, in 2017, Maple reported as its only asset cash in the amount of +$18,281 and expenses of $150, despite it paying +189. +Similarly, for the tax years 2011 through 2016, Maple did not include the value +of the New York property in the total assets it reported and did not include any expenses related +to the New York property in the total expenses it reported to the Government. +190. +Likewise, Laurel's balance sheet as of December 31, 2018 did not reflect any +assets other than cash in the amount of $20,155. Further, Laurel reported only $300 in expenses +for the year ended December 31, 2018, despite it paying +191. Similarly, in 2017, Laurel reported as its only asset cash in the amount of +$37,129 and expenses of $150, despite it paying +192. Similarly, for the tax years 2011 through 2016, Laurel did not include the value +of the Palm Beach property in the total assets it reported and did not include any expenses related +to the Palm Beach property in the total expenses it reported to the Government. +193. +Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the +reality of the above assets held or the above expenses incurred by each entity. +194. +The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were +signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL +STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING +DOCUMENTS, ARE TRUE AND CORRECT ..." + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 40 of 77 + +195. +In fact, Indyke and Kahn knew or should have known that their attestations were +false. Upon information and belief, particularly given the absence of any other justification for +these transactions and the fraudulent nature of their reporting, these transactions were made for +the sole purpose of sheltering these assets from collection. +STATUTES OF LIMITATIONS ARE TOLLED AND DEFENDANTS ARE ESTOPPED +FROM ASSERTING STATUTES OF LIMITATIONS AS DEFENSES +1. +Equitable Estoppel and Fraudulent Concealment +196. +Defendants are equitably estopped from relying upon a statute of limitations +defense for conduct that occurred prior to the limitation period because they undertook active +efforts to deceive the Government and to purposefully conceal their unlawful conduct and +fraudulently assure public authorities that their conduct was in compliance with the laws, all with +the goal of avoiding punishment. +197. Defendants were deliberate in taking steps to conceal their criminal sex +trafficking and abuse conduct and their fraudulent conduct in obtaining unearned tax benefits +from the Government. Defendants' acts of concealment include, but are not limited to, the +following. +198. +Defendants used Epstein's secluded island of Little St. James and his later +purchase of the nearby island of Great St. James to shield their trafficking and sexual abuse of +young women and female children from detection by law enforcement authorities and to prevent +their victims from escaping. +199. +Defendants used Epstein's private aircraft to transport young women and female +children to the Virgin Islands and to Little St. James while limiting public observation of this +trafficking activity. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 41 of 77 + +200. Defendants used Epstein's businesses and ostensibly charitable foundations in +the Virgin Islands to make payments to the victims who were trafficked and sexually abused +while concealing these payments from detection by law enforcement authorities. +201. +Defendants also prevented Epstein Enterprise entity employees from cooperating +with law enforcement by requiring them to sign confidentiality and non-disclosure agreements. +202. Defendants also actively obstructed law enforcement by denying investigators +access to Little St. James beyond its boat dock. +203. +204. +205. +206. +Defendants also concealed their fraud on the Government in obtaining unearned +tax benefits by providing false testimony and submitting false and inaccurate reporting to the +Economic Development Commission to prevent detection of Defendant Southern Trust +Company's non-compliance with requirements concerning the nature of its business and the +residency of the persons it employed +207. The discovery of the nature, scope, and magnitude of Defendants' unlawful +conduct and could not have been acquired earlier through the exercise of reasonable diligence. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 42 of 77 + +2. +Continuing Violations +208. +The continuous criminal conduct by the Defendants has caused repeated and +continuous injury. +209. +Defendants criminal trafficking and sexual abuse of young women and female +children in the Virgin Islands occurred continuously from Epstein's purchase of Little St. James +in 1998 through his arrest and death in prison in 2019. +210. +Flight logs and other sources establish that between 2001 and 2019, Defendants +transported young women and female children to the Virgin Islands, where they were then +transported by private helicopter or boat to Little St. James. +211. +Air traffic controllers and airport personnel have reported seeing, as recently as +2018, Epstein leaving his private jet with young girls who appeared to be between the ages of 11 +and 18 years. +212. One victim was brought by Defendants more than 50 times between 2000 and +2002, when she was around 18 to 20 years old, to Little St. James, where she was required to +have sexual relations with Epstein or his guests multiple times per day and where she saw large +numbers of other young women and female children subject to the same treatment. +213. +Another victim was brought by Defendants dozens of times between 2004 and +2017 to Little St. James, where she too observed a succession of young women and female +children who likewise were transported to the island and were required to have sexual relations +with Epstein and his guests. +214. +Defendants' fraud on the Government in obtaining unearned tax benefits through +Defendant Southern Trust Company likewise was continuous inasmuch as Southern Trust's +failure to perform the informatics services that it represented to the Economic Development + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 43 of 77 + +Commission and its false reporting of the residency and job descriptions of its employees were +continuous from the start of the tax benefits in 2013 through Epstein's arrest and death in prison +in 2019. +215. +The continued criminal conduct by Defendants has caused repeated and +continuous injury. The criminal conduct of the Epstein Enterprise was not completed nor were +all damages incurred until the wrongdoing ceased. +COUNT ONE +Human Trafficking — Trafficking an Individual +Violation of the Crimit.. Suened send CorruV. nizations Act "CICO", +216. +The Government restates and realleges paragraphs 1 to 215 of this Complaint as +if fully set forth herein. +217. +At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. +218. +The Epstein Enterprise engaged in two or more occasions of conduct that +constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly +recruiting, transporting, transferring, harboring, receiving, providing, obtaining, isolating, +maintaining, or enticing female children and young women in the furtherance and performance +of forced labor, sexual servitude and commercial sexual activity in violation of Virgin Islands +laws codified in 14 V.I.C. §$ 133-138. +219. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +220. +Defendants benefited, directly and indirectly, from the pattern of criminal + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 44 of 77 + +221. +At all times material herein, Defendants engaged in said pattern of criminal +activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO.14 V.I.C. §600 et seq. +COUNT TWO +Human Trafficking — Trafficking an Individual +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seq. and 14 V.I.C § 133 +222. +The Government restates and realleges paragraphs 1 to 221 of this Complaint as +if fully set forth herein. +223. +At all times material herein, each Defendant joined in a conspiracy to violate +laws prohibiting human trafficking. +224. Each Defendant engaged in acts that revealed its intent to join and participate in +the criminal conspiracy by recruiting, transporting, transferring, harboring, receiving, providing, +obtaining, isolating, maintaining or enticing female children and young women in the +furtherance and performance of forced labor, sexual servitude and commercial sexual activity in +violation of Virgin Islands laws codified in 14 V.I.C. § 133 - 138. +225. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands. +226. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 45 of 77 + +227. +At all times material herein, Defendants engaged in said pattern of criminal +activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation +of CICO. 14 V.I.C. §600 et seq. +COUNT THREE +Human Trafficking — Forced Labor +Violation of the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seq. and 14 V.I.C § 134 +The Government restates and realleges paragraphs 1 to 227 of this Complaint as +228. +if fully set forth herein. +229. +At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. +230. +The Epstein Enterprise engaged in two or more occasions of conduct that +constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly +using coercion to compel underage girls and young women to provide labor or services by +forced labor in violation of 14 V.I.C. § 134. +231. +The Epstein Enterprise knowingly provided or obtained the labor services of +individuals by means of force, threats of force, physical restraint, and/or threats of physical +restraint; by means of serious harm or threats of serious harm; by means of abuse or threatened +abuse of law or legal processes; and by means of the Epstein Enterprise with the intent to cause +individuals to believe that, if individuals did not perform such labor or services, individuals +would suffer serious harm or physical restraint. +232. +Defendants through a pattern of criminal activity directly and indirectly +participated in or associated with the Epstein Enterprise, an illicit enterprise. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 46 of 77 + +233. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +234. +Defendants benefited, directly and indirectly, from the pattern of criminal +235. +At all times material herein, Defendants engaged in said pattern of criminal +activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation +of CICO. 14 V.I.C. §600 et seq. +COUNT FOUR +Human Trafficking — Forced Labor +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seq. and 14 V.J.C $ 134 +236. The Government restates and realleges paragraphs 1 to 235 of this Complaint as +if fully set forth herein. +237. At all times material herein, each Defendant joined in a conspiracy to violate +laws prohibiting human trafficking. +238. +Each Defendant engaged in acts that revealed its intent to join and participate in +the criminal conspiracy by knowingly using coercion to compel underage girls and young +women to provide labor or services by forced labor in violation of 14 V.I.C. § 134. +239. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 47 of 77 + +240. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, +241. +At all times material herein, Defendants engaged in said pattern of criminal +activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation +of CICO. 14 V.I.C. $600 et seq. +COUNT FIVE +Human Trafficking — Sexual Servitude +Violation of the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seq. and 14 V.I.C $ 135 +242. +The Government restates and realleges paragraphs 1 to 241 of this Complaint as +if fully set forth herein. +243. +At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. +244. +The Epstein Enterprise engaged in two or more occasions of conduct that +constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly +maintaining or making available minors for the purpose of engaging the minors in commercial +sexual activities or using coercion or deception to force young women to engage in commercial +sexual activity in violation of 14 V.I.C. § 135. +245. +On the pretext of providing modeling opportunities, careers and contracts, +Defendants facilitated the transporting or recruiting of young women and girls or lured and +recruited young women and underage girls to travel to the Virgin Islands where they engaged in +sexual acts with Epstein and others. In some instances, young women and underage girls were + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 48 of 77 + +given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts +with Epstein and others. +246. +Defendants through a pattern of criminal activity directly and indirectly +participated in or associated with the Epstein Enterprise, an illicit enterprise. +247. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +248. +Defendants benefited, directly and indirectly, from the pattern of criminal +249. +At all times material herein, Defendants engaged in said pattern of criminal +activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation +of CICO. 14 V.I.C. §600 et seq. +COUNT SIX +Human Trafficking — Sexual Servitude +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. $ 600 et seq. and 14 V.I.C § 135 +250. The Government restates and realleges paragraphs 1 to 249 of this Complaint as +if fully set forth herein. +251. +At all times material herein, each Defendant joined in a conspiracy to violate +laws prohibiting human trafficking. +252. +Each Defendant engaged in acts that revealed its intent to join the criminal +conspiracy by knowingly maintaining or making available minors for the purpose of engaging +the minors in commercial sexual activities or using coercion or deception to force young women +to engage in commercial sexual activity in violation of 14 V.I.C. § 135. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 49 of 77 + +253. +On the pretext of providing modeling opportunities, careers and contracts, +Defendants facilitated the transporting or recruiting of young women and girls or lured and +recruited young women and underage girls to travel to the Virgin Islands where they engaged in +sexual acts with Epstein and others. In some instances, young women and underage girls were +given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts +with Epstein and others. +254. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands. +255. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, +256. +At all times material herein, Defendants engaged in said pattern of criminal +activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation +of CICO. 14 V.I.C. §600 et seq. +COUNT SEVEN +Human Trafficking — Patronizing Minors and Victims of Sexual Servitude +Violation of the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seg. and 14 V.I.C §§ 136-37 +257. The Government restates and realleges paragraphs 1 to 256 of this Complaint as +if fully set forth herein. +258. +At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 50 of 77 + +259. +The Epstein Enterprise engaged in two or more occasions of conduct that +constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly +giving, agreeing to give, or offering to give items of value to young women and minors so that +the young women and minors would engage in commercial sexual activity with Epstein, other +Defendants, and other individuals in violation of 14 V.I.C. $$ 136-137. +260. +In some instances, young women and underage girls were given scholarships, +money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and +others. +261. +Defendants through a pattern of criminal activity directly and indirectly +participated in or associated with the Epstein Enterprise, an illicit enterprise. +262. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +263. +Defendants benefited, directly and indirectly, from the pattern of criminal +264. +At all times material herein, Defendants engaged in said pattern of criminal +activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation +of CICO 14 V.I.C. $600 et seq. +COUNT EIGHT +Human Trafficking — Patronizing Minors and Victims of Sexual Servitude +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seq. and 14 V.I.C §§ 136-37 +The Government restates and realleges paragraphs 1 to 264 of this Complaint as +265. +if fully set forth herein + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 51 of 77 + +266. +At all times material herein, each Defendant joined in a conspiracy to violate +laws prohibiting human trafficking. +267. +Each Defendant engaged in acts that revealed its intent to join and participate in +the criminal conspiracy by knowingly giving, agreeing to give, or offering to give items of value +to young women and minors so that the young women and minors would engage in commercial +sexual activity with Epstein, other Defendants, and other individuals in violation of 14 V.I.C. $$ +136-137. +268. +In some instances, young women and underage girls were given scholarships, +money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and +others. +269. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands. +270. At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, +forced labor, and sexual servitude. +271. +At all times material herein, Defendants engaged in said pattern of criminal +activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation +of CICO 14 V.I.C. §600 et seq. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 52 of 77 + +COUNT NINE +Child Abuse and Neglect—All Defendants Except Darren K. Indyke and Richard D. Kahn +in Their Individual Capacities +Violation of the Criminally Influenced and Corrupt Organization Act, +14 V.I.C. § 600 et seq. and 14 V.I.C $$ 505, 506 and 507 +272. +The Government restates and realleges paragraphs 1 to 271 of this Complaint as +if as if fully set forth herein. +273. +At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. +274. +The Epstein Enterprise engaged in two or more occasions of conduct that +constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly +or recklessly causing a child to suffer physical, mental or emotional injury, or knowingly or +recklessly causing a child to be placed in a situation where it is reasonably foreseeable that such +child may suffer physical, mental or emotional injury, in violation Virgin Islands criminal laws +prohibiting Child Abuse and Neglect in Title 14 V.I.C. § 500 et. seq. +275. +As a result of the Epstein Enterprise's actions numerous young girls suffered +serious physical, mental and emotional injury. +276. Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +277. +Defendants benefited, directly and indirectly, from the pattern of criminal +278. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. $600 et seq. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 53 of 77 + +COUNT TEN +Child Abuse and Neglect +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act +—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual +Capacities, +14 V.I.C. § 600 et seq. and 14 V.I.C §$ 505, 506 and 507 +279. +The Government restates and realleges paragraphs 1 to 278 of this Complaint as +if as if fully set forth herein. +280. +At all times material herein, each Defendant joined in a conspiracy to violate +laws prohibiting child abuse and neglect. +281. Each Defendant engaged in acts that revealed its intent to join and participate in the +criminal conspiracy as they knowingly or recklessly caused a child to suffer physical, mental or +emotional injury, or knowingly or recklessly caused a child to be placed in a situation where it is +reasonably foreseeable that such child may suffer physical, mental or emotional injury, in violation +Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Title 14 V.I.C. § 500 et seq. +282. +As a result of Defendants' actions, numerous young girls suffered serious +physical, mental and emotional injury. +283. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands. +284. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 54 of 77 + +285. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. §600 et seq. +COUNT ELEVEN +Aggravated Rape-All Defendants Except Darren K. Indyke and Richard D. Kahn in +Their Individual Capacities +Violation of the Criminally Influenced and Corrupt Organization Act, +14 V.I.C. § 600 et seq. and 14 V.I.C § 1700a +286. +The Government restates and realleges paragraphs 1 to 285 of this Complaint as +if fully set forth herein. +287. +At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. +288. +The Epstein Enterprise engaged in two or more occasions of conduct that +constitute criminal predicate acts as defined by CICO, including, but not limited to, conduct that +constituted or facilitated the rape of minors by force, intimidation, or the perpetrator's position +of authority over the victim. +289. Epstein and others, using force or intimidation, engaged in sexual intercourse +with underage girls without their consent in violation of 14 V.I.C. § 1700a. +290. +As a result of the Epstein Enterprise's actions, numerous underage girls suffered +serious physical, mental and emotional injury. +291. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +292. +Defendants benefited, directly and indirectly, from the pattern of criminal + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 55 of 77 + +293. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. §600 et seq. +COUNT TWELVE +Aggravated Rape +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, +—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual +Capacities, +14 V.I.C. § 600 et seq. and 14 V.I.C § 1700a +294. +The Government restates and realleges paragraphs 1 to 293 of this Complaint as +if fully set forth herein. +295. +At all times material herein, each Defendant joined in a conspiracy to violate +laws prohibiting aggravated rape. +296. +Each Defendant engaged in acts that revealed its intent to join and participate in +the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of minors +by force, intimidation, or the perpetrator's position of authority over the victim. +297. +Epstein and others, using force or intimidation, engaged in sexual intercourse +with underage girls without their consent in violation of 14 V.I.C. § 1700a. +298. +As a result of Defendants' actions, numerous underage girls suffered serious +physical, mental and emotional injury +299. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 56 of 77 + +300. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, +301. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. §600 et seq. +COUNT THIRTEEN +Rape in the Second Degree-All Defendants Except Darren K. Indyke and Richard D. +Kahn in Their Individual Capacities +Violation of the Criminally Influenced and Corrupt Organization Act, +14 V.I.C. § 600 et seq. and 14 V.I.C § 1702 +14 V.I.C. § 600 et seq. and 14 V.I.C § 1700a +302. +The Government restates and realleges paragraphs 1 to 301 of this Complaint as +if fully set forth herein. +303. At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. +304. +The Epstein Enterprise engaged in two or more occasions of conduct that +constitute criminal predicate acts as defined by CICO, including, but not limited to, conduct that +constituted or facilitated the rape of girls under 18 years of age. +305. +Epstein and others who engaged in rape were over 18 years old at the time of the +incidents. +306. +As a result of the Epstein Enterprise's actions, numerous minors suffered serious +physical, mental and emotional injury. +307. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 57 of 77 + +308. +Defendants benefited, directly and indirectly, from the pattern of criminal +309. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. §600 et seq. +COUNT FOURTEEN +Rape in the Second Degree +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, +—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual +Capacities, +14 V.I.C. § 600 et seq. and 14 V.I.C $ 1702 +310. +The Government restates and realleges paragraphs 1 to 309 of this Complaint as +if fully set forth herein. +311. +At all times material herein, each Defendant joined in a conspiracy to violate +laws prohibiting rape in the second degree. +312. Each Defendant engaged in acts that revealed its intent to join and participate in +the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of girls +under 18 years of age. +313. +Epstein and others who engaged in rape were over 18 years old at the time of the +incidents. +314. +As a result of Defendants' actions, numerous minors suffered serious physical, +mental and emotional injury. +315. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 58 of 77 + +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands. +316. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, +317. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. $600 et seq. +COUNT FIFTEEN +Unlawful Sexual Contact in the First or Second Degree-All Defendants Except Darren K. +Indyke and Richard D. Kahn in Their Individual Capacities +Violation of the Criminally Influenced and Corrupt Organization Act, +14 V.I.C. $ 600 et seg. and 14 V.I.C §§ 1708 and 1709 +318. +The Government restates and realleges paragraphs 1 to 317 of this Complaint as +if as if fully set forth herein. +319. At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. +320. The Epstein Enterprise engaged in two or more occasions of conduct that +constitute criminal predicate acts as defined by CICO, including, but not limited to, using or +facilitating the use of force or coercion to accomplish sexual contact or engaging in sexual +contact with a minor between 13 and 16 years of age. +321. +Epstein and others who engaged in the sexual contact were over 18 years old at +the time of the incidents. +322. +As a result of the Epstein Enterprise's actions numerous young women and +minors suffered serious physical, mental and emotional injury. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 59 of 77 + +323. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +324. +Defendants benefited, directly and indirectly, from the pattern of criminal +325. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO +14 V.I.C. $600 et seq. +COUNT SIXTEEN +Unlawful Sexual Contact in the First or Second Degree +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act +—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual +Capacities, +14 V.I.C. § 600 et seq. and 14 V.I.C $§ 1708 and 1709 +326. The Government restates and realleges paragraphs 1 to 325 of this Complaint as +if as if fully set forth herein. +327. +At all times material herein, each Defendant joined in a conspiracy to violate +laws prohibiting unlawful sexual contact. +328. +Each Defendant engaged in acts that revealed its intent to join and participate in +the criminal conspiracy by using or facilitating the use of force or coercion to accomplish sexual +contact or engaging in sexual contact with a minor between 13 and 16 years of age. +329. +Epstein and others who engaged in the sexual contact were over 18 years old at +the time of the incidents. +330. +As a result of Defendants' actions, numerous young women and minors suffered +serious physical, mental and emotional injury. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 60 of 77 + +331. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands. +332. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, +333. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO +14 V.I.C. $600 et seq. +COUNT SEVENTEEN +Prostitution and Keeping House of Prostitution +Violation of the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. $ 600 et seq. and 14 V.I.C. $$ 1622, 1624 +334. The Government restates and realleges paragraphs 1 to 333 of this Complaint as +if fully set forth herein. +335. +At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. +336. +The Epstein Enterprise engaged in two or more occasions of conduct that +constitute criminal predicate acts as defined by CICO, including the engaging in or facilitating +the knowing and/or reckless abuse of minors through the acts alleged herein. +337. +The Epstein Enterprise knowingly persuaded, induced, enticed, and/or coerced +women and children to travel to the Virgin Islands to engage in prostitution and/or sexual +activity, and/or attempted to do the same. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 61 of 77 + +338. +The Epstein Enterprise kept, maintained, and/or permitted his property at Little +St. James to be used for the purpose of prostitution, lewdness or assignation with knowledge or +reasonable cause to know the same. +339. +The Epstein Enterprise received or offered or agreed to receive women and +children at his property at Little St. James for the purposes of prostitution, lewdness or +assignation, and/or permitted women and children to remain there for such purposes. +340. +The Epstein Enterprise directed, took, transported, and or offered or agreed to +take or transport women and children to Little St. James with the knowledge or reasonable cause +to know that the purpose of such directing, taking or transporting was prostitution, lewdness or +assignation. +341. +The Epstein Enterprise knew or should reasonably have known that individuals +that were the subjects of the actions described in this Count were minors. +342. +As a result of Defendants' actions, numerous young women and minors suffered +serious physical, mental and emotional injury. +343. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +344. +Defendants benefited, directly and indirectly, from the pattern of criminal +345. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. $600 et seq. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 62 of 77 + +COUNT EIGHTEEN +Prostitution and Keeping House of Prostitution +Conspiracy to Via vite Crimesel, indue Videos lorra Dramizations Act, +The Government restated and realleges paragraph 1 to 345 of this Complaint as +346. +if fully set forth herein. +347. +At all times material herein, each Defendant joined a conspiracy to laws against +prostitution. +348. +Each Defendant engaged in acts that revealed its intent to join and participate in the +criminal conspiracy by engaging in or facilitating the persuasion, inducement, enticement or +coercion of women and children to travel to the Virgin Islands to engage in prostitution and/or +sexual activity, and/or attempted to do the same; keeping, maintaining, and/or permitting Epstein's +property at Little St. James, to be used for the purpose of prostitution, lewdness or assignation with +knowledge or reasonable cause to know the same; receiving, offering, or agreeing to receive +individuals at his property at Little St. James for the purposes of prostitution, lewdness or +assignation, and/or permitted women and children to remain there for such purposes; and directing, +taking, transporting, and/or offering or agreeing to take or transport women and children to Little +St. James with the knowledge or reasonable cause to know that the purpose of such directing, +taking or transporting was prostitution, lewdness or assignation, in violation of 14 V.I.C. $8 +1622 and 1624. +349. +Defendants knew or should reasonably have known that individuals that were +the subjects of the actions described in this Count were minors. +350. +As a result of Defendants' actions numerous young women and minors suffered +serious physical, mental and emotional injury. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 63 of 77 + +351. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands +352. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, +forced labor, and sexual servitude. 14 V.I.C. §604(i). +353. At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO +14 V.I.C. $600 et seq. +COUNT NINETEEN +Sex Offender Registry-Estate of Jeffrey E. Epstein +Violation of the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seq. and 14 V.I.C. $ 1721 et seq. +354. The Government restates and realleges paragraphs 1 to 353 of this Complaint as +if fully set forth herein. +355. +Epstein was required to, and did, register under the Virgin Islands Sexual +Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 +et seg. +356. +SORCPA requires that offenders required to register provide information +relating to intended travel in foreign commerce. +357. +On at least two occasions, Epstein traveled to Vienna and Monaco without +disclosing that travel to the Virgin Islands sex offender registry. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 64 of 77 + +358. +Epstein's failure to disclose this travel before, during, or even after his travel was +knowing. +359. +Epstein's violation SORPCA was part of a pattern of criminal activity that was +not isolated but was related to the affairs of the Epstein Enterprise. 14 V.I.C. §604(j). +COUNT TWENTY +Fraudulent Conveyance +Violation of the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seq. and 14 V.I.C. $$ 832-833 +360. +The Government restates and realleges paragraphs 1 to 359 of this Complaint as +if fully set forth herein. +361. +At all times material herein, each Defendant directly and indirectly participated +in or associated with the Epstein Enterprise, an illicit enterprise. +362. +Each Defendant engaged in two or more occasions of conduct that constitute +criminal predicate acts as defined by CICO, including, but not limited to transferring assets to +and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, +hinder or delay claims against them. +363. +Upon information and belief, in an effort to defeat the claims of creditors and +avoid the oversight of the court probating his estate, Epstein, days before his death, transferred +significant assets, including assets held by other Defendants, into The 1953 Trust. +364. +At the time of these transfers, Epstein had numerous actions pending against +him related to his trafficking and sexual assaults seeking financial judgments. +365. +Through these transfers, Epstein and the Epstein Enterprise fraudulently +removed property and effects beyond the jurisdiction of the probate court. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 65 of 77 + +366. +Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of +the property, real or personal, and/or the interests or rights arising out of property, contracts, or +conveyances of Epstein and the Epstein Enterprise. +367. Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or +delay creditors and claimants, including the Government of the Virgin Islands, in collecting on +their judgements, debts and demands +368. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +369. +Defendants benefited, directly and indirectly, from the pattern of criminal +370. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. §600 et seq. +COUNT TWENTY-ONE +Fraudulent Conveyance +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seq. and 14 V.I.C. $§ 832-833 +371. +The Government restates and realleges paragraphs 1 to 370 of this Complaint as +if fully set forth herein. +372. +At all times material herein, each Defendant joined in a conspiracy to commit +fraudulent conveyances. +373. +Each Defendant engaged in acts that revealed its intent to join and participate in +the criminal conspiracy, including, but not limited to, transferring assets to and between various + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 66 of 77 + +entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims +against them. +374. +Upon information and belief, in an effort to defeat the claims of creditors and +avoid the oversight of the court probating his estate, Epstein, days before his death, transferred +significant assets, including assets held by other Defendants, into The 1953 Trust. +375. +At the time of this transfer, Epstein had numerous actions pending against him +related to his trafficking and sexual assaults seeking financial judgments. +376. +Through this transfer, Epstein and the Epstein Enterprise fraudulently removed +property and effects beyond the jurisdiction of the probate court. +377. +Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of +the property, real or personal, and/or the interests or rights arising out of property, contracts, or +conveyances of Epstein and the Epstein Enterprise. +378. +Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or +delay the Government of the Virgin Islands and other creditors and claimants to collect on their +judgements, debts and demands. +379. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude and commercial sexual activity of girls and young women in +knowing or reckless disregard of the laws of the Virgin Islands. +380. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 67 of 77 + +381. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. §600 et seq. +COUNT TWENTY-TWO +Civil Conspiracy +382. +The Government restates and realleges paragraphs 1 to 381 of this Complaint as +if fully set forth herein. +383. +Defendants acted in concert and joined with others to perform the wrongful acts +identified in Counts 1 to 13, among others, concealing the sexual abuse of minor females by +unlawful means. +384. +Each co-conspirator knew, or in the exercise of reasonable care should have +known, about the conduct of the others and about the common unlawful scheme. +385. +These unlawful acts could not have been carried to the length and extent +accomplished without the common understanding shared by Epstein and the Epstein Enterprise +Defendants. +386. +Each of the Defendants had a duty to report, stop or terminate the wrongful +conduct, but instead each Defendant concealed, assisted and furthered the wrongful acts by use +of civil conspiracy. +387. +As a direct and proximate result of Defendants' conspiracy, the Virgin Island has +been injured. +388. +Each co-conspirator is jointly and severally liable for the acts alleged herein. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 68 of 77 + +COUNT TWENTY-THREE +Fraudulent Claims Upon the Government-Southern Trust Company, Inc. +Violation of the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. § 600 et seq. and 14 V.I.C. § 843 +389. +The Government restates and realleges paragraphs 1 to 388 of this Complaint as +if fully set forth herein. +390. +At all times relevant and material herein, each Defendant directly and indirectly +participated in or associated with the Epstein Enterprise, an illicit enterprise. +391. +Each Defendant engaged in two or more occasions of conduct that constitute +criminal predicate acts as defined by CICO, including, but not limited to, making fraudulent +claims upon the Government. +392. +The Epstein Enterprise misrepresented the purpose, activities, employment, and +income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax +incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the +Epstein Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern +Trust Company to employ, pay, and conceal the activities of participants in the criminal +activities of the Enterprise. +393. +The Epstein Enterprise made and presented an application for tax incentives, +testimony, and quarterly reports to the EDC, a commission of the Government, regarding the +Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly +and willfully falsified, concealed or covered up material facts regarding the Southern Trust +Company; made false or fraudulent statements or representations about the purpose, activities, +income, and employment of Southern Trust Company; and made and submitted false affidavits +knowing the same to contain any fraudulent or fictitious statement or entry. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 69 of 77 + +394. +These false statements and documents included affidavits, testimony, an +application, and other documents that misrepresented that Southern Trust Company was +engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of +providing consulting services in financial and biomedical informatics. +395. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude, and commercial sexual activity of underage girls and young +women in knowing and reckless disregard of the laws of the Virgin Islands. +396. +Defendants through a pattern of criminal activity acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or real property. +397. +Defendants benefited, directly and indirectly, from the pattern of criminal +398. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. § 600 et seq. +COUNT TWENTY-FOUR +Fraudulent Claims Upon the Government-Southern Trust Company, Inc. +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, +14 VI.C. $ 600 et seq. and 14 V.I.C. $ 843 +The Government restates and realleges paragraphs 1 to 398 of this Complaint as +399. +if fully set forth herein. +400. +fraudulent conveyances. +At all times material herein, each Defendant joined in a conspiracy to commit + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 70 of 77 + +401. +Each Defendant engaged in acts that revealed its intent to join and participate in +the criminal conspiracy, including, but not limited to, transferring assets to and between various +entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims +against them. +402. +The Epstein Enterprise misrepresented the purpose, activities, employment, and +income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax +incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstein +Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern Trust +Company to employ, pay, and conceal the activities of participants in the criminal activities of +the Enterprise. +403. +The Epstein Enterprise made and presented an application for tax incentives, +testimony, and quarterly reports to the EDC, a commission of the Government, regarding the +Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly +and willfully falsified, concealed or covered up material facts regarding the Southern Trust +Company; made false or fraudulent statements or representations about the purpose, activities, +income, and employment of Southern Trust Company; and made and submitted false affidavits +knowing the same to contain any fraudulent or fictitious statement or entry. +404. +These false statements and documents included affidavits, testimony, an +application, and other documents that misrepresented that Southern Trust Company was +engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of +providing consulting services in financial and biomedical informatics. +405. +Defendants knowingly benefited financially and/or obtained other non-financial +value from participation in the Epstein Enterprise, which has engaged in human trafficking. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 71 of 77 + +forced labor, sexual servitude, and commercial sexual activity of underage girls and young +women in knowing and reckless disregard of the laws of the Virgin Islands. +406. +At all times material herein, each Defendant conspired with Epstein and other +Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, +forced labor, and sexual servitude. 14 V.I.C. $604(j). +407. +At all times material herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of +CICO. 14 V.I.C. $600 et seq. +COUNT TWENTY-FIVE +Fraudulent Claims Upon the Government-Cypress, Inc.; Maple, Inc.; Laurel, Inc. +Violation of the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. $§ 600 et seq. and 14 V.I.C. $ 843 +408. The Government restates and realleges paragraphs 1 to 407 of this Complaint as if +fully set forth herein. +409. At all times relevant and material herein, each Defendant directly and indirectly +participated in or associated with the Epstein Enterprise, an illicit enterprise. +410. Each Defendant engaged in two or more occasions of conduct that constitute +criminal predicate acts as defined by CICO, including but not limited to making fraudulent +claims upon the Government. +411. +Defendants Cypress, Maple, and Laurel misrepresented the values of their assets +held and expenses incurred in their annual reporting to the Government of the United States +Virgin Islands for each of the tax years from 2011 to 2018. +412. +Defendant Cypress misrepresented the value of its assets held during each of these +years by omitting the value of the 49 Zorro Ranch Road, Stanley, New Mexico property that it + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 72 of 77 + +acquired in or about December 2011, and misrepresented the value of its expenses incurred +during each of these years by omitting the annual amounts of property taxes it paid for the New +Mexico property. +413. +Defendant Maple misrepresented the value of its assets held during each of these +years by omitting the value of the 9 East 71st Street, New York, New York property that it +acquired in or about December 2011, and misrepresented the value of its expenses incurred +during each of these years by omitting the annual amounts of property taxes it paid for the New +York property. +414. +Defendant Laurel misrepresented the value of its assets held during each of these +years by omitting the value of the 358 Brillo Way, Palm Beach, Florida property that it acquired +in or about December 2011, and misrepresented the value of its expenses incurred during each of +these years by omitting the annual amounts of property taxes it paid for the Palm Beach property. +415. +Epstein and Defendant/Co-Executor Kahn signed each of Cypress, Maple, and +Laurel's annual reports for these years in which they represented that "ALL STATEMENTS +CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE +TRUE AND CORRECT.... +416. Epstein appears to have maintained divided ownership of these properties, +transferred ownership of them to the Virgin Islands, and then concealed this fact even from +Virgin Islands authorities in an attempt to shield the properties from any judgment in the states +where they are located +417. +Defendants' knowingly and willfully made false representations to the +Government regarding the assets and expenses of Cypress, Maple, and Laurel, and their conduct + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 73 of 77 + +in failing to inform the Government of each company's true assets and expenses, constitute fraud +upon the Government. 14 V.I.C. § 843. +418. +Defendants, through a pattern of criminal activity, acquired and maintained, +directly or indirectly, an interest in or control of the Epstein Enterprise or of real property. +419. +Defendants benefitted directly and indirectly from the pattern of criminal activity +conducted by the Epstein Enterprise. Defendants knowingly benefitted financially and/or +obtained non-financial value from participation in the Epstein Enterprise, which has engaged in +human trafficking, forced sexual servitude, and commercial sexual activity of underage girls and +young women, in knowing and reckless disregard of the laws of the Virgin Islands. +420. At all material times herein, Defendants engaged in a pattern of criminal activity +that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO, +14 V.I.C. §$ 600 et seq. +COUNT TWENTY-SIX +Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. +Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. §§ 600 et seq. and 14 V.I.C. § 843 +421. The Government restates and realleges paragraphs 1 to 420 of this Complaint as if +fully set forth herein. +422. At all material times herein, each Defendant engaged in a conspiracy to commit +fraudulent conveyances. +423. Each Defendant engaged in acts that revealed its intent to join and participate in +the criminal conspiracy, including, but not limited to, transferring assets to and between various +entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder, or delay claims +against them. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 74 of 77 + +424. These false statements and documents included annual financial statements for the +years 2011 to 2018 submitted by each Cypress, Maple, and Laurel to the Office of Lieutenant +Governor of the Virgin Islands that misrepresented the value of the assets held and the amount of +the expenses incurred by each company during each of these years. +425. Epstein appears to have maintained divided ownership of these properties, +transferred ownership of them to the Virgin Islands, and then concealed this fact even from +Virgin Islands authorities in an attempt to shield the properties from any judgment in the states +where they are located. +426. +Defendants knowingly benefitted financially and/or obtained other non-financial +value from their participation in the Epstein Enterprise, which has engaged in human trafficking, +forced labor, sexual servitude, and commercial sexual activity of underage girls and young +women, in knowing and reckless disregard of the laws of the Virgin Islands. +Notice of Allegation of +PUNITIVE DAMAGES +427. +The purpose of punitive damages in the common law is to punish the defendant +for outrageous conduct that is reckless or intentional and to deter others from engaging in such +conduct in the future. +428. +This Complaint describes intentional conduct so egregious, persistent, and +injurious that it shocks the conscience and offends a civilized society. +429. +Punitive damages are especially important in the case of persons or companies +that have so money, assets, and power that mere fines, penalties, and economic damages are +simply not sufficient. + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 75 of 77 + +430. +At all times material herein, Epstein and the Epstein Enterprise engaged +repeatedly in wrongful acts which were intentional and outrageous. The Government gives +notice that it intends to pursue the possibility of punitive damages in any jury verdict. +PRAYER FOR RELIEF +WHEREFORE, the Government respectfully requests that the Court: +A. +Enter a judgment in favor of the Government and against Defendants on all +counts; +B. +Declare that Defendants, through the Epstein Enterprise, have engaged in a +pattern of criminal activity in the Virgin Islands including but not limited to human trafficking, +forced labor and sexual servitude of female children and young women, unlawful sexual contact, +child sexual abuse, child abuse and neglect, rape, prostitution civil conspiracy and other offenses +related offenses, and civil conspiracy; +C. +Pursuant to 14 V.I.C. § 610, enforce and maintain the criminal activity liens the +Government is filing contemporaneously with this lawsuit, or shall file in connection with this +action: +D. +Pursuant to 14 V.I.C. § 607(a)(1) and 14 V.I.C. § 141, issue an order forfeiting +and divesting in favor of the Government of the Virgin Islands all of Defendants' interests in any +real and personal property used to facilitate the criminal enterprise carried out by the Epstein +Enterprise, including but not limited to Little St. James Island and Greater St. James Island; +Issue an order forfeiting to the Government of the Virgin Islands any proceeds or +funds obtained by Defendants, whether directly or indirectly, during the course of the criminal +activity of the Epstein Enterprise; + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 76 of 77 + +F. +Pursuant to 14 V.I.C. § 607(a)(1), require Defendants to divest themselves of any +real property or other interests in favor of the Government of the Virgin Islands used to further +the goals of the Epstein Enterprise; +G. +Pursuant to 14 V.I.C. § 607(a)(3) and (5), order the dissolution of the Epstein +Enterprise, including but not limited to, order the dissolution of the corporate Defendants; +H. +Pursuant to 14 V.I.C. § 607(a)(2) enter an injunction to prevent the further +criminal conduct, and concealment of the criminal conduct, by the Epstein Enterprise; +I. +Pursuant to 14 V.I.C. § 607(a)(4), order the revocation of any and all licenses, +permits and approvals that had been granted by any agency of the Territory, and require the +repayment of any tax benefits that had been bestowed on any Defendant; +J. +Pursuant to 14 V.I.C. §§ 607(a)(6) and 607(k), order all assets and funds of the +Estate of Jeffrey E. Epstein be placed into receivership; +K. +Pursuant to 14 V.I.C. § 607(e), award the Government the maximum civil +penalty for each and every violation of law committed by the Epstein Enterprise; +L. +Pursuant to 14 V.I.C. § 607, award treble damages and all other available +remedies, including attorneys' fees and costs; +M. +Award compensatory and punitive damages for Defendants' civil conspiracy; +N. +Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; +O. +Award such equitable relief, including disgorgement of all ill-gotten gains, as may +be just and proper and appropriate, pursuant to 14 V.I.C. § 608(c)(4), to protect the rights of +victims and innocent persons in the interest of justice and consistent with the purposes of CICO; +P. +Assess and award a judgment in favor of the Government and against the +Defendants for attorneys' fees and costs and pre- and post-judgment interest; and + + +Case 1:22-cv-10904-JSR Document 109-1 Filed 04/03/23 Page 77 of 77 + +Q. +Award any and all other relief this Court deems appropriate. +The Government demands a jury trial on all issues so triable. +RESPECTFULLY SUBMITTED, +DENISE N. +1. ESQ. +ATTORNEY GENERAL +Dated: February 10, 2021 +Is/ Carol +CAROL +1, ESQ. +Assistant Attorney General +Virgin Islands Department of Justice +Office of the Attorney General +34-38 Kronprindsens Gade +1 U.S. Virgin Islands 00802 +Email: +(340) 774-5666 ext. 10101 \ No newline at end of file diff --git a/vision-fixhub/court-05/57112bdc9cb2163419e0fa728bb688919ecf229196c6694169c262d6233c17cf.receipt.json b/vision-fixhub/court-05/57112bdc9cb2163419e0fa728bb688919ecf229196c6694169c262d6233c17cf.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..48e2efc2ac3cbd434529ffefea80db2851c317c0 --- /dev/null +++ b/vision-fixhub/court-05/57112bdc9cb2163419e0fa728bb688919ecf229196c6694169c262d6233c17cf.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -7659, + "dataset": "marble-joined", + "doc_id": "57112bdc9cb2163419e0fa728bb688919ecf229196c6694169c262d6233c17cf", + "engine": "marble-apple-vision", + "event_count": 156, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "c6e8950f9e7f657d79dd16be1236af1394c222c6667377766cc3e3e77975a94e", + "output_sha256": "d27dcba43ab4f95302acd5255da1425c5b1ec48f38ce48b4575c02a1909c61ad", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/57805aeb1fc2888c29c5628bb37fd9b4967caf56a99efce4366117d05169be2d.md b/vision-fixhub/court-05/57805aeb1fc2888c29c5628bb37fd9b4967caf56a99efce4366117d05169be2d.md new file mode 100644 index 0000000000000000000000000000000000000000..584cf01c0cd906e4fedc50ea5f04ab477c86ce95 --- /dev/null +++ b/vision-fixhub/court-05/57805aeb1fc2888c29c5628bb37fd9b4967caf56a99efce4366117d05169be2d.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 267-20 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/57805aeb1fc2888c29c5628bb37fd9b4967caf56a99efce4366117d05169be2d.receipt.json b/vision-fixhub/court-05/57805aeb1fc2888c29c5628bb37fd9b4967caf56a99efce4366117d05169be2d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..01a243aabe3f1e75640763952aaad48d67aaf9d6 --- /dev/null +++ b/vision-fixhub/court-05/57805aeb1fc2888c29c5628bb37fd9b4967caf56a99efce4366117d05169be2d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "57805aeb1fc2888c29c5628bb37fd9b4967caf56a99efce4366117d05169be2d", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "b52df0b6c32c424b798dff4d2a5d3ec7af03745ecc017dc7826ce0f7a5616592", + "output_sha256": "eefa5882599214c0bc2f1d1538b070e5e26e17366112802696e0534f88923853", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5798c503c5a932cf8d21ba4062881bfdbcdab04b224cfc5c5b5872a1c9ab5d54.md b/vision-fixhub/court-05/5798c503c5a932cf8d21ba4062881bfdbcdab04b224cfc5c5b5872a1c9ab5d54.md new file mode 100644 index 0000000000000000000000000000000000000000..39f26c8cf4547e7cb9d695a84a006246955ca1c1 --- /dev/null +++ b/vision-fixhub/court-05/5798c503c5a932cf8d21ba4062881bfdbcdab04b224cfc5c5b5872a1c9ab5d54.md @@ -0,0 +1,664 @@ +Ease 1:22-€v 10904:JSR Document 29-3Fifiled A2R2Ę3pâgg9 brof? +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Case Number: 1:22-cv-10904-JSR +PLAINTIFF, +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +22 PROTOSEDI ORDER FOR MOTION FOR ISSUANCE OF +LETTER OF REQUEST (LETTER ROGATORY) +Upon consideration of the Motion for Issuance of Letter of Request (Letter Rogatory) dated +January 20, 2023, the exhibits annexed thereto, and any oppositions or replies filed with respect to +the Motion, and it appearing that the testimony of and documents in the possession of Miles +Alexander, a resident of South Africa, is material and necessary to the issues of this action, the +Court hereby GRANTS the Motion and ORDERS as follows: +1. The Court will sign and shall issue the Letter of Request (Letter Rogatory) attached as +Exhibit 1 to the Motion to facilitate the taking of the deposition upon oral examination +of Miles Alexander as a witness in this action, as well as the production of documents +described in the Plaintiff's Motion and exhibits annexed thereto; +2. The Clerk of Court is hereby directed to take all necessary steps to ensure the Letter of +Request (Letter Rogatory) is transmitted to Plaintiff in a form sufficient to obtain the +described testimony and documents; and +1 + + +Ease 1:22-€V 10904-JSR Document 29-3Fifeled924233pAgg₴ 3f9f9 +3. The appropriate judicial authority in South Africa is hereby authorized to take and +report the deposition of Miles Alexander and shall have the power by virtue of the +Letter of Request (Letter Rogatory) to administer any necessary oath and to take and +report testimony. +SO ORDERED. +Dated: (/23/23 +New York, New York +Senior Judge +The United States District Court +for the Southern District of New +York +2 + + +Caste 11222ewv119004JS9R Domumeent297 FFridetl0C1Y2200238 FPagge 31cóf139 +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +MOTION FOR ISSUANCE OF LETTER OF REQUEST (LETTER ROGATORY) +NOW COMES, the Plaintiff, in the above referenced action, and moves for the Issuance of +a Letter of Request (Letter Rogatory) pursuant to F.R.C.P. 28 requesting an order requiring Cathy +Alexander, located at 7 Harmonie Crescent, Paradise Beach, Jeffreys Bay 6330, South Africa, to +do the following: +(a) Appear to have her remote deposition taken on a date to be agreed within 30 days of service +of the subpoena at a mutually convenient location in or near Jeffreys Bay; and +(b) Produce all Documents, Communications, and agreements related to her employment by +Jeffrey Epstein, including: +1. Employment and +agreements, +2. Non-disclosure agreements, +3. All payments, in any form, received from or on behalf of Jeffrey Epstein, and +4. All Communications with Jeffrey Epstein, Ghislaine Maxwell, Bella Klein, Daphne +Wallace. Harry Beller, Lesley Groff, +a/k/a +Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. +1 + + +Cane11222w10804J85R Dosumentt297 FFileO220223B FPaggee4af139 +As grounds for this Motion, the Plaintiff states the following: +1. The above captioned case is currently pending in the United States District Court for +the Southern District of New York. +2. Plaintiff alleges decedent Jeffrey E. Epstein ("Epstein") engaged in a criminal sexual +trafficking enterprise in the United States Virgin Islands, wherein he used his vast +wealth and property holdings and a deliberately opaque web of corporations and +companies to transport young women and girls to his privately owned islands where +they were held captive and subject to severe and extensive sexual abuse. Plaintiff +further alleges that Defendant JPMorgan Chase Bank, N.A. and its affiliates had actual +or constructive knowledge of Epstein's misconduct but nevertheless violated their +statutory duties to report suspicious transactions from accounts held by them. +3. Upon information and belief, Cathy Alexander was employed by decedent Epstein as +the house manager for his residence on Little St. James from approximately 1999 to +2007, and, as such, would have first-hand knowledge of Epstein's conduct and visitors +at Little St. James. +4. In order to prepare the case for trial, Plaintiff needs to the take the deposition of Cathy +Alexander. +WHEREFORE Plaintiff respectfully requests that this Honorable Court allow this Motion +and issue a Letter of Request (Letter Rogatory). A proposed Letter of Request (Letter Rogatory) +is attached to this Motion as Exhibit 1. +Dated: January 20, 2023 +CAROL +1 ESQ. +ACTING ATTORNEY GENERAL +/s/Linda +LINDA +2 +(NYS Bar #2473403) + + +Casee11222cwv109004185R Dootumeent297 Fiet01Y220283 FFaggee53cof139 +Admitted Pro Hac Vice +Motley Rice LLO +401 9t Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Isinger@motleyrice.com +CAROL +(NYS Bar #2941300) +Admitted Pro Hac Vice +Acting Attorney General of the United States +Virgin Islands +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +U.S. Virgin Islands 00802 +Tel.: (340) 774-5666 ext. 10101 +DAVID I. ACKERMAN (NYS Bar #4110839) +Motley Rice LLC +401 9* Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 849-4962 +dackerman@motleyrice.com +pboggs@motleyrice.com +CERTIFICATE OF SERVICE +I hereby certify that on January 20, 2023, the foregoing Plaintiff's Motion for Issuance of +Letter of Request (Letter Rogatory) was filed with the Clerk's Office using the CM/ECF system. +Notice of this filing will be sent to all parties of record by operation of, and parties may access this +filing through, the Court's CM/ECF system. +/s/Linda +Linda +3 + + +Case 1:22-0v-10904-JSR Document 291 Fifele 0D22023PA6 bot bfof5 + + + +Case 1:2204-1090 JSR Document 281 FI0121023 PeggY DIS +TO: +LETTER OF REQUEST (LETTER ROGATORY) +Clerk of Humansdorp Magistrate Court +Humansdorp Magistrate Court +Du Plessis St. +Humansdorp 6300 South Africa +RE: Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +In the United States District Court for the Southern District of New York +Civil Action No. 1:22-cv-10904-JSR +Dear Sir/Madam: +The above-captioned civil action is pending before the undersigned Judge of the United +ates District Court for the Southern District of New York. Plaintiff in the action seeks to obta +e deposition of Cathy Alexander and production of documents in her possessic +Thank you for your courtesy in this matter. +BY THE COURT +JED +RAKOFF, U.S.D.J. +Dated: +1/23/23 + + +Case 1:22 04-10904-JSR Document 291 Fifile 0122023 Page 8 BIlS +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +ACTION FOR DAMAGES +JURY TRIAL DEMANDED +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE +(LETTERS ROGATORY) +The United States District Court for the Southern District of New York presents its +compliments to the Humansdorp Magistrate Court of South Africa, and requests international +judicial assistance to obtain evidence to be used in a civil proceeding before this Court in the above +captioned matter. +This Court requests the assistance described herein as necessary in the interests of justice. +The assistance requested is that the appropriate judicial authority of South Africa compel the +appearance of the below named individual to give evidence and produce documents. +The aforesaid mentioned individual: +Cathy Alexander +Residing at: +7 Harmonie Crescent, Paradise Beach, Jeffreys Bay 6330, South Africa +This Court requests Cathy Alexander produce all Documents, Communications, and +agreements related to her employment by Jeffrey Epstein, including: employment and +1 + + +agreements; non-disclosure agreements; all payments, in any form, received from or on behalf of +Jeffrey E. Epstein; and all Communications with Jeffrey E. Epstein, Ghislaine Maxwell, Bella +Klein, Daphne Wallace, Harry Beller, Lesley Groff, +a/k/a +Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. +FACTS +The above-captioned case is currently pending in the United States District Court for the +Southern District of New York. +2. +Plaintiff alleges decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking +enterprise in the Virgin Islands, wherein he used his vast wealth and property holdings and a +deliberately opaque web of corporations and companies to transport young women and girls to his +privately-owned islands where they were held captive and subject to severe and extensive sexual +abuse. Plaintiff further alleges that Defendant JPMorgan Chase Bank, N.A. and its affiliates had +actual or constructive knowledge of Epstein's misconduct but nevertheless violated their statutory +duties to report suspicious transactions from accounts held by them. +3. +Upon information and belief, Cathy Alexander was employed by decedent Jeffrey E. +Epstein as the house manager for his residence on Little St. James from approximately 1999 to +2007, and, as such, would have first-hand knowledge of Epstein's conduct and visitors at Little St. +James. +4. +In order to prepare the case for trial, Plaintiff needs to the take the deposition of Cathy +Alexander. +5. +Plaintiff has previously attempted to obtain Cathy Alexander's deposition and run into +obstacles attempting to depose her. +2 + + +A Subpoena to Testify at a Deposition in a Civil Action is attached hereto, requesting Cathy +Alexander appear to have her deposition taken, at a location to be determined, and produce +documents thirty days after the date she is served with the Subpoena and Letter Rogatory. +The United States District Court for the Southern District of New York is willing to provide +similar assistance to judicial authorities of South Africa. The United States District Court for the +Southern District of New York is willing to reimburse the judicial authorities for costs incurred in +executing this Letters Rogatory. +Thank you for your courtesy in this matter. +BY THE COURT +Dated: January 23 +_ 2023 +JED S. RAKOFF. U.S.D.J. +United States District Court +For the Southern District of New York +United States Courthouse +500 Pearl Street +New York, NY 10007 +(212) 805-0401 Telephone +3 + + +@ase 122010904JSR Documen 29-2 ilere02412923 agagel 1061L9 +AO 88A (Rev. 12/20) Subpoena to Testify at a Deposition in a Civil Action +UNITED STATES DISTRICT COURT +for the +Southern District of New York +Government of the United States Virgin Islands +Plaintiff +V. +Civil Action No. 1:22-cv-10904-JSR +JPMorgan Chase Bank, N.A. +Defendant +To: +SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION +Cathy Alexander +(Name of person to whom this subpoena is directed) +• Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a +deposition to be taken in this civil action. If you are an organization, you must promptly confer in good faith with the +party serving this subpoena about the following matters, or those set forth in an attachment, and you must designate one +or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about +these matters: +Place: A mutually convenient location in or near +Jeffreys Bay, South Africa (remotely) +Date and Time: +Within 30 days after service of Subpoena +The deposition will be recorded by this method: videographically and stenographically +• Production: You, or your representatives, must also bring with you to the deposition the following documents, +electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the +material: See attached Exhibit A. +The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance; +Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to +respond to this subpoena and the potential consequences of not doing so. +Date: +01/20/2023 +CLERK OF COURT +OR +Signature of Clerk or Deputy Clerk +Is/Linda +Attoney's signature +The name, address, e-mail address, and telephone number of the attorney representing (name of party) +Plaintiff, +Government of the United States Virgin Islands +Linda +I Motley Rice LLC, 401 9th Street NW, Suite 630, Washington; DC 20814, (277936892 bpoena, are: +Isinger@motleyrice.com +Notice to the person who issues or requests this subpoena +If this subpoena commands the production of documents, electronically stored information, or tangible things before +trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to +whom it is directed. Fed. R. Civ. P. 45(a)(4). + + +@asse 12220410904JSR JSR Dodumnt29-Filerel10142923 agage220619 +AO 88A (Rev. 12/20) Subpoena to Testify at a Deposition in a Civil Action (Page 2) +Civil Action No. 1:22-cv-10904-JSR +PROOF OF SERVICE +(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) +I received this subpoena for (name of individual and title, if any) +on (date) +• I served the subpoena by delivering a copy to the named individual as follows: +on (date) +i or +• I returned the subpoena unexecuted because: +Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also +tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of +$ +My fees are $ +for travel and $ +for services, for a total of S +0.00 +I declare under penalty of perjury that this information is true. +Date: +Server's signature +Printed name and title +Server's address +Additional information regarding attempted service, etc.: + + +Ease 1:22010904-JSR Document 29-2FilE#0102422823P 949g3306f19 +AO 88A (Rev. 12/20) Subpoena to Testify at a Deposition in a Civil Action (Page 3) +Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13) +(c) Place of Compliance. +(1) For a Trial, Hearing, or Deposition. A subpoena may command a +person to attend a trial, hearing, or deposition only as follows: +(A) within 100 miles of where the person resides, is employed, or +regularly transacts business in person; or +(B) within the state where the person resides, is employed, or regularly +transacts business in person, if the person +(D) is a party or a party's officer; or +(il) is commanded to attend a trial and would not incur substantial +(i) disclosing a trade secret or other confidential research, development, +or commercial information; or +(il) disclosing an unretained expert's opinion or information that does +not describe specific occurrences in dispute and results from the expert's +study that was not requested by a party. +(C) Specifving Conditions as an Alternative. In the circumstances +described in Rule 45(d)(3XB), the court may, instead of quashing or +modifying a subpoena, order appearance or production under specified +conditions if the serving party: +(i) shows a substantial need for the testimony or material that cannot be +otherwise met without undue hardship; and +(ii) ensures that the subpoenaed person will be reasonably compensated. +(2) For Other Discovery. A subpoena may command: +tangible things at a place within 100 miles of where the person resides, is +employed, or regularly transacts business in person; and +(B) inspection of premises at the premises to be inspected. +(d) Protecting a Person Subject to a Subpoena; Enforcement. +(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney +responsible for issuing and serving a subpoena must take reasonable steps +to avoid imposing undue burden or expense on a person subject to the +subpoena. The court for the district where compliance is required must +enforce this duty and impose an appropriate sanction —-which may include +lost earnings and reasonable attorney's fees—-on a party or attorney who +fails to comply. +(2) Command to Produce Materials or Permit Inspection. +(A) Appearance Not Required. A person commanded to produce +documents, electronically stored information, or tangible things, or to +permit the inspection of premises, need not appear in person at the place of +production or inspection unless also commanded to appear for a deposition, +hearing, or trial. +(B) Objections. A person commanded to produce documents or tangible +things or to permit inspection may serve on the party or attorney designated +in the subpoena a written objection to inspecting, copying, testing, or +sampling any or all of the materials or to inspecting the premises +-or to +producing electronically stored information in the form or forms requested. +The objection must be served before the earlier of the time specified for +compliance or 14 days after the subpoena is served. If an objection is made, +the following rules apply: +(i) At any time, on notice to the commanded person, the serving party +may move the court for the district where compliance is required for an +order compelling production or inspection. +(ii) These acts may be required only as directed in the order, and the +order must protect a person who is neither a party nor a party's officer from +significant expense resulting from compliance. +(3) Quashing or Modifying a Subpoena. +(A) When Required. On timely motion, the court for the district where +compliance is required must quash or modify a subpoena that: +(i) fails to allow a reasonable time to comply; +(i) requires a person to comply beyond the geographical limits +(ill) requires disclosure of privileged or other protected matter, if no +exception or waiver applies; or +(iv) subjects a person to undue burden. +(B) When Permitted. To protect a person subject to or affected by a +subpoena, the court for the district where compliance is required may, on +motion, quash or modify the subpoena if it requires: +(e) Duties in Responding to a Subpoena. +(1) Producing Documents or Electronically Stored Information. These +procedures apply to producing documents or electronically stored +(A) Documents. A person responding to a subpoena to produce documents +must produce them as they are kept in the ordinary course of business or +must organize and label them to correspond to the categories in the demand. +(B) Form for Producing Electronically Stored Information Not Specified +If a subpoena does not specify a form for producing electronically stored +information, the person responding must produce it in a form or forms in +which it is ordinarily maintained or in a reasonably usable form or fons. +(C) Electronically Stored Information Produced in Only One Form. The +person responding need not produce the same electronically stored +information in more than one form. +(D) Inaccessible Electronically Stored Information. The person +responding need not provide discovery of electronically stored information +from sources that the person identities as not reasonably accessible because +of undue burden or cost. On motion to compel discovery or for a protective +order, the person responding must show that the information is not +reasonably accessible because of undue burden or cost. If that showing is +made, the court may nonetheless order discovery from such sources if the +requesting party shows good cause, considering the limitations of Rule +26(b)(2)(C). The court may specify conditions for the discovery. +(2) Claiming Privilege or Protection. +(A) Information Withheld. A person withholding subpoenaed information +under a claim that it is privileged or subject to protection as trial-preparation +material must: +(l) expressly make the claim; and +(il) describe the nature of the withheld documents, communications, or +tangible things in a manner that, without revealing information itself +privileged or protected, will enable the parties to assess the claim. +(B) Information Produced. If information produced in response to a +subpoena is subject to a claim of privilege or of protection as +trial-preparation material, the person making the claim may notify any party +that received the information of the claim and the basis for it. After being +notified, a party must promptly return, sequester, or destroy the specified +information and any copies it has; must not use or disclose the information +until the claim is resolved; must take reasonable steps to retrieve the +information if the party disclosed it before being notified; and may promptly +present the information under seal to the court for the district where +compliance is required for a determination of the claim. The person who +produced the information must preserve the information until the claim is +resolved. +(g) Contempt. +The court for the district where compliance is required —and also, after a +motion is transferred, the issuing court—may hold in contempt a person +who, having been served, fails without adequate excuse to obey the +subpoena or an order related to it. +For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013). + + +Ease 1:22810904-J8R Document29-2Fi|FN@|04422฿23P a9&gk4406fLg +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +THIS EXHIBIT MAY INCLUDE THE NAMES OF INDIVIDUALS WHO +ARE VICTIMS OF HUMAN TRAFFICKING OR SEXUAL ABUSE, AND +THEREFORE SHOULD BE TREATED AS CONFIDENTIAL +AND NOT PUBLICLY DISCLOSED. + +Definitions +Unless otherwise specified, the documents specified below are required to be produced for the +time period commencing January 1, 1998 and continuing through the present. Where +production of account data is provided in electronic format or media the preferred software +format to incorporate the data into is Microsoft Excel. +As used herein, the following terms are defined as indicated: +1. +"All/Each." The term "all" and "each" shall be construed as all and each. +2. "And/Or." The connectives "and" and "or" shall be construed either disjunctively or +conjunctively as necessary to bring within the scope of the discovery request all +responses that might otherwise be construed to be outside of its scope. +3. "Communication" means the transmittal of information (in the form of facts, ideas, +inquiries or otherwise). +4. The terms "Document" or "Documents" are defined to be synonymous and equal in +scope to the usage of these terms in Federal Rule of Civil Procedure 34(a), including, +without limitation, any written, drawn, printed, typed, photographed or other graphic or +electronically or computerized recorded data or compilations of any kind or nature +prepared or received by, or in the possession, custody or control of the answering party, +its agents, servants, employees or other representatives. Originals, drafts and all nonidentical copies are separate documents within the meaning of this term. +5. "Referring to", "relating to", "reflecting", "regarding" or "with respect to" mean, without +limitation the concepts: pertain to, deal with, concern, reflect, record, report, constitute, +contain, mention, describe, discuss, analyze, evaluate, estimate, study, survey, project, + + +Case 1:22-0v-10904-JSR Document 29-2Fileie010242DB23P agagt5500 119 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +assess, support, modify, contradict, criticize, summarize, comment, or otherwise involve, +in whole or in part. +6. "You" and "Your" shall mean Cathy Alexander. These terms also shall be deemed to +include all agents and other persons acting or authorized to act on her behalf. +Il. +Instructions +1. When providing Your responses, indicate the Request to which each Document or answer +responds in the metadata field, RequestNo. +2. Documents produced pursuant to these Requests shall be produced as they are kept in the +ordinary course of business. +3. For each Document that You produce, produce the current version together with all earlier +editions or predecessor Documents during the relevant time period, even though the title +of earlier Documents may differ from current versions. Format for Documents produced +electronically: +a. +b. +C. +d. +Data shall be produced in single page TIFFs at a 300 DPI resolution which +are named for the +Number of the page. There shall be no more than +1000 images per folder. +numbers, confidentiality designations, and +redactions shall be burned into the TIFF image file so as not to unreasonably +obstruct any information on the page. +Document Unitization. Each page of a Document shall be electronically +converted into an image as described above. If a Document is more than +one page, the unitization of the Document and any attachments and/or +affixed notes shall be maintained as it existed in the original when creating +the image file and appropriately designated in the load files. The +corresponding parent/attachment relationships, to the extent possible, shall +be provided in the load files furnished with each production. +Include Document level text files containing optical character recognition +("OCR") or extracted text named with the +Number of the first page +of the Document. +Include data load files containing all of the metadata +(both system and +2 + + +Case 1:22cv10904-JSR Døcumemt29-2FileHe@1024Ł2823Pa9âgŁ6@06fL9 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +e. +f. +h. +i. +j. +k. +application - see list below) from the original Native Documents with +extension.dat for Concordance. +Include the database field name in the first line of the metadata file, in such +a manner that it is clear how the metadata is organized in the file. +Include an image loadfile for Concordance - such as opt. +All hidden text (e.g., track changes, hidden columns, comments, notes, etc.) +shall be expanded, extracted, and rendered in the TIFF file. +Documents created in Excel (spreadsheets), CSV files, Access (databases), +and audio and video media files shall be produced in Native format. The +extractable metadata and text shall be produced in the same manner as other +Documents that originated in electronic form (as described herein) to the +extent that metadata exists or is reasonably accessible. +Email attachments and embedded files or links shall be mapped to their +parent. +Produce all attachments to responsive Documents attached to the responsive +Documents. +De-duplicate prior to production. To the extent that exact duplicate +Documents (based on MD5 or SHA-1 hash values at the Document level) +reside within a party's data set, each party is only required to produce a +single copy of a responsive Document, so long as there is a data field that +identifies each custodian who had a copy. In addition, Documents may be +de-duplicated in such a way as to eliminate earlier or incomplete chains of +emails, and produce only the most complete iteration of an email chain so +long as there is a data field that identifies each custodian who had a copy. +REQUIRED METADATA +BEGDOC +BEGATTACH +ATTCOUNT +CUSTODIAN +FROM +ENDDOC +ENDATTACH +ATTACH +AUTHOR +TO +3 + + +Case 1:22410904 J3R Document29-2Filte9422823P agage770₺fL© +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +CC +FILESIZE +DATERECD +DATESENT +CRTDATE +LASTMODDATE +LASTACCDATE +TITLE +EMAILSUBJECT +FILEEXT +ORGANIZATION +RECORD_TYPE +VOLUME +PRINTEDDATE +ATTLST +PSTINSIDEPATH +REQATTANDEES +REPLYTIME +BCC +PGCOUNT +TIMERECD +TIMESENT +CRTTIME +LASTMODTIME +LASTACCTIME +SUBJECT +FILENAME +MDSHASH +FULLPATH +VERSION +COMMENT +ENTRYID +ITEMTYPE +ITEMCREATIONTIME +REMINDERTIME +APPOINTMENTSTARTDATE +APPOINTMENTDURATIONTIME +APPOINTMENTCONTACT +CATEGORY +KEYWORDS +MANAGER +ENCRYPTED +LASTAUTHOR +FAMILYDATE +4 + + +@asse 1:2220410904JSR Dodument29-Filerel 42923 agagl88619 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +NATIVELINK +TEXTPATH +REQUESTNO +4. Format for hard copies of Documents produced in response to this Request: +a. +Re-type the question or request to which the Documents respond and firmly +attach the Documents to the re-typed request; +b. +Number all Documents consecutively, consistently with the numbers used +for the Documents produced electronically. +5. Unless otherwise indicated, the relevant time period for this Request for Production of +Documents is January 1, 1998 to the present. +6. If no Documents responsive to a particular request exist, so state. +7. As to any Document which no longer exists but which You are aware existed at one time, +identify such Document with as much particularity as possible, and in addition, identify +the last known location of the Document, the reason the Document is no longer in +existence, and the person responsible for the Document's disposition. +8. For information that You withhold on the basis of privilege, provide a descriptive list of +each Document stating the grounds for Your refusal and providing the following +information: the name or title of the Document; a description of the nature and subject +matter of the Document sufficient to enable a meaningful challenge to the assertion of +privilege; the date, author(s), sender(s), and recipients) of the Document; and the nature +of the privilege. +9. These requests shall be deemed continuing in character so as to require prompt +supplemental responses if additional Documents called for herein are obtained, discovered, +or become known to You between the time of responding to the Requests and the final +disposition of this action. +5 + + +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +10. Social Security numbers may be redacted from documents to the extent required by +applicable law. +II. +Requests for the Production of Documents +All Documents, Communications, and agreements related to Your employment by Jeffrey +Epstein, including but not limited to: +a. +Employment and +agreements, +b. +Non-disclosure agreements, +C. +All payments, in any form, received from or on behalf of Jeffrey Epstein, +d. +All Communications with Jeffrey Epstein, Ghislaine Maxwell, Bella Klein, Daphne +Wallace, Harry Beller, Lesley Groff, +a/k/a +Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. +6 \ No newline at end of file diff --git a/vision-fixhub/court-05/5798c503c5a932cf8d21ba4062881bfdbcdab04b224cfc5c5b5872a1c9ab5d54.receipt.json b/vision-fixhub/court-05/5798c503c5a932cf8d21ba4062881bfdbcdab04b224cfc5c5b5872a1c9ab5d54.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a4967da727278f40660b8c3645a6c5383c933751 --- /dev/null +++ b/vision-fixhub/court-05/5798c503c5a932cf8d21ba4062881bfdbcdab04b224cfc5c5b5872a1c9ab5d54.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -774, + "dataset": "marble-joined", + "doc_id": "5798c503c5a932cf8d21ba4062881bfdbcdab04b224cfc5c5b5872a1c9ab5d54", + "engine": "marble-apple-vision", + "event_count": 23, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "c04d17cc37341465e7e4120ed0b665d91791f00c7622548f8cbdefea6e728bb7", + "output_sha256": "665e9d3369d51c75a65d7b603635561c1c97e05931beeaf0067b65c72a4428b1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/57d1f6f95c5f7c0ab293ce04ac9bbafd02e665344722366aa560d13a0c9b8417.md b/vision-fixhub/court-05/57d1f6f95c5f7c0ab293ce04ac9bbafd02e665344722366aa560d13a0c9b8417.md new file mode 100644 index 0000000000000000000000000000000000000000..1bd3d24d9455fd66f7f37ba3d335c69f8175f480 --- /dev/null +++ b/vision-fixhub/court-05/57d1f6f95c5f7c0ab293ce04ac9bbafd02e665344722366aa560d13a0c9b8417.md @@ -0,0 +1,47 @@ +Case 1:22-cv-10904-JSR Document 247 Filed 07/26/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 247 Filed 07/26/23 Page 2 of 2 +Date: Thursday, December 2 2010 06:42 PM +Subject: Fwd: Aria Petroleum +From: Jeevacation +To: +Jes Staley : +FYI +Sorry for all the typos. Sent from my iPhone +Begin forwarded message: +From: "The +Date: December 2, 2010 1a12:45 PM ES1 +To: "Jeffrey Epstein" +Subject: FW: Aria Petroleum +I should have done something about this but not sure if the office did. +I am checking but as this is a US institution do you know of anyone who +might like to take a look? +HRH The +of York KG +----Original Message- +From: +@gmail.com [mailto: +Sent: 30 September 2010 13:20 +To: The +Cc: Amanda Thirsk +Subject: Aria Petroleum +@gmail.com] +Dear Prince Andrew, +I am going on board of Aria Petroleum - Central Asia's 2nd largest fuel +distribution company: $3 bt in revenue and very profitable. They source +and distribute fuel all over central asia (Russia, Kazakh, Azerbijian, +Turkministan etc...) and are the preferred vendor of US DoD Defense +Logistics. Company is logistics powerhouse. The business is 50/50 +commercial/military. +Fabulous company. Full transparency. Pristine reputation. +The Company needs a $200 million working capital line due to +significantly increased business from US DoD. +Can you put me in touch with the appropriate senior banker at Barclays +or RBS to discuss? There would likely be significant follow on business +for any bank that provides the line. +The Company is ready to engage immediately with banks. +Warm regards to you and family, + +Estate_006071 diff --git a/vision-fixhub/court-05/57d1f6f95c5f7c0ab293ce04ac9bbafd02e665344722366aa560d13a0c9b8417.receipt.json b/vision-fixhub/court-05/57d1f6f95c5f7c0ab293ce04ac9bbafd02e665344722366aa560d13a0c9b8417.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3426e1700431f28af6065b04b9f83d0c83786548 --- /dev/null +++ b/vision-fixhub/court-05/57d1f6f95c5f7c0ab293ce04ac9bbafd02e665344722366aa560d13a0c9b8417.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "57d1f6f95c5f7c0ab293ce04ac9bbafd02e665344722366aa560d13a0c9b8417", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "2eee16fe43322a821b83f3c9003cac123817ff8a63c8149822960553d70020a0", + "output_sha256": "a8d32b5815f209bde695525e24cd50a9839e54517ea6ad16ffc57c0c31f46f26", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/57d2d823c381b215f78921c7967a2bba13b0e2f664aa036427725d9e24a6609b.md b/vision-fixhub/court-05/57d2d823c381b215f78921c7967a2bba13b0e2f664aa036427725d9e24a6609b.md new file mode 100644 index 0000000000000000000000000000000000000000..710554c6ad65b2ba715e66d149f18865e88aa190 --- /dev/null +++ b/vision-fixhub/court-05/57d2d823c381b215f78921c7967a2bba13b0e2f664aa036427725d9e24a6609b.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 267-22 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/57d2d823c381b215f78921c7967a2bba13b0e2f664aa036427725d9e24a6609b.receipt.json b/vision-fixhub/court-05/57d2d823c381b215f78921c7967a2bba13b0e2f664aa036427725d9e24a6609b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e2f52163b1d084193e1fe1c0526b3391d362ff0b --- /dev/null +++ b/vision-fixhub/court-05/57d2d823c381b215f78921c7967a2bba13b0e2f664aa036427725d9e24a6609b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "57d2d823c381b215f78921c7967a2bba13b0e2f664aa036427725d9e24a6609b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "162eb75531a418ecf7bdc7ad9a3d0c0524c886a32da6861959abbed3eec4e8fb", + "output_sha256": "f438efb1df55873031f850cc15505ffa7c8425269601ea893768a5ec8c4c54f9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/57f7ef554abfbabb803d939abd196f11a044c0a674453506ecadbf1e87fc44e1.md b/vision-fixhub/court-05/57f7ef554abfbabb803d939abd196f11a044c0a674453506ecadbf1e87fc44e1.md new file mode 100644 index 0000000000000000000000000000000000000000..40564ec6e9e529b5fb10f07206b1b54ced43ea31 --- /dev/null +++ b/vision-fixhub/court-05/57f7ef554abfbabb803d939abd196f11a044c0a674453506ecadbf1e87fc44e1.md @@ -0,0 +1,1167 @@ +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 1 of 39 + + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 2 of 39 +NEW YORK STATE +DEPARTMENT OF FINANCIAL SERVICES +ONE STATE STREET +NEW YORK, NEW YORK 10004 +In the Matter of +DEUTSCHE BANK AG, +DEUTSCHE BANK AG NEW YORK BRANCH, and +DEUTSCHE BANK TRUST COMPANY OF THE AMERICAS : +-x +CONSENT ORDER UNDER +NEW YORK BANKING LAW $$ 39 and 44 +The New York State Department of Financial Services (the "Department"), Deutsche +Bank AG, Deutsche Bank AG New York Branch, and Deutsche Bank Trust Company of the +Americas (collectively "Respondents," "Deutsche Bank," or the "Bank") are willing to resolve +the matters described herein without further proceedings. +WHEREAS, Deutsche Bank AG is a global financial institution headquartered in +Frankfurt, Germany; +WHEREAS, Deutsche Bank AG is licensed by the Department to operate a foreign bank +branch in the State of New York, the Deutsche Bank AG New York Branch (the "New York +Branch"), and also operates a trust company, Deutsche Bank Trust Company of the Americas +("DBTCA"), which is likewise licensed and supervised by the Department; +Д л ЕХНІВІТ 40 +DeponenCutkr +Dan 5/2-4128 Rptr am +WWW.DEPOBOOKPRODUCTS.COM + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 3 of 39 +WHEREAS, the Department has been investigating various aspects of Deutsche Bank's +operations, specifically, the Bank's relationship with Jeffrey Epstein and related entities and +correspondent and dollar-clearing relationships with the Federal Bank of the Middle East Ltd. +("FBME") and Danske Bank A/S ("Danske"); +NOW THEREFORE, to resolve this matter without further proceedings pursuant to the +Superintendent's authority under Sections 39 and 44 of the Banking Law, the Department finds +as follows: +THE DEPARTMENT'S FINDINGS FOLLOWING INVESTIGATION +A. +Introduction +1. +Global financial institutions act as a critical line of defense against illegal +financial transactions in an ever changing and interconnected financial network. +The Federal Bank Secrecy Act ("BSA") requires financial institutions to have +adequate anti-money laundering ("AML") policies and systems in place. New York State law +requires financial institutions to devise and implement systems reasonably designed to identify +and report suspicious activity and block transactions prohibited by law. All regulated institutions +are expected to configure systems based on their unique risk factors, incorporating parameters +such as institution size, presence in high-risk jurisdictions, and the specific lines of business +involved, and the institutions have an affirmative duty to ensure that their systems run +effectively. +In addition to having effective AML controls in place, it is also necessary for +financial institutions to monitor their customers for the purpose of preventing their customers +from facilitating criminal activity using the institutions' facilities. Further, Federal and +2 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 4 of 39 +Departmental regulations require correspondent banks to conduct due diligence on, and monitor, +non-U.S. respondent bank clients. +4. +As such, KYC and customer due diligence are critically important, and financial +institutions must collect customer information at the time of establishing new relationships with +clients, including as necessary to assess the risks associated with the client. To properly consider +these risks, financial institutions should consider relevant factors such as the nature of the +client's business, the purpose of the client's accounts, and the nature and duration of the +relationship. For correspondent banking customers that are also foreign financial institutions, the +due diligence should consider reasonably available information as to the customer's own AML +record, the types of customers and markets served, and the AML regime in the client's home +jurisdiction. +Financial institutions must also conduct KYC reviews for each client relationship +at intervals commensurate to the AML risks posed by the client, including reviewing account +activity to determine whether such activity fits with what would have been expected given the +nature of the account. Each client's AML risk should also be re-assessed if material new +information or unexpected account activity is identified. +6. +Financial institutions must also establish criteria for determining when a client +relationship poses too high of a risk and therefore must be terminated. A financial institution may +be liable under applicable laws if it maintains such a relationship despite repeated indications of +facilitation of improper transactions. +The Department has determined that Deutsche Bank failed in various respects to +meet these obligations fully with respect to three different customer relationships: one direct +customer relationship with Jeffrey Epstein and entities related to Mr. Epstein; and two dollar- +3 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 5 of 39 +clearing/correspondent banking relationships with foreign banks, FBME and Danske. Each will +be addressed in turn. +B. The Bank's Relationship with Jeffrey Epstein and Related Entities +8. +Jeffrey Epstein was a wealthy financier with hundreds of millions of dollars in +assets and an extensive network of friends and connections that included prominent financial +institutions, politicians, royalty, and billionaires. Deutsche Bank maintained a relationship with +Mr. Epstein and related individuals and entities from August 2013 until December 2018. At that +point the Bank decided to terminate this relationship following additional negative press related +to Mr. Epstein's past criminal conduct. +Mr. Epstein also had a well-publicized reputation related to the trafficking and +abuse of young women. Allegations against him began appearing in the press as early as March +2005 with the accusation that he paid a 14-year old girl for a "massage." +10. +That year, the Palm Beach (Florida) Police Department commenced an +investigation into allegations against Mr. Epstein related to his activities in Palm Beach. The +investigation quickly uncovered dozens of other alleged victims. In particular, the investigation +identified a number of individuals who were responsible for recruiting young women to come to +Mr. Epstein's house to give "massages" or otherwise furthering his abuse. Press reports state +some of these women told victims they should inform Mr. Epstein that they were 18 years old +and represented to victims that they would be paid for performing such "massages." +11. +According to press reports, in 2006 the State Attorney handling the case, after +meeting privately with an attorney representing Mr. Epstein, referred the case to a state grand +jury instead of charging Epstein and co-conspirators for crimes for which local police believed +there was abundant evidence. As a result, the Palm Beach Police Chief publicly denounced the +4 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 6 of 39 +State Attorney and referred the case to the Federal Bureau of Investigation, which subsequently +opened its own investigation and interviewed potential witnesses and victims. +12. +In September 2007, Mr. Epstein agreed to plead guilty to two prostitution charges +in state court, including the solicitation of a minor to engage in prostitution, in exchange for a +deferred prosecution agreement providing him with immunity from extensive federal sextrafficking charges. The deal included an 18-month sentence and Mr. Epstein was also required +to register as a sex offender upon his release. Mr. Epstein ultimately served only 13 months of +his 18-month sentence in the Palm Beach County jail, and was allowed work release privileges +that enabled him to leave jail six days a week for twelve hours a day. +13. +In 2009, Mr. Epstein's non-prosecution agreement with the U.S. Department of +Justice was made public when it was unsealed in connection with one of several civil suits by his +alleged victims. The agreement, among other things, outlines details from the investigation, +including that Mr. Epstein may have conspired to use a facility or means of interstate commerce +to induce minors to engage in prostitution, to engage in illicit sexual conduct with minors, +conspiring with others to do the same, and trafficking minors. That agreement also notes that the +United States had compiled "a list of individuals whom it [had] identified as victims," and that +Mr. Epstein would pay for legal representation for these alleged victims. +14. +Indeed, between 2005 and 2013, press reports outlined the allegations underlying +the plea agreement and to varying degrees detailed the involvement of Mr. Epstein's alleged coconspirators, including three individuals hereinafter identified as CO-CONSPIRATOR-1, CO- +CONSPIRATOR-2 and CO-CONSPIRATOR-3. Some articles reported that CO- +CONSPIRATORS 1 and 2 had invoked their Fifth Amendment right against self-incrimination, +and others reported that CO-CONSPIRATOR 3 had allegedly recruited underage girls to give +5 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 7 of 39 +Mr. Epstein "massages." The names of these women and several other alleged co-conspirators +were publicly known by 2013. +15. +Additionally, press reports during this time noted allegations that Mr. Epstein was +involved with Eastern European women in particular and that a modeling agency he helped fund +brought "young girls ... often from Eastern Europe" to the U.S. on Mr. Epstein's private jets. +Deutsche Bank Onboarded Epstein in 2013 +16. +In early 2013, Mr. Epstein, who had been banking with one of Deutsche Bank's +competitors (herein, "US BANK-1"), began the process of moving his assets to Deutsche Bank. +17. The relationship between Deutsche Bank and Mr. Epstein came about through a +Deutsche Bank relationship manager (herein, "RELATIONSHIP MANAGER-1") who had left +US BANK-1 to join the Bank's private wealth department. At US BANK-1, RELATIONSHIP +MANAGER-1 had been a member of the team servicing Mr. Epstein's accounts. +18. +RELATIONSHIP MANAGER-1 joined Deutsche Bank in November 2012, and, +soon after joining Deutsche Bank, suggested to senior management in Deutsche Bank that Mr. +Epstein was a potential client who could generate millions of dollars of revenue as well as leads +for other lucrative clients to the Bank. Although it is unclear who made the initial contact, +RELATIONSHIP MANAGER-1 and Mr. Epstein began discussions in the spring of 2013 about +a potential relationship between Deutsche Bank and Mr. Epstein. +19. +In April of 2013, in preparation for Mr. Epstein's onboarding, a junior +relationship coordinator on the Epstein account (herein, "RELATIONSHIP COORDINATOR- +1") prepared a memorandum for RELATIONSHIP MANAGER-1 to send to the Bank's then Co- +Head of the Wealth Management Americas group (herein, "EXECUTIVE-I") and the Chief +Operating Officer of Wealth Management Americas (herein, "EXECUTIVE-2"). +6 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 8 of 39 +20. +Among other things, the memorandum contained information concerning Mr. +Epstein's previous plea deal and prison sentence. In particular, the memorandum stated that +"Epstein was charged with soliciting an underage prostitution [SIC] in 2007," that "[h]e served +13 months out of his 18 month sentence," and that "[h]e was accused of paying young woman +[SIC] for massages in his Florida home." It also highlights that Mr. Epstein was involved in 17 +out-of-court civil settlements related to his conduct in the 2007 conviction. +21. In the email to EXECUTIVE-1 and EXECUTIVE-2 attaching the memorandum, +RELATIONSHIP MANAGER-1 noted how lucrative the relationship could be, stating +"[e]stimated flows of $100-300 [million] overtime [SIC] (possibly more) w/ revenue of $2-4 +million annually over time ...." In the same email, RELATIONSHIP MANAGER-1 proposed +that all Epstein-related accounts be for "entities" affiliated with Mr. Epstein, "not personal +accounts." +22. +On May 5, 2013, EXECUTIVE-1 sent an email (hereinafter, the "Approval +Email") to RELATIONSHIP MANAGER-1 which read "spoke with [the Head of AML +Compliance for Deutsche Bank Americas and the then-General Counsel for Deutsche Bank +Americas, who at that time served as chair of the Bank's Americas Reputational Risk Committee +("ARR")]. Neither suggest [that the Epstein relationship] requires rep risk and we can move +ahead so long as nothing further is identified through KYC and AML client adoptions." The +Bank has represented to the Department that it has no other record of this communication +between EXECUTIVE-1 and the other officers, and the ARRC did not meet in connection with +the initial onboarding of Mr. Epstein. +23. +"Rep risk" as referenced in the Approval Email referred to a review by the +relevant regional reputational risk committee. Deutsche Bank's policies and procedures provide +7 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 9 of 39 +that, should a Deutsche Bank business or compliance unit identify a client that they believe could +pose a reputational risk to the Bank, they must escalate that client for review by the attendant +reputational risk committee. In the case of the onboarding of the Epstein relationship, this was +the ARRC. +24. +The relationship between Deutsche Bank and Mr. Epstein officially began on +August 19, 2013, when the Bank opened brokerage accounts for Southern Trust Company Inc., a +self-described "database company and services" founded in the U.S. Virgin Islands in 2011, and +Southern Financial LLC, a wholly owned subsidiary of Southern Trust Company Inc. According +to the KYC record, the purposes of the brokerage accounts were to "hold marketable securities +and cash" and "to invest long term [SIC] with the bank," respectively. Over the course of the +relationship, Mr. Epstein, his related entities, and associates would eventually open and fund +more than 40 accounts at the Bank. +25. +A Bank AML compliance officer cleared the relationship based on EXECUTIVE- +1's Approval Email. The Bank represented that there is no indication that the AML compliance +officer spoke directly with EXECUTIVE-1 or with the other Compliance or Legal officers +mentioned in the Approval Email. +Epstein Used Deutsche Bank Accounts to Engage in Suspicious Transactions +26. +From the time of Mr. Epstein's onboarding, the relationship was classified by +Deutsche Bank as "high-risk" and therefore subject to enhanced due diligence. Although the +Bank did not initially classify Mr. Epstein as a politically exposed person ("PEP"), the Bank did +designate him an "Honorary PEP" because of his connections to prominent political figures. The +high-risk classification and informal designation as an Honorary PEP resulted in enhanced +8 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 10 of 39 +transaction monitoring of activity within Epstein's accounts. However, and as discussed below, +this scrutiny was not tailored to the specific risks that he posed. +27. +As early as November 1, 2013, however, Mr. Epstein and his representatives +began using Deutsche Bank accounts to send wires to people who had been alleged to be coconspirators in his past criminal offenses. Over the course of the relationship, Mr. Epstein and +his representatives used Deutsche Bank accounts to send dozens of wires, directly and indirectly, +including at least 18 wires in the amount of $10,000 or more to alleged co-conspirators who had +been the subject of past press reports, including CO-CONSPIRATORS-1, -2, and -3. The Bank +was not always aware that the recipients of wire transfers were alleged co-conspirators. For +example, the wire transfers in November 2013 were made to an entity that was only later +publicly associated with a co-conspirator (in 2015). As described further below, however, the +connection was made by Bank personnel for certain transactions. +28. On January 24, 2014, Deutsche Bank opened checking and money market +accounts for an Epstein-related trust named "The Butterfly Trust." The Butterfly Trust included a +number of beneficiaries, including, among others, CO-CONSPIRATORS 1-3, and a number of +women with Eastern European surnames. When Bank personnel asked Epstein and Epstein's +representatives about his relationship with the beneficiaries, Epstein represented that they were +employees or friends. The Bank's KYC records state that the purpose of the money market +account was "to pay all expenses/disbursements related to the trust [such as] taxes, trust fee +[SIC], etc." +29. +The Butterfly Trust accounts were, like the overall Epstein relationship itself, +approved for onboarding based on the earlier Approval Email from EXECUTIVE-1, despite +apparent reputational and possible financial crime risks. Specifically, the beneficiaries of the +9 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 11 of 39 +Butterfly Trust included, among others, CO-CONSPIRATORS 1-3. The existence of coconspirators as beneficiaries of the trust created the very real risk that payments through the +Trust could be used to further or coverup criminal activity and perhaps even to endanger more +young women. +30. +At the time of onboarding of the Butterfly Trust accounts, Bank personnel were +aware that one of the Trust's beneficiaries was an alleged co-conspirator of Epstein's prior +offenses. In October 2013, a compliance officer performed background checks on the +beneficiaries of the trust and flagged for RELATIONSHIP COORDINATOR-1 that one of the +beneficiaries, CO-CONSPIRATOR-2, had been alleged to be one of Epstein's co-conspirators. +In reply RELATIONSHIP COORDINATOR-1 confirmed that "[CO-CONSPIRATOR-2] was +accused as a co-conspirator in a case but was never brought to trial nor ever convicted.... The +account for which she will be associated is a trust account which names her as a beneficiary." +The alert was cleared citing the Approval Email from Executive-1. +31. While Epstein held accounts at Deutsche Bank, he used the Butterfly Trust +account and various other accounts to send over 120 wires totaling $2.65 million to beneficiaries +of the Butterfly Trust, including some transfers to alleged co-conspirators or women with Eastern +European surnames, for the stated purpose of covering hotel expenses, tuition, and rent. +32. +Although payments related to legal expenses are not inherently suspicious, Mr. +Epstein also used his various accounts for what appear to have been multiple settlement +payments totaling over $7 million to law firms, as well as dozens of payments to law firms +totaling over $6 million for what appear to have been the legal expenses of Mr. Epstein and coconspirators. +10 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 12 of 39 +ARRC's Consideration of the Epstein Relationship +33. +At the end of 2014 and into 2015, the Bank's Anti-Financial Crime department +escalated issues concerning Mr. Epstein. The first issue arose in connection with the Bank's +opening of a Global Markets account for Mr. Epstein. In January 2015, during the onboarding +process for that account, an AML Compliance Officer ("AML OFFICER-1") identified recent +developments in the press concerning Mr. Epstein, including (a) a June 2014 federal appeals +court ruling that some of Mr. Epstein's alleged victims would be granted access to the details of +the 2008 plea bargain, potentially reopening their cases, and (b) additional allegations in the +press regarding Mr. Epstein's relationships with a prominent former U.S. politician and a +member of a European +family. +34. +AML OFFICER-1 escalated these issues to a more senior AML officer ("AML +OFFICER-2'"). In response, AML OFFICER-2 initially noted that the same negative allegations +against Epstein had been approved by EXECUTIVE-1, the former Head of AML and the former +General Counsel for the Americas and attached a copy of the Approval Email. AML OFFICER-1 +responded that they should still run the issue by the then Head of AFC Americas because: the +Approval Email was "not a direct approval by [the Head of AML Compliance for Deutsche Bank +Americas and the [then] General Counsel for Deutsche Bank Americas]; it's a statement by a +front office MD about his conversation with them and their alleged opinion not to escalate to Rep +Risk;" the Head of AML Compliance was no longer at the Bank; and there were new +developments in Epstein's case that could lead to the reopening of his 2008 conviction. +35. +As a result of these discussions and additional media reports regarding Epstein's +association with prominent political figures, AML OFFICER-2 put the question of whether to +escalate before EXECUTIVE-2, who agreed to escalate to the ARRC. In the email to +EXECUTIVE-2, AML OFFICER-2 noted that the communication underpinning the Approval +11 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 13 of 39 +Letter occurred before these new developments and for further background also noted, among +other things, that "[b]y 2011, 40 underage girls had come forward with testimony of Epstein +sexually assaulting them" and that "Epstein [had] managed to settle at least 17 lawsuits out of +court." +36. +Later that month, on January 22, 2015, in preparation for the ARR meeting, +EXECUTIVE-1 and RELATIONSHIP MANAGER-1 met in person with Mr. Epstein at his New +York home. During the meeting, EXECUTIVE-1 asked Mr. Epstein about the veracity of the +recent allegations and appeared to be satisfied by Mr. Epstein's response. The Bank has +represented to the Department that it is not in possession of contemporaneous records reflecting +the substance of EXECUTIVE-I's meeting with Epstein and is not aware of any other steps +taken at the time to investigate the veracity of the allegations beyond speaking with Mr. Epstein. +37. +On January 30, 2015, members of the ARR met to discuss the Epstein +relationship. Despite the fact that Deutsche Bank's policies and procedures mandate that detailed +minutes of such meetings be kept, the Bank has represented to the Department that there are no +recorded minutes from that particular meeting. Later that day, however, a member of the ARRC +emailed EXECUTIVE-1 to say, without explanation, that the committee was "comfortable with +things continuing" with Mr. Epstein, and that another member of the committee had "noted a +number of sizable deals recently." +Conditions on the Epstein Relationship Were Communicated to Neither the Relationship +Managers nor the Relevant Transaction Monitoring Team +38. +The following week, another member of the ARRC (the Bank's Head of +Compliance, Americas) reiterated the ARRC's decision in an email to other executives, stating +that ARRC had agreed to "continue business as usual with Jeff Epstein based upon +[EXECUTIVE-1]'s due diligence visit with him." +12 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 14 of 39 +39. +relationship: +That same email outlined three conditions, however, that the ARRC placed on the +a. Mr. Epstein would be allowed to continue to "conduct trades and transactions in +existing accounts without Compliance pre-approval, provided that the business +had determined these transactions do not involve any unusual and/or suspicious +activity or are in a size that is unusually significant or novel in structure." +b. The Bank's Corporate Banking and Securities unit would be allowed to "also +'open' accounts to facilitate activity as a booking matter where the activity has +already been approved by [the Bank's America's Wealth Management division]." +c. The business would "need to monitor for any further developments in connection +with the reputational risk of the client relationship and to review +transactions/activity conducted in the accounts for any activity, size or structure as +described in [the first condition]." +40. +These mandatory conditions were communicated to several senior Bank +personnel, up to and including the Bank's CEO of the Americas. Inexplicably, however, they +were apparently never communicated to all members of the Epstein relationship team. Epstein's +relationship managers continued conducting business with Epstein in the same manner as they +had prior to the ARRC meeting. +41. +This failure was then substantially compounded when AML OFFICER-2 +purportedly misinterpreted the conditions; as a result they were also not communicated to the +transaction monitoring team responsible for monitoring the Epstein relationship. Specifically, +AML OFFICER-2 interpreted the clause "transactions [with] unusual and/or suspicious activity +or are in a size that is unusually significant or novel in structure" to mean transactions that were +13 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 15 of 39 +unusual, suspicious, or novel as compared to the prior history of transactions related to the +Epstein relationship. He communicated this interpretation to the rest of the transaction +monitoring team responsible for the Epstein relationship. The interpretation was exemplified by +a later email exchange in March of 2017, when a member of the transaction monitoring team +responded to an alert about payments to a Russian model and Russian publicity agent, stating, +"[s]ince this type of activity is normal for this client it is not deemed suspicious." +42. +Instead of monitoring the accounts for all potential crimes and suspicious activity +that could be implicated by Mr. Epstein's alleged past conduct, including payments to coconspirators and those that could be related to sex trafficking involving adults, AML OFFICER- +2 only instructed the relevant transaction monitoring team to verify, using internet searches, that +any woman involved with transactions related to the Epstein relationship was at least 18 years +old and to only flag transactions if they could not discern a rational reason for the transaction, a +standard which had little if any effect on the Bank's relationship with Mr. Epstein. +The Bank Continued to Maintain the Relationship for Years Despite Additional Red Flags +43. +On July 21, 2015, Mr. Epstein requested an increase in his trading limits. Several +days later, a member of Epstein's coverage team ("COVERAGE TEAM MEMBER-1"), who +was aware of the ARR's conditions on the relationship, escalated this request to AML +OFFICER-2, who in turn escalated the issue to the Chairman of the ARRC. On July 29, 2015, +after conferring with other members of the ARRC but without formally meeting, the Chairman +replied to AML OFFICER-2 stating they had no objections. The Chairman added, "I also +checked in with [EXECUTIVE-1] last night to make sure he supports this and has heard nothing +negative on the client. [EXECUTIVE-1] confirmed both." +14 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 16 of 39 +44. On January 4, 2016, an accountant representing Mr. Epstein (herein, +"ACCOUNTANT-1") requested that the Bank open a brokerage account for Gratitude America, +Mr. Epstein's private charity. COVERAGE TEAM MEMBER-1 escalated the request to AML +OFFICER-2, who directed the inquiry to the Secretary for the ARRC. The Secretary of the +ARRC conferred with a member of the ARRC and ordered that an external due diligence report +be prepared on Mr. Epstein. In response to the request for additional information, +ACCOUNTANT-1 informed the Bank of Mr. Epstein's resignation from Gratitude America and +withdrew the request to open the account. As a result, no due diligence report was run on Mr. +Epstein. +45. +By April 2016, RELATIONSHIP MANAGER-1 was replaced by another +relationship manager (herein, "RELATIONSHIP MANAGER-2") to handle accounts associated +with Mr. Epstein. Although RELATIONSHIP MANAGER-2 had Mr. Epstein's KYC file and +had been made aware of the prior escalation of the relationship to the ARRC, he was not made +aware by anyone at the Bank of the three conditions the ARRC placed on the relationship after +its February 2015 review. +46. +In a May 2018 email, a compliance officer submitted an inquiry to +RELATIONSHIP MANAGER-2 about payments to the accounts of women with Eastern +European surnames at a Russian bank, and asking for an explanation of the purpose of the wire +transactions and Epstein's relationship with the counterparties. After submitting the questions to +ACCOUNTANT-1, RELATIONSHIP MANAGER-2 forwarded ACCOUNTANT-I's response +to the compliance officer, which read "SENT TO A FRIEND FOR TUITION FOR SCHOOL." +When the compliance officer followed up, asking "[why is this client using this account to ... +pay school tuition?," RELATIONSHIP MANAGER-2 replied "[g]enerally, Jeffrey has separate +15 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 17 of 39 +accounts to manage each of his properties. This is one of them. However, when making one-off +transfers to people, he and his finance staff have the flexibility to use any account they like that +is funded." The Bank has represented to the Department that it has no records of the compliance +officer asking further follow-up questions, and the transaction was cleared. +47. +In addition, payments from the Butterfly Trust accounts and other Epstein +accounts were used for lawsuit settlement payments to alleged victims, and rent, legal, and +immigration expenses made to or on behalf of young (albeit adult) women, including additional +women with Eastern European surnames. +Deutsche Bank Was Aware of Suspicious Cash Activity Throughout the Relationship +48. Several of Mr. Epstein's employees or agents had authority to conduct +transactions in the accounts on Mr. Epstein's behalf. One of them, Mr. Epstein's personal +attorney (herein, "ATTORNEY-I"), was active in withdrawing cash for Mr. Epstein. +ATTORNEY-1, on behalf of Mr. Epstein, made a total of 97 withdrawals from the Bank's Park +Avenue (New York City) Branch from 2013 to 2017 from personal accounts belonging to Mr. +Epstein. The transactions in question occurred roughly two to three times per month, all in the +amount of $7,500 per withdrawal, the Bank's limit for third-party withdrawals (i.e., withdrawals +made by an authorized user who is not a primary account holder). When Bank personnel asked +ATTORNEY-1 why Epstein needed cash, ATTORNEY-1 replied Epstein used it for travel, +tipping and expenses. +49. +Under federal regulations, banks and other financial institutions must file +Currency Transaction Reports ("CTRs") with the U.S. Treasury Department when there are cash +transactions with an individual in excess of $10,000 in one day. Breaking up transactions to +avoid the CTR reporting is a criminal offense commonly referred to as "structuring." When +ATTORNEY-I's cash activity triggered reporting requirements, the Bank complied and filed the +16 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 18 of 39 +requisite CTRs. The Bank also monitored ATTORNEY-1's activity for suspicious activity +reporting. +50. +In May 2014, ATTORNEY-1 inquired into how often he could withdraw cash on +behalf of Mr. Epstein without triggering an alert. The record is unclear as to whether anyone +from the Bank ever responded to ATTORNEY-I's inquiry. RELATIONSHIP COORDINATOR- +1 sent an email to the branch manager stating that ATTORNEY-1 "asked how often they could +come in to withdraw cash without creating some sort of alert," and asking "Is it once a week? +Twice a week? Once every other week?" The Bank has represented that it has no record of any +response. RELATIONSHIP COORDINATOR-1 has since represented that she understood +ATTORNEY-I's inquiry related to ATTORNEY-1's desire to withdraw more than the $7,500 +limit for third-party withdrawals, and not to CTR filing requirements. +51. +In 2017, ATTORNEY-1 again inquired about triggering an alert. Specifically, in +July 2017, ATTORNEY-1 had, among other things, asked a teller whether a withdrawal +transaction in excess of $10,000 would require reporting and, upon being advised that it would, +broke up the withdrawal transaction over two days. In July of that year, members of the Bank's +Wealth Management AML transaction monitoring team, including AML OFFICER-2, met to +discuss suspicions of cash structuring to avoid currency transaction reports ("CTRs") by +ATTORNEY-1. AML OFFICER-2, among others, spoke with ATTORNEY-1 and advised that +(a) his patterns gave the appearance of structuring, (b) this pattern was unacceptable, and (c) he +would be provided with additional information about CTR reporting requirements. +ATTORNEY-1 represented that he had not intended to structure cash withdrawals. Bank +personnel found ATTORNEY-1 credible and permitted him to continue to withdraw cash from +his own and Epstein's accounts. In 2018, just prior to the Bank's closing of the Park Avenue +17 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 19 of 39 +Branch, which was located nearby Mr. Epstein's house, ATTORNEY-1 withdrew $100,000.00 +in cash on behalf of Mr. Epstein. When later questioned why ATTORNEY-1 withdrew these +sums from the Bank, ATTORNEY -1 reported that Mr. Epstein needed the funds for tipping and +household expenses. +52. +In total, in a roughly four-year period, ATTORNEY-1 withdrew on Mr. Epstein's +behalf more than $800,000 in cash from Mr. Epstein's personal accounts. Throughout the +Epstein relationship the Bank filed CTRs appropriately, but there is no indication that the Bank +ever sought or received any explanation for Epstein's cash activity beyond the travel, tipping, +and expenses explanation provided by ATTORNEY-1. +Termination of the Epstein Relationship +53. +In November 2018, the Miami Herald released an article on Mr. Epstein detailing +his 2008 plea deal. The article prompted senior members of Wealth Management to reassess the +relationship's reputational risk and ultimately terminate the Epstein Relationship. On December +21, 2018, the Bank informed Mr. Epstein by letter that they would no longer be servicing his +accounts. +54. +Despite the Bank's decision to offboard all Epstein accounts due to reputational +risks, RELATIONSHIP MANAGER-2 drafted reference letters to two other financial +institutions, on Deutsche Bank letterhead, indicating in one such letter that he was "unaware of +any problems relating to the operation or use of [the] accounts." +Conclusions Regarding the Epstein Accounts +55. +If a financial institution decides to do business with a high-risk client, that +institution is required to conduct due diligence commensurate with that risk and to tailor its +18 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 20 of 39 +transaction monitoring to detect suspicious or unlawful activity based on what the risk is. In this +case, Deutsche Bank failed to do so. +56. +The Bank's fundamental failure was that, although the Bank properly classified +Mr. Epstein as high-risk, the Bank failed to scrutinize the activity in the accounts for the kinds of +activity that were obviously implicated by Mr. Epstein's past. The Bank was well aware not only +that Mr. Epstein had pled guilty and served prison time for engaging in sex with a minor but also +that there were public allegations that his conduct was facilitated by several named coconspirators. Despite this knowledge, the Bank did little or nothing to inquire into or block +numerous payments to named co-conspirators, and to or on behalf of numerous young women, or +to inquire how Mr. Epstein was using, on average, more than $200,000 per year in cash. +57. +Whether or to what extent those payments or that cash was used by Mr. Epstein to +cover up old crimes, to facilitate new ones, or for some other purpose are questions that must be +left to the criminal authorities, but the fact that they were suspicious should have been obvious to +Bank personnel at various levels. The Bank's failure to recognize this risk constitutes a major +compliance failure. +58. +This substantive failure was compounded by a series of procedural failures, +mistakes, and sloppiness in how the Bank managed and oversaw the Epstein accounts. Despite +the nature of Mr. Epstein's prior criminal history, the initial onboarding of the first account was +not reviewed by the Bank's regional reputational risk committee but was instead approved in +what appears to have been an off-hand conversation reflected only in the Approval Email. That +Approval Email was then relied upon, substantially without additional scrutiny, to open +numerous other Epstein-related accounts. When the relationship was finally elevated to the full +ARRC in early 2015, no minutes were taken of that meeting, contrary to Bank policy, and the +19 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 21 of 39 +committee was satisfied enough to continue the relationship based primarily on a brief due +diligence meeting between two front-office personnel and Mr. Epstein himself, the substance of +which was also not reflected in writing. Moreover, the conditions imposed by the ARRC - +conditions that, if followed, might have detected and prevented many subsequent suspicious +transactions — (a) were not transmitted to the majority of the relationship team; and (b) were +misinterpreted by a compliance officer in a way that resulted in very little change in how the +monitoring of the accounts occurred going forward. Throughout the relationship, very few +problematic transactions were ever questioned, and when they were, they were usually cleared +without satisfactory explanation. +59. +These errors are unacceptable in the context of a major international bank and +inexcusable in the context of the heightened scrutiny that should have occurred in the monitoring +of a high-risk customer. +C. +The Bank's Correspondent Banking Relationships with FBME and Danske Bank +60. +Deutsche Bank has had correspondent banking relationships with foreign banks, +including several that were in high-risk jurisdictions or themselves had customers operating in +high-risk industries. The Department has concluded that Deutsche Bank failed to adequately +monitor and manage those relationships, including, in particular, with FBME and Danske. +FBME +61. +In 1982, FBME was established in Cyprus as a subsidiary of the Federal Bank of +Lebanon, which was founded in 1952. +62. +In January 1984, FBME opened a correspondent banking account with Bankers +Trust, which Deutsche Bank acquired in 1999 and later renamed to Deutsche Bank Trust +Company Americas, though this account was mostly unused for years as FBME did limited +20 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 22 of 39 +business with Western financial institutions until Cyprus' 2004 acceptance into the European +Union. +63. +Due to Cypriot laws that placed restrictions on domestic financial institutions that +primarily provided offshore banking services, FBME was incorporated in the Cayman Islands in +1986, though it would remain headquartered and staffed in Cyprus. In 1987, FBME's Cyprus +branch was granted a license by the Central Bank of Cyprus to assume banking activities within +its jurisdiction. +64. In April 2001, FBME's Cyprus branch opened a second account with DBTCA. +65. After the September 11, 2001 terrorist attacks on the United States and in +accordance with the USA PATRIOT Act, the Cayman Islands implemented legislation requiring +all banks registered within the country to establish a physical local presence. In response, rather +than complying with the new directive, FBME management elected to begin the process of +relocating to Tanzania. In 2003 FBME was reincorporated in Tanzania, and also received a +banking license from the Bank of Tanzania. +66. +Cyprus' acceptance to the European Union in May of 2004 precipitated the active +correspondent banking relationship between FBME and Deutsche Bank. On August 23, 2004, +FBME's Cyprus branch opened a third account with DBTCA. +67. +Deutsche Bank was aware of potential issues with FBME's compliance regime +from very early in the active phase of the correspondent banking relationship. A May 2005, +"Annual Anti-Money Laundering Discussion" memo for FBME, for example, shows that the +Bank was aware that: +a. FBME's Compliance Officer headed a department comprised of two staff +members; +21 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 23 of 39 +b. the Compliance Officer was at the time "trying to develop a back office +compliance [SIC]"; +c. FBME was at the time still using a transaction monitoring system that was +partially manual; and +d. FBME at the time considered the cost of compliance with AML and KYC +regulations to be the most significant issue challenging the Cyprus banking sector. +68. +Later-in-time "Anti-Money Laundering Discussions" for FBME showed that +certain aspects of FBME's compliance program did not change over subsequent years, although +those memos did reflect that the number of AML Compliance staff at FBME generally increased +each year between 2005 and 2013 and FBME implemented automated transaction monitoring +and sanction screening tools in 2009 and 2010, respectively. +69. On November 17, 2005, Deutsche Bank's North American Client Screening +Committee ("CS") assigned FBME a Risk Assessment Customer ("RAC"') score of eight, +thereby designating it as a high-risk client. At Deutsche Bank, RAC scores are graded on a scale +of one to ten, with one being the lowest level of risk and ten the highest. Clients who receive a +score of eight and above are considered high-risk. +70. During the relevant period, FBME Cyprus was always rated high-risk, with +Deutsche Bank's records indicating that it was assigned a RAC score, over the years, of eight or +nine. The Bank's records show that FBME Tanzania over this time period had a RAC score of +seven in 2007, and eight thereafter. +71. +At the time of the initial risk rating, information provided to the CSC included +that other banks had alleged in the past that FBME had been associated with money laundering +linked to Russian organized crime. A 2005 memo provided to the CSC stated that the USA +22 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 24 of 39 +PATRIOT Act and the EU Money Laundering Directive limited FBME's ability to commit +money laundering in the hypothetical event that it chose to engage in such conduct. The same +memo noted that the Central Bank of Cyprus ("CBC") had represented to Deutsche Bank that the +CBC regarded FBME as excellent from a KYC and AML perspective, and that FBME's +Compliance Officer was the most experienced in the Cypriot market. This, in part, served as the +justification of Deutsche Bank's continued relationship with FBME. +72. +In January 2007, a former Bank Director of U.S. Anti-Financial Crimes (herein, +"AML COMPLIANCE DIRECTOR-1"), along with executives from Deutsche Bank's Greece +office, met with FBME executives in Cyprus. Over the course of this meeting and subsequent inperson meetings, Deutsche Bank executives became well aware of the state of FBME's +compliance operations and provided annual seminars or "AML workshops" for Cypriot clients, +including FBME, starting in June 2010. +73. +In March 2007, FBME's Cyprus branch, opened a fourth account with Deutsche +Bank's New York Branch. +74. +Since 2008, the Bank identified a total of 826 suspicious transactions that +referenced FBME, with 96 alone in 2008, That year, Deutsche Bank performed an analysis of the +volume of suspicious transactions related to FBME and concluded that FBME presented an +average to greater-than-average risk compared to other banks in an already high-risk market. +75. +This number increased to 125 suspicious transactions in 2009 and eventually +peaked at 132 the following year. While the number of suspicious transactions decreased to 77 in +2012, there was a significant increase in 2014, with the Bank identifying a total of 131 suspicious +transactions concerning FBME. +23 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 25 of 39 +76. +Despite the high number of suspicious transactions in relation to FBME, the Bank +facilitated 478,379 dollar-denominated transactions totaling more than S618 billion over the +course of the relationship. +77. +In communications with Deutsche Bank, FBME sometimes refused to disclose in +writing the ultimate beneficial owners of its own corporate clients, explaining that such +information could not be shared without violating local law. For example, in March of 2007, a +Deutsche Bank official in Greece contacted FBME concerning additional information regarding +OFFSHORE COMPANY-1. In response, FBME stated that the company was a privately-owned +company whose business activities included trading in securities and that FBME had conducted +their own due diligence checks which identified the beneficial owner. However, FBME stated +that it could not share the underlying information with the Bank without violating Cypriot law +governing client confidentiality unless ordered by a court to do so. Three years later, Deutsche +Bank flagged an additional transaction concerning OFFSHORE COMPANY-1, noting that they +had inquired about the same FBME customer before. Despite this lack of transparency with +respect to this FBME customer, Deutsche Bank continued its banking relationship with FBME. +After Deutsche Bank decided to close the FBME relationship in July 2014, the U.S. Government +determined that OFFSHORE COMPANY-I's ultimate beneficial owner was a Russian +businessman who was affiliated with a Syrian research facility responsible for developing and +producing non-conventional weapons. +78. +This was apparently not an isolated incident. Although the Department has not +found that the Bank was aware at the time, many ultimate beneficial owners of clients of FBME +have subsequently been associated in the press with "weapons proliferators, terrorists, and +transnational organized criminals." +24 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 26 of 39 +79. +On July 15, 2014, the U.S. Treasury's Financial Crimes Enforcement Network +("FinCEN") named FBME a foreign financial institution of primary money laundering concern +pursuant to Section 311 of the USA PATRIOT Act (the "311 Designation"), and proposed +prohibiting U.S. financial institutions from opening or maintaining correspondent accounts or +payable through accounts for or on behalf of FBME. +80. +At this time, Deutsche Bank was the largest of the few remaining Western banks +that had continued to maintain correspondent banking relationships with FBME. +81. +In response to the 311 Designation, Deutsche Bank decided by July 18, 2014 to +end its relationship with FBME. +82. +The Department concludes that the high-risk nature of the FBME relationship, the +red flags, numerous suspicious transactions, and overt lack of transparency exhibited by FBME +should have prompted Deutsche Bank to exit the relationship before the 311 Designation, yet it +failed to do so. +Danske Estonia +83. +In 2007, Danske Bank A/S, the largest financial institution in Denmark, acquired +the Baltic business of a Finnish financial institution, Sampo Bank. The segment of the business +located in the nation of Estonia became known as Danske Estonia. +84. +The relationship between Deutsche Bank and Danske Estonia began on October 1, +2007, with the latter institution's opening of a correspondent banking account with Deutsche +Bank. Deutsche Bank assigned Danske Estonia a RAC Score of eight in 2007, i.e., high-risk, due +to Danske Estonia's high-risk jurisdiction, the volume of AML alerts and cases involving Danske +Estonia's customers, and the high-risk market segments serviced by Danske Estonia. +25 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 27 of 39 +85. +Because it was a high-risk client, Danske Estonia was required to undergo annual +due diligence reviews as part of the Bank's KYC process for correspondent banking clients. This +process included a discussion between the client relationship manager and Danske Estonia +personnel focused on AML and KYC issues, including any changes in the relevant laws and +regulations, changes to the client's internal policies and procedures, major banking issues in the +client's country, and the client's risk analysis of its own customers. +86. +By June 2008, Deutsche Bank was aware of issues at Danske Estonia concerning +its non-resident customer accounts. Specifically, Deutsche Bank observed an increase in AML- +related alerts generated by the Bank's monitoring systems involving non-resident customers of +Danske Estonia "with a Russian or Latvian (indirectly Russia[n]) connection." These AML alerts +prompted Bank officials from the U.S. and Germany to meet with Danske Estonia in New York, +at which point they were assured that Danske Estonia was moving away from its non-resident +client portfolio. +87. Additionally, a plan to place the Estonian Branch on the same IT platform as +Danske's home office fell through in 2008. Failure to implement the IT protocols resulted in the +Estonian Branch not having the same AML checks as Danske Bank's home office, despite its +location in a higher-risk jurisdiction. +88. +In July 2009, Deutsche Bank was sufficiently concerned about AML risks posed +by Danske Estonia that AML COMPLIANCE DIRECTOR-1 provided on-site training to Danske +Estonia staff to address AML and KYC topics, which consisted of an overview of U.S. +regulatory requirements. +26 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 28 of 39 +89. +Just a few months later, in November 2009, Deutsche Bank increased Danske +Estonia's RAC score to a nine due to the lack of improvement in compliance seen at the client +bank, despite its assurances a year earlier. +90. +In September 2010, Deutsche Bank elected to increase Danske Estonia's RAC +score again, to a ten, the maximum on the Bank's risk scale, after it continued to see insufficient +improvements from Danske Estonia regarding its non-resident customer portfolio. The score was +expressly based on "the volume and nature" of suspicious activity involving Danske Estonia and +its customers, as well as "law enforcement inquiries related to Danske Estonia and its +customers." Despite this lack of improvement, the Bank elected to continue its relationship with +Danske Estonia. +91. +Deutsche Bank's perception that Danske Bank was not improving was accurate. +Danske Estonia saw a notable increase in non-residential business from Russia and other former +Soviet states in 2010. This business was disproportionately large and lucrative for Danske Bank +— in 2011 alone, Danske Estonia generated 11% of Danske Bank's total profits despite only +accounting for 0.5% of the bank's assets. +92. +In April 2011, AML COMPLIANCE DIRECTOR-1 and other Bank employees +met with Danske Estonia personnel once again to discuss Deutsche Bank's concerns regarding +the volume of AML investigations involving Danske Estonia customers. During the April 2011 +meeting, Deutsche Bank personnel expressed concerns to Danske Estonia involving its nonresident portfolio. In particular, the Bank noted that it would need to consider reassessing its +relationship, including possible termination of Danske Estonia's accounts, unless Danske Estonia +was able to mitigate the AML-related issues involving its non-resident customers. The number of +27 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 29 of 39 +suspicious transactions involving Danske Estonia's customers slightly decreased between 2010 +(21 transactions) and 2011 (17 transactions). +93. +These concerns persisted, however, and the question of whether to retain Danske +Estonia as a client was raised again in late 2013. In a November 1, 2013 email, AML +COMPLIANCE DIRECTOR-1 stated that Deutsche Bank was "[o]nce again, not happy with +what [they had] experience[d] with some of Danske Bank Estonia's clients in addition to some +AML and sanctions controls." AML COMPLIANCE DIRECTOR-1 further stated that the Bank +"value[s] the relationship [with Danske Estonia], but must see improvements." +94. The following week, on November 6, 2013, AML COMPLIANCE DIRECTOR-1 +drafted an internal memorandum after conducting an on-site visit at Danske Estonia. The draft +memorandum concluded that there was a "basis for closure" of the Danske Estonia accounts +largely due to a lack of improvements in AML controls. The memorandum also advocated that +the Bank limit Danske Estonia's transactions to processing payments which originated from +Danske Estonia's customers who were residents of Estonia. This draft memorandum does not +appear to have been sent to any other Deutsche Bank personnel (or third party) prior to the +termination of the Danske Estonia correspondent banking relationship in October 2015. +95. +Two days later, on November 8, 2013, U.S. AFC officers from the Bank had a +phone conversation with their colleagues in Germany. On that call, concerns were raised +regarding recent law enforcement inquiries into Danske Estonia's customers, as well as an +increase in suspicious transactions. It was also mentioned during the call that Danske Estonia +was "not cooperative enough" and had "not improved," despite the Bank's suggestions. This was +subsequently discussed in an in-person meeting on November 20, 2013, in which AML +28 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 30 of 39 +COMPLIANCE DIRECTOR-1 advocated to maintain the relationship while mitigating the risks +involving Danske Estonia's non-resident customer portfolio. +96. +Notwithstanding these concerns, Deutsche Bank decided to maintain the +relationship for two reasons: 1) Danske Estonia was viewed an important component of the +Bank's global relationship with Danske Bank A/S; and 2) Deutsche Bank believed that it could +effectively mitigate and control the risks. +97. +By early 2014, other major Western financial institutions began de-risking efforts +in the Baltic region related to money laundering risks. Deutsche Bank elected to continue to do +business in the region, however. +98. +The Bank was aware that the risks mostly centered on high-risk non-resident +("HRNR") accounts held in the region with beneficial owners located largely in Russia and other +former Soviet states. When later questioned about whether Deutsche Bank was concerned with +the volume of HRNR accounts maintained at Danske Estonia and other financial institutions +based in the Baltics, the Bank's relationship manager stated that "there were legitimate reasons +for former Soviet businesses and individuals to use non-resident banks," and that "such +customers often operated and lived under governments that were corrupt and rapacious, and thus +there were valid reasons for them to hold their money overseas." +99. +In response to the Bank's efforts to mitigate and control the AML risk posed by +Danske Estonia, Danske Estonia did in fact undergo some reforms over the course of 2014, but +these underscored the failings up to that point. For example: +a. Danske Estonia introduced a "customer risk level determination" procedure, the +first change in five years to Danske Estonia's policies and procedures for +evaluating a client's risk. +29 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 31 of 39 +b. While Danske Estonia had previously screened outgoing payments against the +U.S. Treasury Department's Office of Foreign Asset Control and European Union +sanctions lists, it began screening incoming payments against those lists. +100. +Deutsche Bank was aware of the lack of such reforms prior to 2014. For example, +Deutsche Bank's annual AML Discussions, which were required by internal Bank policy for +high-risk clients, reflect that certain aspects of Danske Estonia's AML/KYC program were +largely holdovers from the Sampo Bank era, with the AML Discussions simply listing "[n]o +changes to previous discussion," year after year, with only minor changes. +101. On September 29, 2014, AML COMPLIANCE DIRECTOR-1 stated in a +transition memo that "the Baltics suffer from an inherently high client AML risk .... +[Continued monitoring should be placed on ... Danske Bank Estonia. If the situation for +Danske Bank Estonia worsens, I recommend that the account be closed." +102. Despite this recommendation from a high-ranking and seasoned compliance +professional, Deutsche Bank continued its relationship with Danske Estonia yet again. +103. During the eight-year period between 2007 and 2015, Deutsche Bank cleared +more than $267 billion in 1,638,844 transactions for Danske Estonia. Out of this total, Danske +transferred at least $150 billion in payments from Russia and other former Soviet states through +Deutsche Bank. +104. Between 2007 and 2015, Deutsche Bank identified a total of 340 suspicious +transactions that referenced Danske Estonia's U.S. dollar correspondent accounts. The high +number of suspicious transactions, the history of high RAC scores, and various dialogues that the +Bank had with its client concerning AML policies and controls, put Deutsche Bank on notice that +there were issues that required timely further action. +30 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 32 of 39 +105. +Despite this, the Bank maintained its relationship with Danske Estonia until +October 7, 2015, a year in which Deutsche Bank identified 87 additional suspicious transactions +concerning Danske Estonia. +The Bank's Compliance Failures in its Correspondent Banking Relationships +106. +In connection with the Bank's relationships with these high-risk correspondent +banking customers, the Bank failed to maintain policies that set out sufficiently specific criteria, +such as patterns of high RAC scores or high suspicious activity volumes, under which the Bank +would determine whether to terminate a correspondent banking relationship or whether lesser +risk-mitigation measures would be appropriate. +107. During part of these relationships, the Bank failed to maintain policies that clearly +provided for the closure of accounts based on the failure to obtain or update a USA PATRIOT +Act certification from its correspondent banking clients. +108. Finally, the Bank failed to consistently maintain policies that provided practical +guidance to facilitate their implementation, such as procedures for determining whether other +foreign banks use the respondent's correspondent account, or explanations of how employees +could verify the identities of respondents' beneficial owners. +D. Deutsche Bank's Substantial Cooperation and Remediation +109. +The Department recognizes and credits the Bank's exemplary cooperation during +the course of the Department's investigations of the Bank's former relationships with Danske +Bank, FBME, and Jeffrey Epstein. This cooperation, which occurred over several years, included +conducting comprehensive and thorough internal investigations of each of those former +relationships and sharing the results of those investigations with the Department in a detailed and +transparent manner; collecting, analyzing and producing numerous documents and other +31 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 33 of 39 +information to the Department; and providing timely and detailed responses to the Department's +inquiries. +110. +The Department also recognizes and credits the Bank's ongoing efforts to +remediate the shortcomings identified in this Consent Order, including the fact that these efforts +commenced before the inception of the Department's investigations of the former relationships +described herein. Among other things, the Bank has demonstrated its commitment to remediation +by devoting significant financial and other resources to enhance the Bank's AML program, +including through changes to its policies, procedures, systems, governance structures, and +personnel, as well as its ongoing cooperation with the independent monitor selected by the +Department (as referenced in paragraph 117 below), and by reducing the Bank's portfolio of +high-risk clients in its correspondent banking and Wealth Management businesses. +11l. +Consistent with the requirements of New York Banking Law § 44(5), the +Department has given substantial weight to the commendable conduct described in paragraphs +109 and 110 above. +Violations of Laws and Regulations +112. The Department finds that Deutsche Bank conducted business in an unsafe and +unsound manner, in violation of New York Banking Law § 44. +113. +The Department finds that Deutsche Bank failed to maintain an effective and +compliant anti-money laundering program, in violation of 3 NYCRR § 116.2. - +NOW THEREFORE, to resolve this matter without further proceedings, pursuant to the +Superintendent's authority under Sections 39 and 44 of the Banking Law, the Department and +Respondents stipulate and agree to the following terms and conditions: +32 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 34 of 39 +SETTLEMENT PROVISIONS +Monetary Penalty +114. +Deutsche Bank shall pay a penalty to the Department, pursuant to New York +Banking Law §§ 39 and 44, in the amount of one hundred fifty million U.S. dollars +($150,000,000.00). The entire amount shall be paid to the Department within ten (10) business +days of executing this Consent Order. +115. +Deutsche Bank agrees that it will not claim, assert, or apply for a tax deduction or +tax credit with regard to any U.S. federal, state, or local tax, directly or indirectly, for any portion +of the civil monetary penalty paid pursuant to this Consent Order. +116. Deutsche Bank further agrees that it shall neither seek nor accept, directly or +indirectly, reimbursement or indemnification with respect to payment of the penalty amount, +including but not limited to payment made pursuant to any insurance policy. +Remediation +117. An independent monitor selected by the Department is already engaged to assist +the Bank pursuant to the Consent Order entered into between the Bank and the Department dated +January 30, 2017. The Department has directed the monitor to address the compliance failures +implicated by the instant Consent Order in the context and within the timetables of that +engagement. The Bank reconfirms its commitment to cooperate fully with the monitor and +acknowledges that, although no extension of the monitorship is currently contemplated, the +Department may, in its sole regulatory discretion, extend the scope of duration of the +monitorship to address the Bank's failures described herein. +33 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 35 of 39 +Full and Complete Cooperation +118. +The Bank commits and agrees that it will fully cooperate with the Department +regarding all terms of this Consent Order, and as noted above, the Bank has already provided +exemplary cooperation in these and related matters. +Waiver of Rights +119. +The parties understand and agree that no provision of this Consent Order is +subject to review in any court or tribunal outside the Department. +Parties Bound by the Consent Order +120. +This Consent Order is binding on the Department, Deutsche Bank, including its +New York Branch, as well as any of their successors and assigns. This Consent Order does not +bind any federal or other state agency or any law enforcement authority. +121. +No further action will be taken by the Department against the Bank for the +conduct set forth in this Consent Order provided that the Bank complies with the terms of this +Consent Order. For the sake of clarity, such conduct includes (a) the Bank's AML control +deficiencies with respect to the onboarding and monitoring of foreign bank customers to whom +the Bank provided dollar-clearing services through the date of this Order, including but not +limited to the Bank's relationships with FBME and Danske Estonia discussed herein, but only to +the extent that such deficiencies do not constitute knowing and willful misconduct that would be +subject to penalty under New York Banking Law § 44(4); and (b) the Bank's relationship. with +Jeffrey Epstein and related individuals and entities. +122. +Notwithstanding any other provision in this Consent Order, the Department may +undertake action against Deutsche Bank for transactions or conduct in connection with FBME, +Danske Bank, and Jeffrey Epstein and his related entities that Deutsche Bank did not disclose to +34 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 36 of 39 +the Department in the presentations and written materials submitted to the Department in +connection with these matters. +Breach of Consent Order +123. +In the event that the Department believes any party to this Consent Order to be in +material breach of the Consent Order, the Department will provide written notice to the party, +and the party must, within ten (10) business days of receiving such notice, or on a later date if so +determined in the Department's sole discretion, appear before the Department to demonstrate +that no material breach has occurred or, to the extent pertinent, that the breach is not material or +has been cured. +124. +The parties understand and agree that any party's failure to make the required +showing within the designated time period shall be presumptive evidence of that party's breach. +Upon a finding that a breach of this Consent Order has occurred, the Department has all the +remedies available to it under New York Banking and Financial Services Law and may use any +evidence available to the Department in any ensuing hearings, notices, or orders. +Notices +125. All notices or communications regarding this Consent Order shall be sent to: +For the Department: +Terri-Anne Caplan +Senior Assistant Deputy Superintendent for Enforcement +New York State Department of Financial Services +One State Street +New York, NY 10004 +35 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 37 of 39 +Randolph | +Assistant Counsel for Enforcement +New York State Department of Financial Services +One State Street +New York, NY 10004 +Zachary Shapiro +Attorney for Enforcement +New York State Department of Financial Services +One State Street +New York, NY 10004 +For Deutsche Bank: +Joe Salama +Global Head of Litigation and Regulatory Enforcement +60 Wall Street +New York, NY, 10005-2836 +Andrew Stemmer +Head of Litigation & Regulatory Enforcement - Americas +60 Wall Street +New York, NY, 10005-2836 +Miscellaneous +126. +Each provision of this Consent Order shall remain effective and enforceable until +stayed, modified, suspended, or terminated by the Department. +127. +No promise, assurance, representation, or understanding other than those +contained in this Consent Order has been made to induce any party to agree to the provisions of +the Consent Order. +(The remainder of this page is intentionally blank.) +36 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 38 of 39 +IN WITNESS WHEREOF, the parties have caused this Consent Order to be signed this 6th day +of July, 2020. +NEW YORK STATE DEPARTMENT +DEUTSCHE BANK AG +OF FINANCIAL SERVICES +•R Bank +. BRUCE WEL +Associate Counsel +By:_ +Karen Kuder +General Counsel +Consumer Protection & Financial +Enforcement Division +By Kem pre +KEVIN R. PUVALOWSKI +Senior Deputy Superintendent +Consumer Protection & Financial +Enforcement Division +By: +KATHERINE A +• LEMIRE +Executive Deputy Superintendent +Consumer Protection & Financial +Enforcement Division +By: Inda Alacall +LINDA A. LACEWELL +Superintendent of Financial Services +By: +Thorsten Seyfriec +Jeneral Counsel - Germany anc +EMEA +DEUTSCHE BANK AG, +NEW YORK BRANCH +By: +Joe Salama +Global Head of Litigation and +Regulatory Enforcement +By:_ +Head or Stination & Regulatory +Enforcement - Americas +DEUTSCHE BANK TRUST +COMPANY OF THE AMERICAS +By:_ +Joe Salama +Global Head of Litigation and +Regulatory Enforcement +By:_ +Andrew Stemmer +Head of Litigation & Regulatory +Enforcement - Americas +37 + + +Case 1:22-cv-10904-JSR Document 241-18 Filed 07/25/23 Page 39 of 39 +IN WITNESS WHEREOF, the parties have caused this Consent Order to be signed this 6th day +of July, 2020. +NEW YORK STATE DEPARTMENT +OF FINANCIAL SERVICES +DEUTSCHE BANK AG +By: +R. BRUCE WELLS +Associate Counsel +Consumer Protection & Financial +Enforcement Division +By: +KEVIN R. PUVALOWSKI +Senior Deputy Superintendent +Consumer Protection & Financial +Enforcement Division +By: +KATHERINE A. LEMIRE +Executive Deputy Superintendent +Consumer Protection & Financial +Enforcement Division +By: +LINDA A. LACEWELL +Superintendent of Financial Services +By: Karen Kuder +Karen Kuder +By: +1 Mil +Thorsten Seyfried +General Counsel Germany and +EMEA +DEUTSCHE BANK AG, +NEW YORK BRANCH +By: Joe Salama +fe Salama +Global Head of Litigation and +Regulatory Enforcement +By: Andrew Stemmer +Andrew Stemmer +Head of Litigation & Regulatory +Enforcement - Americas +DEUTSCHE BANK TRUST +COMPANY OF THE AMERICAS +By: Joe Salama +re Salama +Ribal Head of Litigation and +gulatory Exorcement +By:_ +Steven F. 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HARPER-FORDE +Certified Shorthand Reporter (CSR) +Certified RealTime Reporter +(CRR) +Certified LiveNote Reporter (CLR) +Registered Professional Reporter +(RPR) +Notary +Public (FLORIDA) +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23 Page 3 of 11 +CAROL T. +U.S. VIRGIN ISLANDS vs JP +CHASE +in 2017 -- at least I wasn't aware +and I don't know if anyone at Attorney +General's Office was aware of these +allegations in 2017. +(BY ATTORNEY NEIMAN) : +e. And do you know if the +Attorney General's Office in the +Virgin Islands did anything at anytime +prior to 2019 to try to see what kind +of allegations were being made in +publicly filed lawsuits regarding +Jeffrey Epstein? +ATTORNEY ACKERMAN: Object to +July 13, 2023 +132 +form. +THE WITNESS: I'm not aware of +any. +(BY ATTORNEY NEIMAN) : +e. Would you agree with me that +it would have been appropriate for the +Virgin Islands to make efforts to find +out what kind of allegations were +being made against a prominent +resident like Mr. Epstein in publicly +filed lawsuits? +ATTORNEY ACKERMAN: +Object to +& ESQUIRE + + +Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23 Page 4 of 11 +CAROL T. +U.S. VIRGIN ISLANDS vs JP +form. +CHASE +July 13, 2023 +133 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE WITNESS: +If they were +aware. But like I say, I don't know +if anyone at the Virgin -- I don't +know if anyone -- at least I can only +speak as to myself. I know I wasn't +aware, and I don't know if anyone in +the Attorney General's Office was +aware. +(BY ATTORNEY NEIMAN) : +l. No. I understand that. But +I'm asking you a slightly different +question, which is given that Mr. +Epstein was a registered sex offender +living on the Virgin Islands and given +that he had been granted various +waivers of the ordinary registration +notification requirements and given +the difficulties that the Virgin +Islands had with the annual monitoring +visits, do you agree with me that it +would have been appropriate given +those facts for the law enforcement in +the Virgin Islands to make efforts +affirmatively to monitor what was +→ ESQUIRE + + +Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23 Page 5 of 11 +CAROL T. +U.S. VIRGIN ISLANDS vs JP +CHASE +being alleged about Mr. Epstein in +publicly filed civil lawsuits? +ATTORNEY ACKERMAN: Object to +July 13, 2023 +134 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Iorm. +THE WITNESS: +If they were +aware of the publicly filed lawsuits, +and I -- I have no information that +the Virgin Islands was aware of this +lawsuit in 2017. +(BY ATTORNEY NEIMAN) : +2. Are you aware that it is not +hard to learn of publicly filed +lawsuits if you tried? +ATTORNEY ACKERMAN: Object to +form. +THE WITNESS: You know, I +don't know. I don't know what -- I +don't know. +(BY ATTORNEY NEIMAN) : +l. Okay. Do you think that the +Virgin Islands should have at least +tried to find out what was going +alleged in publicly - what was being +alleged in publicly filed lawsuits +regarding Mr. Epstein? +& ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23 Page 6 of 11 +CAROL T. +U.S. VIRGIN ISLANDS vs JP +CHASE +ATTORNEY ACKERMAN: Object to +form Asked and answered. +THE WITNESS: The Virgin +Islands can only respond to what they +know. And like I said, I don't know +if anyone in the Virgin Islands knew. +I was not aware, and I don't know if +anyone was aware in 2017. +(BY ATTORNEY NEIMAN) : +l. All right. I'm going to ask +my question in a slightly different +way, but same - same question. +Do you think part of the +Virgin Islands' responsibility for +protecting the community included +making efforts to try to learn what +was being alleged about Mr. Epstein in +publicly filed lawsuits? +ATTORNEY ACKERMAN: Object to +July 13, 2023 +135 +form. +THE WITNESS: The Virgin +Islands can only take action on what +they know. And I've said it, I have +no information that they were aware of +this. +2 ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23 Page 7 of 11 +CAROL T. +U.S. VIRGIN ISLANDS vs JP +CHASE +July 13, 2023 +146 +Q. We have met before. I am +David Ackerman with the law firm of +Motley Rice. +We represent the +Government of the Virgin Islands in +this action. +I'm just going to have a few +questions for you. And I want to +start with that document that was +marked as Exhibit 10. Can you pull +that in front of you? +A. Yes. +l. And this is a document that's +entitled "Complaint." +Do you see that? +A. Yes. +l. Okay. Does the document +indicate where the Complaint was +filed? +A. It says United States District +Court Southern District of New York. +l. Was this Complaint filed in +the Virgin Islands? +A. No, it was not. +e. +Okay. In your opinion, do you +believe law enforcement has an +& ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23 Page 8 of 11 +CAROL T. +U.S. VIRGIN ISLANDS vs JP +CHASE +obligation to monitor public dockets +of every court in the country for +allegations that may reference the +Virgin Islands? +A. +I don't. I think it's +unreasonable. It would be an +unreasonable obligation on the Virgin +Islands. +l. Okay. Thank you. We can put +that document aside. +Let's go to Exhibit 1, which +is that big document. And I want to +start with the page that is -- I +apologize, I need to find it -- 12500 +near the end of the document. Are you +there? +July 13, 2023 +147 +A. Yes. +l. And this is the E-mail chain +that counsel showed you involving +Clive Rivers and Denise +• And +you were copied on several of these +E-mails; is that correct? +A. Yes. +Q. Okay. If you would look +please at the second page at the very +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23 Page 9 of 11 +CAROL T. +U.S. VIRGIN ISLANDS vs JP +CHASE +July 13, 2023 +148 +bottom. And there is an E-mail that +AG +sent to Attorney Kellerhals +and Attorney Rivers on June 2nd, 2019. +A. Uh-huh. +l. Do you see that? +A. Yes. +e. And then that E-mail continues +over to the next page, correct? +A. Yes. +Q. And if you look at the second +full paragraph on the next page, which +is +numbered 12502 -- +A. Yes. +l. - do you see the section that +says, "While my predecessors have +apparently had differing +interpretations of Title 14, Section +1724B (4) of the Virgin Islands code." +Did I read that correctly? +A. Yes. +l. Okay. In your experience in +government, is it unusual for +different office holders to have +differing interpretations of statutory +provisions? +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23 Page 10 of 11 +CAROL T. +U.S. VIRGIN ISLANDS vs JP +CHASE +A. +This is something - you know, +it happens. Different Attorney +Generals give different -- can have a +different opinion on a particular +issue. +July 13, 2023 +149 +l. Okay. Are you familiar with +Section 1724B (4) of the Virgin +Islands code? +A. Yes. +l. And did you become familiar +with that section in connection with +your review of materials relating to +Mr. Epstein's sex offender +registration? +ATTORNEY NEIMAN: Objection to +form, leading. +THE WITNESS: Yes, I did. +(BY ATTORNEY ACKERMAN) : +l. Okay. Let me ask the question +differently. +How did you become familiar +with that section? +A. When the matter was -- the +issue was brought to me by Attorney +Shani, I reviewed the statute. +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23 Page 11 of 11 +CAROL T. +U.S. VIRGIN ISLANDS vs JP +CHASE +Q. Okay. +Does that statute say +anything about the Attorney General's +role in the notification +requirements? +A. +It gives the Attorney General +the discretion to modify the +notification requirements. +e. okay. Do you have any -- any +understanding as to whether Attorney +General Frazer was exercising his +discretion in granting a waiver? +A. From his letter, that's what +it appears. +l. Okay. Do you believe that +Attorney General Frazer did anything +inconsistent with the statute in +granting the waiver to Mr. Epstein? +A. Attorney Generals are free to +exercise their discretion however they +see fit. And he exercised his +discretion one way, and I -- when I +was sitting Attorney General, I +exercised my discretion in a different +manner. +July 13, 2023 +150 +2. When you were sitting Attorney +→ ESQUIRE \ No newline at end of file diff --git a/vision-fixhub/court-05/57fc87bce892e82b325aa81943ed655b2ba7eb78ae90696c5c2080b2fd0ecdc8.receipt.json b/vision-fixhub/court-05/57fc87bce892e82b325aa81943ed655b2ba7eb78ae90696c5c2080b2fd0ecdc8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..846727bb98a215e377f6085b4e58bf4f570cf441 --- /dev/null +++ b/vision-fixhub/court-05/57fc87bce892e82b325aa81943ed655b2ba7eb78ae90696c5c2080b2fd0ecdc8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -764, + "dataset": "marble-joined", + "doc_id": "57fc87bce892e82b325aa81943ed655b2ba7eb78ae90696c5c2080b2fd0ecdc8", + "engine": "marble-apple-vision", + "event_count": 13, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "97889c445ade7d141006e0fe40cbfdbfa87a1a434be95ddebe227e49b3be4c6a", + "output_sha256": "5d05b1950eadcd60525783ab0302d9fd07c7ef9d77b58917d0bc676ef91df8a6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5805deb00e72ec3e4f1624d32a82f562c38f3f1876a11e63b35708e8154dc4ca.md b/vision-fixhub/court-05/5805deb00e72ec3e4f1624d32a82f562c38f3f1876a11e63b35708e8154dc4ca.md new file mode 100644 index 0000000000000000000000000000000000000000..4496cc4b2c5c41fe1c5f8bf2c085b6d84e6d5100 --- /dev/null +++ b/vision-fixhub/court-05/5805deb00e72ec3e4f1624d32a82f562c38f3f1876a11e63b35708e8154dc4ca.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 240-25 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/5805deb00e72ec3e4f1624d32a82f562c38f3f1876a11e63b35708e8154dc4ca.receipt.json b/vision-fixhub/court-05/5805deb00e72ec3e4f1624d32a82f562c38f3f1876a11e63b35708e8154dc4ca.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..94f332720bc3af1f40e4cf2679ca2c9764cc6b05 --- /dev/null +++ b/vision-fixhub/court-05/5805deb00e72ec3e4f1624d32a82f562c38f3f1876a11e63b35708e8154dc4ca.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "5805deb00e72ec3e4f1624d32a82f562c38f3f1876a11e63b35708e8154dc4ca", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "cd7cc3609e7405760d5694a50aaea7c6f856da0313585f1f7989b8b53bb1a2a2", + "output_sha256": "f94b9de5b3383d52ba08046d2e77d0a39b74a42a81e4de6421ce30d5ba56de5e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/582513ce3e51e5051fa3293ed06d7ddf77098d738b1af229ae6262d2055f5863.md b/vision-fixhub/court-05/582513ce3e51e5051fa3293ed06d7ddf77098d738b1af229ae6262d2055f5863.md new file mode 100644 index 0000000000000000000000000000000000000000..944c329d10dc613ba264b348442acf8a260c2c55 --- /dev/null +++ b/vision-fixhub/court-05/582513ce3e51e5051fa3293ed06d7ddf77098d738b1af229ae6262d2055f5863.md @@ -0,0 +1,352 @@ +Case 1:22-cV-10904-JSR Document 270-18 Filed 08/07/23 Page 1 of 7 + + + +Case 1:22-CV-10904₫SRf Peeweet 270-19 railed 08/03 Zar Rage 2 of 7 +00001 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +Case No. 1:22-cv-10019 (JSR) +-X +JANE DOE 1, Individually +and on behalf of all others +similarly situated, +: +Plaintiffs +VS +: +: +JPMORGAN CHASE BANK, N.A., +Defendant +: +-X +Case No. 1:22-cv-10904 (JSR) +- +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS +-X +: +Plaintiffs +: +VS +: +: +JPMORGAN CHASE BANK, N.A., +Defendant +: +- +-X + +Videotaped deposition of +FRANCIS PEARN taken at the offices of +Boies Schiller Flexner LLP, 55 Hudson +Yards, New York, New York 10001, before +Clifford +1. Certified Shorthand +Reporter, and Notary Public in and for the +State of New York, on March 29, 2023, at +9:47 a.m. EDT. +Page 1 + + +Case 1:22-cv-10904@SRf Poswer 270-19 ralled 08/03Zảr Rage 3 of 7 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So same person -- +A +Yes. +- that you currently report to? +Understood. +When did you start working for JPMorgan? +A +November of 1990. +Q +Have you worked exclusively for +JPMorgan since then? +A +No. +Can you tell me who else you've worked +for and when? +So 1990 through 2001, JPMorgan; 2001 +through 2006, Bank of America; 2006 to 2009, +Lehman Brothers; and then 2009 to today, +JPMorgan. +What -- what were your primary +responsibilities in your -- in your previous +role? +MR. BUTTS: Which -- which previous +role are we talking about? +MR. ARNOLD: Fine. +BY MR. ARNOLD: +What were - what were -- what were +your responsibilities in your previous role as +Page 13 + + +Case 1:22-cv-10904@SRf Peeweer 270-19 ralled 08/03lảr Rage 4 of 7 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +You may answer as a 30 (b) (1) +witness. +A +Yes. +BY MS. BOGGS: +l Here it's signed by a vice president, +looks like Bill Dougherty. +Is it typical for CTRs to be signed by a +vice president? +A +I don't know. +Who usually signs CTRs? +A +The -- the individual or individuals +that are responsible for the filing of the CTR. +Generally it's a group within our operations +teams. +CTRs are different than SARs; right? +A +Yes. +How are they different? +A +The CTR is merely a record of cash +transactions above the 10,000-dollar threshold. +The suspicious activity report, or SAR +as you -- as you said, is when the bank believes +that there is potentially suspicious activity +involving a transaction or a series of +transactions. +Page 119 + + +Case 1:22-cv-10904@SRf Peeweera 270-19 ralled 08/03Zảr Rage 5 of 7 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +In the context of a CTR or a SAR, what +is -- what does it mean for a structuring +transaction? +A +Structuring is not involved in CTRs. +Structuring is a crime and structuring is +something that our AML program monitors for. +So what is structuring? What does it +look like? +Structuring is the customer's attempts +to avoid the regulatory filing of a CTR, in +general terms. +And so structured transactions are +reported in SARs, not CTRs; correct? +That's correct. +JPMorgan is required to file CTRs +pursuant to federal regulation; right? +A +Yes. +If a customer has a good reason for +needing to conduct a currency transaction +exceeding 10,000, do you still need to fill out a +CTR form? +A +Yes. +• So the -- the reasoning is irrelevant; +is that correct? +Page 120 + + +Case 1:22-cv-10904@SRf Peeweer 270-19 ralled 08/03Zảr Rage 6 of 7 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +trafficking that you are looking at in this risk +assessment; it's more just a general pattern of +behavior which would include money laundering and +other activities? +MR. BUTTS: Objection. And +objection to form. +You may answer. +There are -- the -- the activities that +could be indicative of human trafficking or drug +smuggling are what our transaction monitoring is +focused on. +In addition to that, there are various +scenarios that are -- have been in place and are +used to help investigators with once an alert is +generated through those activities that -- that I +talked about, that could be indicators of +activities such as human trafficking or drug +smuggling. +And those are documented as part of the +BSA/AML investigative transaction monitoring +team's processes and procedures that they use that +could be indicative of human trafficking. +So if they see the activity and then +they have the scenarios that would potentially be +Page 136 + + +Case 1:22-cv-10904@SRf Peeweera 270-19 ralled 08/03lảr Rage 7 of 7 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +a human trafficking activity, they would be able +to see +that. +BY MS. BOGGS: +• Did JPMorgan's assessment of its risks +relating to human trafficking materially change +from 2006 to 2019? +MR. BUTTS: objection. Form. +You may answer if you are able. +A +It evolved. Like, as our program did. +As more work was done with other institutions, +with law enforcement, with global bodies such as +the Wolfsberg organization, which we are a +member, the U.S. regulators later in 2014 and +again in 2020 put out supplements -- put out +supplementary guidance specific around human +trafficking. +In there they included what they call +red flags or types of activities, the term I've +been using here, that could be an indicator or +indicators of human trafficking. +So all of that led to or contributed to +our evolving our efforts to identify money -- +potential money laundering related to human +trafficking. +Page 137 \ No newline at end of file diff --git a/vision-fixhub/court-05/582513ce3e51e5051fa3293ed06d7ddf77098d738b1af229ae6262d2055f5863.receipt.json b/vision-fixhub/court-05/582513ce3e51e5051fa3293ed06d7ddf77098d738b1af229ae6262d2055f5863.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9a3583fe8a1705562cca505a5ef02ee3f1a79208 --- /dev/null +++ b/vision-fixhub/court-05/582513ce3e51e5051fa3293ed06d7ddf77098d738b1af229ae6262d2055f5863.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -269, + "dataset": "marble-joined", + "doc_id": "582513ce3e51e5051fa3293ed06d7ddf77098d738b1af229ae6262d2055f5863", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "0d075f918db8f30de0a0eb15fe730a8eb104028f0616600f6ba1f9f1972b8f4d", + "output_sha256": "acbbacb23bd9d650b7cbf144bfe9010bfe6beec0c34e57d144150a6fac0d33a6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/582f606f87eae48d3b22c89e4a646c7cf13dbf5e03d4837ae9b2b08ddeaebf25.md b/vision-fixhub/court-05/582f606f87eae48d3b22c89e4a646c7cf13dbf5e03d4837ae9b2b08ddeaebf25.md new file mode 100644 index 0000000000000000000000000000000000000000..b25ccb95c9e67b5ffae666a8ed62039b8655f4f5 --- /dev/null +++ b/vision-fixhub/court-05/582f606f87eae48d3b22c89e4a646c7cf13dbf5e03d4837ae9b2b08ddeaebf25.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 158-77 Filed 05/23/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/582f606f87eae48d3b22c89e4a646c7cf13dbf5e03d4837ae9b2b08ddeaebf25.receipt.json b/vision-fixhub/court-05/582f606f87eae48d3b22c89e4a646c7cf13dbf5e03d4837ae9b2b08ddeaebf25.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e24db840da598c344c252d87fe195c9c6d0c4774 --- /dev/null +++ b/vision-fixhub/court-05/582f606f87eae48d3b22c89e4a646c7cf13dbf5e03d4837ae9b2b08ddeaebf25.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "582f606f87eae48d3b22c89e4a646c7cf13dbf5e03d4837ae9b2b08ddeaebf25", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "abb9d9fd433da2b0caa268acbe3a2afd0a6e43624086b446cd874d1703c4b024", + "output_sha256": "7c71e7da672355d50573f00aa331c6c9c445efa6822185956bf266e8a60f32f1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/588cdb69a37edad727b9dfc2311fce99646e02dbd026573422085598ef940dff.md b/vision-fixhub/court-05/588cdb69a37edad727b9dfc2311fce99646e02dbd026573422085598ef940dff.md new file mode 100644 index 0000000000000000000000000000000000000000..0d88c34ecc1514c215fe6c681538ff22ac738a56 --- /dev/null +++ b/vision-fixhub/court-05/588cdb69a37edad727b9dfc2311fce99646e02dbd026573422085598ef940dff.md @@ -0,0 +1,79 @@ +Case 1:22-cV-10904-JSR Document 238-45 Filed 07/25/23 Page 1 of 3 + + + +Case 1:22-cV-10904-JSR Document 238-45 Filed 07/25/23 Page 2 of 3 +From: +Sent: +To: +CC: +Subject: +Deluca, Phillip A [phillip.a.deluca@jpmchase.com] +1/10/2011 12:50:19 PM +Nichols, Nina A [nina.a.nichols@jpmchase.com] +Langford, William D [william.d.langford@jpmchase.com] +FW: Jeffrey Epstein +Nina, +Welcome! Sorry to start your day off with a crazy matter but I'm sure when you discuss this with William he'll +provide some color around this matter. This fits into the never a dull moment category. +Please see below. I can also fill you in with additional details when we speak. In essence: +• JPMC maintains the Private Banking (PB) relationship for this individual, Jeffrey Epstein. +• He is alleged to be involved in the human trafficking of young girls and law enforcement is also allegedly +investigating his involvement in this activity. +• He is also an alleged personal associate of the CEO of the Investment Bank (Jes Staley) +• AML Operations went to a PB risk meeting late last week requesting that we exit this relationship. +• The CEO of PB US (Catherine Keating) and PB General Counsel (Anne Verdon) suggest that William and PB +management meet with Jes Staley to review our recent HT initiative with him. +I'm copying William as we have discussed this individual in the past and you may not have email set up +yet. Maryanne Ryan's email below discusses the request as well as additional detail related to Epstein. +Please let me know when you have a few moments to discuss. +Thanks, +Phil +----Original Message---- +From: Ryan, Maryanne X +Sent: Friday, January 07, 2011 7:33 PM +To: DeLuca, Phillip A +Cc: Middlemiss, Arthur +Subject: Jeffrey Epstein +Phil- +This email is a summary of the Rapid Response meeting regarding Jeffrey Epstein. It involves an ask of William so I +am sending to you first. +The RR meeting attended by Catherine Keating, Ann Verdon, the current and former banker, Kevin, Jim and Bonnie +from Risk and Art and I. +Jeffrey Epstein is a friend of Jes S and Catherine feels that PB along with William should meet with him to explain :: +the HT project and explain the banks recognition on the project and whether Epstein if further exposed could have +a potential serious impact. +Epstein was released in July from house arrest and the Palm Beach Post carried two articles saying DO] may be +investigating for child trafficking via a modeling agency he is part owner in. I think Catherine believes that after +the briefing on HT that Jes would need to point blank ask jeffrey the status of any criminal +Investigations. Catherine made sure we knew that no one on today's call was in favor of having retained him as a +Д ПЕХНІВІТ 28 +DeponenCutter +Datel +224/83 Rptr. Am + +WWW.DEPOBOOKPRODUCTS.COM +JPM-SDNYLIT-00152748_R + + +Case 1:22-cV-10904-JSR Document 238-45 Filed 07/25/23 Page 3 of 3 +client. Seems it all is due to Jes's personal relationship. Note he has about 212 mil in the bank and some in JPMS +(old Bear PCS) +I asked legal and asked on the call about if we were ever subpoened and seems it is NO which I find very +interersting as Bear was. I also spent a good deal of time looking at his assistant or young lady he brought over +from Praque or some place like that) account. She was involved in some of the detailed escapades. She opened +accounts in PB sponsered by him. my were her debit transactions enlighting as compared to countless stories +related to his escapades. Lots of salon, lingerie shops, drug stores ny palm beach and in st +(his places of +residence). Plus lots of video like girls gone +Land some other shops not fit for my good catholic +upbringing! The transactions are old 05 to 08. Besides frequent frequent spa like charges it has died down +• Surprised she was never subpoened. +The one new concerning thing is the one article about the DOJ investigation is saying they brought under age girls +to the US via a modeling agency M2 that is owned by a guy named Brunel. Turns out the banker said today we +extended Epstein a loan in relation to this modeling agency. It appears to be a legit modeling agency, If girls were +expolited via their contract or arrangement it would be hard for us to tell. +Bottom line we need W to meet with Jes to explain HT and then Jes could decide the next steps. +Typed on my bb so sorry for typos. I do have a PB rapid response memo I can forward as well. + +JPM-SDNYLIT-00152749_R diff --git a/vision-fixhub/court-05/588cdb69a37edad727b9dfc2311fce99646e02dbd026573422085598ef940dff.receipt.json b/vision-fixhub/court-05/588cdb69a37edad727b9dfc2311fce99646e02dbd026573422085598ef940dff.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6590bb1643dbdd787fea12f4219a042923ab99d5 --- /dev/null +++ b/vision-fixhub/court-05/588cdb69a37edad727b9dfc2311fce99646e02dbd026573422085598ef940dff.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -70, + "dataset": "marble-joined", + "doc_id": "588cdb69a37edad727b9dfc2311fce99646e02dbd026573422085598ef940dff", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "6d037550c0b97580707b62672964ea22560834c7f5abe226e16dd99b782b8028", + "output_sha256": "df27be0719c89e08c837709196b76060051f2954ab00a00b1025391ba4f78a12", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/589302ecc10578658b885b8cba6b425e3dda92bacb3da3b0ba76f5a982613af4.md b/vision-fixhub/court-05/589302ecc10578658b885b8cba6b425e3dda92bacb3da3b0ba76f5a982613af4.md new file mode 100644 index 0000000000000000000000000000000000000000..47cf5575906b084dce01db7c718da5b73f151e01 --- /dev/null +++ b/vision-fixhub/court-05/589302ecc10578658b885b8cba6b425e3dda92bacb3da3b0ba76f5a982613af4.md @@ -0,0 +1,1968 @@ +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 1 of 30 + +FILED UNDER SEAL + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 2 of 30 +Page 1 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +---------- +JANE +DOE 1, individually and on +behalf of all others similarly +situated, +Plaintiff, +-against- +JPMORGAN Chase BANK NA, +Defendants. +- - +--_- +- - - +Case No. +1:22-cV-10019-JSR +- +- x + +Videotaped oral deposition of +MARYANNE RYAN taken pursuant to notice, +was held at BOIES SCHILLER FLEXNER LIP, +commencing May 24, 2023, 9:39 a.m., on +the above date, before Leslie Fagin, a +Court Reporter and Notary Public in the +State of New York. +MAGNA LEGAL SERVICES +(866) 624-6221 +www.MagnalS.com + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 3 of 30 +Page 23 +1 +M. Ryan - Confidential +2 +3 +4 +5 +6 +7 +8 +9 +l. In your experience working at the +10 bank, would 20 cash withdrawals be considered +11 unusual? +12 +A. It all depends. +13 +14 +15 +l. What does it depend on? +A. The customer -- who the customer +is, what they were doing through the bank, +16 +17 +the dollar amounts of the transactions, the +overall value of somebody's account, how the +18 money came into the account, things such as +19 +20 +21 +22 +23 +24 +25 +that. +Q. Is there anything else it might +depend on? +A. +I'm sure there are other things +that once you start to look at the account +might prompt you to include other elements. +09:59:00 +09: 59:01 +09:59:07 +09:59:11 +09:59:16 +09:59:21 +09:59:26 +09:59:29 +09:59:30 +09:59:36 +09:59:37 +09:59:39 +09:59:41 +09:59:45 +09:59:47 +09:59:50 +09:59:53 +09:59:55 +09:59:56 +09:59:57 +10:00: 01 +10:00:03 +10:00: 05 +10:00:10 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 4 of 30 +Page 25 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +M. Ryan - Confidential +When a document +came +from the private bank, what would be the next +step for the investigation team? +A. +We would look it over, and as long +as we were of the same opinion, we would file +the document as is -- almost as is, into a +SAR. +Is it possible that the +investigation team would determine no SAR was +necessary? +A. +Since we were charged with SAR +10:01:22 +10:01:25 +10:01:26 +10:01:28 +10:01:34 +10:01:40 +10:01:43 +10:01:45 +10:01:50 +10:01:53 +10:01:56 +10:01:59 +10:02:00 +10:02:01 +10:02:05 +10:02:09 +10:02:11 +10:02:15 +10:02:19 +10:02:25 +10:02:27 +10:02:29 +10:02:32 +10:02:33 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 5 of 30 +Page 27 +1 +M. Ryan - Confidential +2 +have a requirement to discuss it with anyone +10:03:52 +3 +else at the bank, is that correct? +10:03:53 +4 +A. Correct. +10:03:55 +5 +l. Is it possible despite not having a +10:03:56 +6 +requirement to do so, your team or the +10:03:59 +7 +investigation team may still discuss it with +10:04:01 +8 +others at the bank? +10:04:03 +9 +MR. KRAUSE: Objection. +10:04:05 +10 +A. The SAR decision lies solely with +10:04:06 +11 +the investigations department. Could an +10:04:11 +12 employee under me have discussed it with +10:04:15 +13 +another person within investigations? Sure. +10:04:18 +14 +But they weren't going back to the +10:04:20 +15 +business to discuss +the merits of SAR filing, +10:04:24 +16 +17 +if that's what you are implying. +10:04:28 +Would you have ever discussed the +10:04:30 +18 merits of a SAR filing with anyone outside of 10:04:32 +19 +20 +21 +22 +23 +24 +25 +the investigation team? +10:04:35 +10:04:37 +MR. KRAUSE: +objection. +A. I would discuss facts that might be 10:04:38 +in a SAR, but I would not be discussing +whether or not to put it on the clock or not +put it on the clock. +Was there anyone at JPMorgan who +10:04:42 +10:04:44 +10: 04:46 +10:04:48 + + +Case 1:22-CV-10904-JSR Document 263-49 Filed 08/07/23 Page 6 of 30 +Page 52 +1 +M. Ryan - Confidential +2 +Q. Who is Mary +7? +3 +A. According to Jim, she was the +4 +market manager. +5 +6 +In the last sentence, it says, We +will revisit if the allegations turn into an +7 +indictment. Is that right? +8 +A. +Correct. +9 +l. Is it your understanding that Jim +10 +is reporting Mary +determination or +1l making his own determination about that? +12 +MR. KRAUSE: Objection. +13 +A. I have no idea. +14 +15 +2. Do you have a view why the bank +would wait until allegations turn into an +16 +17 +indictment before doing an update of the DDR? +MR. KRAUSE: Objection. +18 +19 +A. Can you repeat the question? +e. Do you have a view as to why the +20 +bank would wait to revisit the allegations +22 +23 +24 +25 +21 until they turn into an indictment? +MR. KRAUSE: Objection. +A. +So there is too much unknown in +this sentence, the way it's written. I don't +know that -- whether or not the allegations +10:42:19 +10:42:21 +10:42:23 +10:42:24 +10:42:28 +10:42:32 +10:42:33 +10:42:34 +10:42:40 +10:42:46 +10:42:48 +10:42:49 +10:42:50 +10:42:53 +10:42:57 +10:43:04 +10:43:12 +10:43:14 +10:43:21 +10:43:27 +10:43:29 +10:43:30 +10:43:47 +10:43:51 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 7 of 30 +Page 53 +1 +M. Ryan - Confidential +2 +were included in the +• last DDR since she knew +3 +about it or not. +4 +It is -- there is lots of things -- +5 +lots of people that are in the news that +6 +7 +never go anywhere. +So the fact that somebody +is waiting for it to solidify into an +8 +indictment is not that unusual. +9 +2. Earlier you said, quote, That's the 10:44:34 +10 +forced timeline, but a banker can update his +1l profile of a customer at any point. End +12 quote. +13 +10:43:56 +10:43:59 +10:44:08 +10:44:10 +10:44:15 +10:44:18 +10:44:22 +10:44:38 +10:44:41 +10:44:44 +10:44:45 +14 +Do you have a view why, given these +news articles, why the banker would not want +10:44:50 +15 to update the profile sooner rather than +waiting for an indictment? +10:44:53 +10:44:56 +16 +17 +MR. KRAUSE: +objection. +A. I have never been in the banker's +10:44:58 +18 +20 +10:45:00 +19 role, so I don't know what he or she feels is +10:45:03 +important to include or not include nor could +10:45:07 +21 I tell from this sentence whether or not it +10:45:11 +22 +23 +24 +25 +was or wasn't included in +that last annual +10:45:14 +DDR. +10:45:17 +Would an investigator ask a banker +why they're making that determination? +10:45:18 +10:45:22 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 8 of 30 +Page 70 +1 +M. Ryan - Confidential +2 +11:22:33 +3 +11:22:35 +4 +11:22:35 +5 +11:22:38 +6 +11:22:41 +7 +11:22:45 +8 +9 +10 +11:22:48 +11:22:53 +11:22:54 +11 +11:22:57 +12 +It was your understanding at that +11:23:01 +13 +time that Jeffrey Epstein was not using any +11:23:03 +14 bank accounts or wire services in his +11:23:06 +15 +exploitation of women or children? +16 +MR. KRAUSE: Objection. +11:23:11 +11:23:14 +17 +A. If I had thought, I would have +11:23:16 +18 acted on it. +11:23:18 +19 +l. When Phil says, I hope -- sorry, he 11:23:19 +20 +doesn't say I -- he says, Hope that they do +11:23:28 +21 +not cave. +11:23:32 +22 +What did you understand that to +11:23:32 +23 +mean? +24 +11:23:34 +11:23:37 +25 +A. +We were presenting to the business +to tee it back up again to make a decision on 11:23:41 + + +Case 1:22-CV-10904-JSR Document 263-49 Filed 08/07/23 Page 9 of 30 +Page 71 +1 +M. Ryan - Confidential +2 +retention. So Phil was of the mindset, as +3 +was I, that he had to go. +4 +e. Why did you think he had to go? +5 +A. He was +a reputational risk to the +6 +bank. +7 +Q. +Why was it a reputational risk to +8 +the bank? +9 +A. Any client that would be +10 +consistently in the news for any variety of +11 +reasons would present reputational risk to +12 the bank. +13 +l. But in this particular instance, +14 +what was the reputational risk to the bank? +15 +A. There were allegations and there +16 +was a conviction about improper behavior with +17 +a minor. +18 +Q. And at that time you believed those +19 +allegations? +20 +21 +MR. KRAUSE: Objection. +A. I had no firsthand knowledge. I +22 +23 +24 +25 +was reading what I read +in the paper, and I +thought it was disturbing enough that the +customer should be re-reviewed for exit +determination by JPMorgan. +11:23:44 +11:23:49 +11:23:52 +11:23:57 +11:24:00 +11:24:01 +11:24:04 +11:24:05 +11:24:10 +11:24:15 +11:24:18 +11:24:18 +11:24:20 +11:24:23 +11:24:25 +11:24:30 +11:24:35 +11:24:39 +11:24:41 +11:24:45 +11:24:47 +11:24:50 +11:24:53 +11:24:57 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 10 of 30 +Page 92 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +M. Ryan - Confidential +l. But it is fair to say that at the +very least at this rapid response meeting +whether or not to keep Jeffrey Epstein as a +client was discussed, is that right? +A. That was the intention of the +discussion. +Do you believe it is proper for a +banker to directly ask a client for facts +regarding an investigation into whether the +11:54:07 +11:54:09 +11:54:14 +11:54:17 +11:54:19 +11:54:22 +11:54:24 +11:54:26 +11:54:29 +11:54:32 +11:54:33 +11:54:34 +11:54:39 +11: 54:42 +11:54:46 +11:54:49 +11:54:51 +11:54:54 +11:54:56 +11:54:59 +11:55:01 +11:55:02 +11:55:06 +11:55:13 +LeGAl SerVIceS + + +Case 1:22-cV-10904-JSR Document 263-49 Filed 08/07/23 Page 11 of 30 +Page 107 +1 +M. Ryan - Confidential +2 +Do you see +that? +3 +A. I do. +4 +5 +I. Did you find it surprising that the +bank had extended a loan in relation to a +6 +modeling agency that the DOJ appeared to be +7 +investigating in relation to underage sex +8 +trafficking? +9 +10 +MR. KRAUSE: Objection. +A. I needed to know more. It was the +12:13:37 +12:13:37 +12:13:38 +12:13:43 +12:13:50 +12:13:56 +12:14:02 +12:14:03 +12:14:04 +11 +first I was hearing of it, +so I wanted to +12 understand more about M2. +13 +When you said, If girls were +14 +12:14:07 +12:14:14 +12:14:19 +12:14:27 +15 +exploited via their contract or arrangement +it would be hard for us to tell, what did you 12:14:30 +16 +17 +mean by that? +A. If some girl signed on to a +18 modeling agency and was of the belief that +19 +20 +21 +22 +23 +24 +25 +she was coming to America to do modeling and +that wasn't the case, we would not know +12:14:39 +12:14:41 +12:14:44 +12:14:48 +12:14:51 +whether or not that was true or not. +12:14:55 +12:14:59 +In 2011, did you believe the +allegations regarding the M2 modeling agency? +12:15:02 +MR. KRAUSE: Objection. +A. I think I just heard about it. +12:15:05 +12:15:06 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 12 of 30 +Page 108 +1 +2 +4 +5 +6 +7 +8 +M. Ryan - Confidential +There was one article and I just heard about +it right there in that meeting that there was +a loan, +that's all I knew. +Once you learned move about the M2 +modeling agency, did you form an opinion +about +whether the allegations regarding +underage +sex trafficking +were true? +MR. KRAUSE: Objection. +A. +Again, there was an article that +the DOJ was looking at it, that's all I knew. +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So you end this email by saying, +Bottom line, we need Wto meet with Jes to +explain HT and then Jes can decide the next +steps. Typed on my BB, so sorry for typos. +I do have a PB rapid response memo I can +12:15:08 +12:15:11 +12:15:13 +12:15:15 +12:15:18 +12:15:21 +12:15:25 +12:15:28 +12:15:29 +12:15:32 +12:15:37 +12:15:40 +12:15:44 +12:15:52 +12:15:56 +12:15:56 +12:16:00 +12:16:02 +12:16:05 +12:16:06 +12:16:24 +12:16:27 +12:16:33 +12:16:38 + + +Case 1:22-CV-10904-JSR Document 263-49 Filed 08/07/23 Page 13 of 30 +Page 129 +1 +M. Ryan - Confidential +2 +know what -- I didn't know what Cutler knew +3 +or didn't know about the bank's HT work. +4 +I'm just trying to understand why +5 +you think Steve Cutler may feel differently, +6 +7 +8 +9 +10 +11 +12 +MR. KRAUSE: +Objection. Asked and +answered. +A. We were trying to get him out on +13 +reputational risk reasons. +Marrying together +14 +the current work that the department was +15 +doing, coupled with his old approval would +16 +have given him a complete picture to +17 +reapprove or relook at whether or not he was +18 still comfortable. +19 +Q. You then write, +I circled back with +20 +PB and that was the reason for the RR meeting +21 +on Friday. Seems -- no, let's stop there. +22 +23 +24 +25 +I will restate that. You write, I +circled back with PB and that was the reason +for the RR meeting on Friday. +Do you see that? +13:26:08 +13:26:10 +13:26:16 +13:26:21 +13:26:26 +13:26:30 +13:26:33 +13:26:37 +13:26:37 +13:26:39 +13:26:39 +13:26:44 +13:26:49 +13:26:54 +13:26:57 +13:27:00 +13:27:02 +13:27:04 +13:27:07 +13:27:12 +13:27:19 +13:27:21 +13:27:23 +13:27:26 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 14 of 30 +Page 133 +1 +M. Ryan - Confidential +2 +that if it were up to them, they would have +13:31:13 +3 +terminated their relationship with Jeffrey +13:31:16 +4 +Epstein? +13:31:19 +5 +MR. WOHLGEMUTH: objection. +13:31:19 +6 +A. +I don't recall anything specific +13:31:21 +7 +said. +13:31:24 +8 +l. You then write, Digging will take a 13:31:35 +9 few days, I will get back to you when I am +13:31:38 +10 +done. The guy likes cash so the paper trail +13:31:40 +11 +could be hard. +13:31:48 +12 +13 +14 +Do you see that? +13:31:50 +A. I do. +13:31:50 +2. What did you mean when you said, +13:31:50 +15 the guy likes cash so the paper trail could +13:31:53 +16 be hard? +13:31:56 +17 +A. +As I recall, there were not credit +13:32:01 +18 cards activity so I couldn't place people in +13:32:10 +19 +places at a certain time which is something +20 +we might look at credit card data for because +21 +paid -- he took out a lot of cash. +22 +23 +24 +25 +13:32:16 +13:32:18 +13: 32:22 +13:32:25 +13:32:29 +13:32:33 +13:32:34 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 15 of 30 +Page 134 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +M. Ryan - Confidential +MR. LAW: This will be Exhibit 10, +number JPM-SDNYLIT-W-00021929. +(Ryan Exhibit 10, Email Chain, +marked for identification.) +THE WITNESS: Okay. +13:32:36 +13:32:39 +13:32:42 +13:32:43 +13:32:44 +13:32:47 +13:32:49 +13:32:53 +13:32:56 +13:33:41 +13:33:43 +13:33:54 +13:33:54 +13:34:59 +13:35:00 +13: 35:03 +13:35: 07 +13:35:12 +13:35:13 +13:35:14 +13:35:19 +13:35:27 +13:35:30 +13:35:30 +EFTA02813021R + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 16 of 30 +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 139 +M. Ryan - Confidential +13:41:44 +13: 41:46 +13:41:50 +13:41:51 +13: 41:55 +13: 41:58 +13:42:02 +13:42:05 +13:42:10 +13:42:15 +13:42:18 +13:42:21 +13:42:21 +13:42:24 +13:42:27 +13:42:30 +13:42:34 +MR. LAW: This is Exhibit 11, +13:43:13 +number JPM-SDNYLIT-00194154. +13:43:16 +(Ryan Exhibit 11, Email, marked for 13:43:24 +identification.) +13:43:47 +THE WITNESS: Okay. +13:43:47 +l. This is an email from you, Maryanne 13:43:48 +Ryan, to Phillip Deluca on November 29, 2011, 13:43:53 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 17 of 30 +Page 202 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +M. Ryan - Confidential +16:13:17 +16:13:19 +16:13:22 +16:13:26 +16:13:30 +16:13:34 +16:13:37 +16:13:45 +16:13:48 +16:13:52 +16:13:58 +16:14:01 +16:14:03 +16:14:05 +16:14:10 +16:14:14 +16:14:18 +16:14:23 +16:14:27 +16:14:34 +16:14:40 +16:14:43 +16:14:45 +16:14:48 +LeGAl ServIceS + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 18 of 30 +Page 203 +1 +2 +3 +4 +5 +6 +7 +8 +M. Ryan - Confidential +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +16:14:51 +16:14:54 +16:15:00 +16:15:05 +16:15:08 +16:15:15 +16:15:23 +16:15:23 +16:15:26 +16:15:30 +16:15:32 +16:15:35 +16:15:39 +16:15:40 +16:15:42 +16:15:45 +16:15:51 +16:15:56 +16:15:59 +16:16:01 +16:16:02 +16:16:05 +16:16:08 +16:16:10 +LeGAl ServiceS + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 19 of 30 +Page 208 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +M. Ryan - Confidential +16:23:14 +16:23:15 +16:23:17 +16:23:22 +16:23:25 +16:23:28 +16:23:30 +16:23:31 +16:23:34 +16:23:39 +16:23:42 +16:23:45 +16:23:47 +16:23:47 +16:23:47 +16:23:56 +16:24:01 +16:24:08 +16:24:11 +16:24:15 +16:24:18 +16:24:23 +16:24:23 +16:24:27 +LeGAl ServiceS + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 20 of 30 +Page 209 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +M. Ryan - Confidential +16:24:30 +16:24:32 +16:24:34 +16:24:38 +16:24:42 +16:24:45 +16:24:47 +16:24:51 +16:24:54 +16:24:58 +16:25:01 +16:25:04 +16:25:08 +16:25:11 +16:25:15 +16:25:16 +16:25:21 +16:25:27 +16:25:29 +16:25:42 +16:25:46 +16:25:49 +16:25:54 +16:25:59 +LegAl ServiceS + + +Case 1:22-CV-10904-JSR Document 263-49 Filed 08/07/23 Page 21 of 30 +Page 221 +1 +M. Ryan - Confidential +2 +to MC2 Models Management LLC. +3 +Do you see that? +4 +A. I do. +5 +l. Did you find it unusual that the +6 +bank had issued a million dollars letter of +7 +8 +credit to Jeffrey Epstein to backstop a loan +of a model management company that was +9 publicly alleged to facilitate underage sex +10 +trafficking? +11 +MR. KRAUSE: Objection. +12 +A. As a standby letter of credit, it's +13 a backstop. So we were guaranteeing the +14 +million -- or Jeffrey Epstein was +15 guaranteeing the million dollars if something +16 +went wrong with the Mellon loan. +17 +l. The next email up, Paul Morris +18 writes, Jim, FYI, expires in April. I +19 +believe this has been extended for a year +20 +21 +22 +23 +24 +25 +each of the last two years. Let me know if +you want to discuss. Thanks. +Do you see that? +A. I do. +e. Do you know if that loan was +extended in April of 2011? +16:46:17 +16:46:23 +16:46:23 +16:46:24 +16:46:27 +16:46:32 +16:46:37 +16:46:42 +16:46:48 +16:46:49 +16:46:53 +16:46:58 +16:47:03 +16:47:04 +16:47:06 +16:47:11 +16:47:15 +16:47:19 +16:47:22 +16:47:25 +16:47:26 +16:47:26 +16:47:27 +16:47:29 + + +Case 1:22-CV-10904-JSR Document 263-49 Filed 08/07/23 Page 22 of 30 +Page 222 +1 +M. Ryan - Confidential +2 +A. I do not know. +3 +Q. Would you have been surprised if +4 +the loan was extended in April of 2011 given +16:47:36 +16:47:37 +16:47:39 +5 +the public allegations +regarding MC2 Models +16:47:42 +6 Management LLC? +16:47:47 +7 +MR. KRAUSE: Objection. +16:47:48 +8 +A. There was +an +article about MC2, +16:47:49 +9 +yes. But MC2 Model Management, LIC, the same +16:47:57 +10 +entity, or -- I don't know if it's the exact +16:48:04 +11 +same entity. But I don't know -- it's a +16:48:07 +12 backstop loan that was never called upon. So +16:48:12 +13 +I don't know what goes into making a credit +16:48:20 +14 +decision of pure exit or if there are strings +16:48:22 +15 attached to it. +16:48:26 +16 +Would it strike you as unusual for +16:48:27 +17/ +the bank to offer credit to a client to +16:48:29 +18 backstop a loan for a company that has +16:48:35 +19 +20 +21 +22 +23 +24 +publicly been alleged to facilitate underage +sex trafficking? +MR. KRAUSE: Objection. +A. +I would hope that in the annual +review that fact would have come out and +might have stopped them from renewing the +25 +loan. +16:48:39 +16:48:42 +16:48:44 +16:48:45 +16:48:53 +16:48:56 +16:48:58 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 23 of 30 +Page 225 +1 +M. Ryan - Confidential +2 +0. When you say +some other interesting +17:09:09 +3 +finds but no smoking guns were. +17:09:13 +4 +Do you see that? +17:09:16 +5 +A. Yes. +17:09:16 +6 +O. What did you mean by, other +17:09:17 +7 +interesting finds? +17:09:23 +8 +MR. KRAUSE: +Objection. +17:09:28 +9 +A. Just other things I noticed that I +17:09:29 +10 +was including so he could have other facts +17:09:32 +11 +when he went to speak to Jes. +17:09:42 +12 +Q. What was interesting about these +17:09:44 +13 +14 +finds? +17:09:47 +A. I mean he sponsored other customers +17:09:51 +15 +to the bank, saw different payments, no huge +17:10:08 +16 +amounts. I referred to him as a sugar daddy. 17:10:14 +17 +His foundation began paying donations to the +17:10:19 +18 Palm Beach police department down in Florida, +17:10:26 +19 +around -- as reported, just before the case +17:10:31 +20 +started; paid other monies to different +17:10:33 +21 +schools, nothing -- no astronomical payments. +17:10:36 +22 +And I noticed that his business +17:10:41 +23 +account, I saw no credits and debits to +17:10:43 +24 +particular investors of his. He sent a lot +25 +of money to his local Palm Beach bank +17:10:48 +17:10:54 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 24 of 30 +Page 226 +1 +M. Ryan - Confidential +2 +account. +17:11:00 +3 +So those were the finds, correct? +17:11:00 +4 +A. i +Correct. +17:11:05 +5 +2. What was interesting about those +17:11:05 +6 +finds? +17:11:08 +7 +A. Just terminology I applied to it. +17:11:10 +17:11:14 +8 +Nothing - nothing underhanded about, I just +9 thought they were things I told William as he 17:11:20 +10 prepared for that meeting. +17:11:22 +11 +17:11:23 +12 +13 +why do you +think you needed to tell William about these +17:11:26 +17:11:29 +14 +15 +16 +finds? +17:11:33 +MR. KRAUSE: Objection. +17:11:35 +A. He was meeting with Jes about +17:11:37 +17 +retaining Epstein as a customer. So there +17:11:39 +18 were different facts that I thought I should +19 pass on to William beforehand. +17:11:44 +17:11:46 +20 +0. +So for example, if we look at No. +17:11:52 +21 2, where you say, His foundation account did +17:11:57 +22 +pay donations to the Palm Beach police +17:11:59 +23 +department as reported just before the case +17:12:02 +24 +started, this same foundation account did pay 17:12:04 +25 +monies direct to models and payments direct +17:12:08 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 25 of 30 +Page 227 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +1 +M. Ryan - Confidential +2 +to specialty schools (massage, culinary) and +3 +universities on behalf of models/aspiring +4 +actresses, nothing was +astronomical. +17:12:11 +17:12:19 +17:12:24 +5 +Do you see that? +6 +A. I do. +7 +Q. Were you aware in 2011 that Jeffrey +Epstein was alleged to commit sexual +9 misconduct in relation to massages? +17:12:29 +17:12:29 +17:12:29 +17:12:37 +17:12:42 +A. I don't know when I became aware of 17:12:53 +certain things. There +has been so much press +17:12:57 +that -- throughout the years, I can't speak +17:13:00 +to exact moment that I heard about different +17:13:03 +allegations. +17:13:07 +Were you aware in 2011 that Jeffrey +17:13:08 +Epstein's sexual misconduct often involved +17:13:17 +models and aspiring +actresses? +17:13:23 +MR. KRAUSE: Objection. +A. +I don't -- I don't recall what I +read or didn't read about the people he +associated to. +17:13:28 +17:13:29 +17:13:35 +17:13:38 +17:13:40 +17:13:44 +17:13:47 +17:13:52 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 26 of 30 +Page 228 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +M. Ryan - Confidential +17:13:55 +17:13:57 +17:14:00 +17:14:03 +17:14:08 +17:14:12 +17:14:16 +17:14:19 +17:14:22 +17:14:28 +17:14:32 +17:14:36 +17:14:39 +17:14:42 +17:14:43 +17:14:44 +17:14:46 +17:14:50 +17:14:53 +17:14:55 +17:14:59 +17:15:01 +17:15:04 +17:15:07 +LeGAl ServIceS + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 27 of 30 +Page 229 +1 +M. Ryan - Confidential +2 +17:15:09 +3 +17:15:10 +4 +17:15:16 +5 +17:15:19 +6 +17:15:23 +7 +17:15:33 +8 +17:15:37 +9 +10 +11 +12 +13 +14 +15 +16 +17 +19 +20 +21 +22 +23 +24 +25 +17:15:41 +17:15:43 +17:15:46 +l. In the previous find you call +Jeffrey Epstein a sugar daddy. +Do you see that? +17:15:55 +17:15:58 +17:16:03 +A. +I do. +17:16:03 +What does that mean? +17:16:03 +A. +Somebody that likes to spend his +17:16:04 +18 money on ladies. +17:16:08 +e. +Does the term sugar daddy, in your +17:16:15 +view, imply financial support in exchange for +17:16:19 +sexual favors? +17:16:25 +A. +R. +No, it does not. +Did you find it unusual that he +spends, quote, a good deal at spa +establishments, end quote? +17:16:26 +17:16:32 +17:16:36 +17:16:39 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 28 of 30 +Page 230 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +M. Ryan - Confidential +A. They spent, he didn't spend. +l. Did you find it unusual that they +spent a good deal at spa establishments? +A. No. +l. Looking at the beginning of find +No. I, you say, the opening of DDA accounts +and a CC for two 18-year-olds turned 19 days +later, that appear to be part of his inner +entourage. One is mentioned in many of the +recaps of the escapades +as a willing +participant and assistant when hosting +visitors. +She has received about 450,000 +since opening from Epstein. +Do you see that? +A. +I do. +l. Did you find it unusual that a man +17:16:50 +17:16:59 +17:17:02 +17:17:08 +17:17:25 +17:17:27 +17:17:32 +17:17:39 +17:17:43 +17:17:45 +17:17:48 +17:17:50 +17:17:53 +17:17:56 +17:17:56 +17:17:57 +over 50 years old was opening accounts for +17:18:02 +18-year-old women who were not his relatives? +17:18:09 +A. +If they were significant other to +17:18:18 +him, no, I would not have found that unusual. 17:18:21 +Did you find it unusual that a +17:18:25 +willing participant of the escapades was paid 17:18:30 +450,000 from Epstein? +A. I'm not sure which article this is +17:18:37 +17:18:46 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 29 of 30 +Page 231 +1 +M. Ryan - Confidential +2 +referring to. +The way -- the way I phrased +3 it, if we are referring to that person +4 +earlier that I looked at, that was in another +5 +email, if -- I thought she +was his +6 +significant other and she was routinely +gifted money from Epstein and had her own +8 +account with her own +credit card, which had +9 +no strings; meaning he didn't control it. +10 +She came and went with the banker however she +11 +would see fit, that did not appear that +12 unusual to me. +13 +Q. If you learned that she was not his +14 +significant other, would it have appeared +15 +unusual to you? +16 +A. I would have found it very unusual +17 +that he would have sponsored somebody for the +18 private bank to independently operate if -- +that would not fit a fact pattern of somebody +17:18:51 +17:18:54 +17:18:57 +17:19:01 +17:19:09 +17:19:11 +17:19:15 +17:19:17 +17:19:20 +17:19:22 +17:19:26 +17:19:27 +17:19:29 +17:19:33 +17:19:33 +17:19:36 +17:19:38 +19 +20 +21 +22 +23 +24 +25 +17:19:46 +17:19:50 +that was controlling somebody to me. +l. Are you aware of anyone at the bank 17:19:52 +asking Jeffrey Epstein whether these women +were his significant others? +A. I am not aware of what led to the +opening of these accounts. +17:19:56 +17:20:00 +17:20:04 +17:20:08 + + +Case 1:22-cv-10904-JSR Document 263-49 Filed 08/07/23 Page 30 of 30 +Page 278 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +M. Ryan - Confidential +e. +So I do want to ask you a little +about Mr. Deluca's statement. +As you just testified, he responds +to your email about the large cash +withdrawals not stopping, and he said +shouldn't the business have been telling us +this, correct? +A. +That's what he wrote. +18:23:07 +18:23:09 +18:23:12 +18:23:16 +18:23:20 +18:23:20 +18:23:23 +18:23:27 +18:23:29 +18:23:34 +18:23:36 +18:23:47 +18:23:57 +18:23:59 +18:24:04 +18:24:06 +18:24:08 +18:24:10 +18:24:12 +18:24:15 +18:24:17 +18:24:20 +18:24:22 +18:24:23 \ No newline at end of file diff --git a/vision-fixhub/court-05/589302ecc10578658b885b8cba6b425e3dda92bacb3da3b0ba76f5a982613af4.receipt.json b/vision-fixhub/court-05/589302ecc10578658b885b8cba6b425e3dda92bacb3da3b0ba76f5a982613af4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9b35c4ff5983c2a4dcf7fea3340f71a50ad05344 --- /dev/null +++ b/vision-fixhub/court-05/589302ecc10578658b885b8cba6b425e3dda92bacb3da3b0ba76f5a982613af4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -920, + "dataset": "marble-joined", + "doc_id": "589302ecc10578658b885b8cba6b425e3dda92bacb3da3b0ba76f5a982613af4", + "engine": "marble-apple-vision", + "event_count": 32, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "0c9293f101cfc7dba0c115248681b241e167441ba099183a33540efc50996ece", + "output_sha256": "6a23754bd835d015efa0ff721e0e343667f2933020c8c881d44352cab4ddb6f8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/58d347d934e9f74b99f700d4dc5edc1074d8cbbd01191dca731d61ff5c320b04.md b/vision-fixhub/court-05/58d347d934e9f74b99f700d4dc5edc1074d8cbbd01191dca731d61ff5c320b04.md new file mode 100644 index 0000000000000000000000000000000000000000..5e62a8db2b25696aef401e3bdeb6e85888afdc09 --- /dev/null +++ b/vision-fixhub/court-05/58d347d934e9f74b99f700d4dc5edc1074d8cbbd01191dca731d61ff5c320b04.md @@ -0,0 +1,52 @@ +Case 1:22-cv-10904-JSR Document 133 Filed 05/05/23 Page 1 of 3 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-ev-10904-JSR +MOTION FOR ADMISSION +PRO HAC VICE +FOR EDEN SCHIFFMANN +JPMORGAN CHASE BANK, N.A., +Defendant / +Third-Party Plaintiff +JPMORGAN CHASE BANK, N.A.., +Third-Party Plaintiff, +JAMES EDWARD STALEY, +Third-Party Defendant. +Pursuant to Rule 1.3(c) of the Local Rules for the United States District Courts for the +Southern and Eastern Districts of New York, 1, Eden Schiffmann, hereby move this Court for an +Order for admission to practice pro hac vice to appear as counsel in the above-captioned case on +behalf of Third-Party Defendant James Edward Staley. +I am a member in good standing of the bars of Maryland and the District of Columbia, and +there are no pending disciplinary proceedings against me in any state or federal court. I have never +been convicted of a felony. + + +Case 1:22-cv-10904-JSR Document 133 Filed 05/05/23 Page 2 of 3 +I have never been censured, suspended, disbarred or denied admission or readmission by +any court. I have attached the affidavit pursuant to Local Rule 1.3. +Dated: May 5, 2023 +Respectfully submitted, +/s/ Eden Schiffmann +Applicant Signature +Applicant's Name: Eden Schiffmann +Firm name: +& Connolly LLP +Address: 680 Maine Avenue, S.W. +City / State / Zip: Washington, D.C. 20024 +Telephone: (202) 434-5977 +Fax: (202) 434-5029 +Email: ESchiffimann@wc.com +Attorney for James Edward Staley + + +Case 1:22-cv-10904-JSR Document 133 Filed 05/05/23 Page 3 of 3 +CERTIFICATE OF SERVICE +I hereby certify that on May 5, 2023, I electronically filed the foregoing document with the +Clerk of Court using the CM/ECF system which will send notification of such filing to all counsel +of record in this matter who are on the CM/ECF system. +/s/ Eden Schiffmann +Eden Schiffmann diff --git a/vision-fixhub/court-05/58d347d934e9f74b99f700d4dc5edc1074d8cbbd01191dca731d61ff5c320b04.receipt.json b/vision-fixhub/court-05/58d347d934e9f74b99f700d4dc5edc1074d8cbbd01191dca731d61ff5c320b04.receipt.json new file 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"epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5983c93a5fa102c056b9b6ae9af914a4f5daab32cc2672aa4f2a1cb18dcb6ed3.md b/vision-fixhub/court-05/5983c93a5fa102c056b9b6ae9af914a4f5daab32cc2672aa4f2a1cb18dcb6ed3.md new file mode 100644 index 0000000000000000000000000000000000000000..d0061d8e9c10f13a697cd7d70b31e5dadcdea3b2 --- /dev/null +++ b/vision-fixhub/court-05/5983c93a5fa102c056b9b6ae9af914a4f5daab32cc2672aa4f2a1cb18dcb6ed3.md @@ -0,0 +1,299 @@ +Case 1:22-cV-10904-JSR Document 263-66 Filed 08/07/23 Page 1 of 8 + +FILED UNDER SEAL + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +VS. +JPMORGAN CHASE BANK, N.A., +Defendant. +Case No. +1:22-CV-10904-JSR +JPMORGAN CHASE BANK, N.A., +Third-Party +Plaintiff, +vs. +JAMES EDWARD STALEY, +Third-Party +Defendant. +23 +24 +Wednesday, April 19, 2023 +CONFIDENTIAL - ATTORNEYS' EYES ONLY +Videotaped deposition of Phillip Deluca, held +at the offices of Ulmer & Berne, 65 East State Street, +Columbus, Ohio, commencing at 9:06 a.m., on the above +date, before Carol A. Kirk, Registered Merit Reporter, +Certified Shorthand Reporter, and Notary Public. +GOLKOW LITIGATION SERVICES +877.370.DEPS +deps@go1kow.com +Page 1 + + +Jeffrey Epstein from the bank? +2 +MR. KRAUSE: Objection. +3 +You can answer. +4 +A. Do I understand +can you repeat +5 +that, please? +6 +Q. Do you know the basis for AML +7 Investigations' recommendation to exit +Mr. Epstein from the bank? +A. I believe it was reputational +9 +10 risk. +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +Reputational risk based on what? +A. Based on a prior conviction. +Q. A prior conviction for what? +A. +Some type of sexual activity. +Do you know when relative to +Mr. Epstein's conviction the recommendation to +exit him from the bank was made? +A. No, I don't. +Q. Do you recall whether AML +Investigations recommended more than once that +Mr. Epstein be exited from the bank? +A. I don't recall. +l. Did you speak with Mr. Langford +24 +about the disagreement between Private Bank and +Page 85 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 += +Page 298 + + +1•22••989 & +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +BY +Page 299 + + +1 +2 +3 +4 +5 +6 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +What did he say in response? +A. +"I'll get back to you." +e. +Do you recall anything else? +A. +Pardon? +l. Do you recall anything else about +the call? +A. +No. +Q. How was it left? +A. +That he would get back to me. +e. +So did you ever hear back from +Mr. Moyer? +A. +About that? No. +e. Did you ever hear back from anyone +else at the FBI, whether an investigator, an +agent, or otherwise? +A. +NO. +2. Given your consistent dealings +with law enforcement, how did you interpret the +fact that the FBI never got back to you about +Epstein? +A. +That they weren't interested. +Okay. One more topic, and then +we'll be done. +Page 330 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +Did anyone from JPMorgan's +Private Bank ever at any time try to dissuade +you personally from doing anything at all in +connection with Jeffrey Epstein? +A. No. +l. Are you aware of any instance +where anyone from any of JPMorgan's businesses +Page 331 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +tried to dissuade you or any of your colleagues +from doing anything at all relating to +Jeffrey Epstein? +A. +I'm not aware of any of them. +• +You did or did not develop a good +understanding of Maryanne Ryan's temperament and +skills from your time working with her? +A. +Yes. +How skilled was Maryanne as an +investigator? +A. +Maryanne was extremely skilled. +You did or did not develop a good +understanding of Maryanne Ryan's temperament +from your time working with her? +Page 332 \ No newline at end of file diff --git a/vision-fixhub/court-05/5983c93a5fa102c056b9b6ae9af914a4f5daab32cc2672aa4f2a1cb18dcb6ed3.receipt.json b/vision-fixhub/court-05/5983c93a5fa102c056b9b6ae9af914a4f5daab32cc2672aa4f2a1cb18dcb6ed3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..220ea0ffd72d98448e810a104c7d8aeded6f2c92 --- /dev/null +++ b/vision-fixhub/court-05/5983c93a5fa102c056b9b6ae9af914a4f5daab32cc2672aa4f2a1cb18dcb6ed3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -297, + "dataset": "marble-joined", + "doc_id": "5983c93a5fa102c056b9b6ae9af914a4f5daab32cc2672aa4f2a1cb18dcb6ed3", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "d5473551a9bd1e008f3ad3fc3f3314fa3635c57fb03c4fdc65f9f1558338e80f", + "output_sha256": "42e8dfc95a26221e3a9c485e529749f0fa7ddcb82de64c0ea44b87201eb640ac", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5987b06536d82ede1573dd9e8bff56f2b717cc2ca443692c9997219cdfec1d2c.md b/vision-fixhub/court-05/5987b06536d82ede1573dd9e8bff56f2b717cc2ca443692c9997219cdfec1d2c.md new file mode 100644 index 0000000000000000000000000000000000000000..be748195eacb081e90449d2f04251abc4280cfc6 --- /dev/null +++ b/vision-fixhub/court-05/5987b06536d82ede1573dd9e8bff56f2b717cc2ca443692c9997219cdfec1d2c.md @@ -0,0 +1,3810 @@ +Case 1:22-cv-10904-JSR Document 70-2 +Filed 03/08/23 Page 1 of 131 + + + +Casse1122260v1D9019JSFR Documeet 7B62 FfliekD0.BI38/33 Fagge120₺11BB1 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +Jane Doe 1, individually and on +behalf of all others similarly +situated +CLASS ACTION COMPLAINT +Plaintiffs, +JURY TRIAL DEMANDED +v. +JP| +Case No.: 22-cv-10019-JSR +Chase Bank, N.A., +Defendant. +) +/ +FIRST AMENDED INDIVIDUAL AND CLASS ACTION COMPLAINT +Plaintiff Jane Doe 1 files this first amended individual and civil class action +complaint for damages and other relief under (among other provisions of law) the +United States federal anti-sex trafficking statute, 18 U.S.C. § 1591, et seq.—the +Trafficking Victim Protection Act ("TVPA") and for aiding and abetting, +intentional infliction of emotional distress, and negligence related to sexual offenses +as defined in article one hundred thirty of the penal law, pursuant to the New York +Adult Survivors Act, N.Y. CPLR §214-j. The suit arises from Defendant JP +Chase Bank, N.A.'s (hereinafter "JP +) participation and intentional +involvement in Jeffrey Epstein's widespread and well-publicized sex-trafficking +operation, as well as the direct financial benefits it received therefrom. +knew that it was providing the financial lifeblood for Epstein's +1 + + +Casse1122260v1D9019JSFR Documeet 7B62 FfliekD0.BI38233 Flagge230d 11.BB1 +international sex-trafficking organization from 1998 through August 2013. In +exchange for that crucial financial support, JP | +knowingly and intentionally +benefited and received things of value from Epstein and his sex-trafficking +operation. And that crucial financial support allowed Epstein to successfully rape, +sexually assault, and coercively sex traffic Jane Doe 1 and the numerous other +members of the Class proposed below (the "Class"). JP | +knew that Epstein +was regularly committing violations of New York Penal Law Art. 130, including, +and especially, New York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66, +and acted to enable, aid and abet, and facilitate Epstein's commission of such +offenses against countless young women, including Jane Doe 1 and Class Members. +also knew that Epstein would use means of force, threats of force, +fraud, abuse of legal process, exploitation of power disparity, and a variety of other +forms of coercion to cause young women and girls to engage in commercial sex acts. +Knowing that it would earn millions of dollars in exchange for facilitating Epstein's +sex abuse and trafficking, JP +chose profits over following the law. +Specifically, JP +chose participating in and facilitating Epstein's sextrafficking conspiracy for many years, including through the criminal investigation +and incarceration of Jeffrey Epstein, in order to churn profits. +Jane Doe 1 makes the following allegations on information and belief and +believes that substantial additional evidentiary support will exist for the allegations +2 + + +Casse11222601D901955R Documeet 7B62 FfiekD0.3138233 Flagge340₺11.BB1 +set forth herein after a reasonable opportunity for discovery: +1. JURISDICTION, VENUE, AND TIMELINESS +1. +This action is brought pursuant to various federal and state statues, +including the federal TVPA, 18 U.S.C. § 1589 through § 1595. This Court has +federal question subject-matter jurisdiction pursuant to 28 U.S.C. §1331, because +Jane Doe —individually and on behalf of the other Class membersproceeds +under the federal TVPA statute. +2. +This Court also has supplemental jurisdiction over the state law claims +recounted below pursuant to 28 U.S.C. § 1367(a), because all claims alleged herein +are part of a uniform pattern and practice and form part of the same case or +controversy. +3. +This Court is "an appropriate district court of the United States" in +accordance with 18 U.S.C. § 1595, in which to bring this action. Venue is proper in +this District under 28 U.S.C. § 1391(b)(2), because Epstein, his co-conspirators, and +all conducted substantial activities in this District and knowingly aided +and abetted, facilitated, and directly participated in Epstein's illegal venture through +actions that originated in this District. In addition, Epstein sexually abused and +trafficked Jane Doe 1 and members of the Class is this District. +Often these acts of sexual abuse and commercial sex acts, committed +by Jeffrey Epstein and certain select friends of his, took place in Jeffrey Epstein's +3 + + +Casse11222601D901955R Doocumeet 7862 FftekD0.3138233 Flagge450₺11 BB1 +New York mansion, located within this District at 9 East 71st Street in New York +City. Epstein also used his New York mansion to harbor his victims and as a base +from which to transport them to other locations outside of New York. +5. +A substantial part of the acts, events, and omissions giving rise to this +cause of action occurred in this District. +6. This action has been timely filed pursuant to 18 U.S.C. § 1595(c)(1), +which provides that a plaintiff shall have ten years after the cause of action arose to +file suit against any person who knowingly benefits, financially or by receiving +anything of value from participation in a venture which that person knew or should +have known violated the laws against sex trafficking. This action is also timely +because the conspiracy continued until recently. This action is also timely under +New York's Adult Survivor's Act, N.Y. CPLR § 214-j. +7. +II. PARTIES +Jane Doe 1 is a U.S. citizen and was at all relevant times a resident of +and domiciled in the State of New York. +Plaintiff Jane Doe 1 is using a pseudonym to protect her identity +because of the sensitive and highly personal nature of this matter, which involves +sexual assault. +9. +Jane Doe 1 is also at serious risk of retaliatory harm because the coconspirators who participated in the Epstein sex-trafficking venture had and +4 + + +Casse11222601D9019155R Doocumeet 7B62 FftekD0.3138233 Flagge560₺11 BB1 +continue to possesstremendous wealth and power and have demonstrated a clear +ability to cause her serious harm. +10. +Jane Doe I's safety, right to privacy, and security outweigh the public +interest in her identification. +11. Jane Doe I's legitimate concerns outweigh any prejudice to Defendant +by allowing her to proceed anonymously. +12. As discussed below, many other women are similarly situated to Jane +Doe 1 and also need to proceed anonymously for the same reasons. The identities of +most of these other women are known to Defendant. +13. Defendant JP +is a global financial institution headquartered in +New York, New York. +14. Defendant JP +is licensed by the New York State Department +of Financial Services to operate a foreign bank branch in the State of New York. +15. Defendant JP +currently conducts substantial business in this +District and conducted substantial business at the time of events covered in this +complaint. +16. As one example of business conducted in this District, JP +ordinarily trades shares on the New York | +Exchange, located in this District. +As another example, JP +maintains branch banks within this District. +17. JP| +financial activities, including the events alleged herein, +5 + + +Casse1122260v1D9019JSFR Documeet 7B62 FfliekD0.BI38233 Fagge67od11BB1 +were in and affecting interstate and foreign commerce. In connection with the acts +alleged in this complaint, Defendant, directly or indirectly, used the means and +instrumentalities of interstate commerce, including, but not limited to, the mails, +interstate telephone communications, and the facilities of national securities +markets. +18. JP +is responsible, under United States law and otherwise, for +the acts of its officers, directors, employees, and agents, including the acts described +in this complaint. The acts alleged were committed by JP +officers, +directors, employees, and agents were within actual and apparent scope of their +employment and with the intention, at least in part, to benefit JP +III. INTRODUCTION +19. Jeffrey Epstein's sex-trafficking venture operated in many respects as +a sex-themed cult designed to ensnare vulnerable young women and indoctrinate +them into Epstein's carefully constructed world in which Epstein was their messiah. +Epstein and his co-conspirators preached the gospel of Epstein. Epstein's victims +were taught to do what he said, and he would protect them; but disobey him, and he +would punish them; and continue to disobey, and he would cause them serious harm +from which they could never recover. +20. +Once in Epstein's clutches, each victim was taught and understood that +she must be completely compliant with every demand Epstein had for her; otherwise, +6 + + +Casse1122260v1D9019JSFR Documeet 7B62 FfliekD0.BI38233 Flagge780d 11.BB1 +she would certainly suffer serious reputational, financial, and psychological harm. +By using these and other means of force, threats of force, fraud, threats of abuse of +the legal process and coercion, Epstein and his co-conspirators sexually trafficked +and sexually abused Jane Doe 1 and the other members of the Class. +21. The Epstein sex-trafficking venture originated in the early 1990's. +From its inception until Jeffrey Epstein's arrest by the FBI for sex trafficking in 2019 +(and his subsequent death on August 10, 2019, by apparent suicide), the venture +operated primarily for the purpose of luring young women and girls into a position +where Jeffrey Epstein and his co-conspirators could coerce them to engage in +commercial sex acts and commit sexual offenses against them. His venture also +operated to conceal its sex trafficking from law enforcement organizations. And his +venture provided financial and other benefits to those who assisted and enabled the +venture. +22. The Epstein sex-trafficking venture was well-structured from the +beginning and grew increasingly more complex and powerful as it victimized more +young women and as its relationship with Defendant JP| +grew. +23. Epstein could not and did not act alone. He created and maintained his +sex-trafficking venture with the assistance of other influential individuals and +entities who knew he was sexually abusing and sexually trafficking young women +and girls and provided support to facilitate his sexual abuse and sex trafficking +7 + + +Casse1122260v1D9019JS5R Documeet 7B62 FfliekD0.BI38233 F1agge89od 11.BB1 +operation. +24. +Epstein's sex-trafficking venture was not possible without the +assistance and complicity of a financial institution specifically, a banking +institution +-which provided special treatment to Jeffrey Epstein and the sextrafficking venture, thereby ensuring its continued operation and sexual abuse and +sex-trafficking of young women and girls. Without the financial institution's +participation, Epstein's sex trafficking scheme could not have existed and flourished. +25. Epstein's victims were young women and girls, who suffered severe +abuse as Epstein's sex-trafficking victims and who believed they had to remain loyal +to the venture at all costs to survive. Epstein victimized hundreds of young women +and girls with the assistance of a wide network of co-conspirators, including JP +26. Epstein's sexual abuse and sex trafficking scheme was supported by +virtually unlimited wealth, derived from select wealthy individuals who acted as the +financial engine behind the sex-trafficking operation, in exchange for sexual and +other benefits. +27. Epstein masterfully assessed the specific needs and vulnerability of +each of his targeted victims. He then closed the trap on his victims with offers of +money, food, shelter, medical care for them or family members, travel, schooling, +and career opportunities. +Epstein groomed the young women and girls, +8 + + +Casse: 22202090199BR DoomenTB& Filed OB/18/23 Page 90fof 381 +indoctrinating them to believe that the sexual abuse was normal. +28. +Epstein fraudulently represented to the victims that he would take care +of them in various ways, which ultimately allowed Epstein to cause them to engage +in commercial sex acts with himself and, on occasion, select others, as well as to +create the opportunity for Epstein to sexually abuse them. +29. The Epstein sex-trafficking venture's purpose included enticing, +obtaining, harboring, and transporting the young victims without drawing unwanted +attention from law enforcement. The venture had everything a sex-trafficking +organization needed-funding, infrastructure, the appearance of legitimacy, and a +complicit banking institution. It was by many accounts the most powerful and +wealthiest sex-trafficking venture ever created. +30. The Epstein sex-trafficking venture knowingly used means of force, +threats of force, fraud, coercion (including threats of serious harm or physical +restraint), and abuse of law and the legal process, to cause Jane Doe 1, and many +dozens of others similarly situated women to engage in commercial sex acts. +31. +The Epstein sex-trafficking venture operated in and affected interstate +and foreign commerce. Epstein recruited, solicited, coerced, harbored, transported, +and enticed some of his victims, including Jane Doe 1 and others similarly situated, +to engage in commercial sex acts in, among other places, New York (including the +Southern District of New York), Florida, the U.S. Virgin Islands, New Mexico, +9 + + +Casse11222c01D9019155R Doocumeet 7862 FfekD03138283 Feel D1o611BB1 +England, and France. +32. The Epstein sex-trafficking venture operated throughout the world from +in and around (at least) 1998 through (at least) in and around August 10, 2019, when +Epstein died by apparent suicide. Thereafter, through at least July 2020, to and +including the date of this complaint, members of the sex-trafficking venture +continued to further the venture by concealing the activities and extent of the +venture. +33. The manner of operation for Epstein's particular sexual abuse and sex +trafficking operation was widely publicized. He would lure young girls or women +to one of his luxurious mansions, under the guise of being a wealthy philanthropist, +able to advance careers, education, or provide other life necessities, and once inside +he would force his would-be victim into providing a massage that would turn sexual, +and from there he would cause each of his unsuspecting victims to engage in a +variety of commercial sex acts. +34. +Once in his presence, each victim knew it was no option to disobey +Epstein. It was well known and understood that he was one of the most powerful +and connected people in the United States, able to help any of these young victims +and capable and willing to seriously harm any of his victims. +35. While Epstein's abuse began in the early 1990s with the use of his +paramour turned madame, Ghislaine Maxwell ("Maxwell"), Epstein's appetite for +10 + + +Casse11222c0109019155R Doocumeet 7862 FfiekD03138283 Flygel120611BB1 +sexually abusing young women and girls grew over the years. +36. By (at least) 1998, Epstein's sex trafficking venture had crystalized into +criminal conspiracy. By 1998, each victim was being directed to recruit other +vulnerable victims and being paid handsomely, typically in cash, for each +recruitment, creating a pyramid scheme of abuse. +37. +A Florida criminal investigation uncovered that the number of victims +of Epstein's sex-trafficking conspiracy grew exponentially in and around the early +2000s. +38. +While Epstein did pay victims and his many co-conspirators using wire +transfers and checks, because there were hundreds of victims, Epstein could not pay +all of his victims with traceable wires. +39. One primary reason why Epstein's sex-trafficking venture and +conspiracy accumulated new victims at an alarming rate in the late 1990s and +accelerated even faster by 2000 was Epstein's access to unlimited amounts of cash +and his knowledge that he had a complicit bank-JP +through which he +could operate his illegal abuse organization without fear of being reported to law +enforcement. +40. Without exorbitantly large amounts of cash, Epstein's operation could +not effectively operate, as newly recruited victims were each paid hundreds of +dollars in cash immediately after Epstein sexually abused them, as hush money. +11 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Fagel 230611BB1 +41. Each victim was also informed that she would be paid hundreds of +dollars in cash for each additional victim she recruited, and Epstein made good on +those promises of large cash payments to keep his victims quiet and complicit. +42. The public documents and articles stemming from the 2006 arrest made +abundantly clear that Epstein was doling out thousands of dollars in cash every +single day as hush money to victims he was sexually abusing and to victims he was +using to recruit additional victims. +43. If Epstein paid every victim with wire transfers or checks and left a +documented money trail, his illegal sexual abuse and sex trafficking operation would +have been easily uncovered; however, with access to unlimited amounts of cash, +Epstein was able to commit the most egregious sexual crimes many times a day +without leaving a paper trail. +44. Accordingly, Epstein's constant expansion of sexual abuse and +trafficking required cash on hand for Epstein to pay each victim as hush money for +the abuse she was suffering as well as each victim's finder's fee for bringing another +victim. +45. To access the large amount of cash needed to maintain his active sexual +abuse of young women, it was essential that the financial institution where he banked +be complicit in his operation, and more specifically that Epstein bank at a financial +institution that would allow him to constantly withdraw cash from his accounts +12 + + +Casse11222c01D9019155R Doocumeet 7862 FfiekD03138283 Flegel 340611BB1 +without following anti-money laundering and reporting laws. +46. +To put it plainly, Epstein needed a bank that knew he was engaging in +illegal activity and did not care, which Epstein had in JP | +47. This scheme of paying victims to recruit other victims worked +effectively for Epstein. It not only allowed expansion through the recruitment of +other victims in a pyramid scheme or spiderweb fashion, but it also gave each victim +hope that she could avoid future sexual abuse-she could bring someone else who +would get abused in her place. +48. Epstein's aptitude as a sex-trafficker and appetite as a sexual abuser did +not suffer because of his Florida incarceration in 2008. Even while he was in jail in +Florida, Epstein brazenly continued to sexually abuse young girls and women from +his work-release office. +49. Once out of jail and off work release, Epstein continued to collect +young women and lure them through force, fraud, or coercion into one of his +mansions, primarily his townhouse located at 9 East 71 Street, New York, NY, +where he would sexually abuse each one. +50. Epstein's sexual abuse and sex-trafficking operation continued as it had +in the past, although it became more elaborate, creating more phony companies, +opening more bank accounts, withdrawing excessive amounts of cash, and +delivering money to victims through wires, payroll, direct deposits, and other means +13 + + +Cassel1222e0v1D90193S5R Doooumeett7B62 FfleedD0B138283 FRagel15ob11BB1 +known to his financial institution as evidence of the continuation of his criminal sex +trafficking scheme. +51. +As time went by, especially after Epstein's Florida arrest, the news +articles and lawsuits about his activities continued to mount. More information +became publicly available that Epstein was continuing to abuse young women and +was using professionals on his payroll to help him conceal his illegal activity and +give him ostensible cover as a purported well-connected money manager. +52. As a registered sex offender discovered to be sexually abusing multiple +young women each day through a pyramid-type recruiting scheme that required the +transfer of millions of dollars to continue the operation, a complicit bank became +more important than ever. +53. As further detailed below, JP +worked closely with Epstein +through every step of the sex trafficking operation's expansion and growth in some +of its most prolific of years +between around 1998 through 2013. +IV. THE TRAFFICKING VICTIMS PROTECTION ACT +54. The Trafficking Victims Protection Act (TVPA) outlaws sex trafficking +activities that affect interstate or foreign commerce or take place within the territorial +jurisdiction of the United States. It is to be construed broadly because it serves a +remedial purpose and uses intentionally broad language. +55. The TVPA forbids, among other things, the following sex-trafficking +14 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flegel 560611BB1 +conduct: +(a) Whoever knowingly +(1) in or affecting interstate or foreign commerce, or within +the special maritime and territorial jurisdiction of the +United States +recruits, +entices, harbors, transports, +provides, obtains, advertises, maintains, patronizes, or +solicits by any means a person; or +(2) benefits, financially or by receiving anything of value, +from participation in a venture which has engaged in an +act described in violation of paragraph (1), +knowing, or, except where the act constituting the violation of +paragraph is advertising, in reckless disregard of the fact, that means of +force, threats of force, fraud, coercion described in subsection (e) (2), or +any combination of such means will be used to cause the person to +engage in acommercial sex act, or that the person has not attained the +age of 18 years and will be caused to engage in a commercial sex act, +shall be punished as provided in subsection (b). +18 U.S.C. § 1591(a). +56. +The TVPA also forbids (among other things) conspiring to violate 18 +U.S.C. § 1591. 18 U.S.C. § 1594(c). +57. +The TVPA also contains an explicit "civil remedy" provision which +allows an individual who is a victim of a violation of Chapter 77 of Title 18 (e.g., +violation of 18 U.S.C. §§ 1591-94) to bring a civil action against the perpetrator and +any person or entity who knowingly benefits, financially or by receiving anything of +value from participation in an illegal sex-trafficking venture. 18 U.S.C. § 1595(a). +58. +Unlike the criminal penalties provisions in the TVPA, the civil +15 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfiekD03138283 Feel 670611BB1 +remedies provision contains a "constructive knowledge" provision. This provision +allows a +civil action to be brought not only against a person or entity who +participated in a venture known to have engaged in illegal sex trafficking but also +against a person or entity who participated in a venture that the person or entity +should have known had engaged in illegal sex trafficking. 18 U.S.C. § 1595(a). This +expansive provision is known as the "constructive knowledge" provision, which +provides an alternative to proving actual knowledge as part of civil damages claim. +59. In the paragraphs that follow, wherever Jane Doe 1 alleges that +Defendant acted with actual knowledge, or in reckless disregard of the fact, that the +Epstein sex-trafficking venture used means of force, threats of force, fraud, coercion, +abuse of process, or some combination thereof to cause a person to engage in +commercial sex acts, the Plaintiff also allege that, at a bare minimum, Defendant +should have known that the Epstein sex-trafficking venture had used such means to +engage in illegal sex trafficking in violation of 18 U.S.C. §§ 1591-94—i.e., that they +had constructive knowledge of Epstein's sex trafficking. +60. In this complaint, Jane Doe 1 and other members of the Class also +allege that JP +was willfully blind to the fact that was facilitating and +participating in Epstein's sex-trafficking venture. +V. FACTUAL ALLEGATIONS +A. The Epstein Sex-Trafficking Venture and Conspiracy +16 + + +Cassel1222e0v1D90191S5R Doooumeett7B62 FfleeldD0B138283 FRagel78ob11BB1 +61. During all times relevant to this complaint, Jeffrey Epstein was an +extraordinarily wealthy man with multiple residences in the United States, including +a New York City mansion, a Palm Beach mansion, and an island in the U.S. Virgin +Islands. +62. Beginning in and around 1998 and continuing through the summer of +2019, Jeffrey Epstein knowingly established and ran a sex-trafficking venture and +conspiracy in violation of 18 U.S.C. §§ 1591-95. As part of the venture, Epstein +used means of force, threats of force, fraud, coercion, abuse of legal process, and a +combination of these means to cause young women and girls from all over the world +to engage in commercial sex acts and to sexually abuse them. Epstein and others +also conspired to violate 18 U.S.C. § 1591. +63. In creating and maintaining this network of victims in multiple states +and in other countries to sexually abuse and exploit, Epstein worked and conspired +with others, including employees and associates who facilitated his conduct by, +among other things, recruiting victims, coercing victims, and scheduling their sexual +abuse by Epstein at his New York mansion, his Palm Beach mansion, and his island +in the U.S. Virgin Islands. +64. Epstein and his co-conspirators used Epstein's vast (yet mysterious) +wealth and connections to other rich and powerful individuals to lure victims into +his home for seemingly innocuous activity. Victims were initially recruited to speak +17 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flegel 890611BB1 +with an allegedly philanthropic Epstein and provide "massages" to him. +65. +Epstein and his co-conspirators had perfected a scheme for +manipulation and abuse of young females. As part of the scheme, a female +"recruiter" would approach a young female and strike up a conversation in an effort +to quickly learn about the young female's background and any vulnerabilities they +could expose. The recruiter would then manipulate the young female into coming +back to one of Epstein's residences by offering the young female something she +needed. At times, the recruiter's lure would be a modeling opportunity, money for +education, help for the young female's family, and a whole host of other related +offers depending on their target's situation. Once in the residence, the recruiter and +Epstein would work in concert to impress and intimidate the young female with +displays of vast wealth, including having employees that were butlers and maids +formally dressed around the house. They would also strategically place photographs +of very powerful political and social figures amongst photographs and art displaying +nude females in an effort to normalize the sexual abuse. They would normalize the +sexual abuse by placing a massage table and spa related products around the massage +area in an effort to legitimize the area where the abuse was set to occur. Once +abused, Epstein and his co-conspirators continued to manipulate the victims, using +their financial power, promises, and threats to ensure that the victim returned as +directed and remained compliant with their demands. +18 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Fagel 200611BB1 +66. Once at the home and trapped in Epstein's bedroom the victims would +be instructed to remove their clothing. Epstein would then force the massages to +become increasingly sexual in nature, typically including one or more forced sex +acts. Epstein would use means of force, threats of force, or fraud to coerce the +victims to participate in these sex acts and to cause them to return and continue to +engage in commercial sex acts with him. Epstein and his associates then paid his +victims hundreds of dollars in cash for each sexual encounter. +67. In this District and elsewhere, Epstein perpetuated this pattern of abuse +in similar ways, hundreds of times. +68. Moreover, Epstein actively encouraged and coerced his victims to +become recruiters themselves, forcing them to recruit additional girls to be similarly +sexually abused and causing the number of victims to grow exponentially. Epstein +incentivized his victims to become recruiters by paying these victim-recruiters +hundreds of dollars for each girl that they brought to Epstein. In so doing, Epstein, +through this system of paying victims to recruit others whom he would in turn pay +to recruit others, created a sexual abuse and sex trafficking spider web and +maintained a steady supply of new victims to exploit. +69. Epstein was skilled at ascertaining his victim's greatest fears and +aspirations and targeted those fears and aspirations to coerce and trap his victims +into performing commercial sex acts and to be subject to sexual abuse. +19 + + +Casse11222c01D9019155R Doocumeet 7862 FfielD03138283 Fage2010611BB1 +70. Among other things, Epstein sexually abused his many victims and +caused his victims to engage in commercial sex acts, specifically sex acts for which +his victims received things of value, including money, promises of educational and +career advancement, a place to live, and promises that Epstein would provide various +forms of assistance. +71. Epstein provided things of value to his victims in order to coerce them +to engage sex acts with him and on occasion his friends, co-conspirators, or other +victims. +72. As one means of coercing victims to engage in commercial sex acts, +Epstein and his co-conspirators threatened that harm would come to victims if they +did not comply with his demands that they perform commercial sex acts. +73. As another means of coercing victims to engage in commercial sex acts, +Epstein and his co-conspirators fraudulently promised to further victims' +educational or career aspirations if they would comply with his sexual demands. +These promises were a quid pro quo for the sex acts that occurred. +74. +As one means of coercing victims to engage in commercial sex acts, +Epstein and his co-conspirators would give his victims money to stay quiet about the +assault or as a "finder's fee" for bringing other young women. Epstein would also +provide them with living accommodations, clothing, education, or other necessities, +exploiting the vulnerabilities of his often poor and underprivileged victims. +20 + + +Casse11222c0/1D9019155R Doocumeet 7862 FfiekD03138283 Fage2720611BB1 +75. In addition to coercing commercial sex acts from his victims, Epstein +also committed coercive sexual offenses against them as defined in New York Penal +Law § 130, as described in greater detail below. +76. Throughout around 1998 through about July 2019, the Epstein's sextrafficking venture recruited, solicited, enticed, harbored, obtained, provided, and +transported hundreds of victims to cause them to engage in commercial sex acts with +Epstein and Epstein's friends. +77. At all relevant times, Epstein maintained numerous apartment units at +301 East 66" Street in New York City, where Epstein's co-conspirators often stayed +and which operated as stash houses where numerous victims were kept over the +years. +78. JP +knew of the 301 East 66"h Street Epstein properties and knew +that these units operated as victim stash houses. +79. In 2006, Jeffrey Epstein was arrested in Florida after state and federal +law enforcement discovered that he had sexually abused more than 30 children in +his Palm Beach, Florida mansion. During that investigation, the government +concluded that Epstein and his co-conspirators had committed federal criminal acts +constituting violations of the TVPA and other federal laws, including 18 U.S.C $8 +2422(b), 2423(f), 2423(b), 2424 (e); 18 U.S.C § 371; 18 U.S.C §§ 1591(c)(1), +1591(a)(1), 1591(a)(2); as well as state crimes in violation of Florida Statutes §8 +21 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfiekD03138283 Fleage2230611BB1 +796.07 and 796.03, against dozens of young women. +80. +As a consequence of the Florida investigation, Epstein pled guilty to +two felonies, was permanently labeled a "Registered Sex Offender," and was jailed +in 2008. Epstein also entered into a non-prosecution agreement with the U.S. +Attorney's Office for the Southern District of Florida barring his prosecution (and +prosecution of his known and unknown co-conspirators) for violations of the TVPA +and other sex offenses in Florida. When the U.S. Attorney's Office entered into that +non-prosecution agreement with Epstein, it had not received reports from JP +about vast sums of cash that it was providing Epstein. Nor did JP +provide +any other assistance in the investigation. +81. Epstein's criminal case in Florida and the many related news reports +left no doubt about Jeffrey Epstein and his extraordinary penchant for sex abuse and +trafficking of young females. For instance, it was reported that up until the time of +his Florida arrest in July 2006, Epstein had been sexually abusing during that year +and the previous year three to four young females per day; it was a full-time job for +him. +82. +Beginning with his 2006 Florida arrest and for years moving forward, +Epstein was embroiled in dozens of public lawsuits detailing his sexual abuse of +females, and thousands of news stories circulated worldwide about his illegal sexual +proclivities. +22 + + +Cassel1222eov1D9019JSSR Doocumeet7862 FfliekD03138283 Feayge234o611BB1 +83. Epstein paid millions of dollars to settle sexual abuse lawsuits filed +against him by many victims. The money used to make settlement payments was +paid from Epstein-related entity accounts at JP +And while he was paying +to settle these claims, Epstein was continuing to abuse new victims—all facts known +to JP +84. +In addition to the many civil lawsuits seeking damages for sexual abuse, +Epstein's victims also filed a public lawsuit against the Unites States under 18 U.S.C. +§ 3771, the Crime Victim's Rights Act ("CVRA"), further exposing Epstein's sexual +crimes as well as his secret Non-Prosecution Agreement with the Federal +Government. +85. Epstein recruited, solicited, enticed, harbored, obtained, provided, and +transported his victims to cause them to engage in commercial sex acts in ways that +were in and affecting interstate and foreign commerce, including using means of +interstate communications (such as cell phones) and means of interstate and foreign +travel (such as aircraft that he owned and controlled). +86. Epstein transported his victims in interstate and foreign commerce, +including transportation to and from his mansion in this District. +87. The Epstein sex-trafficking venture transported victims across state +boundaries between New York, Florida, New Mexico, New Jersey, Massachusetts, +the U.S. Virgin Islands, and elsewhere, and in foreign commerce between the United +23 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfiekD03138283 Feage2450611BB1 +States and Europe, especially Eastern Europe. +88. +At all times relevant to this complaint, the Epstein sex-trafficking +venture was a group of two or more individuals associated in fact, even if they were +not a formal legal entity. Indeed, members of the Epstein sex-trafficking venture +referred to it as "The Organization." Epstein was continuously at the hub of The +Organization, which operated throughout the times indicated in this complaint. +89. +On July 2, 2019, the United States Attorney's Office for the Southern +District of New York filed a sealed, two-count Indictment against Epstein, including +one count of sex trafficking conspiracy and one count of sex trafficking for violations +of 18 U.S.C. § 1591, in part due to Epstein's criminal activities in his New York +Mansion located at 9 East 71st Street. See United States v. Jeffrey Epstein, Case No. +1:19-cr-00490 (S.D.N.Y.). +90. On July 8, 2019, Epstein was arrested pursuant to the New York +Indictment. +91. On August 10, 2019, prison guards found Epstein unresponsive in his +Metropolitan Correctional Center jail cell, where was awaiting trial on the federal +sex trafficking charges. He was later pronounced dead from apparent suicide. +92. In July 2020, Epstein's co-conspirator in the sex-trafficking venture, +Maxwell, was arrested on federal sex-trafficking charges filed in the Southern +District of New York. The charges alleged that she had assisted, facilitated, and +24 + + +Cassel1222eov1D9019JSFR Doocumeett7B62 FfleekD03138283 FRewyge2860611BB1 +contributed to Epstein's abuse of sex-trafficking victims, helping Epstein to recruit, +groom, and ultimately abuse his victims. See United States v. Maxwell, Case No. +1:20-cr-00330 (S.D.N.Y.). +93. On December 29, 2021, after a weeks-long jury trial during which +witnesses testified about Epstein's sex-trafficking operation in painstaking detail, +Maxwell was found guilty on five federal sex-trafficking counts and is now serving +nearly 20 years in federal prison for these crimes. +B. Consistent With Jeffrey Epstein's Uniform Pattern and Practice, Jane +Doe 1 Was Forced to Engage in Commercial Sex Acts with Epstein by +Means of Force, Fraud, and Coercion. +94. Jane Doe 1 was living with her mother when she met Jeffrey Epstein in +2006. +95. At that time, Jane Doe 1 was a ballet dancer in New York. Another +young female who had also fallen prey to Jeffrey Epstein's sex trafficking scheme +recruited Jane Doe 1 to meet Epstein. +96. Epstein and his co-conspirators had a long history of grooming, +indoctrinating, controlling, and ultimately committing sexual offenses against +young, vulnerable women like Jane Doe 1. Epstein and his co-conspirators +constantly reminded Jane Doe 1 how powerful and important Epstein was. Jane Doe +1 was chastised if she refused Epstein's sexual demands and told she should be +grateful that Epstein was willing to help her with her career and education. She came +25 + + +Casse11222c01D9019155R Doocumeet 7862 FfiekD03138283 Flege2B70611BB1 +to believe what she was told. +97. +The well-oiled Epstein sex abuse and trafficking venture included +frequent statements to Jane Doe 1 and other victims by Epstein and his +co-conspirators that: (1) Epstein possessed extraordinary wealth, power and +influence; (2) Epstein's business and political friends, including world leaders, also +included some of the most powerful people in the world; (3) Epstein had the ability +to advance or destroy nearly anyone financially, reputationally, and otherwise; +(4) medical and other life necessities would be denied victims if they, including Jane +Doe 1, failed to perform commercial sex acts for Epstein; and (5) Epstein could take +away Jane Doe I's and other victims' life necessities such as shelter or housing if +she or they failed to perform those acts. +98. Jane Doe 1 was exceptionally vulnerable to being victimized by +Epstein. His sex-trafficking venture targeted vulnerable young women and Jane Doe +1 was soon indoctrinated and unable to extricate herself. Jane Doe 1 was sexually +abused and trafficked by Epstein for several years. Having been conditioned that +the sexual abuse was "normal" and knowing that everyone surrounding Epstein, +including accountants, lawyers, and other important people, were aware of the sex +abuse, Jane Doe 1 was coerced into a cult-like life controlled and manipulated by +Epstein and others doing Epstein's bidding. +99. +Over the ensuing years, from 2006 through 2013, Epstein sexually +26 + + +Casse11222c01D9019155R Doocumeet 7862 FfiekD03138283 Fage2780611BB1 +abused Jane Doe 1 on a number of occasions in New York, Florida, New Mexico, +and the United States Virgin Islands in direct violation of Article 130 of New York's +Penal Law, including but not limited to the following: +a. Sexual misconduct as defined in §130.20, inasmuch as Jeffrey Epstein +engaged in sexual intercourse with Plaintiff without Plaintiff's consent; +b. Rape in the first degree as defined in §130.35, inasmuch as Jeffrey +Epstein engaged in sexual intercourse with Plaintiff by forcible +compulsion; +c. Criminal sexual act in the first degree as defined in §130.50, inasmuch +as Jeffrey Epstein engaged in oral sexual conduct with Plaintiff by +forcible compulsion; +d. Forcible touching as defined in §130.52, inasmuch as Jeffrey Epstein, +intentionally and for no legitimate purpose, engaged in the forcible +sexual touching of Plaintiff for the purpose of degrading or abusing her +or for the purpose of gratifying his own sexual desire; and +e. Sexual abuse in the third degree as defined in §130.66, inasmuch as +Jeffrey Epstein inserted a foreign object in the vagina of Plaintiff by +forcible compulsion. +100. Jane Doe 1 was also coercively trafficked to Jeffrey Epstein's friends +for commercial sex acts in this District. +101. Epstein used means of force, threats of force, fraud, coercion, abuse of +process, and a combination of such means to cause Jane Doe 1 to engage in +commercial sex acts. +102. Epstein recruited Jane Doe 1 to cause and force her to engage in +commercial sex acts in ways that were in and affecting interstate and foreign +27 + + +Cassel1222eov1D9019JSSR Doooumeet7862 FfliekD03138283 Fewyge289o611BB1 +commerce, including use of cell phones and means of interstate transportation (such +as aircraft that he owned or controlled). +103. Epstein transported Jane Doe 1 from New York to other states to cause +her to engage in commercial sex acts. +104. Jane Doe 1 wanted to escape from the Epstein sex-trafficking venture, +yet Epstein and his supporting team of co-conspirators increased the tactics of fraud, +force, or coercion to cause her to remain compliant in fulfilling Epstein's sexual +demands. +105. Jeffrey Epstein controlled Jane Doe 1 financially, emotionally, and +psychologically. He used his knowledge of Jane Doe 1's aspirations, fears, and +problems to manipulate her until she was completely controlled by and dependent +upon him. +106. When Epstein went to jail for sex offenses in Florida, he maintained +contact with Jane Doe 1. He and employees of his business entities, which were +created to support and legitimize Epstein's sexual abuse and sex-trafficking +enterprise, including HBRK, NES, Financial Trust, and Florida Science Foundation, +caused Jane Doe 1 to be transported to Florida to engage in commercial sex with +Epstein in his Florida residence while on so-called "work release" from jail, while +he was still wearing his ankle monitor. +107. There came a time when Epstein forced Jane Doe 1 to give massages to +28 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 FReyge290o611.BB1 +certain of his powerful friends. During some of these massages Jane Doe 1 was +sexually abused, by force and against her will, by Epstein's friends whom she had +been required to massage. At least one of Epstein's friends used aggressive force in +his sexual assault of her and informed Jane Doe 1 that he had Epstein's permission +to do what he wanted to her. Out of fear, Jane Doe 1 has still not named this powerful +financial executive publicly. +108. Epstein and his co-conspirators withdrew large sums of cash from JP +to make cash payments to victims, including Jane Doe 1, in furtherance of +the sex-trafficking operation. +109. Jane Doe 1 was regularly paid cash by Epstein or one of his coconspirators that was withdrawn from one of Epstein's accounts at JP +110. As alleged more fully below, JP +knew that its accounts were +being used for Epstein's sex-trafficking venture based on a number of facts, +including but not limited to the identity of the individuals making the withdrawals +and wire transfers, the vast size of the withdrawals and transfers, the identity of the +recipients, the account opening activity, the pattern of the financial activity, the +personal relationship between Epstein and at least one high-ranking executive with +as detailed more thoroughly below, and Epstein's well-documented +criminal history and involvement in trafficking. +111. Over the ensuing years, Epstein threatened Jane Doe 1 in many ways +29 + + +Casse11222c01D9019155R Doocumeet 7862 FfiekD03138283 Flyge3B10611BB1 +including threatening that if she did not abide by his demands, she would lose contact +with people she cared about and that those people would also suffer serious harm. +112. Epstein would alternate promises and threats to secure Jane Doe I's +compliance with his demands, including demands that she engage in commercial sex +acts with him and others. In some instances, Epstein would pay Jane Doe 1 directly +in cash obtained from JP +for sex acts. +113. Epstein and his co-conspirators continued to coerce Jane Doe 1 in +various ways until her ultimate escape around the end of 2013. +114. Epstein and his co-conspirators continued to coerce Jane Doe 1 to +engage in commercial sex with Epstein, through the use of Epstein's force, fraud +(such as false promises, including the continued promise to assist Jane Doe I's sister +medically) and coercion (making it clear that if she did not abide then she would +suffer serious financial and reputational harm), through the end of 2013. +115. James "Jes" Staley ("Staley"), the then-head of JP +private +banking division, was a regular visitor of Epstein's during that period of time, +through and beyond 2013, and personally observed Jane Doe 1 as a sexual trafficking +and abuse victim at times including through his departure from JP| +in 2013. +C. JP +Role in the Sex-Trafficking Venture +1. Banking laws and regulations exist to prevent funding of criminal ventures. +116. The Federal Bank Secrecy Act ('BSA") requires financial institutions +30 + + +Casse11222601D9019155R Documeet 7862 FfiekD03138283 Flege3320611.BB1 +to have adequate anti-money laundering ("AML") policies and systems in place. +New York state law also requires financial institutions to devise and implement +systems reasonably designed to identify and report suspicious activity and block +transactions prohibited by law. +117. All regulated institutions are expected to configure systems based on +their unique risk factors, incorporating parameters such as institution size, presence +in high-risk jurisdictions, and the specific lines of business involved, and the +institutions have an affirmative duty to ensure that their systems run effectively. +118. In addition to having effective AML controls in place, it is also +necessary for financial institutions to monitor their customers for the purpose of +preventing their customers from facilitating criminal activity using the institutions' +facilities. +119. As part of preventing criminal activity, Know Your Customer ("KYC") +and customer due diligence are critically important, and financial institutions must +collect customer information at the time of establishing new relationships with +clients, including as necessary to assess the risks associated with the client. To +properly consider these risks, financial institutions must consider relevant factors +such as the nature of the client's business, the purpose of the client's accounts, and +the nature and duration of the relationship. +120. Financial institutions must also conduct KYC reviews for each client +31 + + +Casse11222c01D9019155R Doocumeet 7862 FfiekD03138283 Flyge3330611.BB1 +relationship at intervals commensurate to the AML risks posed by the client, +including reviewing account activity to determine whether such activity fits with +what would have been expected given the nature of the account. Each client's AML +risk should also be re-assessed if material new information or unexpected account +activity is identified. +121. Financial institutions must also establish criteria for determining when +a client relationship poses too high of a risk and therefore must be terminated. A +financial institution may be liable under applicable laws if it maintains such a +relationship despite repeated indications of facilitation of improper transactions. +2. JP +directly participated in Epstein's sex-trafficking venture. +122. With the encouragement of Staley, JP +knowingly and +intentionally participated in the Epstein sex-trafficking venture by (among other +things) providing the financial underpinnings for Epstein to have ready and reliable +access to resources—including cashto recruit, lure, coerce, and entice young +women and girls to cause them to engage in commercial sex acts and other +degradations. +123. In or about 1998, in furtherance of his rapidly growing sexual abuse +and sex trafficking operation, Epstein realized that he needed a reliable banking +institution that would provide the necessary legitimate appearance for his operation, +allow him to open many accounts for illegitimate companies, ignore red flags and +32 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfiekD03138283 Fege334o611.BB1 +relevant state and federal banking laws, permit him to transfer money without +questioning, +allow him access to abundant cash, and to otherwise knowingly +facilitate the commercial aspect of his commercial sex trafficking enterprise. +Epstein found all of those things in JP +124. From about 1998 through 2013 (and following), JP +knowingly +and intentionally participated in the Epstein sex-trafficking venture by (among other +things) providing the essential financial underpinnings for the venture. It also +financially benefited from that participation. There can be no doubt that JP +conduct, as described below, was outrageous and intentional. +125. Around 2000, Epstein developed a key relationship to expanding +exploitative sexual abuse and his sex-trafficking operation when he began working +with Staley, the then-head of JP +private banking division. +126. Before meeting Staley, Epstein was a serial sexual abuser of young girls +and women, with an insatiable desire to sexually abuse females that were, in his +words, "the younger, the better." +127. Before Staley, Epstein relied heavily on the massive wealth bestowed +upon him primarily by one individual, Leslie (Les) Herbert Wexner ("Wexner"), to +give him the appearance of grand importance while relying on his then-madame, +Maxwell, to find and groom young women to be abused. +128. It has been reported that Wexner claims Epstein stole the money from +33 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flyge3250611.BB1 +him. Nonetheless, the origin of Epstein's money was always a mystery, with Epstein +claiming to be a money manager to a stable of clients who entrusted him with a +minimum of $1 billion. JP +I knew that was a lie. Staley knew without any +doubt that Epstein was trafficking and abusing girls and that all of his staff, including +his main attorney and accountant, worked full time to conceal the illegal operation. +129. However, Epstein could not expand his operation to the level it +ultimately reached without a complicit financial banking institution that would +ignore red flags and assist him in paying hundreds of young females in wire transfers +and cash and allow him access to hundreds of thousands of dollars in cash to pay +hush money to his growing number of victims. +130. Staley was the key to making all of Epstein's depraved dreams of sexual +abuse and sex trafficking of countless young women possible. With his help, the +number of victims of the Epstein sex-trafficking operation began to grow on a +vertical trajectory beginning in and around 2000. +131. When Epstein and Staley first teamed up, in or around 2000, Staley was +the head of JP +private banking division and was later promoted to CEO of +Asset Management in 2001. +132. The relationship between Epstein and Staley was symbiotic and special. +Epstein agreed to bring many ultra-high wealth clients to JP +and in +exchange, Staley would use his clout within JP +to make Epstein +34 + + +Casse11222c01D9019155R Doocumeet 7862 FfiekD03138283 Flyge3560611.BB1 +untouchable. +133. Staley bragged within JP| +about Epstein's value to the bank and +used his position in the bank to silence any critics of the relationship between JP +and Epstein. +134. This meant that JP +would keep Epstein on as a client at all +costs, including failing to act on any red flags and ultimately allowing him to run +and grow an operation designed to sexually abuse and traffic countless young girls +and women. +135. Once Epstein had JP +(through Staley) in his pocket, Epstein +moved on to his next target, another known sexual abuser, Jean-Luc Brunel, a +model scout who had suffered public disgrace for serial sexual abuse of young +females. +136. Epstein enlisted Brunel to recruit new victims from all over the world, +enticing them with promises of modeling careers before sexually abusing and +trafficking them through a modeling agency Epstein and Brunel established called +MC2. +137. In 2019, Brunel was arrested in France for sex trafficking related to his +relationship with Jeffrey Epstein and, like Epstein, was found hanging in his cell +from an apparent suicide. +138. There were several key figures who conspired and participated in +35 + + +Cassel1222cov1D9019JSSR Doooumeet7B62 FfliekD03138283 Flege3B7ob11BB1 +Epstein's international sex trafficking operation, most notably Ghislaine Maxwell, +Les Wexner, Jean Luc Brunel, and Jes Staley, acting through and on behalf of JP +139. In later years, Deutsche Bank swapped in for JP +and provided +the necessary complicit financial institution for the operation, not coincidentally onboarding Epstein's trafficking operation through a former JP +banker, Paul +Morris. +140. These co-conspirators were essential to Epstein's operation. Without +Maxwell, Epstein would never have been able to recruit his first victims and bring +them into his abusive lair. Maxwell approached young, vulnerable victims and +painted Epstein as an altruistic messiah who could help them. Once the girls were +in Epstein's clutches, Maxwell groomed them to make them feel comfortable being +sexually exploited and abused. +141. Without Brunel, Epstein would not have been able to expand his +international recruiting of young victims and, specifically, aspiring models he could +lure in with promises of opportunities. +142. Without Wexner, Epstein's sex-trafficking operation could never have +occurred to the extent that it did, as Epstein needed the appearance of extraordinary +wealth to attract his victims and force them to stay silent. +143. However, +even with Wener's funding of Epstein's operation, +36 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flyge3380611.BB1 +Epstein's sexual abuse of hundreds of women would have been limited because the +money trail from Epstein's accounts to the many victims and recruiters would have +quickly exposed his illegal venture. +144. Therefore, Epstein could not risk having a typical banking relationship +where the bank might uncover something suspicious and report him to law +enforcement. The final essential ingredient Epstein needed to expand his sexual +abuse of young women and sex trafficking enterprise was therefore a financial +institution that would know—but not care that Epstein was sexually abusing +women on a daily basis and paying out millions in hush money. Indeed, Epstein +needed an institution that would in fact assist and participate in that activity, and that +would support his enterprise and conceal it if he was ever caught. +145. JP +provided the final component Epstein needed, and Staley +had a special relationship with Epstein and made sure Epstein and his illegal sexual +abuse organization were absolutely protected by the bank. +146. From the beginning of the Epstein/Staley relationship, Staley +understood that Epstein's money was only a part of the incentive to protect Epstein's +operation. +147. During the Palm Beach Police Department's 2005 investigation into +Epstein's sexual abuse of minor children, the detectives pulled message pads left by +Epstein's assistant from his trash as well as a search warrant executed at Epstein's +37 + + +Cassel1222cov1D9019JSSR Doooumeet7B62 FfliekD03138283 Feyge389o611.BB1 +Palm Beach, Florida mansion. +148. According to those message pads, Staley was a frequent caller to +Epstein's Florida home throughout the course of Epstein's banking relationship with +IMPORTANT MESSAGE +Teftu y +NE. 09/03/05 TME 4: 40A +" Joss stuly +PHONE +MOBILE + +TELEPHONED +PLEASE CALL +CAME TO SEE YOU +WILL CALLAGAN +WANTS TO SEE YOU +RUSH +RETURNED YOUR CALL +SPECIAL AITENTION +MESSAGE +IMPORTANT MESSAGE +FOR- +Mr. J.E . +DATE +M E. +12/21/04 +TME 10:27 SI +Jess Stanley +OF +nw: (212) 837-2375 +TELEPHONED +PLEASE CALL +CAME TO SEE YOU +WILL CALL AGAN +WANTS TO SEE YOU +RUSH +RETURNED YOUR CALL +SPECIAL ATTENTION +MESSAGE- +'Returning four +Cell" +SAO01088 +SIGNED +IMPORTANT MESSAGE +FOR_ +JE +DATE — +3/18/05 +"Jei Stely +oF (212) 744-0770 +PHONE +uGEN E +TELEPHONED +CAME TO SEE YOU +WANTS TO SEE YOU +RETURNED VOUR CALL +PLEASE CALL +WILL CALL AGAN +RUSH +SPECIAL ATTENTION +MESSAGE +SIGNED. +IMPORTANT MESSAGE +FOR_MR: EPSTEIN +DATE +05/21/04 +THie 6.49 FM +JES +STALEY +OF L. HA +MEE 212 744. 0770 +TELEPHONED +PLEASE CALL +CAME TO SEE YOU +WILL CALL AGAIN +WANTS TO SEE YOU +RUSH +RETURNED YOUR CALL +SPECIAL ATTENTION +MESSAGE.- +'CALL ME * +SAO2834 +SIGNED +BIGNED +38 + + +Cassel1222eov1D9019JSSR Doocumeett7B62 FfleekD03138283 FReyge380o611BB1 +IMPORTANT MESSAGE +FOR. +TR ERSTEIN +DATE - +ME JEFF STALEY +OF +MOSE 2/2 744 0770 +TELEPHONED +CAME TO SEE YOU +WANTS TO SEE YOU +RETURNED YOUR CALL +/ PLEASE CALL +WILL CALL AGAIN +RUSH +SPECIAL ATTENTION +MESSAGE +CALLED +AM. +. РМ +IMPORTANT MESSAGE +FOR +DATE. +м.К +J.F +111/05 +MME 6:27 A1- +Jess Stalay +00(00) 912-7145 +TELEPHONED +PLEASE CALL +CAME TO SEE YOU +WILL CALL AGAIN +WANTS TO SEE YOU +RUSH +RETURNED YOUR CALL +SPECIAL ATTENTION +MESSAGE +FPl6256 call ma +back!" +SA +SIGNED. +SIGNED +149. On at least one occasion it appears Staley and Les Wexner called +Epstein together. +IMPORTANT MESSAGE +MR. FASTEN +IME +_AM. +DATE. +M.- +OF- +LES SESS +MOONE. +TELEPHONED +CAME TO SEE YOU +WANTS TO SEE YOU +RETURNED YOUR CALL +PLEASE CALL +WILL CALL AGAIN +RUSH +SPECIL ATTENTION +MESSAGE +SAO2852 +150. As long as Epstein's money stayed at JP +Staley also knew that +Wexner, Epstein's client who had turned over a power of attorney to Epstein, would +likewise keep his money with JP +Wexner's money was said to amount to +39 + + +Casse11222c0/1D9019155R Doocumeet 7862 FfleekD03138283 Fego4010611BB1 +over a billion dollars. +151. Epstein made clear that Wexner was not the only JP +client +whose allegiance to the bank Epstein controlled. Staley knew that Epstein "collected +people" and was close with many ultra-wealthy individuals that he could bring into +the bank, and Epstein did bring additional customers to the bank in exchange for JP +aiding and facilitating his international sex trafficking operation. These new +customers made JP +even more profitable. Along the way, Epstein gave +credit for these new bank customers to Staley, which made Staley even more +powerful within JP +152. Epstein controlled Staley like he did his many victims: by flaunting his +power and connections to the extremely wealthy. Epstein made it clear to Staley +that if JP +ever decided to terminate its relationship with Epstein, the bank +would lose Wexner and the other wealthy connections Epstein had promised JP +153. Staley and Epstein's relationship grew closer as the years went on. In +fact, during the criminal investigation into Epstein in 2005, Staley flew on Epstein's +plane along with +individuals who had bank +accounts through Epstein at JP +and who were publicly identified as +Epstein's co-conspirators in trafficking offenses. +154. Rather than merely providing routine banking for Epstein, JP +40 + + +Casse11222c0/1D9019155R Doocumeet 7862 FfiekD03138283 Flygo1420611BB1 +went far beyond what a non-complicit bank would have done and instead assisted +Epstein in setting up the necessary financial structure to operate his sex-trafficking +venture. +155. Specifically, money was paid from Epstein affiliated JP +accounts to victims of trafficking and to known Epstein co-conspirators. Money was +also withdrawn from Epstein affiliated JP | +accounts in cash to pay victims +in furtherance of the sex trafficking operation. +156. JP +also deliberately failed to follow routine banking practices +of review Epstein's accounts against the backdrop of the public information outing +him as a serial sex abuser and reporting Epstein for what was obviously a sex +trafficking operation he was running. JP +for example, purposely and +deliberately failed to timely file required Suspicious Activity Reports ("SARs") for +large cash and other suspicious activities of Epstein. In short, instead of providing +ordinary and routine banking, JP +instead assisted Epstein in covering up his +past crimes and committing new ones. +157. Acting on behalf of JP +Staley assured Epstein that the two +were close friends and he would help Epstein and his operation in any way he could. +advised Epstein strategically about opening new accounts for additional +Epstein-related entities and assured him his cash needs would be satisfied +permitting Epstein to continue to pay hush money to victims that could harm Epstein + + +Cassel1222eov1D9019JSSR Doooumeet7B62 FfliekD03138283 Fewygo4230611.BB1 +in the criminal investigation. +158. JP +chose not to cooperate with law enforcement and other +investigations into Epstein's sex trafficking, because it knew it would be exposed as +assisting in Epstein's scheme. +159. During a trip to the U.S. Virgin Islands in January 2007, Jane Doe 1 +was repeatedly raped and coerced into commercial sex. She was paid $10,000 in +hush money, which Epstein's agents apparently withdrew from JP| +in cash. +Epstein told Jane Doe 1 he expected her to remain loyal to him and compliant, +making clear that if she did not, then she would suffer serious harm. +160. Epstein was one of the most coveted clients of JP +because of +the financial benefits he provided to JP +and its officers and employees, +including Staley. Through the years, Staley helped accumulate other protectors of +Epstein within JP +161. The New York Times reported in 2019 that Mary C. Erdoes, one of JP +highest-ranking executives intervened to keep Epstein as a client after he +pled guilty to sex crimes and was registered a sex offender. +162. With JP +complicity, Epstein was free to sexually abuse +hundreds of women, paying millions in hush money, without the fear of detection +by law enforcement. Epstein used the support of a reputable institution-JP +-to help cover up his sex-trafficking venture. +42 + + +Casse11222c0/1D9019155R Doocumeet 7862 FfiekD03138283 Fego434o611BB1 +163. JP +cared about profiting and showed absolute loyalty to +Epstein, including a willingness to violate banking laws, ignore multiple red flags of +criminality, and participate directly in sex trafficking to enable Epstein to fulfill his +abusive sexual appetite at the expense of countless vulnerable young women. +164. As Epstein's criminal sex trafficking venture expanded, he needed +more protection and support from JP| +became more deeply involved with JP +Through Staley and others, Epstein +providing JP +with more +financial benefits. And. as a quid pro quo, JP +allowed Epstein to transfer +massive amounts of hush money to his victims and recruiters. JP +allowed +Epstein to withdraw hundreds of thousands of dollars in cash so that all the payments +were not traceable (the most obvious red flag for any criminal enterprise). +165. As another example of JP +_ and Staley's benefit from assisting +Epstein, a highly profitable deal for JP +was the Highbridge acquisition. +166. In 2004, when Epstein's sex trafficking and abuse operation was +running at full speed, Epstein served up another big financial payday for JP| +167. Epstein was close friends with Glenn [ +, the billionaire who ran +Highbridge Capital Management. +168. Through Epstein's connection, it has been reported that Staley arranged +for JP +to buy a majority stake in +fund, which resulted in a sizeable +profit for JP +This arrangement was profitable for both Staley and JP +43 + + +Casse11222c0/1D9019155R Doocument 7862 FfiekD03138283 Fygo1450611BB1 +further incentivizing JP +to ignore the suspicious activity in +Epstein's accounts and to assist in his sex-trafficking venture. +169. For example, despite that Epstein was not FINRA-certified, Epstein +was paid more than $15 million for his role in the Highbridge/JP +deal. +170. Moreover, Highbridge, a wholly-owned subsidiary of JP | +trafficked young women and girls on its own private jet from Florida to Epstein in +New York as late as 2012. +171. Staley and JP +benefited from Epstein's sex-trafficking +operation because, in exchange for JP +knowing participation in that +operation, Epstein generated millions of dollars for JP +directly and +indirectly. Because Staley was generally in charge of Epstein's JP| +accounts, +he also benefited in the receipt of massages, private jet flights with victims or coconspirators of the operation, and other things of value. +172. Over many years, some JP +executives lobbied within JP +to sever ties with Epstein due to the sex-trafficking allegations against him. +leadership ignored their pleas and ultimately decided each time to keep +Epstein as a client. JP +decided that, because it was receiving such large +monetary benefits from Epstein, it would continue participating in the Epstein sextrafficking venture by providing its financial infrastructure. +173. Epstein offered his business, and the many millions it generated, +44 + + +Cassel1222eov1D9019JSFR Doocuneett7B62 FfleekD0B138283 Fego1560611BB1 +exclusively to JP +because JP +was willing to knowingly aid Epstein's +sex trafficking operation and to help conceal it. JP +knew that if it stopped +aiding and concealing the operation, it would lose Epstein's accounts and the +substantial financial benefits resulting from handling those accounts. +174. In addition to housing Epstein's accounts, JP +also housed +accounts for numerous of Epstein's co-conspirators, including Epstein's main sextrafficking madame, Maxwell, who is now serving 20 years in prison for sextrafficking related to her participation in Epstein's operation. +175. In 2022, JP +representative +McHugh testified in +Maxwell's criminal sex-trafficking trial that between 1999 and 2007, Epstein +transferred approximately $31 million to Maxwell, an amount believed to be +payment for her role in Epstein's sex trafficking venture. +176. In addition to the necessary financial infrastructure provided by JP +, as late as 2012, a JP +subsidiary company assisted with transporting +certain Epstein sex-trafficking victims by private jet from Florida to Epstein in New +York. +177. Ultimately, JP +financially benefited by earning millions of +dollars for its participation in the Epstein sex-trafficking venture. +178. Throughout its relationship with Epstein, JP| +violated numerous +banking laws and regulations in order to conceal and continue its lucrative venture +45 + + +Casse11222c0/1D9019155R Doocument 7862 FfiekD03138283 Flygo1670611BB1 +facilitating the Epstein sexual abuse and sex-trafficking scheme. +179. For example, JP +allowed Epstein and his agents to "structure" +cash withdrawals to further the sex-trafficking venture. +180. As another example, JP +failed to file with the federal +government the required SARs that financial institutions must file with the Financial +Crimes Enforcement Network ("FinCEN") whenever there is a suspected case of +money laundering or fraud. Timely filing of these reports is required by the Bank +Secrecy Act and related laws and regulations. These reports are tools that the federal +government uses to detect and prosecute, among other illegal activities, sex +trafficking in violation of the TVPA. While JP +was providing Epstein vast +sums of cash each year, it was required to timely file SARs about Epstein's +suspicious and unusual cash transactions. +181. JP +failure to timely file SARs about Epstein's sex-trafficking +venture, in spite of numerous red flags, was wrongful and purposeful. +182. A recent amended complaint filed by the government of the U.S. Virgin +Islands against JP +in this Court describes some of the red flags JP| +simply ignored: +Between 2003 and 2013, Epstein and/or his associates +used Epstein's accounts to make numerous payments to +individual women and related companies. 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. +46 + + +Cassel1222eov1D9019JSFR Doocumeett7B62 FfleekD03138283 Flygo1480611BB1 +For example, Epstein paid more than $600,0000 to Jane +Doe 1, a woman who-according to news reports +contained in JP +due diligence reports-Epstein +purchased at the age of 14. Like other women who +received payments +from Epstein, Jane Doe 1 listed +Epstein's apartments on 66th Street in New York City as +her address, which should have been a red flag to JP +Epstein and/or his associates also made significant cash +withdrawals and 95 foreign remittances with no known +payee. For example, Hyperion Air, Inc.—the Epsteincontrolled company that owned Epstein's private jet— +issued over $547,000 in checks payable to +cash +purportedly for "fuel expenses when traveling to foreign +countries." Additionally, between January 2012 and June +2013, Hyperion converted more than $120,000 into +foreign currency. Many of these cash withdrawals either +exceeded the +: $10,000 reporting threshold or were +seemingly structured to avoid triggering the reporting +requirement. This is particularly significant since it is well +known that Epstein paid his victims in cash. +In addition, Epstein and/or his representatives appeared to +be misusing JP +accounts for Epstein's purported +charitable +organizations, including the C.O.U.Q. +Foundation and Enhanced Education. Epstein made +payments trom these accounts with no clear nexus to the +organization's charitable purpose. For example, Epstein +and/or his representative used the C.O.U.Q. Foundation +account to pay $29,464.66 to three young women, +including two known victims, and over $20,000 to a +company called Phoenix Realty Home Inc. +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., +Case No. 22-cv-10904-JSR, Amended Complaint (Dkt. 16) at 16-17 (S.D.N.Y. +47 + + +Casse11222c01D90191SSR Documeet 7862 FfiekD03138283 Flewgo1890611BB1 +Jan. 10, 2023).' +183. In taking the steps described above, JP | +obstructed, attempted +to obstruct, and interfered with the federal government's enforcement of the TVPA, +including the U.S. Attorney's Office for the Southern District of Florida's criminal +investigation of Epstein in and around 2006 to 2008 and the U.S. Attorney's Office +for the Southern District of New York's criminal investigation leading to his +indictment in 2019. +184. Over the many years of the venture between JP +and Epstein, +numerous JP +executives, and several compliance officers, demanded that JP +sever ties with Epstein and his criminal organization due to the public sextrafficking allegations against Epstein. But JP +leaders and those in control +of those decisions were influenced by Staley to continue to support Epstein. Given +all the surrounding circumstances and Staley's knowledge, JP +decisions +to support Epstein were made with knowledge that he was operating a sex-trafficking +' Jane Doe 1 hereby adopts by reference the substantive factual allegations +regarding JP +participation in Epstein's sex-trafficking venture and +conspiracy found the U.S. Virgin Islands' (USVI) Amended Complaint against JP +into this Amended Complaint. See Fed. R. Civ. P. 10(c). A copy of that +amended complaint is attached to this complaint as Exhibit 1. With regard to issues +concerning the scope and duration of JP +participation in the venture and +conspiracy, as well as the nature of the venture and conspiracy, Jane Doe 1 relies on +her own complaint. Jane Doe 1 does not believe any of the substantive factual +allegations by the USVI are inconsistent with hers. But, if any inconsistency exists, +Jane Doe 1 relies solely on her allegations. +48 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flewgo450o611.BB1 +venture and conspiracy. +185. +In 2013, due to the overwhelming publicity about Epstein's illegal +sexual activities, and the departure of Staley from JP | +1 JP L +realized +that its claims to not knowing what Epstein was doing were no longer facially +plausible. Accordingly, and reluctantly, JP| +stopped being Epstein's banker. +186. While JP +stopped being Epstein's banker, it did not make a +clean break of things by disclosing its actions in support of the conspiracy to the +authorities. Nor did it communicate its abandonment of its conspiring with Epstein +and others in a manner reasonably calculated to reach Epstein's co-conspirators. +187. While JP +stopped being Epstein's banker, it continued to take +subsequent actions to promote the venture and conspiracy. For example, it +deliberately and willfully continued to fail to timely file SARs about the suspicious +activities it had seen. And it continued to recommend Epstein as good client to +others how inquired. +188. After losing Staley, Epstein no longer had his primary protector at JP +In order to continue to operate, Epstein would need to find a new bank. As +alleged in greater detail in another complaint pending before this Court, Epstein +found that new bank to facilitate his sex trafficking venture-Deutsche Bank. See +Jane Doe 1 v. Deutsche Bank Aktiengesellschaft et al., Case No. 22-cv-10018-JSR, +Amended Complaint (S.D.N.Y. Jan. 13, 2023). +49 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfekD03138283 Flyge5510611BB1 +3. JP| +knew about Epstein's sex-trafficking venture and conspiracy. +189. As explained above, between (at least) 2000 and 2005, Epstein +provided clients to JP +and, in exchange, JP +allowed Epstein to do +as he pleased with his JP| +accounts. JP +directly aided Epstein's sex +trafficking venture by allowing Epstein to engage in structuring violations and other +financial maneuvers required to maintain and conceal his criminal enterprise. JP +financially benefited from allowing Epstein to use his JP | +accounts +to run his sex trafficking venture. +190. However, in 2006, Epstein's relationship with JP +hit a snag +when Epstein was publicly exposed for sexually abusing dozens of young women +and girls, several as young as 14 years old. There were hundreds of pages of police +reports and news articles revealing that Epstein was a serial sexual abuser and +trafficker, and that his operation depended on his accessing nearly unlimited cash to +use as payments to his victims. +191. With respect to the specific discoveries, the authorities found that some +of the victims "went to Mr. Epstein's house only once, some went there as much as +100 times or more." +192. It was publicly revealed in the investigation that Epstein was sexually +abusing three to four young females every single day of his life and that he was +paying each victim hundreds of dollars in hush money, usually in cash. +50 + + +Casse11222c0/1D9019155R Doocumeet 7862 FfiekD03138283 Flyge5520611BB1 +193. The criminal investigation also publicly revealed that Epstein was +paying countless recruiters to constantly bring him more victims, making clear that +quick access to cash at a financial institution was the lifeblood for his sex-trafficking +venture. +194. The money trail into Epstein's accounts was a dead giveaway that +Epstein was engaging in crimes and the recipients of his money exposed the type of +crimes. +195. At this point (and earlier), JP| +knew that Jeffrey Epstein was an +international sex trafficker. To the extent JP +could publicly feign plausible +deniability before Epstein's arrest in 2006, thereafter its ability to play dumb +thereafter was eviscerated, as the details of his daily sexual abuse of young females +came to public light and when he ultimately was required to register as a sex +offender. +196. JP +undoubtedly knew about Epstein's arrest in 2006. +197. Because Epstein was so publicly exposed as a sex trafficker and abuser, +one of his primary financial engines, Les Wexner, abandoned him and separated +himself from Epstein. +198. The federal criminal case against Epstein was under investigation from +(at least) 2006 through 2008, when Epstein eventually entered his guilty plea, +registered as a sex offender, and went to jail. +51 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfiekD03138283 Fee5230611BB1 +199. In the summer of 2008, Epstein's Non-Prosecution Agreement +("NPA") with the U.S. Department of Justice was made public when it was unsealed +in connection with a challenge to the NPA by two of his victims. Among other +things, the agreement outlined the possible federal sex offense charges that could +have resulted from the investigation, including TVPA charges. +200. Epstein's legal team also garnered significant publicity between 2006 +and 2008, not only because of their well-known names but also the unusual number +of them. Epstein hired Roy Black, Ken Starr, Jay Lefkowitz, Guy +Michael +Tien, Lily Ann +Gerald Lefcourt, Guy Fronstein, Jack Goldberger, and +more. All of these lawyers were now on Epstein's payroll and millions of dollars +were being shelled out to these attorneys from JP +accounts to pay for his +legal defense of the most heinous of sexual abuse allegations. Not only was JP +(through Staley) well aware of the allegations, but JP| +(through +Staley) knew the identities of co-conspirators and many of the victims. Staley had +observed victims personally, and he was aware that Epstein was shelling out millions +of dollars to attorneys to take on these well-founded allegations. +201. In 2008, around the same time Epstein was pleading guilty to felony +sex offenses and registering as a lifetime sex offender, JP +learned that +another of its high value clients, Bernie Madoff, was running the largest Ponzischeme in modern history through his accounts at JP| +This led to JP +52 + + +Cassel1222eov1D9019JSSR Doocumeet7B62 FfliekD03138283 Flewyge534o611BB1 +reviewing its clientele with the directive of severing ties with any problematic +customers. +202. With indisputable publicly available knowledge that Epstein was a +sexual offender who was using his wealth to run a sexual abuse and trafficking +operation, any responsible bank providing only routine banking support would have +cut ties with Epstein. +203. However, rather than cut ties with Epstein, Staley, acting on behalf of +and within the scope of his actual and apparent employment, personally +visited Epstein when he was serving his jail sentence in Florida and arranged for an +even tighter connection between JP +and Epstein. +204. After Epstein was released from his Florida incarceration, he picked up +right where he left off-abusing young women on a daily basis, paying recruiters, +and paying hush money to victims. JP +continued its supporting actions as +well, continuing its role in Epstein's sex trafficking conspiracy and allowing it to +continue to flourish. Epstein continued abusing and trafficking with the same +frequency as he had been for years, and he could do so because he had a bank that, +even though it knew what he was doing, would not turn on him. +205. After Staley went to visit Epstein in Florida while Epstein was +incarcerated on sex offenses, Epstein and JP +relationship continued to +grow through Staley. Ultimately, after Epstein's release from jail, Staley and +53 + + +Casse11222c01D9019155R Doocument 7862 FfekD03138283 Fee5850611.BB1 +Epstein spent significant time together at Epstein's townhouse in New York City. +Staley also visited Epstein on his private island in the United States Virgin Islands +an island commonly dubbed "Pedophile Island." These visits were within the actual +and apparent scope of Staley's employment at JP | +206. Acting through Staley and to protect its financial benefits from dealing +with Epstein, JP +made clear to Epstein that he could continue to fund his +sexual abuse operation through JP +and it would continue to conceal the +illegal operation. JP +and Epstein agreed, tacitly and otherwise, that Epstein +could continue to fund his sex-trafficking venture through JP| +and JP +would reap the financial benefits from its connection with Epstein. +207. After his arrest in 2008, dozens of public lawsuits were filed against +Epstein, revealing greater details of Epstein's sexual abuse of young women. +208. The lawsuits detailed millions in payments that Epstein was making to +recruiters, co-conspirators, cover-guys (such as his longtime fixer/lawyer and +fixer/accountant), and his victims. +209. Through the civil lawsuits, evidence (such as the previously referenced +message pads) taken from Epstein's trash by police or through prior search warrants, +as well as flight logs and black books began to publicly surface, shedding further +public light on the expansiveness of Epstein's sex-trafficking operation. +210. Through the lawsuits, other relevant information also became public +54 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfleekD03138283 Fee5560611.BB1 +and was widely published: Epstein had no college degree, he had never obtained +any specialized license, none of the companies with whom he was associated had +any legitimate business structure or purpose, and he had no documented expertise +that would provide the requisite skill or knowledge to amass his vast wealth. +211. Epstein's victims' court challenge against Epstein's federal NPA also +continued between 2008 and 2013 (and beyond) and attracted significant media +attention. Indeed, between around 2006 and 2013, hundreds of press reports outlined +the allegations underlying the NPA and to varying degrees detailed the involvement +of Epstein's alleged co-conspirators, including Lesley Groff, +Some articles reported that +had invoked +their Fifth Amendment right against self-incrimination. +212. Additionally, press reports during this time noted allegations that +Epstein was involved with Eastern European women in particular and that a +modeling agency he helped develop with his friend and known sexual abuser, Jean +Luc Brunel, brought "young girls ... often from Eastern Europe" to the U.S. on +Epstein's private jets. +213. At all times material hereto, JP +was aware of the foregoing +information and more about Epstein's sex trafficking activities. When some +executives on the board at JP +made strong and successful arguments, leading to JP +recommended cutting ties with Epstein, Staley +keeping Epstein as a +55 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Fage5570611BB1 +customer. +214. In support of maintaining its relationship with Epstein, JP | +CEO of private banking, Mary Erdoes, argued that Epstein was too valuable of a +client to let go and played a pivotal role in maintaining the relationship. +215. Upon information and belief, internal documents also reflect JP +knowledge of the extensive publicly available information about Epstein's +sex-trafficking scheme. +216. JP +including its CEO Jamie Dimon and the highest levels of +the bank, made the decision to monitor the public news being disseminated about +Epstein, knew that Epstein had been arrested for sexual offenses against young +women, knew that Epstein was a registered sex offender, knew that Epstein's coconspirators like Ghislaine Maxwell were involved in the sex trafficking operation, +knew that Epstein had paid to settle a number of civil lawsuits related to sexual abuse +of underage girls, and still made an intentional decision to keep Epstein on as a client. +217. JP +including its CEO Jamie Dimon and the highest levels of +the bank, knew of Jes Staley's personal involvement with Epstein and yet still +allowed Staley to remain a decision maker for JP | +on Epstein accounts. +218. Even before the sexual abuse investigation in Florida, media reports +raised questions about the facts that nobody knew how Epstein made his fortune nor +what he did to continue making the millions of dollars needed to support his life. +56 + + +Cassel1222eov1D9019JSSR Doocumeett7B62 FfleekD0B138283 Feyge5580611BB1 +219. Media reports also appeared about Epstein's prior SEC violations in his +job at Bear Stearns arose. A former business partner of Epstein's, Steven +Hoffenberg, even explained how Epstein assisted him in running a massive Ponzi +scheme that landed Hoffenberg in prison. JP | +was aware of these and other +reports. +220. Epstein, it was reported, claimed to be a financial bounty hunter and +money manager to those who would entrust him with $1 billion or more, yet JP +, with access to Epstein's accountants, knew Epstein's stated profession was +a lie. +221. Despite the false rumors he had created to conceal his true "business," +Epstein was exposed as literally nothing other than a sex trafficker and abuser of +young females, a fact easily discernible by any responsible financial institution with +whom he was banking. +222. For JP +, a sophisticated financial institution legally responsible +for complying with Know Your Customer laws and other banking obligations, the +details of Epstein's sexual abuse and trafficking were not a surprise. Even so, JP +never cooperated in any civil or criminal case against Epstein, because to +do so would reveal JP +complicity in Epstein's operation. +223. For example, in 2009, one of Jeffrey Epstein's sexual abuse victims +served a subpoena on JP +in connection with a civil case. JP +refused +57 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfiekD03138283 Fee589o611.BB1 +to comply with the subpoena, making it abundantly clear whose side JP +was +on. +224. JP +never timely filed required SARs about Epstein's suspicious +transactions, including large cash transactions, which would have revealed to law +enforcement authorities the sex-trafficking venture. +225. Fearful that Epstein could turn on the bank for its participation in the +sex-trafficking venture, JP +(and its agent, Staley) remained incentivized to +maintain and grow the relationship and to assist in concealing Epstein's suspicious +and illegal banking practices. +226. To be clear, during his years as a top executive at JP +Staley +was not only one of Epstein's closest pals, but more importantly, he was a frequent +visitor at Epstein's townhouse, including visiting the massage room; Staley met +many of Epstein's trafficking victims, including Jane Doe 1; Staley visited the +Epstein-owned victim stash house apartments at 301 East 66 Street, and Staley +personally observed the sexual abuse of young women, including Jane Doe 1. These +actions were within the scope of Staley's employment at JP| +227. Staley was well aware that Epstein was running a sex trafficking +venture, based on that facts that he: (1) went to Epstein's house in New York many +times; (2) personally spent time with young girls whom he met through Epstein on +several occasions; (3) personally visited young girls at Epstein's apartments located +58 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flage550o611.BB1 +at 301 East 66*" Street; (4) personally visited Epstein on his island; (5) was frequently +calling and emailing with Epstein; (6) personally observed Epstein around young +girls, (7) personally observed Epstein sexually grab young women in front of him; +and (8) even visited Epstein in Florida while Epstein was serving his jail sentence. +All of these circumstances, and more, gave Staley direct and actual knowledge that +Epstein was engaged in sex-trafficking venture. +228. As a result of Staley's direct and actual knowledge of Epstein's sextrafficking venture, JP +had direct and actual knowledge of Epstein's sextrafficking venture. +229. Due to Staley's knowledge, JP +knew that Epstein had no job +and still helped open dozens of accounts for Epstein, allowing him to transfer money +with no underlying legitimate business operation. +230. Through Staley and other officers and employees, JP +saw that +Epstein's JP +accounts were almost exclusively used to pay for: (1) living +and travel expenses; (2) expenses related to apparent criminal activity; (3) lawyers +relating to his Florida criminal case; (4) lawyers defending civil lawsuits (including +paying for all of the witnesses' and co-conspirators' attorneys); (5) sex-abuse victim +settlements; (6) private investigators to investigate sex abuse victims; and (7) +extravagant lifestyles for his many co-conspirators. +231. Through Staley and other officers and employees, JP +: (1) knew +59 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfiekD03138283 Fege6610611BB1 +that Epstein was always surrounded by young women and girls; (2) knew Epstein's +stated public profession of financial advisor was false; (3) knew Epstein had no real +expertise in business investing; (4) knew that his accounts, including many business +accounts, had underlying legitimate business activity; (4) saw Epstein's regular, +suspicious, and large cash withdrawals; (5) saw Epstein's frequent payments to +known co-conspirators; (6) knew that Epstein was funding a modeling agency with +Jean-Luc Brunel (an already exposed sexual abuser); (7) knew that Epstein was +making regular transfers in even, hundred-dollar increments; (8) knew that Epstein +was arrested in Florida and required to register as a sex-offender; (9) knew that +Epstein's co-conspirators had bank accounts at JP +associated with his +accounts; and (10) knew that Epstein's madame, Ghislaine Maxwell, was paid +millions of dollars by Epstein. +232. JP +had awareness of all the facts listed in the previous +paragraphs because, among other things, Staley, in the course his employment at JP +regularly visited Epstein's home in Manhattan, Epstein's Island, and +Epstein's victim stash house on East 66" Street. +233. During a 2019 investigation by the UK Financial Conduct Authority +into Staley's relationship with Epstein, JP| +produced more than 1,200 emails +exchanged between Staley and Epstein between 2008 and the end of Staley's tenure +at JP +These emails were accessible to JP +and written in Staley's +60 + + +Casse11222c0v109019155R Doocumeet 7862 FfiekD03138283 Flyge6820611BB1 +capacity as an officer and employee of JP +All of the information contained +in those emails is imputed to JP +including information about sexual and +related topics. These emails show, among other things, the close personal +relationship between Epstein and Staley, that Epstein and Staley communicated and +visited while Epstein was incarcerated, and that Staley visited Epstein's private +island on multiple occasions. +234. Despite knowledge of Epstein's illegal trafficking operation and the +fact that one of JP +top executives being so in bed with the operation, JP +continued to aid Epstein in his sex trafficking enterprise. +235. JP +, through its agents and employees such as Staley, had direct +and specific knowledge that Epstein was operating a sex-trafficking venture and that +he needed extraordinary banking infastructure from JP +to successfully +operate that illegal venture. +236. JP| +also knew that +women +with Epstein-facilitated bank accounts at JP +whom Staley knew well, were +involved in the trafficking. +237. Importantly, in January 2007, in the heart of the federal criminal +investigation, Epstein trafficked Jane Doe 1 to the U.S. Virgin Islands where she was +repeatedly raped. Not coincidentally, she was taken on Epstein's private jet the +same one Staley traveled on +-with +, the same + + +Casse11222c01D9019155R Doocumeet 7862 FfiekD03138283 Flyge6230611.BB1 +account-holding passengers Staley traveled with and who were identified +by the U.S. Government as Epstein's criminal co-conspirators. +238. JP +also knew from the press that Epstein was a registered sex +offender who was always surrounded by young girls. Even so, JP +conspired +with Epstein to assist him to operate the financial side of the sex-trafficking scheme. +239. JP +knew, through Staley and other information, without any +doubt that Epstein was a serial abuser and that sex-trafficking was his everyday +lifestyle. JP +also knew that without the bank's complicity, Epstein could +not pay for commercial sex acts, for co-conspirators, for his co-conspirators' +lawyers, for his own legal dream team, or for his private planes to traffic women to +his New York mansion and island to abuse. +240. Numerous of Epstein's co-conspirators had JP +accounts tied to +Epstein accounts. During the time when +were publicly outed +as co-conspirators of Epstein's, they each had JP +accounts that were noted +as Epstein-related accounts, putting JP +on clear notice that the criminal +organization Epstein was running through the bank was an expansive one of sexual +abuse and trafficking. +241. MC2, the Epstein/Brunel modeling agency that was used to expand the +trafficking scheme internationally, was funded through JP| +loans on Epstein +accounts. This agency was started at a time when Brunel had already been publicly +62 + + +Casse11222c0/1D9019155R Doocumeet 7862 FfleekD03138283 Flyge684o611.BB1 +ostracized from other known modeling agencies because he was a child sex abuser, +a fact which JP +was aware. +242. All of Epstein's connections that were known to JP +were either +very wealthy individuals, companies that had no verifiable legitimate purpose, +internationally known sex-abusing model scouts, publicly identified co-conspirators +in the Epstein sex trafficking operation the crimes of which were identified in a +public non-prosecution agreement, and young women and girls who could not +possibly have a legal and legitimate connection to Epstein. JP +knew all of +this against the backdrop of their client-Epstein-having no professional expertise +or legitimate business with legitimate banking needs. +243. JP +worked with Epstein to open new accounts in the name of +companies that had no plausible legitimate purpose, move money from one account +to another to mask payments to sexual abuse victims or co-conspirators, make wire +transfers to trafficking recruiters, and worked with Epstein's agents to make his sex +trafficking conspiracy less obvious to law enforcement authorities and others. +244. It is well known-and JP +did know-that a large number of +cash transactions by a customer can be an indicator of criminal activity generally +and sex trafficking in particular, and JP +knew Epstein was a sex trafficker +constantly needing access to large amounts of cash. +245. Payments to victims of sex trafficking are often made in cash to avoid +63 + + +Casse11222c01D9019155R Doocumeet 7862 FfekD03138283 Flyge6850611.BB1 +leaving a "paper trail" for law enforcement or other investigators to follow. +246. Forced sexual exploitation of victims has been estimated to generate +approximately $100 billion in yearly illicit profits, according to a recent study (2018) +by the Financial Action Task Force entitled "Financial Flows from Human +Trafficking." +247. Given the illegal nature of sex trafficking, individuals perpetrating the +crime, as well as laundering the proceeds of that crime, may be identifiable by +observing financial transactions and information obtained by financial institutions in +the course of conducting their customer due diligence and the behavior of offenders. +248. Sex trafficking organizations have the need for large amounts of cash +because many illegal transactions are often necessary to keep the organization +functioning. The techniques that financial institutions use to detect other criminal +enterprises using their accounts can also be employed to detect sex trafficking. For +example, sex trafficking organizations often use assets for money laundering (such +as cash, real estate, cars, etc.) that other criminal organizations use. +249. Sex trafficking organizations may also make cash deposits and +withdrawals below customer identification thresholds to avoid triggering additional +scrutiny or bank reporting requirements. Sex trafficking organizations may also use +multiple accounts to disguise the nature of their illegal transactions, thereby +"laundering" the funds involved. +64 + + +Cassel1222eov1D9019JSSR Doocumeet7B62 FfliekD03138283 F1yge656ob11.BB1 +250. One indicator of sex trafficking can be media coverage of an account +holder's activities relating to sex trafficking. +251. Another indicator of sex trafficking can be recurring payments for +transportation of logistics service in the late night or early morning. A similar +indicator can be significant payments for transportation or logistics (car rental, taxi, +and ride sharing service transactions). +4. Epstein used JP +accounts for the sex-trafficking venture, and JP +knowingly and directly benefits from the venture. +252. Over the course of the relationship, Epstein and his representatives used +accounts to send dozens of wires, directly and indirectly, to coconspirators in the sex-trafficking venture. +253. Over the course of the relationship, Epstein and his representatives also +obtained vast sums of cash from JP +to fund the sex-trafficking venture. +254. JP +was aware that the recipients of some of these wire transfers +and cash described in the previous paragraphs were to Epstein's co-conspirators and +that the wire and cash transfers were in furtherance of the Epstein sex-trafficking +venture. +255. JP +was aware that known co-conspirators of Epstein also had +accounts. +256. Epstein used JP | +accounts to pay, through wire transfers and in +cash, for coerced commercial sex acts by Jane Doe 1 and other Class Members. +65 + + +Casse11222601D9019155R Doocumeet 7862 FfleekD03138283 Flyge6670611BB1 +257. Given JP +knowledge about Epstein's past sex trafficking, its +continuation of its financial relationship with Epstein was, at a minimum, in reckless +disregard of the fact that Epstein was using means of force, threats of force, fraud, +coercion (and a combination of such means) to cause Epstein's victims to engage in +commercial sex acts. +258. If a financial institution decides to do business with a high-risk client, +that institution is required to conduct due diligence commensurate with that risk and +to tailor its transaction monitoring to detect suspicious or unlaw ful activity based on +what the risk is. JP +knowingly, intentionally, deliberately, and maliciously +failed to do so with regard to its relationship with Epstein. +259. JP +was well aware not only that Epstein had pled guilty and +served prison time for engaging in sex with a minor but also that there were public +allegations that his conduct was facilitated by several named co-conspirators. +260. Despite its knowledge, JP +deliberately did little or nothing to +inquire into or block numerous payments to named co-conspirators, and to or on +behalf of numerous young women, or to inquire how Epstein was using hundreds of +thousands of dollars per year in cash. JP +intentionally failed to conduct this +basic inquiry, knowing that an inquiry would reveal the sex-trafficking scheme. +Instead, it chose to continue to financially benefit from its relationship with Epstein +and his co-conspirators. +66 + + +Casse11222c0/1D9019155R Doocumeet 7862 FfiekD03138283 Fee6580611.BB1 +261. Hush money, financial compensation to recruiters, and compensation +to victims was integral to Epstein's scheme, without which his sex-trafficking +conspiracy could not effectively operate. The ability to send wire transfers and cash +to young females was critical to Epstein's ability to coerce his victims into +commercial sex acts. +262. Suspicious wire transfers and withdrawals of millions of dollars in cash +are basic hallmarks of any major criminal enterprise. A bank that would allow +Epstein to operate in this blatant criminal fashion was necessary for him to continue +to operate his sex-trafficking conspiracy and for the continued abuse of hundreds of +young women. +263. In January 2013 - the year JP +terminated Epstein's accounts +the Office of the Comptroller of the Currency ("OCC") entered into a consent order +with JP +regarding deficiencies in the bank's overall program for BSA/AML +compliance. The OCC found that JP +failed to develop adequate due +diligence on customers and failed to comply with federal banking regulations. In +fact, the OCC noted that JP +"failed to identify significant volumes of +suspicious activity."2 +264. Before JP +became Epstein's banker, Epstein was only able to +~ See NYSDFA Consent Order at 2-4 (Jan. +14, 2013), +https://occ.treas.gov/news-issuances/news-releases/2013/nr-occ-2013-8a.pdf. +67 + + +Cassel1222eov1D9019JSSR Doocumeet7B62 FfliekD03138283 Flewyge689o611.BB1 +abuse young women sporadically and in fear of being caught. Once JP +became Epstein's banker, it eliminated that fear, agreeing and conspiring with +Epstein to ensure that the suspicious money trail that would reveal Epstein's +operation would be concealed. +265. JP +desire to maintain its profitable relationship with Epstein +led it to avoid taking steps that would have documented its involvement in Epstein's +sex-trafficking venture. +266. JP +knowingly and intentionally benefited financially and in +other ways from its participation in Epstein's sex-trafficking venture, with +knowledge, or with reckless disregard of the fact, that Epstein used means of force, +threats of force, fraud, and coercion (and combinations thereof) to force young +women and girls into engaging in commercial sex acts. +267. As recounted throughout this complaint, JP +financially +benefited by earning millions of dollars from its participation in the Epstein-sextrafficking venture. The benefits that JP +received came directly from its +participation in the sex-trafficking venture and because of its participation in that +venture. In other words, there was a causal relationship between JP +conduct furthering Epstein's sex-trafficking venture and its receipt of the financial +benefits with actual (and constructive) knowledge of that causal relationship. +268. By facilitating and financing Epstein's commercial sex acts in interstate +68 + + +Cassel1222eov1D9019JSSR Doocumeet7B62 FfliekD03138283 Flewyge690o611.BB1 +and foreign commerce, JP +earned interest, commissions, fees, and other +financial benefits directly from its connection with Epstein, Epstein-related entities, +and others acting in concert with Epstein. Epstein provided those financial benefits +to JP +precisely because it was facilitating his sex-trafficking venture—-and +knew that was the reason that Epstein was providing them with those +financial benefits. +269. JP +benefited by receiving things of value from its participation +in the Epstein sex-trafficking venture. Among the various things of value it received +were (1) connections with Jeffrey Epstein, his co-conspirators, and his wealthy +friends and associates; (2) additional deposits from Epstein, his co-conspirators, and +his wealthy friends and associates; (3) the opportunity to earn financial benefits from +the funds that had been deposited with it. JP +knowingly and intentionally +received these things of value as a direct result of its participation in the Epstein sextrafficking venture and because it was furthering Epstein's sex-trafficking venture. +270. JP +knowingly and intentionally financed Epstein's illegal sextrafficking venture. JP +knew that if it did not finance Epstein's illegal sextrafficking venture, then it would lose valuable Epstein-related accounts. Faced with +the choice between profiting from Epstein's sex-trafficking venture or following the +law, JP +chose to profit. +271. In violation of various banking laws and regulations, including various +69 + + +Cassel1222cov1D9019JSSR Doocumeet7B62 FfliekD03138283 Fwyge7D10611BB1 +"Know Your Customer" and anti-structuring laws, JP +regularly authorized +cash withdrawals and deposits for the Epstein sex-trafficking venture, which allowed +Epstein, his co-conspirators, and those they directed to conduct the business of the +sex-trafficking venture. +272. JP +knowing and intentional banking law violations allowed +Epstein and his various corporations to stay "under the radar" and continue the sex +trafficking operation without close scrutiny or interference. +273. Among the young women and girls whose sex trafficking and sex abuse +participated in, benefited from, aided and abetted, and furthered were +Jane Doe 1 and the Class Members. +D. The Statute of Limitations +274. The statute of limitations under the TVPA is ten years after the cause +of action arose, or ten years after the victim reaches eighteen years of age, if the +victim was a minor at the time of the alleged offense. 18 U.S.C. § 1595(c)(1), (2). +The TVPA causes of actions for Jane Doe 1, and the other Class Members, arose +within ten years of the filing of this complaint. Epstein's sex-trafficking venture +constituted a criminal conspiracy and a sex-trafficking venture that operated +continuously from around 1998, through and including September 2013, and up to +and following Epstein's death in 2019. The conspiracy and venture undertook +criminal actions in violation of the TVPA throughout those years, including 2013 +70 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfiekD03138283 Flyge7120611BB1 +and after, thereby automatically bringing all actions in furtherance of the conspiracy +and venture within TVPA's statute of limitations. +275. The New York Adult Survivors Act has opened up a one-year revival +window for the statute of limitations regarding intentional and negligent torts +connected to violations of the New York Penal Law Chapter 130. See New York +State, Governor Hochul Signs Adult Survivors Act, Governor Kathy Hochul (May +24, +2022), +https://www.governor.ny.gov/news/governor-hochul-signs-adultsurvivors-act ("For many survivors, it may take years to come to terms with the +trauma of sexual assault and feel ready to seek just."). +VI. CLASS ACTION ALLEGATIONS +276. Jane Doe 1 brings this action pursuant to Federal Rule of Civil +Procedure 23(b)(3) and 23(c)(4) on behalf of herself and the following Class: +All women who were sexually abused or trafficked by Jeffrey Epstein during +the time when JP| +| maintained bank accounts for Epstein and/or +Epstein related-entities, which included January 1, 1998, through in or about +August 2013, both dates inclusive, and continuing to the time of Epstein's +death on August 10, 2019 (the "Class Period"). +277. Jane Doe 1 reserves the right to seek leave to modify this definition, +including the addition of one or more subclasses, after having the opportunity to +conduct discovery. +278. Numerosity: The Class consists of dozens of women, making joinder +impracticable, in satisfaction of Fed. R. Civ. P. 23(a)(1). The exact size of the Class +71 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flege7230611BB1 +and the identities of the individual Class members are ascertainable through records +maintained by the Epstein Estate and JP +including but not limited to JP +records for Epstein-related accounts (e.g., account ledgers reflecting +payments from Epstein to Class members). +279. Typicality: Jane Doe 1's claims are typical of the claims of the other +Class members she seeks to represent. The claims of Jane Doe 1 and the other Class +members are based on the same legal theories and arise from the same unlawful +pattern and practice of JP +participation in, conspiring to join in, and +funding of the Epstein's sexual abuse and Epstein's sex-trafficking venture. +280. Commonality: There are many questions of law and fact common to +the claims of Jane Doe 1 and the other Class members, and those questions +predominate over any questions that may affect only individual Class members, +within the meaning of Fed. R. Civ. P. 23(a)(2) and (b)(3). Class treatment of +common issues under Fed. R. Civ. P. 23(c)(4) will materially advance the litigation. +281. Common questions of fact and law affecting Class members include, +but are not limited to, the following: +a. Whether the Epstein sex-trafficking venture and conspiracy caused its +victims to engage in commercial sex acts in violation of Trafficking +Victims Protection Act, 18 U.S.C. § 1591(a)(1); +b. Whether the Epstein sex-trafficking venture and conspiracy recruited, +72 + + +Cassel1222e0v1D90191S5R Dooouneett7B62 FfleelD0B138283 FRage784ob11BB1 +enticed, solicited, harbored, provided, obtained, and transported victims +in ways that were in or affecting interstate or foreign commerce; +c. Whether Epstein and his co-conspirators used means of force, fraud, +coercion, and abuse of legal process, or a combination of such means, +to sexually abuse the victims and to cause victims to engage in +commercial sex acts; +d. Whether JP +knowingly and intentionally assisted, facilitated, +and supported the Epstein sex-trafficking venture's pattern and practice +of coercively forcing victims to engage in commercial sex acts; +e. Whether JP +benefited financially or by receiving things of +value from its participation in a venture which has engaged in sex +trafficking in violation of TVPA, 18 U.S.C. § 1591(a)(1); +f. Whether JP | +knew or should have known that the Epstein sextrafficking venture had engaged in violations of the TVPA, 18 U.S.C. +§ 1591(a); +g. Whether JP +was part of conspiracy to violate 18 U.S.C. § +1591(a), in violation of 18 U.S.C. § 1594(c); and +h. Whether JP +| committed intentional and negligent acts or +omissions that facilitated sexual abuse which would constitute a sexual +offense as defined in article 130 of New York Penal Law committed +73 + + +Casse11222c01D90191SSR Documeet 7862 FfiekD03138283 Flyge/450611.BB1 +against such persons who were eighteen years of age or older. +282. Absent a class action, most of the Class members would find the cost +of litigating their claims to be cost-prohibitive and will have no effective remedy. +The class treatment of common questions of law and fact is also superior to multiple +individual actions or piecemeal litigation, in that it conserves the resources of the +courts and the litigants and promotes consistency and efficiency of adjudication. +283. Adequacy: Jane Doe 1 will fairly and adequately represent and protect +the interests of the other Class members she seeks to represent. Jane Doe 1 has +retained counsel with substantial experience in prosecuting complex litigation and +class actions. Jane Doe 1 and her counsel are committed to vigorously prosecuting +this action on behalf of the other Class members and have the financial resources to +do so. Neither Jane Doe 1 nor her counsel have any interests adverse to those of the +other Class members. +284. This action has been brought and may properly be maintained as a class +action against JP +pursuant to Rule 23 of the Federal Rules of Civil Procedure +because there is a well-defined community of interest in the litigation and the +proposed Class is easily ascertainable from JP +records. +285. Superiority: A class action is superior to all other available methods +for the fair and efficient adjudication of this controversy because: +a. Joinder of all Class Members is impracticable; +74 + + +Cassel1222cov1D9019JSSR Doooumeet7B62 FfliekD03138283 Flewyge7560b11BB1 +b. The prosecution of individual remedies by members of the Class will +tend to establish inconsistent standards of conduct for JP +result in the impairment of Class Member's rights and the disposition +of their interests through actions to which they were not parties; +c. Class action treatment will permit a large number of similarly-situated +persons +to prosecute their common claims in a single forum +simultaneously, efficiently, and without the unnecessary duplication of' +effort and expense that numerous individual actions would engender; +d. Absent a class action, Class Members will continue to suffer losses and +be aggrieved and JP +will escape lability for its criminal and +tortious conduct and be able to continue to violate New York and +federal law without remedy; +e. Class treatment of this action will cause an orderly and expeditious +administration of class claims, economies of time, effort and expense +will be fostered, and uniformity of decisions will be ensured; +f. Jane Doe 1 and her counsel are unaware of any class action brought +against JP +by victims for the violations alleged in this action; +g. The forum is desirable because Jane Doe 1 conducted the subject +business with Jeffrey Epstein in this District and Class Members were +consequently trafficked in this District; and, +75 + + +Cassel1222e0v1D9019155R Doooumeett7B62 FfleedD0B138283 FRage767ob11BB1 +h. This action presents no difficulty that would impede its management by +the Court as a class action. +VII. CAUSES OF ACTION +COUNT I +AIDING, ABETTING, AND FACILITATING +BATTERY +286. Plaintiff Jane Doe 1 realleges and incorporates by paragraphs 1 - 285, +as if fully set forth in this Count. +287. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +288. Between about 1998 and 2013, in this District in New York, Jeffrey +Epstein intentionally committed batteries and other intentional tortious conduct, +including crimes in violation of New York Penal Law Chapter 130 such as New +York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66 (hereinafter +"Chapter 130 crimes"), against Jane Doe 1 and the Class Members. Epstein +committed the intentional tortious conduct and crimes against Jane Doe 1 and Class +Members and when they were 18 or older. As described throughout this complaint, +Epstein intentionally and non-consensually touched Jane Doe 1 and the Class +Members in a harmful and offensive manner that resulted in substantial injuries, +including damages from physical and psychological injury, extreme emotional +distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and +76 + + +Casse11222c01D9019155R Doocumeet 7862 FfiekD03138283 Flewge7780611BB1 +invasion of privacy. +289. The resulting injuries that Jane Doe 1 and the Class Members suffered +include injuries directly and proximately suffered as a result of sex offenses +committed by Epstein and other co-conspirators and criminalized under article 130 +of the New York Penal Laws. The offenses included sexual intercourse without +consent and oral sexual conduct without consent, forbidden by New York Penal Law +§ 130.20. The offenses included forcible touching of sexual or other intimate parts +without consent, forbidden by New York Penal Law §§ 130.20, 130.35, 130.50, +130.52, and 130.66. +290. Regardless of when the tortious conduct (e.g., battery) and Chapter 130 +Crimes were committed by Epstein, the conduct and crimes are now civilly +actionable, regardless of any statute of limitations to the contrary, because they are +covered by the one-year "look back" window in New York Adult Survivors Act. +See N.Y. C.P.L.R. § 214-j. +291. Between about 1998 and 2013, JP +knowingly and intentionally +aided, abetted, and facilitated Epstein's intentional tortious conduct (e.g., battery), +through Chapter 130 Crimes recounted in the preceding paragraphs of this Count. +Because JP +criminally aided, abetted, and facilitated Epstein's conduct and +crimes in violation of Chapter 130, it is vicariously and otherwise liable for damages +caused by the conduct and crimes. +77 + + +Cassel1222eov1D9019JSSR Doooumeet7B62 FfliekD03138283 Flewyge789o611.BB1 +292. Between about 2000 and 2013, when it provided substantial assistance +to Epstein, JP +was well aware of its important and substantial role as a part +of Epstein's intentionally tortious and illegal activity in committing Chapter 130 +Crimes. +293. As a direct and proximate result of Epstein's tortious conduct and +crimes, which JP +knowingly and intentionally aided, abetted, and facilitated, +Jane Doe 1 and the Class Members have in the past suffered, and in the future will +continue to suffer, substantial damages, including damages from physical and +psychological injury, extreme emotional distress, humiliation, fear, psychological +trauma, loss of dignity and self-esteem, and invasion of her privacy. +294. At the time of Epstein's batteries, intentionally tortious conduct, and +crimes against Jane Doe 1 and the Class Members, JP +was well aware of +Epstein's sex-trafficking venture and that its concrete steps in furtherance of the +venture were aiding, abetting, and facilitating his batteries, tortious conduct, and +crimes. +295. At the time of Epstein's crimes against Jane Doe 1 and the Class +Members, JP +knowingly provided substantial assistance in Epstein's +tortious conduct and crimes. That knowing substantial assistance went beyond mere +knowledge and approval of Epstein's wrongdoing. For example, JP +knowingly and intentionally provided the cash and the financial support that made +78 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flewge780o611.BB1 +it possible for Epstein to commit the coercive sex offenses described in the preceding +paragraphs in this Count. Without that cash and financial support, Epstein could not +have committed his tortious conduct and crimes—a fact that JP +knew. +296. JP +knowingly and intentionally committed both substantial acts +in support of Epstein and substantial deliberate omissions in support of Epstein. For +example, JP +deliberately omitted to take important steps (such as timely +filing SARs) that substantially assisted Epstein to commit his crimes against Jane +Doe 1 and Class Members in violation of New York Penal Law Chapter 130. +297. In aiding, abetting, and facilitating Epstein's intentional tortious +conduct and crimes, JP +could readily foresee direct and proximate injury to +Jane Doe 1 and the Class Member. JP +should have foreseen direct and +proximate injury from its actions and inactions to Jane Doe and the Class Members. +Indeed, JP | +did foresee injury to Epstein's victims, including Jane Doe 1 and +Class Members. +298. In aiding, abetting, and facilitating Epstein's tortious conduct and +crimes, JP +committed intentional torts directed against Jane Doe 1 and the +Class Members. JP +aiding, abetting, and facilitating Epstein's tortious +conduct and crimes were its own wrongful acts and omissions. JP +had a +duty not to commit tortious conduct and crimes-specifically aiding, abetting, and +facilitating New York sex crimes as described above- +— directed against Jane 1 and +79 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 FeeB810611BB1 +the Class Members. +299. As a result of the foregoing, JP +is liable civilly for damages it +directly, tortiously, and criminally caused to Jane Doe 1 and the Class Members. +Jane Doe 1 and the Class Members according are entitled to bring a cause of action +for damages for physical, psychological, or other injury or condition suffered as a +direct and proximate result of JP +_ aiding, abetting, and facilitating +Epstein's tortious conduct and crimes described above and for damages for physical, +psychological, or other injury or condition suffered as a direct and proximate result +of Epstein's tortious conduct and crimes. +300. By virtue of acting intentionally, outrageously, and with a high degree +of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal +indifference to civil obligations, JP +is liable to Jane Doe 1 and other +Members of the Class for punitive damages. +COUNT II +INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS +301. Plaintiff Jane Doe 1 realleges and incorporates by paragraphs 1 - 285, +as if fully set forth in this Count. +302. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +303. As a direct and proximate result of aiding, abetting, and facilitating +Epstein's tortious conduct and sex crimes in violation of Chapter 130, JP +80 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flyg:8820611BB1 +intentionally inflicted emotional distress against Jane Doe 1 and the Class Members. +304. JP +actions, described above, constitute extreme and +outrageous conduct that shocks the conscience. For example, JP +intentionally and knowingly participated in Epstein's sex-trafficking venture, as +outlined above. JP +had a legal duty not to participate in, facilitate, or aid and +abet Epstein's sex-trafficking venture and Epstein's Chapter 130 Crimes. +305. JP +conduct was especially extreme and outrageous due to +Jane Doe 1 and the Class Members' particular vulnerabilities as targets of a sextrafficking venture. +306. JP| +intended to cause, and did cause, Jane Doe 1 and the Class +Members severe emotional distress. At the very least, JP +recklessly +disregarded a substantial probability that its actions in aiding, abetting, and +facilitating Epstein's sex crimes would cause Jane Doe 1 and the Class Members +severe emotional distress. +307. Because JP +intentionally inflicted extreme emotional distress +on Jane Doe 1 and the Class Members, it is liable to Jane Doe 1 and the Class +Members for damages they suffered as a direct and proximate result. +308. As a direct and proximate result of JP +conduct, Jane Doe 1 +and the Class Members have in the past and will in the future continue to suffer +substantial damages from psychological and physical injury, including extreme +81 + + +Casse11222c01D9019155R Doocumeet 7862 FflekD03138283 FeeB830611.BB1 +emotional distress, humiliation, fear, psychological trauma, loss of dignity and selfesteem, and invasion of privacy. JP +aiding, abetting, and facilitating +Epstein's sex crimes in violation of Chapter 130 directly and proximately caused +Epstein's sex crimes. +309. By virtue of acting intentionally, outrageously, and with a high degree +of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal +indifference to civil obligations, JP +is liable to Jane Doe 1 and other +Members of the Class for punitive damages. +COUNT III +NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE TO +PREVENT PHYSICAL HARM +310. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +311. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +312. In addition to any duties that might arise as a financial institution +(alleged in the next Count, below), JP +owed a duty to Jane Doe 1 and the +Class Members to exercise reasonable care to avoid conduct that created a risk of +physical harm to them. JP +duties included a duty to exercise reasonable +care to avoid conduct that would combine with Epstein's crimes, and permit +Epstein's crimes, in violation of Chapter 130. +82 + + +Casse11222c0/109019155R Doocumeet 7862 FfiekD03138283 Flec834o611.BB1 +313. JP +own conduct in providing financial and other support for +Epstein's sex trafficking venture set forces in motion that directly and proximately +injured and caused physical harm to Jane Doe 1 and the Class Members. These +forces that JP +set in motion caused Epstein's intentional tortious conduct +and Chapter 130 Crimes against Jane Doe 1 and the Class Members, causing +physical harm and in themselves constituted physical harm to Jane Doe 1 and the +Class Members. JP +owed Jane Doe 1 and the Class Members a duty not to +set those forces in motion because they unreasonably created a risk of physical harm. +314. JP +reasonably could foresee, and did in fact foresee, that its +negligent failure to prevent physical harm would result in physical harm to Jane Doe +1 and the Class Members. JP +owed a duty to prevent that physical harm. +315. JP +failed to act objectively reasonably in failing to take +precautions to prevent Epstein's intentional tortious conduct and sex-trafficking and +sex crimes in violation of Chapter 130, which were committed against Jane Doe 1 +and the Class Members. If JP +had acted reasonably to prevent physical +harm, it would not have supported and allowed Epstein's tortious conduct and sextrafficking and sex crimes to occur. JP +owed Jane Doe 1 and the Class +members a duty to act objectively reasonably. +316. At the time of JP +own negligent conduct, JP +both +realized and should have realized the likelihood that it was creating an opportunity +83 + + +Casse11222c0v1D9019155R Doocumeet 7862 FfiekD03138283 Fag:8850611.BB1 +for Epstein to commit intentional tortious conduct and Chapter 130 Crimes against +Jane Doe 1 and the Class Members. Indeed, JP +knew that its own conduct +was necessary to create Epstein's opportunities to engage in that conduct and commit +those crimes. JP +owed Jane Doe 1 and the Class Members a duty not to +create those opportunities for Epstein. +317. JP +breaches of its legal duties were the direct—i.e., the butfor-cause of physical and psychological injuries to Jane Doe 1 and the Class +Members. Without JP +breaches of legal duties, those injuries would not +have occurred. The injuries that occurred were readily foreseeable to JP +318. Jane Doe 1 and the Class Members were easily within the zone of +foreseeable harm from the JP +negligent acts and omissions. JP +negligent acts and omissions foreseeably created substantial risk of Jeffrey Epstein +and his co-conspirators committing sex crimes against young women with whom he +was in contact. Tragically, Jane Doe 1 and the Class Members fell within that zone. +319. Because of JP +negligent failure to prevent physical harm to +Jane Doe 1 and the Class Members, it is liable to Jane Doe 1 and the Class Members +for damages suffered as a direct and proximate result. +320. As a direct and proximate result of JP +negligent failure to +prevent physical harm, Jane Doe 1 and the Class Members have in the past and will +in the future continue to suffer substantial damages from psychological and physical +84 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flec8860611.BB1 +injury, including extreme emotional distress, humiliation, fear, psychological +trauma, loss of dignity and self-esteem, and invasion of privacy. JP +aiding, abetting, and facilitating Epstein's tortious conduct and sex crimes in +violation of Chapter 130 directly and proximately caused Epstein's sex crimes. +321. By virtue of acting intentionally, outrageously, and with a high degree +of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal +indifference to civil obligations, JP +is liable to Jane Doe 1 and other +Members of the Class for punitive damages. +COUNT IV +NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE AS A +BANKING INSTITUTION PROVIDING NON-ROUTINE BANKING +322. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +323. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +324. JP +owed a duty to Jane Doe 1 and the Class Members not to +knowingly provide non-routine banking support and assistance for Epstein that it +knew, and reason to know, would lead to and support intentional tortious conduct +and Chapter 130 Crimes by Epstein against Jane Doe 1 and the Class Members. +325. As described in detail above, JP +did not merely provide routine +banking support for Epstein. Instead, it participated in, aided and abetted, and +85 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 FlygeB870611BB1 +facilitating his sex-trafficking venture and his commission of intentional tortious +conduct and Chapter 130 crimes. JP +also knew, and was willfully blind to +the fact, that it was going beyond providing routine banking support but instead +facilitating Epstein's sex-trafficking venture and his commission of tortious conduct +and Chapter 130 crimes. +326. As an example, in providing hundreds of thousands of dollars in cash +to Epstein and his co-conspirators in circumstances where it knew that the cash +would be used to facilitate coercive sex acts, JP +took substantial actions +outside the scope of a routine, lawful, and ordinary customer relationship. +327. As another example, JP| +deliberately failed to follow numerous +banking requirements in connection with financial dealings with Epstein, including +AML rules, KYC rules, and anti-structing rules. In deliberately ignoring and failing +to follow those rules, JP +acted in a non-routine way to facilitate and support +Epstein's and his co-conspirators' intentional torts, sex-trafficking, and commission +of Chapter 130 Crimes. JP +• through Staley, knew that Epstein was abusing +females sexually on a daily basis and through that knowledge, developed a special +relationship with Epstein. As a banking institution providing the necessary +infrastructure to the sex trafficking operation, JP +developed a special +relationship with Epstein and thus undertook an obligation to protect others from his +abuse. +86 + + +Cassel1222eov1D9019JSSR Doocumeet7B62 FfliekD03138283 Flewygc8880611.BB1 +328. Likewise, JP +, acting through Staley, having observed Jane Doe +1 in circumstances indicating sexual abuse and trafficking, and whose relationship +with Epstein was always maintained for the benefit of JP +owed a duty to +protect the victims from the abuse of Jeffrey Epstein about which Staley, on behalf +of JP +was well aware. +329. JP +also owed Jane Doe 1 and the Class Members a duty of care +because it affirmatively and intentionally chose not to investigate Epstein's +suspicious banking activities even after being confronted with explicit information +that Epstein was using JP +to further a sex-trafficking venture harming Jane +Doe 1 and the Class Members. JP +chose not to do so because it knew what +the investigation would reveal, and that it would need to end its lucrative relationship +with Epstein as a result of the investigation. Once JP| +had information about +Epstein's use of JP +for a sex-trafficking venture, and once it knew or has +reason to know that it was providing material support to that venture, it owed a duty +of care to investigate suspicious banking activity. +330. But for JP +Epstein could not have successfully run and +expanded his sexual abuse organization. Epstein could not have abused the hundreds +of victims that he did without JP +331. JP +failed to act objectively reasonably by failing to comply +with relevant banking laws and regulations with regard to its interactions with +87 + + +Casse11222c0/1D9019155R Doocumeet 7862 FfiekD03138283 FeeB89o611.BB1 +Epstein and his co-conspirators. JP L +owed a duty to Jane Doe 1 and the Class +Members to act objectively reasonably in its interactions with Epstein and his coconspirators and to exercise reasonable care to prevent them from engaging in +foreseeable tortious and criminal activity by using JP +exceptional and nonroutine banking infrastructure. +332. JP +owed a legal duty to Jane Doe 1 and the Class Members to +act objectively reasonably and to not deliberately ignore banking obligations, +including KYC and AML laws and regulations described above, so as to provide +Epstein and others with an opportunity to engage in tortious conduct, coercive sextrafficking and Chapter 130 Crimes. +333. Under KYC, AML, and related laws and regulations, JP +had +special duties not ignore tortious conduct and crimes being committed by its +customers duties above and beyond any duties that the general public may have. +The inquiries that banks must make include duties to inquire about specific +individuals who banks know are being harmed. The regulations establish a duty of +care that must be followed by banks, including JP| +These duties exist at +least in situations where a bank is knowingly going beyond offering routine banking +for its customers and instead offers banking infrastructure specially adapted to +facilitate tortious conduct and crimes. +334. JP| +also owed Jane Doe 1 and the Class Members a duty of care +88 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flec890o611.BB1 +because it knew, and had reason to know, that Epstein and his co-conspirators were +using JP +to facilitate a sex-trafficking venture, raising a duty to make a +reasonable inquiry about suspicious activity. +335. JP +owed Jane Doe 1 and the Class Member a duty not to +deliberately and purposely fail to file SARs—filings which would have alerted +federal authorities to Epstein's and his co-conspirators' illegal activities, including +committing Chapter 130 Crimes. +336. JP +also owed Jane Doe 1 and the Class Members a duty to +prevent physical harm to them when confronted with explicit information that +Epstein and his co-conspirators were using JP +non-routine banking to +further a sex-trafficking venture harming Jane Doe 1 and the Class Members. Once +had information about Epstein's use of JP +for a sex-trafficking +venture that was physically harming Jane Doe 1 and the Class Members, it owed +them a duty of care to investigate and prevent Epstein's and his co-conspirators' +suspicious, tortious, and criminal activities. +337. In the exercise of reasonable care, JP +and its employees knew, +and should have known, of the dangerous propensities of Jeffrey Epstein and his coconspirators to commit intentional torts and violations of article 130 of New York +Penal Law against women and girls with whom he was in close proximity, including +Jane Doe 1 and the Class Members. +89 + + +Cassel1222eov1D9019JSFR Doocumeett7B62 FfleekD03138283 Feage9910611BB1 +338. JP +breached its legal duties to Jane Doe 1 and the Class +Members as described above. JP +breach of its duties led to it failing to +prevent Epstein from committing intentional torts and Chapter 130 Crimes against +Jane Doe 1 and the Class Members. JP +realized that Epstein were +committing intentional torts and Chapter 130 Crimes against Jane Doe 1 and the +Class Members. +The criminal activity that harmed Jane Doe 1 and the Class +Members included foreseeable intentional torts as well as TVPA and Chapter 130 +Crimes committed by the Epstein. +339. As a direct and proximate result of the breach of legal duties by JP +Jane Doe 1 and the Class Members repeatedly suffered direct and +foreseeable injuries from Epstein and his co-conspirators, including injuries from +federal and state sexual offenses (including sexual assaults) and resulting emotional +distress, mental pain and suffering, and other physical, psychological, and other +injuries. +340. The breaches of JP +legal duties were the direct—i.e., the butfor cause of these physical and psychological injuries to Jane Doe 1 and the Class +Members. Without JP +breaches of its legal duties, those injuries would +not have occurred. The injuries that occurred were readily foreseeable to JP +341. The injuries that Jane Doe 1 and the Class Members suffered included +injuries directly and proximately suffered while they were adults who were present +90 + + +Casse11222c/1D9019155R Documeet 7862 FfiekD03138283 Flege9920611BB1 +in this District. These injuries are permanent in nature and Jane Doe 1 and the other +Class Members will continue to suffer these losses in the future. +342. JP +could reasonably foresee that their actions and omissions in +facilitating Epstein's sex trafficking enterprise would lead to intentional torts and +sex offenses against Jane Doe land the Class Members. Indeed, JP +was +aware, and should have been aware, that Epstein was a high risk to commit sex +offenses against young women and girls. +343. Jane Doe 1 and the Class Members were easily within the zone of +foreseeable harm from JP +negligent acts and omissions. JP| +acts +and omissions foreseeably created substantial risk of Jeffrey Epstein and his coconspirators committing intentional torts and sex crimes against young women with +whom he was in contact. Tragically, Jane Doe 1 and the Class Members fell within +that zone. +344. While the foregoing allegations easily make out a clear case of +negligence, this case does not involve mere negligence. Instead, Defendants' +tortious conduct in this case evinced a high degree of moral turpitude and +demonstrated such wanton dishonesty as to imply a criminal indifference to civil +obligations. It also involved outrageous and intentional acts and omissions, because +it was a deliberate attempt to further the crimes of a widespread and dangerous +criminal sex trafficking organization. JP +tortious conduct was directed +91 + + +Casse11222601D9019155R Doocumeet 7862 FfiekD03138283 Flyge9930611BB1 +specifically at Jane Doe 1 and other Members of the Class, who were the victims of +Epstein's sexual abuse and sex trafficking organization. +345. As a result of JP +negligent actions and omissions described +in this Count, Jane Doe 1 and the Class Members have sustained both general and +specifical damages from physical and psychological injury in substantial amounts. +346. By virtue of acting intentionally, outrageously, and with a high degree +of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal +indifference to civil obligations, JP +is liable to Jane Doe 1 and other +Members of the Class for punitive damages. +COUNT V +KNOWING BENEFICIARY IN A SEX-TRAFFICKING VENTURE IN +VIOLATION OF THE TRAFFICKING VICTIMS PROTECTION ACT, +18 U.S.C. §§ 1591(a)(2), 1595 +347. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +348. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +349. JP +knowingly and intentionally benefitted, financially and by +receiving things of value, from participating in, assisting, supporting, and facilitating +an illegal coercive sex-trafficking venture that was in and affecting interstate and +foreign commerce, together and with others, in violation of 18 U.S.C. § 1591(a)(2). +350. JP +took many concrete steps to aid and participate in Epstein's +92 + + +Cassel1222eov1D9019JSSR Doocuneet7B62 FfliekD03138283 Flege934o611.BB1 +sex-trafficking venture. Among the concrete steps that JP +took to aid Epstein +was providing vast sums of cash, which made the sex-trafficking venture possible. +Providing Epstein with large sum of U.S. currency caused JP +to receive +financial benefits. JP +willingness to provide large amounts of cash to +Epstein was the quid pro quo for it receiving financial benefits from Epstein. +351. The cash that JP +provided was necessary for Epstein to coerce +Jane Doe 1 as well as other Class Members to engage in commercial sex acts. The +cash directly formed part of the commercial nature of the sex acts. The cash was +also a necessary and required part of Epstein's recruitment of Jane Doe 1 and other +victims of his sex-trafficking venture. By providing cash that JP +knew +would be used to fund the sex trafficking venture, JP +actively participated +in the recruitment of victims of the venture. +352. The cash that JP +provided went far beyond providing routine +banking opportunities for a client. It was far from routine for JP +to provide +substantial sums of cash per year to Epstein, who did not have an apparent legitimate +need for such extravagant sums. Moreover, the circumstances in which Epstein was +requesting such large amounts were far from routine and raised numerous "red +flags"—taking it well outside routine circumstances. +353. JP +providing large sums of cash to Epstein, under the +circumstances of this case, was entirely inconsistent with the ordinary duties of a +93 + + +Cassel1222eov1D9019JSSR Doooumeet7B62 FfliekD03138283 Flewyge99150611.BB1 +bank or its employees. +354. The reason that JP +ignored the numerous red flags about +Epstein was to receive financial benefits from Epstein and his sex-trafficking +venture. JP +knew that it would gain far-from-routine financial benefits by +ignoring the red flags associated with Epstein and by participating in his sextrafficking venture. +355. Among the concrete steps that JP +took to aid and participate in +the Epstein sex-trafficking venture were opening up numerous accounts at JP +for Epstein, his related entities, and associates. By opening these accounts, +received many benefits from participating in Epstein's venture. The +opening of these accounts was affirmative conduct that caused JP +to receive +those benefits. +356. Among the concrete steps that JP +took to aid the Epstein sextrafficking venture, between about 2000 and continuing through about August 2013, +concealed its delivery of vast sums of cash (likely hundreds of thousands +of dollars) to Epstein and his associates. In order to benefit from the Epstein sextrafficking venture, JP| +willfully failed to timely file required SARs with the +federal government, because doing so would imperil its ability to profit from the +sex-trafficking venture. JP +concealment of the cash transactions caused it +to receive financial benefits through continuation of the Epstein sex-trafficking +94 + + +Casse11222601D9019155R Doocument 7862 FfleekD03138283 Fage9560611BB1 +venture. +357. Among the concrete steps that JP | +took to aid the Epstein sextrafficking venture were its failure to follow AML requirements. This failure was +not just passive facilitation, but a deliberate omission by JP | +This omission +was specific act of concealment, which allowed Epstein to continue funding his sextrafficking venture through suspicious transactions that would have otherwise been +prevented. +358. By taking the concrete steps outlined above (along with the others +alleged in this complaint), JP +knowingly participated in sex trafficking and +furthered the Epstein sex-trafficking venture. The concrete steps above constituted +taking part in the sex-trafficking venture and were necessary for its success. The +concrete steps above constituted active engagement by JP| +in Epstein's sextrafficking venture. +359. JP| +knowingly and intentionally benefited financially from, and +received value for, its participation in the sex-trafficking venture, in which Epstein, +with JP +knowledge, or its reckless disregard of the fact, that Epstein would +use means of force, threats of force, fraud, coercion, and a combination of such +means to cause Jane Doe 1, as well as other Class Members, some of whom were +under the age of eighteen, to engage in commercial sex acts. +360. JP +actually knew, through Staley and other officers and +95 + + +Cassel1222cov1D9019JSSR Doocumeet7B62 FfliekD03138283 Fegge997ob11BB1 +employees, that it was participating in a particular sex-trafficking venture—i.e., the +coercive Epstein sex-trafficking venture outlined above. JP +knowledge +went far beyond having an abstract awareness of sex trafficking in general. Indeed, +discussed internally Epstein's specific sex trafficking and the large +amounts of cash that JP +was giving him. Thus, JP +did not simply +fail to adequately detect signs of Epstein's sex trafficking; it did detect multiple signs +of Epstein's coercive sex-trafficking venture and continued to participate in the +venture. JP +knew that the venture was on-going, which was why Epstein +required vast sums of cash. +361. JP +actions extend well beyond a situation of failing to train +its staff about recognizing the warning signs of sex trafficking. JP +employees did recognize the signs of Epstein's sex trafficking. Indeed, JP +employees knew about Epstein's sex-trafficking venture. But JP| +decided to +continue facilitating the Epstein sex-trafficking venture rather than ending its +participation in the venture. +362. Among the signs that JP +was facilitating Epstein's sex +trafficking venture were those facts that came to the attention of JP +employees discussed above, which caused those employees to escalate issues +regarding Epstein's coercive sex-trafficking venture to more senior levels. +363. Among the signs that JP +was facilitating Epstein's sex +96 + + +Casse112220109019155R Document 7862 FfleekD03138283 Flege9980611 BB1 +trafficking venture were those facts that came to the attention of JP| +were +those facts that came to its attention through Jes Staley's observations of Epstein's +sex trafficking. Because of those observations, Staley—and JP| +-knew to a +certainty that Epstein was engaged in sex trafficking. +364. JP +actual knowledge extended to the fact that specific +individual women and girls were being coercively sex trafficked by Epstein between +the time of his on-boarding and the termination of its relationship with Epstein. Even +if JP +did not know all the names of Epstein's victims, it knew that specific +victims (e.g., Jane Doe 1) of a specific trafficker (Epstein) at a specific time period +(various dates between 2000-2013 and following) existed and were being forced to +engage in commercial sex acts. It also knew that some of the victims had eastern +European surnames. JP +was on notice, and knew, that such victims were +being coercively trafficked by Epstein's sex-trafficking venture. +365. One of JP +officers, Jes Staley, also knew the names of the +many of Epstein's sex trafficking victims. +366. JP +helped to conceal the names of Epstein's victims from the +public and from law enforcement and prosecuting agencies by helping to conceal the +existence of the sex-trafficking venture. Among the ways in which JP +helped to conceal the venture's existence was by providing the cash necessary for +the venture to avoid leaving a visible "paper trail." +97 + + +Casse11222c0109019155R Documeet 7862 FfiekD03138283 Flege989o611.BB1 +367. JP +concealment included failing to follow through on +enhanced monitoring that was required for someone like Epstein. JP +failed +to implement that enhanced monitoring specifically to help conceal Epstein's +ongoing sex-trafficking. JP +knew that if it implemented that enhanced +monitoring, it would have to stop providing Epstein with the cash needed to run his +sex-trafficking venture. +368. JP +concealment included failing to file required SARs for +Epstein's suspicious cash transactions. +369. In addition to having actual knowledge that it was participating in +Epstein's sex trafficking venture, JP L +had constructive knowledge that it was +participating in Epstein's sex trafficking venture. JP +also had constructive +knowledge that Jane Doe 1, as well as other Members of the Class, were being +coercively sex trafficked by Epstein. Its constructive knowledge extended to the +names of Epstein's victims, because Epstein and his associates knew the names of +the victims. Staley also the knew the names of many of the victims. +370. JP +had constructive knowledge of Epstein's sex-trafficking +venture because of specific acts by Epstein that put it on notice of a particular and +ongoing sex trafficking venture. Among the specific acts were Epstein's use of vast +sums of cash in circumstances that prompted JP +employees to specifically +raise questions about Epstein's sex-trafficking. +98 + + +Cease: 222G1090499BR DDaoeen C@ Filed OB/D8/23 Page 990fof3B1 +371. Also among the specific acts giving rise to constructive knowledge +were the facts that associates of Epstein made numerous cash withdrawals from JP +accounts. The circumstances of these withdrawals gave the bank notice that +"structuring" was occurring to avoid alerting federal authorities. +372. Among the financial benefits that the JP +received for +participating in and facilitating Epstein's sex-trafficking venture were the deposit of +funds that Epstein and Epstein-controlled entities made to JP +profited from the use of these deposits. Epstein and Epstein-controlled entities +deposited these funds in exchange for JP +facilitation and participation in +the sex trafficking venture, including its willingness to provide large amounts of cash +in suspicious circumstances and to allow "structuring" of withdrawals to avoid +triggering reporting requirements. +373. Among the financial benefits that JP| +received for participating +in Epstein's sex-trafficking venture was referral of business opportunities from +Epstein and his co-conspirators. JP | +profited from these referred business +opportunities. Epstein referred business entities and business opportunities to JP +in exchange for its facilitation and participation in the sex trafficking +venture. These referrals were a quid pro quo for JP +participation in the +sex-trafficking venture. +374. JP +financially profited from the deposits made by Epstein and +99 + + +Casse112220/1090191STR Doocumeet 7862 FfeekD03138223 Peggel D010611 BB1 +Epstein-controlled entities and from the business opportunities referred to JP +by Epstein in exchange for its facilitation and participation in Epstein's sex +trafficking venture. +375. JP +knowingly received financial benefits in return for its +assistance, support, and facilitation of Epstein's sex-trafficking venture. JP +knew that if it stopped providing assistance, support, and facilitation of Epstein's +sex-trafficking venture, it would no longer receive those benefits. +376. JP +knew, and was in reckless disregard of the fact, that it was +Epstein's pattern and practice to use the channels and instrumentalities of interstate +and foreign commerce, to entice, recruit, solicit, harbor, provide, obtain, and +transport young women and underage girls for purposes of causing commercial sex +acts, in violation of 18 U.S.C. § 1591(a)(1). +377. JP +and its employees had actual knowledge that they were +facilitating Epstein's sexual abuse and sex trafficking conspiracy to recruit, solicit, +entice, coerce, harbor, transport, obtain and provide Jane Doe 1 as well as other +Members of the Class, into commercial sex acts, through the means of force, threats +of force, fraud, abuse of process, and coercion, and a combination of all these means. +378. Despite such knowledge, JP +intentionally paid for, facilitated, +and participated in Epstein's violations of 18 U.S.C. § 1591(a)(1), which JP +knew, and were in reckless disregard of the fact that, Epstein would coerce, defraud, +100 + + +Casse112220/1090191STR Documeet 7362 FfleekD03138223 Peggel D020611 BB1 +and force Jane Doe 1, as well as other Members of the Class, to engage in +commercial sex acts. +379. JP +through its employees and agents (including Staley), +actively participated in the sex trafficking conspiracy and led Jane Doe 1, as well as +other Class Members, to believe that they would be rewarded if they cooperated and +acquiesced to Epstein's coercive demands. +380. JP +affirmative conduct was committed knowingly, and in +reckless disregard of the facts, that Epstein would use cash and financial support +provided by JP +as a means of defrauding, forcing, and coercing sex acts +from Jane Doe 1 as well as other Members of the Class. JP +conduct was +outrageous and intentional. +381. In addition to actual knowledge that it was participating in and +facilitating the Epstein sex-trafficking venture, JP| +also should have known +that it was participating in and facilitating a venture that had engaged in coercive sex +trafficking, as covered by 18 U.S.C. § 1595(a). +382. In exchange for facilitating and covering up Epstein's commercial sex +trafficking, the JP| +officers and employees (including Staley) advanced in +their careers at JP +and received financial benefits therefrom by securing the +-Epstein relationship. +383. Facilitating and covering up Epstein's sexual trafficking and +101 + + +Casse112220109019195R Document 7362 FilibeD03138223 Flagel 02306f18B1 +misconduct was a means of obtaining economic success and promotion within the +hierarchy. +384. JP +knowing and intentional conduct has caused Jane Doe 1 +and the other Members of the Class serious harm including, without limitation, +physical, psychological, emotional, financial, and reputational harm. +385. JP +knowing and intentional conduct has caused Jane Doe 1 +and the other Members of the Class harm that is sufficiently serious, under all the +surrounding circumstances, to compel a reasonable person of the same background +and in the same circumstances to perform or to continue performing commercial +sexual activity, in order to avoid incurring that harm. +386. This case does not involve mere fraud. Instead, JP +criminal +conduct in violating the TVPA was outrageous and intentional, because it was in +deliberate furtherance of a widespread and dangerous criminal sex trafficking +organization. JP +criminal conduct also evinced a high degree of moral +turpitude and demonstrated such wanton dishonesty as to imply a criminal +indifference to civil obligations. JP +criminal conduct was directed +specifically at Jane Doe 1 and other members of the Class, who were the victims of +Epstein's sexual abuse and sex trafficking organization. +387. JP +outrageous and intentional conduct in this case is part of +a pattern and practice of JP +• profiting by undertaking illegal "high risk, high +102 + + +Casse112220/1090191STR Documeet 7862 FfleekD03138223 Peggel 1340611 BB1 +reward" clients. +388. By virtue of these knowing and intentional violations of 18 U.S.C. §§ +1591(a)(2), 1595, JP +is liable to Jane Doe 1 and the other Members of the +Class for the damages they sustained and reasonable attorneys' fees. +389. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ +1591(a)(2), 1595, JP +is liable to Jane Doe 1 and other members of the Class +for punitive damages. +PARTICIPATING IN A SEX TRUCKING VENTURE IN VIOLATION +OF THE TRAFFICKING VICTIMS PROTECTION ACT, +18 U.S.C. §§ 1591(a)(1), 1595 +390. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +391. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +392. JP +knowingly and intentionally, through various means, +participated in, perpetrated, assisted, supported, facilitated a sex-trafficking venture +that was in and affecting interstate and foreign commerce, together and with others, +in violation of 18 U.S.C. § 1591(a)(1). +393. Among other things, JP| +knowingly and intentionally, through +various means, recruited, enticed, provided, obtained, advertised, and solicited by +various means Jane Doe 1, as well as other Class Members, knowing that Epstein +103 + + +Casse112220/1090191STR Doocumeet 7862 FfeekD03138223 Peggel D050611 BB1 +would use means of force, threats of force, fraud, coercion, and a combination of +such means to cause Jane Doe 1, as well as other Class Members, some of whom +were under the age of eighteen, to engage in commercial sex acts. +394. JP +and its officers and employees (including Staley) had actual +knowledge that they were perpetrating and facilitating Epstein's sexual abuse and +sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain +and provide Jane Doe 1 as well as other Members of the Class, into commercial sex +acts, through the means of force, threats of force, fraud, abuse of process, and +coercion. +395. Despite such knowledge, JP +intentionally paid for, facilitated, +perpetrated, and participated in Epstein's violations of 18 U.S.C. § 1591(a)(1), which +knew, and were in reckless disregard of the fact that, Epstein would +coerce, defraud, and force Jane Doe 1, as well as other Class Members, to engage in +commercial sex acts. +396. As part of perpetrating TVPA violations and enticing and recruiting +victims, between on or about 2000 and August 2013, JP +delivery of vast sums of cash to Epstein and his associates. +concealed its +397. As part of perpetrating TVPA violations, JP +failed to file required SARs with the federal government. +also willfully +398. JP +affirmative conduct was committed knowing, and in +104 + + +Casse112220/1090191STR Doocumeet 7862 FfeekD03138223 Peggel D560611 BB1 +reckless disregard of the facts, that Epstein would use cash and the financial support +provided by JP +as a means of defrauding, forcing, and coercing sex acts +from Jane Doe 1 as well as other Class Members. JP +conduct was +outrageous and intentional. +399. JP +knowing and intentional conduct has caused Jane Doe 1 +and the other Class Members serious harm including, without limitation, physical, +psychological, emotional, financial, and reputational harm. +400. JP +knowing and intentional conduct has caused Jane Doe 1 +and the other Members of the Class harm that is sufficiently serious, under all the +surrounding circumstances, to compel a reasonable person of the same background +and in the same circumstances to perform or to continue performing commercial +sexual activity, in order to avoid incurring that harm. +401. This case does not involve mere fraud. Instead, JP +criminal +conduct in perpetrating TVPA violations was outrageous and intentional, because it +was in deliberate furtherance of a widespread and dangerous criminal sex trafficking +organization. JP +criminal conduct (including Staley conduct on behalf of +also evinced a high degree of moral turpitude and demonstrated such +wanton dishonesty as to imply a criminal indifference to civil obligations. JP +criminal conduct was directed specifically at Jane Doe 1 and other +members of the Class, who were the victims of Epstein's sexual abuse and sex- +105 + + +Cassel1222e0/1090191S5R Doocumeet7B62 FfeekD03138223 Peggel D670611 BB1 +trafficking organization. +402. JP +outrageous and intentional conduct in this case is part of +a pattern and practice of JP +profiting by undertaking illegal and "high risk, +high reward" clients. +403. By virtue of its knowing and intentional violations of 18 U.S.C. §8 +1591 (a)(1), 1595, JP +is liable to Jane Doe 1 and the other Members of the +Class for the damages they sustained and reasonable attorneys' fees. +404. By virtue of these intentional and outrageous violations of 18 U.S.C. §8 +1591(a)(1), 1595, JP +is liable to Jane Doe 1 and other members of the Class +for punitive damages. +COUNT VII +AIDING, BETTING, AND INDUCING A SEX-TRAFFICKING VENTURE +IN VIOLATION OF THE TRAFFICKING VICTIMS PROTECTION ACT, +18 U.S.C. §§ 2, 1591(a)(1) & (2), 1595 +405. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1-285, as if fully set forth in this Count. +406. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +407. Acting through its officers and employees (including Staley), JP +aided, abetted, and induced Epstein's sex-trafficking venture that was in and +affecting interstate and foreign commerce, together and with others, in violation of +18 U.S.C. §8 2, 1591(a)(1) & (a)(2). +106 + + +Casse112220109019195R Document 7362 FilibeD03138223 Flagel D0806f18B1 +408. Under 18 U.S.C. § 2, JP +is punishable as a principal under 18 +U.S.C. §§ 1591(a)(1) & (a)(2) and thereby committed and perpetrated violations of +Chapter 77, Title 18, U.S. Code, when it aided, abetted, procured, and induced +Epstein's sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other +Class Members. +409. Under 18 U.S.C. § 2, JP| +committed and perpetrated crimes in +violation of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, and inducing +Epstein's and his conspirators sex-trafficking venture and sex trafficking of Jane +Doe 1, as well as other Class Members. As a consequence, Jane Doe 1, as well as +other members of the Class, are victims of JP +criminally aiding, abetting, +and inducing Epstein's violations of 18 U.S.C. $§ 1591(a)(1) & (a)(2). These actions +were in and affecting interstate and foreign commerce. +410. The crimes that JP +aided and abetted are (1) Epstein's +perpetrating of coercive sex trafficking, in violation of 18 U.S.C. § 1591(a)(1), and +(2) Epstein's co-conspirators' knowingly benefitting from coercive sex trafficking, +in violation of 18 U.S.C. § 1591(a)(2). These crimes were in and affecting interstate +and foreign commerce. +411. Epstein's co-conspirators benefitted financially and received things of +value from their participation in the Epstein sex-trafficking venture, including +payments and other compensation from Epstein. The co-conspirators who benefitted +107 + + +Casse112220/1090191STR Documeet 7B62 FfeekD03138223 Peggel D890611 BB1 +financially include Ghislaine Maxwell, Lesley Groff, +412. Acting through its officers and employees (including Staley), JP +itself directly committed and perpetrated violations of Chapter 77, Title 18, +U.S. Code, including 18 U.S.C. §§ 1591(a)(1) & (a)(2), by aiding, abetting, and +inducing a sex-trafficking venture and the sex trafficking of Jane Doe 1, as well as +other Class Members. JP| +itself directly violated Chapter 77 by committing +and perpetrating these violations. +413. Among other things, JP | +aided, abetted, and induced Epstein's +sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other Class +Members, knowing that Epstein would use means of force, threats of force, fraud, +coercion, and a combination of such means to cause Jane Doe 1, as well as other +Class Members, some of whom were under the age of eighteen, to engage in +commercial sex acts. +414. By aiding, abetting, and inducing Epstein's sex-trafficking venture and +sex trafficking of Jane Doe 1, as well as other Class Members, JP +knowingly +benefited, both financially and by receiving things of value, from participating in +Epstein's sex-trafficking venture. +415. JP +and its officers and employees had actual knowledge that +they were aiding, abetting, and inducing Epstein's sexual abuse and sex trafficking +108 + + +Casse1122260/1090191STR Doocumeet 7B62 FfeekD03138223 Peggel D900611 BB1 +conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain and provide +Jane Doe 1 as well as other Members of the Class, into commercial sex acts, through +the means of force, threats of force, fraud, abuse of process, and coercion. JP +knew, and should have known, that Epstein had engaged in acts in violation +of the TVPA. +416. Despite such knowledge, JP +intentionally paid for and aided, +abetted, procured, and induced Epstein's and his co-conspirators violations of 18 +U.S.C. §§ 1591(a)(1) & (a)(2), which constituted perpetrating violations of those +laws under 18 U.S.C. § 2. JP +knew, and acted in reckless disregard of the +fact that, Epstein would coerce, defraud, and force Jane Doe 1, as well as other Class +Members, to engage in commercial sex acts. +417. JP +affirmative conduct of aiding, abetting, procuring, and +inducing Epstein's and his co-conspirators' violations was committed knowingly, +and in reckless disregard of the facts, that Epstein would use cash and financial +supported provided by JP +_ as a means of defrauding, forcing, and coercing +sex acts from Jane Doe 1 as well as other Class Members. JP +conduct was +outrageous and intentional. +418. Acting within this District and in attempting to further the Epstein sextrafficking venture, after various times between about 1998 and 2013, JP | +knowingly and intentionally took substantial and significant steps to aid and abet +109 + + +Cassel122201090191STR Documeet 7862 FfleekD03138223 Peggel 1D10611 BB1 +Epstein's sex trafficking venture, including opened various brokerage accounts for +Epstein and Epstein-related individuals and entities. These accounts were in and +affecting interstate and foreign commerce +419. JP +knowing and intentional conduct of aiding, abetting, and +inducing Epstein's violations has caused Jane Doe 1 and the other Class Members +serious harm including, without limitation, physical, psychological, emotional, +financial, and reputational harm. +420. JP +knowing and intentional conduct of aiding, abetting, and +inducing Epstein's violations has caused Jane Doe 1 and the other Class Members +harm that is sufficiently serious, under all the surrounding circumstances, to compel +a reasonable person of the same background and in the same circumstances to +perform or to continue performing commercial sexual activity, in order to avoid +incurring that harm. +421. This case does not involve mere fraud. Instead, JP +criminal +conduct in aiding, abetting, and inducing Epstein's TVPA violations was outrageous +and intentional, because it was in deliberate furtherance of a widespread and +dangerous criminal sex trafficking organization. JP +criminal conduct also +evinced a high degree of moral turpitude and demonstrated such wanton dishonesty +as to imply a criminal indifference to civil obligations. JP +criminal +conduct was directed specifically at Jane Doe 1 and other members of the Class, who +110 + + +Cassel122260/1090191STR Doocumeet 7B62 FfeekD03138223 Peggel1120611 BB1 +were the victims of Epstein's sexual abuse and sex trafficking organization. +422. JP +outrageous and intentional conduct in this case is part of +a pattern and practice of JP +profiting by undertaking illegal "high risk, high +reward" clients. +423. By virtue of these knowing and intentional violations of 18 U.S.C. §§ +1591(a)(1), 1595, JP +is liable to Jane Doe 1 and the other members of the +Class for the damages they sustained and reasonable attorneys' fees. +424. By virtue of these intentional and outrageous violations of 18 U.S.C. §8 +1591(a)(1), 1595, JP +is liable to Jane Doe 1 and other members of the Class +for punitive damages. +COUNT VIII +CONSPIRACY TO COMMIT VIOLATIONS OF THE TRAFFICKING +VICTIM PROTECTION ACT, 18 U.S.C. §§ 1594(c), 1591, 1595 +425. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +426. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +427. JP +intentionally conspired with others, including Epstein and +his other co-conspirators, by agreement and understanding, to violate 18 U.S.C. $8 +1591(a)(1) & (a)(2) & 1591(d), and to further Epstein's sex-trafficking venture to +coerce commercial sex acts from Jane Doe 1 and other Class Members, all in +111 + + +Cassel1222e0/1090191S5R Doocumeet7B62 FfeekD03138223 Pegge1 1 P30611 BB1 +violation of 18 U.S.C. § 1594(c). JP| +officers and employees (e.g., Staley) +directly conspired with Epstein himself to further the sex-trafficking venture. +428. JP +conspiracy to violate 18 U.S.C. 1591(a)(1) & (a)(2) was +forbidden by 18 U.S.C. § 1594(c), and JP +thereby violated Chapter 77, Title +18. JP +conspiracy directly, proximately, and foreseeably harmed Jane Doe +1, as well as other members of the Class, by directly leading to their forcibly being +caused to engage in commercial sex acts and in other ways. JP +conspiracy +victimized Jane Doe 1 and the other members of the Class. +429. JP +conspiracy to violate 18 U.S.C. 1591(d) was forbidden by +18 U.S.C. § 1594(c), and JP +thereby violated Chapter 77, Title 18. JP +conspiracy directly, proximately, and foreseeably harmed Jane Doe 1, as +well as other members of the Class, by directly leading to their forcibly being caused +to engage in commercial sex acts and in other ways. JP +conspiracy +victimized Jane Doe 1 and the other Members of the Class. +430. JP +conspired with Epstein and his other co-conspirators to +further the Epstein sex-trafficking venture and with the purpose of facilitating +Epstein's illegal sex trafficking. JP L +had actual knowledge of Epstein's sextrafficking venture. JP +acted with the specific intent to violate 18 U.S.C. §S +1591(a)(1) & (a)(2), that is, with consciousness of the nature of Epstein's sextrafficking venture and with the specific intent to further venture. JP +112 + + +Casse112220/1090191STR Doocumeet 7862 FfeekD03138223 Peggel 1.840611 BB1 +Epstein had a meeting of the minds as to the essential nature of the plan. +431. JP +conspiracy with Epstein was part of its participation in his +sex-trafficking venture. Without JP| +agreeing to facilitate the venture (by, +for example, conspiring to keep the existence of cash disbursals secret), Epstein +would not have been a position to move forward with his sex-trafficking venture and +to recruit and entice victims of the venture. +432. JP| +also conspired with Epstein and his other co-conspirators to +obstruct, attempt to obstruct, to interfere with, and to prevent the enforcement of the +TVPA, violating 18 U.S.C. § 1591(d). The conspiracy included an agreement to +keep Epstein's sex-trafficking venture secret or, at least, concealed to the greatest +extent possible. Among the means for keeping the venture secret were paying for +the commercial sex acts in cash, structuring cash withdrawals in a way to avoid +detection, and JP +failing to timely file SARs of Epstein's suspicious +activities. +433. Further actions regarding JP +conspiracy to obstruct TVPA +enforcement are outlined in Count X (obstruction) below in paragraph 472-86, which +are hereby incorporated by reference as if set forth in full in this Count. +434. Within this District, JP | +intentionally committed overt acts in +furtherance of the conspiracy, agreement, and understanding to violate 18 U.S.C. $ +1591(a) by knowingly playing an active role in assisting, supporting, and facilitating +113 + + +Casse112220/1090191STR Doocumeet 7862 FfeekD03138223 Peggel 1750611 BB1 +the recruiting, enticing, coercing, harboring, transporting, and inducing and forcibly +causing Jane Doe 1 and other Class Members to engage in commercial sex acts, +through providing financial support for the Epstein sex-trafficking venture. A +number of those acts were committed by JP +officer, Jes Staley, acting +within the actual and apparent scope of his employment to further JP +interests. +435. Among the many overt acts intentionally committed by JP| +in +furtherance of the sex-trafficking venture were creating and maintaining a special +and unusual financial relationship between JP +and Epstein within this +District designed to facilitate Epstein's sex-trafficking. The relationship went far +beyond providing routine banking opportunities. +436. Acting within this District and in furtherance of the Epstein sextrafficking venture, on or about August 19, 2013, JP +opened various +brokerage accounts for Epstein-related companies. JP +knew, and should +have known, that opening these accounts would facilitate Epstein's coercive sex +trafficking. +437. In furtherance of the Epstein sex-trafficking venture, between about +200 and August 2013, JP| +opened numerous financial accounts for Epstein, +his related entities, and associates. The accounts were in and affecting interstate and +foreign commerce. These accounts were opened within this District. +114 + + +Casse112220/1090191STR Documeet 7862 FfleekD03138223 Pegel 1 560611 BB1 +438. In furtherance of the Epstein sex-trafficking venture, between about +2000 and August 2013 and following, JP +concealed its delivery of vast sums +of cash to Epstein and his associates. Among its affirmative acts of concealment, JP +willfully failed to timely file required SARs with the federal government. +439. JP +deliberately and purposely omitted to timely file appropriate +SARs about Epstein's cash transactions, wrongful omissions that were actions in +furtherance of its conspiracy. +440. JP +actions in furtherance of Epstein's conspiracy were +intertwined with Epstein's sex-trafficking venture, as the funding for the sextrafficking venture (and particularly cash for the venture) were essential tools for +Epstein to commit coercive commercial sex acts. +441. It was part of the conspiracy that JP | +would financially benefit +from providing financial support for the Epstein sex-trafficking venture. JP| +did financially benefit from its participation in the venture, including receiving +valuable deposits and business opportunities from Epstein. +442. JP +participation in furthering Epstein's sex-trafficking +venture was intentional and willful and, therefore, JP +intentionally and +willfully caused Epstein's commission of the forcible commercial sex acts with Jane +Doe 1 and other Class Members through its affirmative and overt acts supporting +Epstein. JP +knew, and was in reckless disregard of the fact, that means of +115 + + +Casse112220/1090191STR Documeet 7862 FfleekD03138223 Peggel 1 670611BB1 +force, threats of force, fraud, coercion, and a combination of such means would be +used by Epstein and his other co-conspirators to cause Jane Doe 1 and other Class +Members to engage in commercial sex acts. +443. JP +knew, acted in reckless disregard of the fact, and should +have known, that its conspiracy would directly and proximately lead to unlawful +coercive commercial sex acts by Epstein with young women and girls, including +Jane Doe 1 and other Class Members. +444. The conspiracy that JP +joined had specific knowledge that Jane +Doe 1, as well as other Members of the Class, were being coercively sex trafficked +by Epstein. The conspiracy's knowledge extended to the names of Epstein's victims, +because Epstein and his co-conspirators knew the names of the victims, including +Jane Doe 1's name. JP +, through its officer Jes Staley, also new many of the +names of the victims. +445. JP| +conspired to violate 18 U.S.C. § 1591(a) with Epstein and +through its affirmative acts and substantial support to Epstein committed, +perpetrated, and directly and proximately caused Jane Doe 1 and other Class +Members to engage in commercial sex acts through means of force, threats of force, +fraud, coercion, and a combination of such means. +446. In addition to acting with knowledge that they were conspiring to +support the Epstein sex-trafficking venture, JP +benefited financially from +116 + + +Casse1122201090191STR Documeet 7B62 FfleekD03138223 Peggel 178611 BB1 +conspiring to participate in the Epstein sex-trafficking venture, which JP | +knew and should have known that had engaged in coercive sex trafficking in +violation of 18 U.S.C. § 1591(a)(1) & (a)(2), as well as obstruction of the +enforcement of the TVPA in violation of 18 U.S.C. § 1591(d). +447. JP +conspiracy has caused Jane Doe 1 and other Class +Members serious harm, including, without limitation, physical, psychological, +financial, and reputational harm. That harm was directly and proximately caused by +the conspiracy and the harm resulting from conspiracy was foreseeable. +448. JP +conspiracy has caused Jane Doe 1 harm that is sufficiently +serious, under all the surrounding circumstances, to compel a reasonable person of +the same background and in the same circumstances to perform or to continue +performing commercial sexual activity in order to avoid incurring that harm. +449. This case does not involve mere fraud. Instead, JP +criminal +conduct in conspiring to violate the TVPA was outrageous and intentional, because +it was in deliberate furtherance of a widespread and dangerous criminal sex +trafficking organization. JP +conspiracy also evinced a high degree of +moral turpitude and demonstrated such wanton dishonesty as to imply a criminal +indifference to civil obligations. JP L +conspiracy was directed specifically +at Jane Doe 1 and other members of the Class, who were the victims of Epstein's +sex trafficking organization. +117 + + +Cassel12220/1090191STR Doocumeet 7862 FfeekD03138223 Peggel 1 890611 BB1 +450. By virtue of these violations of 18 U.S.C. § 1594(c) JP +is liable +to Jane Doe 1 and the other Members of the Class for the damages they sustained +and reasonable attorneys' fees under 18 U.S.C. § 1595. +451. By virtue of its intentional and outrageous conspiracy to violate 18 +U.S.C. §§ 1594(c), JP +is liable to Jane Doe 1 and other members of the Class +for punitive damages under 18 U.S.C. § 1595. +ATTEMPT TO COMMIT VIOLAOONS OF THE TRAFFICKING VICTIM +PROTECTION ACT, 18 U.S.C. §$ 1594(a), 1591, 1595 +452. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +453. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +454. JP +intentionally attempted to violate 18 U.S.C. § 1591(a)(1) +and (a)(2), and to further Epstein's sex-trafficking venture to coerce commercial sex +acts from Jane Doe 1 and other Class Members, all in violation of 18 U.S.C. § +1594(a). +455. JP +officers and employees, including Staley, deliberately took +substantial steps to attempt to violate 18 U.S.C. § 1591(a)(1) & (a)(2) within this +District. +456. JP +deliberately took substantial steps toward attempting to +118 + + +Cassel122260/1090191STR Doocumeet 7862 FfeekD03138223 Peggel 1200611 BB1 +violate 18 U.S.C. § 1591(a)(1) & (a)(2), by providing substantial financial support +for the Epstein sex-trafficking venture. The financial support included hundreds of +thousands of dollars in cash. +457. Among the many substantial steps taken by JP | +to deliberately +attempt to violate 18 U.S.C. § 1591(a)(1) & (a)(2) were creating a special and +unusual financial relationship between JP | +and Epstein within this District +that was designed to, and did, facilitate Epstein's sex-trafficking venture and the sex +trafficking of Jane Doe 1, as well as other Members of the Class. +458. In attempting to further the Epstein sex-trafficking venture, between +about 2000 and August 2013, JP| +opened numerous accounts for Epstein, his +related entities, and associates. The accounts were in and affecting interstate and +foreign commerce. JP +opened the accounts within this District for the +purpose of attempting to facilitate Epstein's sex-trafficking venture. +459. In opening numerous accounts for Epstein, his related entities, and +associates, JP +took a substantial step toward benefitting from participating +in Epstein's sex-trafficking venture. JP| +also took other substantial, concrete +steps toward benefitting from the venture. +460. It was part of the attempt to violate 18 U.S.C. 1591(a) that JP| +would financially benefit from participating in and providing financial support for +the Epstein sex-trafficking venture. JP | +did financially benefit from its +119 + + +Casse1122260/1090191STR Doocumeet 7862 FfeekD03138223 Peggel PD10611 BB1 +participation in the venture, including receiving valuable deposits from Epstein and +Epstein-related entities into JP +461. JP +attempt to violate the TVPA by furthering Epstein's sextrafficking venture was intentional and willful and, therefore, JP +intentionally and willfully caused Epstein's commission of sexual abuse and +commercial sex acts with Jane Doe 1 and other Class Members through its +affirmative and overt acts supporting Epstein. +462. JP +knew and acted in reckless disregard of the fact, that its acts +and conduct attempting to support and facilitate Epstein would lead to sexual abuse +and unlawful coercive commercial sex acts by Epstein with young women and girls, +including Jane Doe 1 and other Class Members. +463. In addition to acting intentionally and with knowledge that they were +supporting the Epstein sex-trafficking venture, JP| +benefited financially from +attempting to participate in the Epstein sex-trafficking venture which JP +should have known that had engaged in coercive sex trafficking in violation of 18 +U.S.C. § 1591(a)(1) & (a)(2). +464. This case does not involve mere fraud. Instead, JP +criminal +conduct in attempting to violate the TVPA was outrageous and intentional, because +it was a deliberate attempt to further the crimes of a widespread and dangerous +criminal sex trafficking organization. JP| +criminal attempts also evinced a +120 + + +Casse112220/1090191STR Doocumeet 7B62 FfeekD03138223 Peggel 2220611 BB1 +high degree of moral turpitude and demonstrated such wanton dishonesty as to imply +a criminal indifference to civil obligations. JP +criminal attempt was +directed specifically at Jane Doe 1 and other members of the Class, who were the +victims of Epstein's sex trafficking organization. +465. JP +conduct has caused Jane Doe 1 and other Class Members +serious harm, including, without limitation, physical, psychological, financial, and +reputational harm. This harm was a direct, proximate, and foreseeable result of JP +attempt in violation of 18 U.S.C. § 1594(a). +466. By virtue of these violations of 18 U.S.C. § 1594(a), JP +is liable +to Jane Doe 1 and the other Members of the Class for the damages they sustained +and reasonable attorneys' fees under 18 U.S.C. § 1595. +467. By virtue of its intentional and outrageous attempt to violate 18 U.S.C. +§ 1594(a), JP | +is liable to Jane Doe 1 and other members of the Class for +punitive damages under 18 U.S.C. § 1595. +COUNT X +OBSTRUCTION OF THE ENFORCEMENT OF THE TRAFFICKING +VICTIM PROTECTION ACT, 18 U.S.C. § 1591(d) +468. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +469. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +121 + + +Casse1122260/1090191STR Doocumeet 7B62 FfeekD03138223 Peggel P230611 BB1 +470. JP +and its officers and employees (including Staley) knowingly +and intentionally obstructed, attempted to obstruct, interfered with, and prevented +the enforcement of 18 U.S.C. §$ 1591(a)(1) & (a)(2), all in violation of 18 U.S.C. § +1591(d). This activity is hereinafter referred to collectively simply as "obstruction." +471. JP +obstruction of the enforcement of 18 U.S.C. §§ 1591(a)(1) +and (a)(2) was forbidden by 18 U.S.C. § 1591(d), and JP | +thereby violated +Chapter 77, Title 18. JP +obstruction described here and in the preceding +paragraph directly, proximately, and foreseeably harmed Jane Doe 1, as well as other +members of the Class, by directly resulting in them coercively being caused to +engage in commercial sex acts and in other ways. +472. As outlined above, the United States Department of Justice (including +the U.S. Attorney's Office for the Southern District of New York and the U.S. +Attorney's Office for the Southern District of Florida) was investigating Epstein's +federal criminal liability for violating (among other laws) the TVPA up to and +following the return of an indictment against Epstein on or about July 8, 2019. On +or about that date, the U.S. Attorney's Office for the Southern District of New York +indicted Epstein (and unnamed "associates") for violating the TVPA. Later, on about +June 29, 2020, the same Office indicted Epstein's co-conspirator, Ghislaine +Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. +The federal criminal investigation of Maxwell included investigation of possible +122 + + +Casse112220/1090191STR Documeet 7862 FfleekD03138223 Peggel 2240611 BB1 +violations of the TVPA. +473. By providing financing for Epstein's sex trafficking organization from +about 2000 through about August 2013, and concealing its actions thereafter, JP +obstructed, interfered with, and prevented the federal government's +enforcement of the TVPA against Epstein. To the extent that the federal government +was able to ultimately charge Epstein with TVPA violations, the filing of those +charges was delayed by JP +actions. Because of that delay, Jane Doe 1 as +well as other members of the Class, were coercively caused to engage in commercial +sex acts. +474. As one example of how JP +obstructed, attempted to obstruct, +interfered with, and prevented the federal government's enforcement of the TVPA, +provided large amounts of cash to Epstein and his associates so that the +coercive commercial sex acts would escape the detection of federal law enforcement +and prosecuting agencies. JP +provided large amounts of cash to further the +Epstein sex-trafficking venture and with the purpose of helping Epstein evade +criminal liability for violating the TVPA. +475. As another example of how JP +obstructed, attempted to +obstruct, interfered with, and prevented the federal government's enforcement of the +TVPA, JP +did not follow AML and anti-structuring reporting requirements +found in the Banking Secrecy Act and other laws. These requirements included an +123 + + +Cassel12220/1090191STR Documeet 7B62 FfleekD03138223 Peggel 2450611 BB1 +obligation that JP +would review transactions in the Epstein's JP +accounts for a determination of whether they involved suspicious transactions. If JP +had observed these requirement imposed by law, then it would have +prevented many of the subsequent transactions committed by the Epstein sextrafficking venture. +knowingly did not follow these requirements +because it knew that doing so would have prevented Epstein's secret cash +transactions that were necessary to his sex-trafficking operation escaping knowledge +of federal investigative and prosecuting agencies. Without JP +cash, Jane +Doe 1, as well as other members of the Class, would not have been coercively forced +to engage in commercial sex act. +476. As another example of how JP +obstructed, attempted to +obstruct, interfered with, and prevented the federal government's enforcement of the +TVPA, JP +failed to timely file with the federal government the required +SARs that financial institutions must file with FinCEN whenever there is a suspected +case of money laundering or fraud. Timely filing of these reports is required by the +Bank Secrecy Act and related laws and regulations. These reports are tools that the +federal government uses to detect and prosecute, among other illegal activities, sex +trafficking in violation of the TVPA. By failing to timely file the required SARs +regarding Epstein's cash transactions, JP +obstructed, attempted to obstruct, +interfered with, and prevented the federal government's enforcement of the TVPA +124 + + +Casse112220109019195R Document 7362 FilieD03138223 Flagel 29606118B1 +by concealing from the federal government's attention Epstein's cash transaction in +aid of sex trafficking. +477. JP +disclosing the existence of a SAR. JP +can disclose its failure to file appropriate SARs without +is not protected from liability for +failure to file a required SAR. +478. JP +failure to timely file SARs about Epstein's sex-trafficking +venture, in spite of numerous red flags, was wrongful and purposeful. +479. If JP +had filed timely required SARs about Epstein's sextrafficking venture with the federal government, the appropriate federal agencies +would have been well positioned to investigate Epstein's sex-trafficking venture's +TVPA violations. JP +failure to timely file the required SARs obstructed +the federal government's ability to investigate those TVPA violations, including +violations harming Jane Doe 1 and other Class Members. IfJP +had timely +filed the required SARs, it would have prevented the continuation of Epstein's sex +trafficking venture, which required the ability to secretly use cash to payoff victims. +480. By providing large amounts of cash to Epstein and his associates, JP +intended and knew that Epstein's coercive commercial sex acts would +escape the detection of federal law enforcement and prosecuting agencies for some +period of time. JP +provided large amounts of cash to further the Epstein +sex-trafficking venture and with the purpose of helping Epstein evade criminal +125 + + +Casse1122260/1090191STR Doocumeet 7B62 FfeekD03138223 Peggel PB70611 BB1 +liability for violating the TVPA. +481. JP +obstruction, attempted obstruction, interference with, and +prevention of the enforcement of the TVPA were all done intentionally and +knowingly. For example, JP +knew that Epstein was high risk-specifically, +high risk to violate the TVPA through continuing criminal sex trafficking activities. +482. JP +was well aware that Epstein had pleaded guilty and served +prison time for engaging in sex with a minor—a crime closely connected with sex +trafficking in violation of the TVPA. JP +_ was also well aware that there were +public allegations that his illegal conduct was facilitated by several named coconspirators. But JP +concealed from the federal government its numerous +cash payments to those co-conspirators. JP +continued its affirmative conduct +of providing cash to Epstein so that he could make those cash payments to his coconspirators with knowledge that such cash transaction did not produce a clear paper +trail. JP +intentional conduct obstructed, attempted to obstruct, in many +ways interfered with, and prevented the enforcement of the TVPA by federal +investigators and prosecuting agencies. +483. JP +relationship with Epstein in providing to his sextrafficking venture with vast sums of cash each year went far beyond a normal (and +lawful) banking relationship. JP| +knew, and intended, that its relationship +with Epstein would go far beyond a normal banking relationship. JP| +knew +126 + + +Casse112220/1090191STR Doocumeet 7862 FfleekD03138223 Peggel 2280611 BB1 +that its decision to beyond a normal banking relationship with Epstein obstructed the +ability of federal law enforcement and prosecuting agencies to enforce the TVPA. +484. JP +obstruction of the federal government's TVPA and other +law enforcement efforts was intentional and willful and, therefore, JP +intentionally and willfully caused Epstein's commission of the forcible commercial +sex acts with Jane Doe 1 and other Class Members through its obstruction supporting +the concealment of Epstein's sex-trafficking venture. JP +knew that Epstein +and his other co-conspirators would use means of force, threats of force fraud, +coercion, and a combination of such means to cause Jane Doe 1 and Class Members +to engage in commercial sex acts. +485. JP +knew, acted in reckless disregard of the fact, and should +have known, that its obstruction in violation of 18 U.S.C. § 1591(d) would directly +and proximately lead to unlawful coercive commercial sex acts by Epstein with +young women and girls, including Jane Doe 1 and other Class Members. +486. JP +obstruction has caused Jane Doe 1 and other Class +Members serious harm, including, without limitation, physical, psychological, +financial, and reputational harm. That harm was directly and proximately caused by +the obstruction and the harm resulting from obstruction was foreseeable. +487. JP +obstruction has caused Jane Doe 1 harm that is sufficiently +serious, under all the surrounding circumstances, to compel a reasonable person of +127 + + +Casse1122260/1090191STR Doocumeet 7B62 FfeekD03138223 Peggel P890611 BB1 +the same background and in the same circumstances to perform or to continue +performing commercial sexual activity in order to avoid incurring that harm. +488. This case does not involve mere fraud. Instead, JP +criminal +conduct in obstructing enforcement of the TVPA was outrageous and intentional, +because it was in deliberate furtherance of a widespread and dangerous criminal sex +trafficking organization. JP +obstruction also evinced a high degree of' +moral turpitude and demonstrated such wanton dishonesty as to imply a criminal +indifference to civil obligations. JP L +obstruction was directed specifically +at Jane Doe 1 and other members of the Class, who were the victims of Epstein's +sex trafficking organization. +489. By virtue of these violations of 18 U.S.C. § 1591(d), JP| +is liable +to Jane Doe 1 and the other Members of the Class for the damages they sustained +and reasonable attorneys' fees by operation of 18 U.S.C. § 1595. JP +perpetrated an obstruction of the TVPA, and therefore perpetrated a violation of +Chapter 77, Title 18. +490. By virtue of its intentional and outrageous obstruction to prevent +enforcement of the TVPA, in violation 18 U.S.C. § 1591(d), JP +is liable to +Jane Doe 1 and other members of the Class for punitive damages by operation of 18 +U.S.C. § 1595. +VIII. REQUEST FOR RELIEF +128 + + +Casse11222e0/1090191S5R Doouneet7B62 FfeekD03138223 Paggel 2900611 BB1 +Jane Doe 1 respectfully requests that the Court enter judgment in her +favor, and against JP +as follows: +a. That the Court certify the Class, name Jane Doe 1 as Class +Representative, and appoint her lawyers as Class Counsel; +b. That the Court award Plaintiff and the other members of the Class +compensatory, consequential, general, nominal, and punitive damages +against Defendant in an amount to be determined at trial; +c. That the Court award punitive and exemplary damages against Defendant +in an amount to be determined at trial; +d. That the Court award to Plaintiff the costs and disbursements of the action, +along with reasonable attorneys' fees, costs, and expenses; +e. That the Court award pre- and post-judgment interest at the maximum +legal rate; and +f. That the Court grant all such other and further relief as it deems just and +proper. +JURY DEMAND +Plaintiffs demand a trial by jury on all claims so triable. +Dated: January 13, 2023 +Respectfully Submitted, +POTTINGER, LLC +By: /s/| +129 + + +Cassel1222e0/1090191S5R Doocumeet7B62 FfeekD03138223 Pegge1 BB10611 BB1 +J. +425 N. Andrews Ave., Suite 2 +Fort Lauderdale, FL 33301 +(954)-524-2820 +Fax: (954)-524-2822 +Email: brad@epllc.com +POTTINGER +Brittany N. +1501 Broadway +Floor 12 +New York, NY +(954)-524-2820 +Fax: (954)-524-2820 +Email: brittany@epllc.com +David Boies +Boies Schiller Flexner LLP +55 Hudson Yards +New York, New York +Telephone: (212) 446-2300 +Facsimile: (212) 446-2350 +E-mail: dboies(@bsfllp.com +Sigrid McCawley +Pro Hac Vice +Boies Schiller Flexner LLP +401 E. Las Olas Blvd. Suite 1200 +Fort Lauderdale, FL 33316 +Telephone: (954) 356-0011 +Facsimile: (954) 356-0022 +Email: smccawley@bsfllp.com +130 \ No newline at end of file diff --git a/vision-fixhub/court-05/5987b06536d82ede1573dd9e8bff56f2b717cc2ca443692c9997219cdfec1d2c.receipt.json b/vision-fixhub/court-05/5987b06536d82ede1573dd9e8bff56f2b717cc2ca443692c9997219cdfec1d2c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d45f51caacee5fc3ad84ffe3f9efa92676091dea --- /dev/null +++ b/vision-fixhub/court-05/5987b06536d82ede1573dd9e8bff56f2b717cc2ca443692c9997219cdfec1d2c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1807, + "dataset": "marble-joined", + "doc_id": "5987b06536d82ede1573dd9e8bff56f2b717cc2ca443692c9997219cdfec1d2c", + "engine": "marble-apple-vision", + "event_count": 185, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "f7d90c105e96c52f3b815893ec416e2d9dad2a888dde9dd7e9670a47bd318343", + "output_sha256": "2b717b157b81a21e2cebc5ae4cd647ad9c7e87226e50cb12b5b2344e4cc97e31", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/598b8b18dc96940eecc886007b0cecd2cd5197e4992ac6232a11193c1265db68.md b/vision-fixhub/court-05/598b8b18dc96940eecc886007b0cecd2cd5197e4992ac6232a11193c1265db68.md new file mode 100644 index 0000000000000000000000000000000000000000..63aeb8eaf1cb261842029915c9e8f0785a43818c --- /dev/null +++ b/vision-fixhub/court-05/598b8b18dc96940eecc886007b0cecd2cd5197e4992ac6232a11193c1265db68.md @@ -0,0 +1,173 @@ +Case 1:22-cV-10904-JSR Document 239-17 Filed 07/25/23 Page 1 of 5 + + + +Case 1:22-cV-10904-JSR Document 239-17 . Filed 07/25/23 Page 2 of 5 +To: +Subject: +mary.erdoes@jpmorgan.com [mary.erdoes@jpmorgan.com] +9/20/2007 12:27:09 PM +jes.staley@jpmorgan.com +Re: Ny post +It's actually on page 14 in the "page six" column. Epstein. Rumored 15 months jail with 15 months home +confinement. Then a few details of one of the nights-yuck. +• Jes Staley +-- Original Message --- +From: Jes Staley +Sent: 09/20/2007 06:24 AM CDT +To: Mary Erdoes +Subject: Re: Ny post +What's on Six? +* Mary E Erdoes +rom: Mary E Erdoe +Sent: 09/20/2007 07:22 AM ED +To: Jes Staley +Subject: Ny post +"Page six" + + +WIT: Staley +DATE: +6/10/23 +C. +, RDR CAR CSR #13921 +JPM-SDNYLIT-00099500 + + +Case 1:22-cV-10904-JSR Document 239-17 Filed 07/25/23 Page 3 of 5 +To: +lisa.e.waters@jpmorgan.com [lisa.e.waters@jpmorgan.com] +9/20/2007 7:42:35 PM +mary.erdoes@jpmorgan.com +FYI. Sorry if this is a duplication. +September 20, 2007 -- THE sordid sex case involving Jeffrey Epstein may be coming to an +unhappy ending - with a plea deal that would put the publicity-shy billionaire behind bars for 15 +months for allegedly soliciting underage teen girls for sex at his Palm Beach mansion. +Sources tell Page Six that Epstein's high-powered lawyers - including Alan Dershowitz, +Gerald Lefcourt, Roy Black and Kenneth Starr - have been negotiating a deal with federal +prosecutors who are probing, among other things, whether the gray-haired money manager +paid West Palm Beach girls for sex or transported them across state lines. Epstein is currently +charged by the State of Florida with soliciting young prostitutes for sex - but federal charges +would be far more serious. +The Palm Beach Post reported yesterday that Epstein is very close to a deal with the feds that +would send him to jail for 1½ to 2 years. Sources tell us that while a deal has not yet solidified, +what's under discussion is a guilty plea to at least one charge in exchange for a sentence of 15 +months in a Florida state prison, followed by 15 months of home confinement. That would be a +fraction of the time he would have to serve if he were to be convicted by a jury. +Epstein's spokesman, Howard Rubenstein, said his client would have no comment. +Dershowitz also declined to comment late yesterday. +Palm Beach police records show that on March 15, 2005, a 14-year-old girl alleged she had +visited Epstein's estate, where she partially stripped and gave him a massage during which he +"pulled out a purple vibrator" and used it on her in exchange for $300. A further probe +uncovered five young women who said Epstein had masturbated and touched their genitals +during massages, the records state. A woman named +- who described herself +as "like a Heidi Fleiss" - later admitted bringing six girls between the ages of 14 and 16 to +Epstein's house, according to cops. +Despite the allegations, Epstein was only nailed on a single charge of soliciting a +- but +it sparked a federal probe. Epstein's lawyers and friends have insisted he was the hapless +victim of a vendetta by Palm Beach Police Chief Michael Reiter, whom they described as a +"born-again nutcase." +Lisa E. Waters +Managing Director +IRS Circular 230 Disclosure: +JPMorgan Chase & Co. and its affiliates do not provide tax advice. Accordingly, any discussion of U.S. tax +atters contained herein (including any attachments) is not intended or written to be used, and cannot be use +i connection with the promotion, marketing or recommendation by anyone unaffiliated with JPMorgan Cha +& Co. +of any of the matters addressed herein or for the purpose of avoiding U.S. tax-related penalties. + +JPM-SDNYLIT-00099501 + + +Case 1:22-cV-10904-JSR Document 239-17 Filed 07/25/23 Page 4 of 5 +To: +lisa.e.waters@jpmorgan.com [lisa.e.waters@jpmorgan.com] +9/20/2007 6:08:12 PM +September 20, 2007 -- THE sordid sex case involving Jeffrey Epstein may be coming to an +unhappy ending - with a plea deal that would put the publicity-shy billionaire behind bars for 15 +months for allegedly soliciting underage teen girls for sex at his Palm Beach mansion. +Sources tell Page Six that Epstein's high-powered lawyers - including Alan Dershowitz, +Gerald Lefcourt, Roy Black and Kenneth Starr - have been negotiating a deal with federal +prosecutors who are probing, among other things, whether the gray-haired money manager +paid West Palm Beach girls for sex or transported them across state lines. Epstein is currently +charged by the State of Florida with soliciting young prostitutes for sex - but federal charges +would be far more serious. +The Palm Beach Post reported yesterday that Epstein is very close to a deal with the feds that +would send him to jail for 1½ to 2 years. Sources tell us that while a deal has not yet solidified, +what's under discussion is a guilty plea to at least one charge in exchange for a sentence of 15 +months in a Florida state prison, followed by 15 months of home confinement. That would be a +fraction of the time he would have to serve if he were to be convicted by a jury. +Epstein's spokesman, Howard Rubenstein, said his client would have no comment. +Dershowitz also declined to comment late yesterday. +Palm Beach police records show that on March 15, 2005, a 14-year-old girl alleged she had +visited Epstein's estate, where she partially stripped and gave him a massage during which he +"pulled out a purple vibrator" and used it on her in exchange for $300. A further probe +uncovered five young women who said Epstein had masturbated and touched their genitals +during massages, the records state. A woman named +- who described herself +as "like a Heidi Fleiss" - later admitted bringing six girls between the ages of 14 and 16 to +Epstein's house, according to cops. +Despite the allegations, Epstein was only nailed on a single charge of soliciting a +- but +• it sparked a federal probe. Epstein's lawyers and friends have insisted he was the hapless +victim of a vendetta by Palm Beach Police Chief Michael Reiter, whom they described as a +"born-again nutcase." +Lisa E. Waters +Managing Director +IRS Circular 230 Disclosure: +JPMorgan Chase & Co. and its affiliates do not provide tax advice. Accordingly, any discussion of U.S. tax +matters contained herein (including any attachments) is not intended or written to be used, and cannot be used, +in connection with the promotion, marketing or recommendation by anyone unaffiliated with JPMorgan Chase +& Co. +of any of the matters addressed herein or for the purpose of avoiding U.S. tax-related penalties. + +JPM-SDNYLIT-00390951 + + +Case 1:22-cV-10904-JSR Document 239-17 Filed 07/25/23 Page 5 of 5 +To: +Subject: +lisa.e.waters@jpmorgan.com [lisa.e.waters@jpmorgan.com] +9/20/2007 6:16:31 PM +phil.diiorio@jpmorgan.com +NY post page 6 +September 20, 2007 -- THE sordid sex case involving Jeffrey Epstein may be coming to an +unhappy ending - with a plea deal that would put the publicity-shy billionaire behind bars for 15 +months for allegedly soliciting underage teen girls for sex at his Palm Beach mansion. +Sources tell Page Six that Epstein's high-powered lawyers - including Alan Dershowitz, +Gerald Lefcourt, Roy Black and Kenneth Starr - have been negotiating a deal with federal +prosecutors who are probing, among other things, whether the gray-haired money manager +paid West Palm Beach girls for sex or transported them across state lines. Epstein is currently +charged by the State of Florida with soliciting young prostitutes for sex - but federal charges +would be far more serious. +The Palm Beach Post reported yesterday that Epstein is very close to a deal with the feds that +would send him to jail for 1½ to 2 years. Sources tell us that while a deal has not yet solidified, +what's under discussion is a guilty plea to at least one charge in exchange for a sentence of 15 +months in a Florida state prison, followed by 15 months of home confinement. That would be a +fraction of the time he would have to serve if he were to be convicted by a jury. +Epstein's spokesman, Howard Rubenstein, said his client would have no comment. +Dershowitz also declined to comment late yesterday. +Palm Beach police records show that on March 15, 2005, a 14-year-old girl alleged she had +visited Epstein's estate, where she partially stripped and gave him a massage during which he +"pulled out a purple vibrator" and used it on her in exchange for $300. A further probe +during massages, the records state. A woman named l +- who described herself +as "like a Heidi Fleiss" - later admitted bringing six girls between the ages of 14 and 16 to +Epstein's house, according to cops. +Despite the allegations, Epstein was only nailed on a single charge of soliciting a +- but +it sparked a federal probe. Epstein's lawyers and friends have insisted he was the hapless +victim of a vendetta by Palm Beach Police Chief Michael Reiter, whom they described as a +"born-again nutcase." +Lisa E. Waters +Managing Director +IRS Circular 230 Disclosure: +JPMorgan Chase & Co. and its affiliates do not provide tax advice. Accordingly, any discussion of U.S. tax +matters contained herein (including any attachments) is not intended or written to be used, and cannot be used +in connection with the promotion, marketing or recommendation by anyone unaffiliated with JPMorgan Chas +d Co. +of any of the matters addressed herein or for the purpose of avoiding U.S. tax-related penalties. + +JPM-SDNYLIT-00390952 \ No newline at end of file diff --git a/vision-fixhub/court-05/598b8b18dc96940eecc886007b0cecd2cd5197e4992ac6232a11193c1265db68.receipt.json b/vision-fixhub/court-05/598b8b18dc96940eecc886007b0cecd2cd5197e4992ac6232a11193c1265db68.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5f72312a6a49250714fc58132d13f8c6e880b2d6 --- /dev/null +++ b/vision-fixhub/court-05/598b8b18dc96940eecc886007b0cecd2cd5197e4992ac6232a11193c1265db68.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -177, + "dataset": "marble-joined", + "doc_id": 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b/vision-fixhub/court-05/59e9551eddb611611306058c818400d6aabcd742f78cdfdb5e4cc7c5e8234868.md new file mode 100644 index 0000000000000000000000000000000000000000..2ee274e71db3556d275bbc2a0e4f6c2a74549c91 --- /dev/null +++ b/vision-fixhub/court-05/59e9551eddb611611306058c818400d6aabcd742f78cdfdb5e4cc7c5e8234868.md @@ -0,0 +1,662 @@ +Case 1:22-eV-1090#-JSR Documen 303FfeØA½2233p&go9 bof° +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +[PROPOSED| ORDER FOR MOTION FOR ISSUANCE OF +LETTER OF REQUEST (LETTER ROGATORY) +Upon consideration of the Motion for Issuance of Letter of Request (Letter Rogatory) dated +January 20, 2023, the exhibits annexed thereto, and any oppositions or replies filed with respect to +the motion, and it appearing that the testimony of and documents in the possession of Cathy +Alexander, a resident of South Africa, is material and necessary to the issues of this action, the +Court hereby GRANTS the Motion and ORDERS as follows: +1. The Court will sign and shall issue the Letter of Request (Letter Rogatory) attached as +Exhibit 1 to the Motion to facilitate the taking of the deposition upon oral examination +of Cathy Alexander as a witness in this action, as well as the production of documents +described in the Plaintiff's Motion and exhibits annexed thereto; +2. The Clerk of Court is hereby directed to take all necessary steps to ensure the Letter of +Request (Letter Rogatory) is transmitted to Plaintiff in a form sufficient to obtain the +described testimony and documents; and +1 + + +Case 1:22-Ov-10904-JSR Document 30-3Fifete 0I/2R033PAge 2 Bfot° +3. The appropriate judicial authority in South Africa is hereby authorized to take and +report the deposition of Cathy Alexander and shall have the power by virtue of the +Letter of Request (Letter Rogatory) to administer any necessary oath and to take and +report testimony. +SO ORDERED. +Dated: (/23/23 +New York, New York +Rakoff +Senior Judge +The United States District Court +for the Southern District of New +York +2 + + +Cane11222010804185R Dostument308 FiledOR202288 Fagge 31 off 139 +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +MOTION FOR ISSUANCE OF LETTER OF REQUEST (LETTER ROGATORY) +NOW COMES, the Plaintiff, in the above referenced action, and moves for the Issuance of +a Letter of Request (Letter Rogatory) pursuant to F.R.C.P. 28 requesting an order requiring Miles +Alexander, located at 7 Harmonie Crescent, Paradise Beach, Jeffreys Bay 6330, South Africa, to +do the following: +(a) Appear to have his remote deposition taken on a date to be agreed within 30 days of service +of the subpoena at a mutually convenient location in or near Jeffreys Bay; and +(b) Produce all Documents, Communications, and agreements related to his employment by +Jeffrey Epstein, including: +1. Employment and +agreements, +2. Non-disclosure agreements, +3. All payments, in any form, received from or on behalf of Jeffrey Epstein, and +4. Alace. Mary inter, Lesty Fostein, Chislaine Maxwell, Bella Klein, Daphna +Wallace, Harry Beller, Lesley Groff, +Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. +1 + + +Casse11222109004J55R Dootumemt308 Fileet0Y220233 Fagge4cof139 +As grounds for this Motion, the Plaintiff states the following: +1. The above captioned case is currently pending in the United States District Court for +the Southern District of New York. +2. Plaintiff alleges decedent Jeffrey E. Epstein ("Epstein") engaged in a criminal sexual +trafficking enterprise in the United States Virgin Islands, wherein he used his vast +wealth and property holdings and a deliberately opaque web of corporations and +companies to transport young women and girls to his privately owned islands where +they were held captive and subject to severe and extensive sexual abuse. Plaintiff +further alleges that Defendant JPMorgan Chase Bank, N.A. and its affiliates had actual +or constructive knowledge of Epstein's misconduct but nevertheless violated their +statutory duties to report suspicious transactions from accounts held by them. +3. Upon information and belief, Miles Alexander was employed by decedent Epstein as +the house manager for his residence on Little St. James from approximately 1999 to +2007, and, as such, would have first-hand knowledge of Epstein's conduct and visitors +at Little St. James. +4. In order to prepare the case for trial, Plaintiff needs to the take the deposition of Miles +Alexander. +WHEREFORE Plaintiff respectfully requests that this Honorable Court allow this Motion +and issue a Letter of Request (Letter Rogatory). A proposed Letter of Request (Letter Rogatory) +is attached to this Motion as Exhibit 1. +Dated: January 20, 2023 +CAROL +, ESQ. +ACTING ATTORNEY GENERAL +Is/Linda +LINDA +2 +(NYS Bar #2473403) + + +Cae11222w109904J5R Dostumentt308 FilletOW220228 PeageBof39 +Admitted Pro Hac Vice +Motley Rice LLC +401 9' Street NW, Suite 63( +Washington, DC 20004 +Tel: (202) 232-5504 +Isinger@motleyrice.com +CAROL +(NYS Bar #2941300) +Admitted Pro Hac Vice +Acting Attorney General of the United States +Virgin Islands +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +St. 1 +• U.S. Virgin Islands 00802 +Tel.: (340) 774-5666 ext. 10101 +DAVID I. ACKERMAN (NYS Bar #4110839) +Motley Rice LLC +401 9* Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 849-4962 +dackerman@motleyrice.com +' Street NW, Suite 630 +Ta: 33D-C20004 +pboggs@motleyrice.com +CERTIFICATE OF SERVICE +I hereby certify that on January 20, 2023, the foregoing Plaintiff's Motion for Issuance of +Letter of Request (Letter Rogatory) was filed with the Clerk's Office using the CM/ECF system. +Notice of this filing will be sent to all parties of record by operation of, and parties may access this +filing through, the Court's CM/ECF system. +Is/Linda +Linda +3 + + +Case 1:2204-10904-JSR Document 281 FieldO D2P233 PA996 boIS + + + +Case 1:220410904JSR Document 201 FiedODDRM33 PEgge BbIS +TO: +LETTER ROGATORY +Clerk of Humansdorp Magistrate Court +Humansdorp Magistrate Court +Du Plessis St. +Humansdorp 6300 South Africa +RE: +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +In the United States District Court for the Southern District of New York +Civil Action No. 1:22-cv-10904-JSR +Dear Sir/Madam: +The above-captioned civil action is pending before the undersigned Judge of the United +States District Court for the Southern District of New York. Plaintiff in the action seeks to obtain +the deposition of Miles Alexander and production of documents in his possession +Thank you for your courtesy in this matter. +BY THE COURT +JED S. RAKOFF, U.S.D. +Set bat +Dated: +1/23/23 + + +Case 1:22-cv-10904-JSR Document 281 Fifele 0D22023PAgg8 3ft$ +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +ACTION FOR DAMAGES +JURY TRIAL DEMANDED +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +) +REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE +(LETTERS ROGATORY) +The United States District Court for the Southern District of New York presents its +compliments to the Humansdorp Magistrate Court of South Africa, and requests international +judicial assistance to obtain evidence to be used in a civil proceeding before this Court in the above +captioned matter. +This Court requests the assistance described herein as necessary in the interests of justice. +The assistance requested is that the appropriate judicial authority of South Africa compel the +appearance of the below named individual to give evidence and produce documents. +The aforesaid mentioned individual: +Miles Alexander +Residing at: +7 Harmonie Crescent, Paradise Beach, Jeffreys Bay 6330, South Africa +This Court requests Miles Alexander produce all Documents, Communications, and +agreements related to his employment by Jeffrey Epstein, including: employment and +1 + + +Case 1:22-04-109041SR Document 201 Fife 0 DRO33 PEgge 401S +agreements; non-disclosure agreements; all payments, in any form, received from or on behalf of +Jeffrey E. Epstein; and all Communications with Jeffrey E. Epstein, Ghislaine Maxwell, Bella +Klein, Daphne Wallace, Harry Beller, Lesley Groff, +Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. +a/k/a +FACTS +The above-captioned case is currently pending in the United States District Court for the +Southern District of New York. +2. +Plaintiff alleges decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking +enterprise in the Virgin Islands, wherein he used his vast wealth and property holdings and a +deliberately opaque web of corporations and companies to transport young women and girls to his +privately-owned islands where they were held captive and subject to severe and extensive sexual +abuse. Plaintiff further alleges that Defendant JPMorgan Chase Bank, N.A. and its affiliates had +actual or constructive knowledge of Epstein's misconduct but nevertheless violated their statutory +duties to report suspicious transactions from accounts held by them. +3. +Upon information and belief, Miles Alexander was employed by decedent Jeffrey E. +Epstein as the house manager for his residence on Little St. James from approximately 1999 to +2007, and, as such, would have first-hand knowledge of Epstein's conduct and visitors at Little St. +James. +4. +In order to prepare the case for trial, Plaintiff needs to the take the deposition of Miles +Alexander. +Plaintiff has previously attempted to obtain Miles Alexander's deposition and run into +obstacles attempting to depose him. +2 + + +Case 1:22 @v-10904 JSR Document 38-1ilEde@102420823P agag05o61.9 +A Subpoena to Testify at a Deposition in a Civil Action is attached hereto, requesting Miles +Alexander appear to have his deposition taken, at a location to be determined, and produce +documents thirty days after the date he is served with the Subpoena and Letter Rogatory. +The United States District Court for the Southern District of New York is willing to provide +similar assistance to judicial authorities of South Africa. The United States District Court for the +Southern District of New York is willing to reimburse the judicial authorities for costs incurred in +executing this Letters Rogatory. +Thank you for your courtesy in this matter. +BY THE COURT +Dated: January_ 23, 2023 +United States District Court +For the Southern District of New York +United States Courthouse +500 Pearl Street +New York, NY 10007 +(212) 805-0401 Telephone +3 + + +Case 1:22 cv 10904JSR Document 38-2ilEde0102422823P agagle1 10b119 +AO 88A (Rev. 12/20) Subpoena to Testify at a Deposition in a Civil Action +UNITED STATES DISTRICT COURT +for the +Southern District of New York +Government of the United States Virgin Islands +Plaintiff +V. +Civil Action No. 1:22-cv-10904-JSR +JPMorgan Chase Bank, N.A. +Defendant +SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION +Miles Alexander +To: +(Name of person to whom this subpoena is directed) +• Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a +deposition to be taken in this civil action. If you are an organization, you must promptly confer in good faith with the +party serving this subpoena about the following matters, or those set forth in an attachment, and you must designate one +or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about +these matters: +Place: A mutually convenient location in or near +Jeffreys Bay, South Africa (remotely) +Date and Time: +Within 30 days after service of Subpoena +The deposition will be recorded by this method: +videographically and stenographically +• Production: You, or your representatives, must also bring with you to the deposition the following documents, +electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the +material: See attached Exhibit A. +The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance; +Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to +respond to this subpoena and the potential consequences of not doing so. +Date: +01/20/2023 +CLERK OF COURT +OR +Signature of Clerk or Deputy Clerk +Is/Linda +Attorney's signature +The name, address, e-mail address, and telephone number of the attorney representing (name of party) +Plaintiff, +Government of the United States Virgin Islands +Linda +1 ofte Rice SC, 45 gig Street N, Suite 630, Washington, DC 20504, (202) Sets this subpoena, are: +Isinger@motleyrice.com +Notice to the person who issues or requests this subpoena +If this subpoena commands the production of documents, electronically stored information, or tangible things before +trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to +whom it is directed. Fed. R. Civ. P. 45(a)(4). + + +Case 1:22010904JSR Document 30-2FilFIl@102420323P 498g62206f19 +AO 88A (Rev. 12/20) Subpoena to Testify at a Deposition in a Civil Action (Page 2) +Civil Action No. 1:22-cv-10904-JSR +PROOF OF SERVICE +(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) +I received this subpoena for (name of individual and tille, if'any) +on (date) +• I served the subpoena by delivering a copy to the named individual as follows: +On (date) +; or +• I returned the subpoena unexecuted because: +Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also +tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of +$ +My fees are $ +for travel and $ +for services, for a total of S +0.00 +I declare under penalty of perjury that this information is true. +Date: +Server's signature +Printed name and title +Server's address +Additional information regarding attempted service, etc.: + + +Case 1122010904JSR Document 38-2Fi|BH@04420823P agag3306f19 +AO 88A (Rev. 12/20) Subpoena to Testify at a Deposition in a Civil Action (Page 3) +Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13) +(e) Place of Compliance. +(1) For a Trial, Hearing, or Deposition. A subpoena may command a +person to attend a trial, hearing, or deposition only as follows: +(A) within 100 miles of where the person resides, is employed, or +regularly transacts business in person; or +(B) within the state where the person resides, is employed, or regularly +transacts business in person, if the person +(i) is a party or a party's officer; or +(ii) is commanded to attend a trial and would not incur substantial +expense. +(i) disclosing a trade secret or other confidential research, development, +(i) disclosing an unretained expert's opinion or information that does +not describe specific occurrences in dispute and results from the expert's +study that was not requested by a party +(C) Specifying Conditions as an Alternative. In the circumstances +described in Rule 45(d)(3)(B), the court may, instead of quashing or +modifying a subpoena, order appearance or production under specified +conditions if the serving party: +(i shows a substantial need for the testimony or material that cannot be +otherwise met without undue hardship; and +(i) ensures that the subpoenaed person will be reasonably compensated. +(2) For Other Discovery. A subpoena may command: +(A) production of documents, electronically stored information, or +tangible things at a place within 100 miles of where the person resides, is +employed, or regularly transacts business in person; and +(B) inspection of premises at the premises to be inspected. +(d) Protecting a Person Subject to a Subpoena; Enforcement. +(1) Avoiding Undue Burden or Expense; Sanctions. A party or attomey +responsible for issuing and serving a subpoena must take reasonable steps +to avoid imposing undue burden or expense on a person subject to the +subpoena. The court for the district where compliance is required must +enforce this duty and impose an appropriate sanction —which may include +lost earnings and reasonable attorney's fees—-on a party or attorney who +fails to comply. +(2) Command to Produce Materials or Permit Inspection. +(A) Appearance Not Reguired. A person commanded to produce +documents, electronically stored information, or tangible things, or to +permit the inspection of premises, need not appear in person at the place of +production or inspection unless also commanded to appear for a deposition, +(B) Objections. A person commanded to produce documents or tangible +things or to permit inspection may serve on the party or attorney designated +in the subpoena a written objection to inspecting, copying, testing, or +sampling any or all of the materials or to inspecting the premises—or to +producing electronically stored information in the form or forms requested. +The objection must be served before the earlier of the time specified for +compliance or 14 days after the subpoena is served. If an objection is made, +the following rules apply: +order compelling production or inspection. +(il) These acts may be required only as directed in the order, and the +order must protect a person who is neither a party nor a party's officer from +significant expense resulting from compliance. +(3) Quashing or Modifying a Subpoena. +(A) When Required. On timely motion, the court for the district where +compliance is required must quash or modify a subpoena that: +(f) fails to allow a reasonable time to comply; +(il) requires a person to comply beyond the geographical limits +specified in Rule 45(c); +(lil) requires disclosure of privileged or other protected matter, if no +exception or waiver applies; or +(iv) subjects a person to undue burden. +(B) When Permitted. To protect a person subject to or affected by a +subpoena, the court for the district where compliance is required may, on +motion, quash or modify the subpoena if it requires: +(e) Duties in Responding to a Subpoena. +(1) Producing Documents or Electronically Stored Information. These +procedures apply to producing documents or electronically stored +(A) Documents. A person responding to a subpoena to produce documents +must produce them as they are kept in the ordinary course of business or +must organize and label them to correspond to the categories in the demand. +(B) Form for Producing Electronically Stored Information Not Specified. +If a subpoena does not specify a form for producing electronically stored +information, the person responding must produce it in a form or forms in +which it is ordinarily maintained or in a reasonably usable form or forms. +(C) Electronically Stored Information Produced in Only One Form. The +person responding need not produce the same clectronically stored +information in more than one form. +(D) Inaccessible Electronically Stored Information. The person +responding need not provide discovery of electronically stored information +from sources that the person identifies as not reasonably accessible because +of undue burden or cost. On motion to compel discovery or for a protective +order, the person responding must show that the information is not +reasonably accessible because of undue burden or cost. If that showing is +made, the court may nonetheless order discovery from such sources if the +requesting party shows good cause, considering the limitations of Rule +26(b)(2)(C). The court may specify conditions for the discovery. +(2) Claiming Privilege or Protection. +(A) Information Withheld. A person withholding subpoenaed information +under a claim that it is privileged or subject to protection as trial-preparation +material must: +(i) expressly make the claim; and +(ii) describe the nature of the withheld documents, communications, or +tangible things in a manner that, without revealing information itself +privileged or protected, will enable the parties to assess the claim. +(B) Information Produced, If information produced in response to a +subpoena is subject to a claim of privilege or of protection as +trial-preparation material, the person making the claim may notty any party +that received the information of the claim and the basis for it After being +notified, a party must promptly return, sequester, or destroy the specified +information and any copies it has; must not use or disclose the information +until the claim is resolved; must take reasonable steps to retrieve the +information if the party disclosed it before being notified; and may promptly +present the information under seal to the court for the district where +compliance is required for a determination of the claim. The person who +produced the information must preserve the information until the claim is +resolved. +(g) Contempt. +The court for the district where compliance is required—and also, after a +motion is transferred, the issuing court—may hold in contempt a person +who, having been served, fails without adequate excuse to obey the +subpoena or an order related to it. +For access to subpoena materials, sce Fod. R. Civ. P. 45(a) Committee Note (2013). + + +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +THIS EXHIBIT MAY INCLUDE THE NAMES OF INDIVIDUALS WHO +ARE VICTIMS OF HUMAN TRAFFICKING OR SEXUAL ABUSE, AND +THEREFORE SHOULD BE TREATED AS CONFIDENTIAL +AND NOT PUBLICLY DISCLOSED. + +I. +Definitions +Unless otherwise specified, the documents specified below are required to be produced for the +time period commencing January 1, 1998 and continuing through the present. Where +production of account data is provided in electronic format or media the preferred software +format to incorporate the data into is Microsoft Excel. +As used herein, the following terms are defined as indicated: +1. "All/Each." The term "all" and "each" shall be construed as all and each. +2. "And/Or." The connectives "and" and "or" shall be construed either disjunctively or +conjunctively as necessary to bring within the scope of the discovery request all +responses that might otherwise be construed to be outside of its scope. +3. "Communication" means the transmittal of information (in the form of facts, ideas, +inquiries or otherwise). +4. The terms "Document" or "Documents" are defined to be synonymous and equal in +scope to the usage of these terms in Federal Rule of Civil Procedure 34(a), including, +without limitation, any written, drawn, printed, typed, photographed or other graphic or +electronically or computerized recorded data or compilations of any kind or nature +prepared or received by, or in the possession, custody or control of the answering party, +its agents, servants, employees or other representatives. Originals, drafts and all nonidentical copies are separate documents within the meaning of this term. +5. "Referring to", "relating to", "reflecting", "regarding" or "with respect to" mean, without +limitation the concepts: pertain to, deal with, concern, reflect, record, report, constitute, +contain, mention, describe, discuss, analyze, evaluate, estimate, study, survey, project, + + +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +assess, support, modify, contradict, criticize, summarize, comment, or otherwise involve, +in whole or in part. +6. "You" and "Your" shall mean Miles Alexander. These terms also shall be deemed to +include all agents and other persons acting or authorized to act on her behalf. +II. +Instructions +1. When providing Your responses, indicate the Request to which each Document or answer +responds in the metadata field, RequestNo. +2. Documents produced pursuant to these Requests shall be produced as they are kept in the +ordinary course of business. +3. For each Document that You produce, produce the current version together with all earlier +editions or predecessor Documents during the relevant time period, even though the title +of earlier Documents may differ from current versions. Format for Documents produced +electronically: +a. +b. +c. +d. +Data shall be produced in single page TIFFs at a 300 DPI resolution which +are named for the +Number of the page. There shall be no more than +1000 images per folder. +numbers, confidentiality designations, and +redactions shall be burned into the TIFF image file so as not to unreasonably +obstruct any information on the page. +Document Unitization. Each page of a Document shall be electronically +converted into an image as described above. If a Document is more than +one page, the unitization of the Document and any attachments and/or +affixed notes shall be maintained as it existed in the original when creating +the image file and appropriately designated in the load files. The +corresponding parent/attachment relationships, to the extent possible, shall +be provided in the load files furnished with each production. +Include Document level text files containing optical character recognition +("OCR") or extracted text named with the +Number of the first page +of the Document. +Include data load files containing all of the metadata +(both system and +2 + + +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +e. +f. +g. +h. +i. +j. +K. +application - see list below) from the original Native Documents with +extension.dat for Concordance. +Include the database field name in the first line of the metadata file, in such +a manner that it is clear how the metadata is organized in the file. +Include an image loadfile for Concordance - such as .opt. +All hidden text (e.g., track changes, hidden columns, comments, notes, etc.) +shall be expanded, extracted, and rendered in the. TIFF file. +Documents created in Excel (spreadsheets), CSV files, Access (databases), +and audio and video media files shall be produced in Native format. The +extractable metadata and text shall be produced in the same manner as other +Documents that originated in electronic form (as described herein) to the +extent that metadata exists or is reasonably accessible. +Email attachments and embedded files or links shall be mapped to their +parent. +Produce all attachments to responsive Documents attached to the responsive +Documents. +De-duplicate prior to production. To the extent that exact duplicate +Documents (based on MD5 or SHA-1 hash values at the Document level) +reside within a party's data set, each party is only required to produce a +single copy of a responsive Document, so long as there is a data field that +identifies each custodian who had a copy. In addition, Documents may be +de-duplicated in such a way as to eliminate earlier or incomplete chains of +emails, and produce only the most complete iteration of an email chain so +long as there is a data field that identifies each custodian who had a copy. +REQUIRED METADATA +BEGDOC +BEGATTACH +ATTCOUNT +CUSTODIAN +FROM +ENDDOC +ENDATTACH +ATTACH +AUTHOR +TO +3 + + +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +CC +FILESIZE +DATERECD +DATESENT +CRTDATE +LASTMODDATE +LASTACCDATE +TITLE +EMAILSUBJECT +FILEEXT +ORGANIZATION +RECORD_TYPE +VOLUME +PRINTEDDATE +ATTLST +PSTINSIDEPATH +REQATTANDEES +REPLYTIME +BCC +PGCOUNT +TIMERECD +TIMESENT +CRTTIME +LASTMODTIME +LASTACCTIME +SUBJECT +FILENAME +MDSHASH +FULLPATH +VERSION +COMMENT +ENTRYID +ITEMTYPE +ITEMCREATIONTIME +APPOINTMENTDURATIONTIME +REMINDERTIME +APPOINTMENTSTARTDATE +APPOINTMENTCONTACT +CATEGORY +KEYWORDS +MANAGER +LASTAUTHOR +ENCRYPTED +FAMILYDATE +4 + + +Case 1:22 EV 10904-JSR Document 30-2File0102422323P agg k8906 fL9 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A +Civil Action No. 1:22-cv-10904-JSR +NATIVELINK +TEXTPATH +REQUESTNO +4. Format for hard copies of Documents produced in response to this Request: +a. +Re-type the question or request to which the Documents respond and firmly +attach the Documents to the re-typed request; +b. +Number all Documents consecutively, consistently with the numbers used +for the Documents produced electronically. +5. Unless otherwise indicated, the relevant time period for this Request for Production of +Documents is January 1, 1998 to the present. +6. If no Documents responsive to a particular request exist, so state. +7. As to any Document which no longer exists but which You are aware existed at one time, +identify such Document with as much particularity as possible, and in addition, identify +the last known location of the Document, the reason the Document is no longer in +existence, and the person responsible for the Document's disposition. +8. For information that You withhold on the basis of privilege, provide a descriptive list of +each Document stating the grounds for Your refusal and providing the following +information: the name or title of the Document; a description of the nature and subject +matter of the Document sufficient to enable a meaningful challenge to the assertion of +privilege; the date, author(s), sender(s), and recipient(s) of the Document; and the nature +of the privilege. +9. These requests shall be deemed continuing in character so as to require prompt +supplemental responses if additional Documents called for herein are obtained, discovered, +or become known to You between the time of responding to the Requests and the final +disposition of this action. +5 + + +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +10. Social Security numbers may be redacted from documents to the extent required by +applicable law. +Requests for the Production of Documents +1. All Documents, Communications, and agreements related to Your employment by Jeffrey +Epstein, including but not limited to: +a. +Employment and +agreements, +b. Non-disclosure agreements, +C. +All payments, in any form, received from or on behalf of Jeffiey Epstein, +d. +All Communications with Jeffrey Epstein, Ghislaine Maxwell, Bella Klein, Daphne +Wallace, Harry Beller, Lesley Groff, | +a/k/a +Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. +6 \ No newline at end of file diff --git a/vision-fixhub/court-05/59e9551eddb611611306058c818400d6aabcd742f78cdfdb5e4cc7c5e8234868.receipt.json b/vision-fixhub/court-05/59e9551eddb611611306058c818400d6aabcd742f78cdfdb5e4cc7c5e8234868.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d99b039db7f0abf78633c51fb3b160e80899e954 --- /dev/null +++ b/vision-fixhub/court-05/59e9551eddb611611306058c818400d6aabcd742f78cdfdb5e4cc7c5e8234868.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -774, + "dataset": "marble-joined", + "doc_id": "59e9551eddb611611306058c818400d6aabcd742f78cdfdb5e4cc7c5e8234868", + "engine": "marble-apple-vision", + "event_count": 23, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "fe4c04a1dd50be850d823da7424673de0aad7ad4dbd723842a9ee47758137e1a", + "output_sha256": "04f618e512fbb1a3ab359078740639243ad0740affa1095d6d5720d617876433", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5a1a430ec02eb914dd5749f3fe3ca00d80e884763bdb278b1ae8d37c9b2cdba1.md b/vision-fixhub/court-05/5a1a430ec02eb914dd5749f3fe3ca00d80e884763bdb278b1ae8d37c9b2cdba1.md new file mode 100644 index 0000000000000000000000000000000000000000..eb61dbc2e8c815faf997f7b4d5eff12493f88733 --- /dev/null +++ b/vision-fixhub/court-05/5a1a430ec02eb914dd5749f3fe3ca00d80e884763bdb278b1ae8d37c9b2cdba1.md @@ -0,0 +1,1149 @@ +Case 1:19-cr-00830-AT Document 35 +Filed 04/24/20 Page 1 of 34 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA +- V.- +TOVA NOEL and MICHAEL +19 Cr. 830 (AT) +Defendants. +MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA +IN OPPOSITION TO DEFENDANT MICHAEL +MOTION TO COMPEL +GEOFFREY S. BERMAN +United States Attorney +Southern District of New York +Rebekah Donaleski +Jessica Lonergan +Nicolas Roos +Assistant United States Attorneys +- Of Counsel - + + +Case 1:19-cr-00830-AT +Document 35 +Filed 04/24/20 + +TABLE OF CONTENTS +PRELIMINARY STATEMENT +STATEMENT OF FACTS +I. +II. +The Indictment +Pretrial Discovery and the Defendant's Request for Additional Materials +A. The Government's Discovery Production +B. Defense Requests for Additional Discovery Materials. +ARGUMENT. +I. +Applicable Law... +A. Brady & Giglio +B. +Rule 16 +II. +is Not Entitled to Additional Materials +A. The Government Has Satisfied its Discovery and Disclosure Obligations +B. The Requested Records Are Not "Material" to Preparing a Defense and Are +Sought for the Impermissible Purpose of Jury Nullification +1. Applicable Law +2. Discussion +C. +The Government is Not Required to Collect Materials From Agencies Who +Were Not Part of the Prosecution Team +1.Applicable Law. +2.Discussion. +D. Any Draft Inspector General Report is Not Subject to Disclosure. +E. +Has Not Carried His Burden With Respect to Discovery of Material in +Support of a Selective Prosecution Claim +1.Applicable Law +2. Discussion +CONCLUSION +.. 1 +...2 +..2 +..3 +3 +. 4 +..7 +...7 +.. 7 +8 +8 +8 +10 +10 +12 +15 +16 +19 +..21 +24 +24 +. 26 +29 + + +Case 1:19-cr-00830-AT +Document 35 Filed 04/24/20 Page 3 of 34 +TABLE OF AUTHORITIES +Cases +Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479 (S.D.N.Y. 2010) +Brady v. Maryland, 373 U.S. 83 (1963) +Color of Change v. United States Dep't of Homeland Sec., 325 F. Supp. 3d 447 +(S.D.N.Y. 2018) +Dep't of Interior v. Klamath Water Users Protective Ass'n, 532 U.S. 1 (2001) +Giglio v. United States, 405 U.S. 150 (1972). +In re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997). +In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008) +Kyles v. Whitley, 514 U.S. 419 (1995).... +N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975). +Nat'l Res. Def. Council v. United States Envtl. Prot. Agency, 954 F.3d 150 (2d Cir. +2020). +Standefer v. United States, 447 U.S. 10 (1980) +United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) .. +United States v. Armstrong, 517 U.S. 456, (1996) +United States v. Avellino, 136 F.3d 249 (2d Cir. 1998). +United States v. Bagley, 473 U.S. 667 (1985) +United States v. Barcelo, 628 F. App'x 36 (2d Cir. 2015). +United States v. Bass, 536 U.S. 862 (2002).. +United States v. Berrios, 501 F.2d 1207 (2d Cir. 1974) +United States v. Blaszczak, 308 F. Supp. 3d 736 (S.D.N.Y. 2018). +United States v. Bryan, 868 F.2d 1032 (9th Cir. 1989). +United States v. Carr, 424 F.3d 213 (2d Cir. 2005). +United States v. +, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) +ii +27 +- passim +27 +26,27 +• passim +. 26 +15 +19 +26 +26 +13 +29,30,31 +• passim +19,25 +. 7 +19 +30,33 +30,31 +.. 20 +24 +. 12 +, 20 + + +Case 1:19-cr-00830-AT Document 35 +Filed 04/24/20 + +United States v. Coppa, 267 F.3d 132 (2d Cir. 2001). +United States v. Defreitas, No. 07 Cr. 543 (DLI), 2011 WL 317964, at *10 (E.D.N.Y. +Jan. 31, 2011). +United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *4 (S.D.N.Y. +May 12, 2015).. +United States v. +101 F.3d 17 (2d Cir. 1996) +United States v. Fares, 978 F.2d 52 (2d Cir. 1992). +United States v. Fernandez, 231 F.3d 1240 (9th Cir. 2000) +United States v. Finnerty, 411 F. Supp. 2d 428 (S.D.N.Y. 2006).. +United States v. Floyd, No. 99 Cr. 0234 (DAB), 1999 WL 476438, at *2 (S.D.N.Y. +July 7, 1999). +United States v. +8 F. Supp. 2d 253 (S.D.N.Y. 1998) .. +United States v. +, 786 F. Supp. 56 (D.D.C. 1992)... +United States v. Ghailani, 687 F. Supp. 2d 365 (S.D.N.Y. 2010) +United States v. Gibbons, 602 F.2d 1044 (2d Cir. 1979)... +United States v. +(S.D.N.Y. Apr. 9, 2020). +1. No. 19 Cr. 123-2 (NRB), 2020 WL 1809293, at *5 +United States v. LeRoy, 687 F.2d 610 (2d Cir. 1982) .. +United States v. Levin, No. 15 Cr. 101 (KBF), 2016 WL 2990831, at *12 (S.D.N.Y. +Jan. 25, 2016). +United States v. +, 35 F.3d 148 (4th Cir. 1994). +United States v. +, 517 F.3d 20 (Ist Cir. 2008) +United States v. Libby, 429 F. Supp. 2d 1 (D.D.C. 2006). +United States v. Manzano, 945 F.3d 616 (2d Cir. 2019) +United States v. McGuinness, 764 F. Supp. 888 (S.D.N.Y. 1991) +United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5 +(S.D.N.Y. Aug. 17, 2018). +United States v. Moon, 718 F.2d 1210 (2d Cir. 1983) +iii +• 7,8 +12,17 +16 +13 +30, 31, 33 +26 +20 +. 16 +26 +15 +21 +16 +10 +.. 7 +13,16 +28 +32 +24 +13,17 +11 +20,22 +30,33 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 5 of 34 +United States v. Payne, 63 F.3d 1200 (2d Cir. 1995). +United States v. Pelullo, 399 F.3d 197 (3d Cir. 2005) +United States v. +940 F. Supp. 540 (S.D.N.Y. 1996). +United States v. Persico, 645 F.3d 85 (2d Cir. 2011)... +United States v. Reese, 933 F. Supp. 2d 579 (S.D.N.Y. 2013).. +United States v. Rigas, 258 F. Supp. 2d 299 (S.D.N.Y. 2003) +United States v. Rigas, 583 F.3d 108 (2d Cir. 2009) ... +United States v. Rosado, 728 F.2d 89 (2d Cir. 1984) .. +United States v. Rosenfield, 469 F.2d 598 (3d Cir. 1972) +United States v. Ruggiero, 472 F.2d 599 (2d Cir. 1973) . +United States v. Sanders, 17 F. Supp. 2d 141 (E.D.N.Y. 1998) .. +United States v. Southland Corp., 760 F.2d 1366 (2d Cir. 1985).. +United States v. +424 F. Supp. 2d 720 (S.D.N.Y. 2006) +United States v. Stevens, 985 F.2d 1175 (2d Cir. 1993) +United States v. +, 116 F.3d 606 (2d Cir. 1997). +United States v. Underwood, No. 04 Cr. 424 (RWS), 2005 WL 927012, at *1 +(S.D.N.Y. Apr. 21, 2005). +United States v. Upton, 856 F. Supp. 727 (E.D.N.Y. 1994) +United States v. Volpe, 42 F. Supp. 2d 204 (E.D.N.Y. 1999)... +United States v. Washington, 705 F.2d 489 (D.C. Cir. 1983).. +United States v. +972 F.2d 16 (2d Cir. 1992). +United States v. Yousef, 327 F.3d 56 (2d Cir. 2003). +8 +21 +10 +8 +13,16 +11,12 +.. 20 +17 +15 +.. 7 +29 +15 +21 +9,12 +12 +10 +21 +24 +14,15 +. 33 +19 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 6 of 34 +PRELIMINARY STATEMENT +The Government respectfully submits this memorandum of law in opposition to defendant +Michael +motion to compel discovery. (Dkt. No. 33) ("Mot."). +seeks an order +compelling the Government to collect materials that are not in its possession, not discoverable +under any legal basis, and not related to any legally cognizable defense. +motion is +entirely without merit and should be denied.' +concedes that the Government has produced a "multitude" of discovery directly +relevant to the charges against him. (Mot. 6). Nonetheless, he seeks an order compelling the +Government to collect and produce additional materials that he believes would support his +purported defenses, namely, that he committed the offenses because of staffing issues and +supervisory lapses, and that he was singled out for prosecution. Specifically, +seeks: (i) a +copy of a report being prepared by the Department of Justice, Office of the Inspector General +("DOJ-OIG"), which does not yet exist and would principally be based on the same primary +materials that the Government produced to +in December 2019 (Mot. 5, 8-9); (ii) reports +and documents prepared by the Bureau of Prisons ("BOP") and other agencies who were not and +are not members of the prosecution team (Mot. 6-7); (iii) reports and documents related to "any +and all [Metropolitan Correctional Center ("MCC")] employees" who have engaged in "the same +or similar conduct," including an incident in "2005 or 2006" where officers failed to conduct +counts or rounds and an inmate committed suicide (Mot. 6); and (iv) reports, statistics, and +documents related to purported staffing issues, supervisory lapses, and the application of BOP +' Tova Noel did not file any pretrial motions, and has not joined in +pretrial +motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the deadline for making a Rule +12(b)(3) motion, the motion is untimely. But a court may consider the defense, objection, or +request if the party shows good cause."). + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 7 of 34 +policies which relate to the "much larger context" at the BOP (Mot. 6, 7, 9, 10). +As an initial matter, the Government has satisfied its Rule 16, Brady, and Giglio obligations +and is not in possession of the additional materials that +seeks. More importantly, +is not entitled to compel the Government to collect the additional records for at least four separate +reasons. First, the records are not "material"" to preparing a defense because they are wholly +irrelevant to the false statement charges against +and are intended to prompt jurors to +nullify the charges against him. Second, the BOP records | +seeks are not in the "possession" +of the prosecution team, and there is no legal basis for compelling the Government to collect +materials from other agencies or components of the Department of Justice who are not and were +not part of the criminal investigation that led to the charges against +Third, there is no +legal basis to require the Government to produce a draft of the report being prepared by the DOJ- +OIG, which is subject to the deliberative process privilege. Fourth, +is not entitled to +discovery relating to what happened to other MCC employees when they "falsified] the same +documents," (Mot. +6), because he has utterly failed to identify evidence that the decision to +prosecute him had a discriminatory effect and was motivated by a discriminatory purpose. +motion should be denied in all respects. +STATEMENT OF FACTS +I. +The Indictment +Indictment 19 Cr. 830 (AT) (the "Indictment") was filed on November 19, 2019, charging +defendants Tova Noel and Michael +in six counts: (i) conspiring to defraud the United +States and to make or use a false writing or document, in violation of Title 18, United States Code, +Section 371 (Count One); and (ii) five counts of making or using a false writing or document, in +violation of Title 18, United States Code, Sections 1001(a)(3) and 3 (Counts Two through Six). +2 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 8 of 34 +Both defendants are charged in Counts One, Four, Five, and Six; defendant Noel only is charged +in Counts Two and Three. The charges in the Indictment stem from a fourteen-hour time period, +from approximately 4:00 p.m. on August 9, 2019 to approximately 6:30 a.m. the following day, +August 10, 2019, when the defendants were working as correctional officers at the MCC. As +charged in the Indictment, during that time period, the defendants failed to perform mandated +counts of prisoners housed in MCC's Special Housing Unit ("SHU"), but nevertheless signed false +certifications attesting to having conducted those counts, when, in fact, no counts or rounds of the +SHU were conducted from approximately 10:30 p.m. on August 9 to 6:30 a.m. on August 10. +II. Pretrial Discovery and the Defendants' Request for Additional Materials +A. The Government's Discovery Production +At the initial pretrial conference on November 25, 2019, the Court set a discovery deadline +of December 31, 2019. On that date, pursuant to a protective order entered by the Court, the +Government made a substantial discovery production to both defendants, consisting in part of the +following: surveillance video for the common area of the SHU; analysis of the computers used by +Noel and +from August 9 to 10, 2019; count slips and thirty-minute round reports; MCC +phone records; personnel records and prior work schedules; and reports and notes of witness +interviews prepared by agents from the Federal Bureau of Investigation ("FBI") and the DOJ-OIG +who were participating in the investigation.? +Subsequently, the Government made three additional discovery productions, much more +limited in scope. On January 23, 2020, the Government produced additional interview reports and +2 The Government does not concede that production of all of the materials was required +under Rule 16, but nonetheless produced the materials in its possession out of an abundance of +caution. +3 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 9 of 34 +notes. +On January 30, 2020,3 the Government reproduced video surveillance footage with +timestamps, and on March 16, 2020, the Government produced forensic reports for three electronic +devices and a photograph of a text message. +B. Defense Requests for Additional Discovery Materials +The defendants have made a number of requests for additional discovery materials, in +response to which the Government has provided information in its possession as consistent with +Rule 16 and its other disclosure obligations, as described below. +At the initial pretrial conference on November 11, 2019, +through counsel, raised +the issue of an "ongoing ... report" by the Office of the Inspector General and requested the +"status" of the report and when it would be completed. (Conf. Tr., Nov. 25, 2019, at 3-4, 7-9). +In response, the Government explained that "to the extent counsel's asking for a summary of the +results of the criminal investigation, obviously we'll be turning over in discovery all of the +underlying results of the criminal investigation. ... I don't have a time frame on the [I]nspector +[G]eneral report, but the [G]overnment will produce to the defense all of the relevant discovery +materials in this matter, which includes the Rule 16 materials relevant to the criminal charges that +have been brought against the defendants." (Id. at 7-8). As there was no pending issue to resolve, +the Court declined to rule at that time. +On January 29, 2020, +and Noel each submitted discovery requests to the +Government. +letter reiterated his prior request for "any and all reports, memorandums, +3 The January 30, 2020 production was made to Noel's counsel on January 24, 2020, while +the Government was still waiting for an additional hard drive from +counsel. ++ Based on conversations with attorneys at DOJ-OIG tasked with preparing this report, the +Government understands that the report will likely focus on the events surrounding the death of +Jeffrey Epstein and BOP policies and procedures. +4 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 10 of 34 +written statements, photos, videos, and incident reports created, manufactured or possessed by the +United States Inspector General." Noel's January 29 letter sought materials related to the MCC +video surveillance system and additional surveillance video, as well as assistance locating +particular information in the surveillance video footage that the Government had previously +produced in discovery. +At the pretrial conference the following day, +, through counsel, renewed his request +for "whatever investigation was done and whatever information there is that is discoverable with +respect to the Inspector General's report." (Conf. Tr., Jan. 30, 2020, at 6, 9). The Court directed +I to file a motion formalizing his request. (Id. at 9).5 +The Government responded to the defendants' discovery requests by letter dated March +14, 2020. As for | +report, the Government referred +request for materials related to any forthcoming Inspector General's +to its prior response as stated at the November 25, 2019 +pretrial conference. With respect to Noel's requests for additional materials related to the MCC +video surveillance system, the Government explained that to the extent such materials were in the +Government's possession and currently subject to disclosure, they had already been produced. In +addition, the Government provided additional information answering certain of Noel's questions, +including video timestamps to assist with review of the surveillance footage. +On March 27, 2020, +submitted another discovery request to the Government, +seeking, among other things, information from the BOP regarding other correctional officers and +information about the Government's charging decisions. The Government responded by letter +, through counsel, previewed that he would also likely file a motion to dismiss +the indictment based on "selective prosecution." (Conf. Tr., Jan. 30, 2020 at 6). The deadline for +filing motions, which was extended at counsel's request, has passed, and +has failed to +timely file a motion to dismiss. +5 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 11 of 34 +dated April 1, 2020, explaining that any responsive information in the Government's possession +and subject to disclosure had already been produced. The letter further explained that to the extent +the requests called for items not in the Government's possession or not subject to disclosure, +had not identified any legal basis or authority for his requests and the Government was +not aware of any authority requiring the Government to obtain or produce the requested +information. +On April 9, 2020, +filed the instant motion seeking an order from the Court +compelling the Government to produce the following: +• The Inspector General's report investigating the death of Jeffrey Epstel +nd BOP policies and procedures (referred to herein as the "Inspecto +General's Report"), as well as all supporting memoranda and other +documents, (Mot. 4-5); +• Any and all "reports generated by investigators within the [BOP] regarding +the August 10, 2019 incident" as well as "documents, reports, witness +statements and disciplinary records of any and all MCC employees who +have engaged in the same or similar conduct," including "results of any +disciplinary proceedings and documents maintained by the BOP regarding +the discipline or administrative adjudication of any other employees who +have failed to conduct rounds or inmate counts," (Mot. 4, 6); +• Any previously undisclosed reports, witness statements, and documents +created by "any other federal agencies that investigated the circumstances +surrounding the death of Jeffrey Epstein," (Mot. 4, 7). +For the reasons that follow, +is not entitled to the materials he seeks, and his motion +should be denied. +6 + + +Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 12 of 34 +ARGUMENT +Applicable Law +A. +Brady & Giglio +The Government has an obligation under the Due Process Clause to make a timely +disclosure of any exculpatory or impeaching evidence that is material and in its possession. See +Brady v. Maryland, 373 U.S. 83 (1963); Giglio v. United States, 405 U.S. 150 (1972); see also +United States v. Coppa, 267 F.3d 132, 139-40 (2d Cir. 2001). Evidence is "material" in this sense +only if "its suppression undermines confidence in the outcome of a trial." United States v. Bagley, +473 U.S. 667, 678 (1985). "The rationale underlying Brady is not to supply a defendant with all +the evidence in the Government's possession which might conceivably assist the preparation of +his defense, but to assure that the defendant will not be denied access to exculpatory evidence only +known to the Government." United States v. LeRoy, 687 F.2d 610, 619 (2d Cir. 1982) (citing +United States v. Ruggiero, 472 F.2d 599, 604 (2d Cir. 1973)). +Impeachment evidence is material only "where the witness at issue supplied the only +evidence linking the defendants) to the crime, or where the likely impact on the witness's +credibility would have undermined a critical element of the prosecution's case." United States v. +Payne, 63 F.3d 1200, 1210 (2d Cir. 1995) (internal quotation marks and citations omitted). +Similarly, "where the undisclosed evidence merely furnishes an additional basis on which to +challenge a witness whose credibility has already been shown to be questionable or is subject to +extensive attack by reason of other evidence, the undisclosed evidence may properly be viewed as +cumulative, and hence not material." United States v. Persico, 645 F.3d 85, 111 (2d Cir. 2011) +(citing cases). With regard to the timing of disclosing material under Giglio, the Second Circuit, +in Coppa, rejected the argument that such material should be disclosed when defendants make a +7 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 13 of 34 +demand for it. 267 F.3d at 146. The court held that as a general rule, Brady and its progeny do +not require immediate disclosure of all impeachment material upon a defendant's request. Id. It +found that the time required for its effective use would depend on the materiality of the evidence +as well as the particular circumstances of the case, and suggested that district courts may order +disclosure of material it deems material as a matter of case management. Id. As described above, +the Government disclosed reports and notes of witness statements as part of its discovery +productions, such that the defendants will have possessed substantial material that may serve as +potential impeachment evidence for one year in advance of trial. +B. Rule 16 +Rule 16 of the Federal Rules of Criminal Procedure requires the Government to permit the +defendants to inspect and copy documents and objects within the Government's possession, +custody, or control if the items are material to preparing the defense, if the Government intends to +use them in its case-in-chief at trial, or if the items were obtained from or belong to the defendant. +Fed. R. Crim. P. 16(a)(1)(E). An item is "material to preparing the defense" under Rule 16 "if it +could be used to counter the Government's case or bolster a defense." United States v. Stevens, +985 F.2d 1175, 1180-81 (2d Cir. 1993). +II. +is Not Entitled to Additional Materials +A. +The Government Has Satisfied its Discovery and Disclosure Obligations +As an initial matter, the Government is aware of, has satisfied, and will continue to satisfy +its discovery and disclosure obligations. +The Government has met its Rule 16 discovery and disclosure obligations. As set forth +above, the Government has produced an expansive amount of discovery, which includes among +other things, hundreds of hours of video surveillance going back to July 5, 2019 (despite the fact +8 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 14 of 34 +that the Indictment relates to a 14-hour time period); count slips, thirty minute round forms, and +staffing rosters for the three-week period surrounding Epstein's suicide; internal MCC phone +records; employee files and staffing history for Noel and +; and a wide range of written +Bureau of Prison policies and regulations, among other documents and materials. In addition and +while not required by Rule 16, the Government produced months in advance of trial (and now, +approximately a year in advance of trial) statements for all of the witnesses interviewed during the +investigation. While the Government is not aware of any other information that warrants +disclosure, it will produce any such materials to the extent it becomes aware of them. +The Government is likewise aware of, and has complied with, its Brady and Giglio +obligations. The Government has already produced any evidence in its possession that is arguably +exculpatory or impeaching. To the extent Giglio material exists in notes of witness statements or +attorney proffers made on behalf of witnesses that have not already been produced, the +Government intends to comply with its obligations and will make such disclosures sufficiently in +advance of trial to be effectively used. Based on that representation alone, the defendant's motion +should be denied. See United States v. +No. 19 Cr. 123-2 (NRB), 2020 WL 1809293, at +*5 (S.D.N.Y. Apr. 9, 2020) (denying a motion to compel because the government "represented +that it had complied with and would continue to comply with its Brady and Rule 16 obligations); +United States v. Underwood, No. 04 Cr. 424 (RWS), 2005 WL 927012, at *1 (S.D.N.Y. Apr. 21, +2005) ("The courts of this Circuit repeatedly have denied pretrial requests for discovery orders +pursuant to Brady where the government has made such good faith representations."); United +States v. +940 F. Supp. 540, 553 (S.D.N.Y. 1996) (denying defendant's motion to compel +production of Brady based on Government's representation that it was aware of and had complied +with Brady). +9 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 15 of 34 +B. The Requested Records Are Not "Material" to Preparing a Defense and Are +Sought for the Impermissible Purpose of Jury Nullification +All of the records +seeks in his motion are not "material to preparing a defense" +under Rule 16, and are not exculpatory under Brady, because they are irrelevant to countering the +Government's false statements case or advancing a legitimate defense. Instead, +seeks +evidence of staffing shortages, working conditions, the implementation of BOP policies, +supervisory lapses, and instances in which other BOP employees were not prosecuted so that he +can engage in attempted jury nullification by arguing that those conditions "led" to the criminal +conduet that he is charged with and are a reason to acquit him. (Mot. 5, 7, 9, 14). +is not +entitled to records—and certainly would not be entitled to introduce any such evidence at trial— +that would aid in that nullification effort because Rule 16 only entitles a defendant to discovery +for purposes of bolstering a defense to the Government's case in chief, not the merits of the +decision to prosecute. +1. +Applicable Law +An item or record that the Government does not intend to use in its case-in-chief at trial is +discoverable under Rule 16(a)(1)(E) only if it "is material to preparing the defense." Fed. R. Crim. +P. 16(a)(1)(E). "It is [a defendant's] burden to make a prima facie showing that documents sought +under Rule 16(a)(1)(E)(i) are material to preparing the defense." United States v. Rigas, 258 F. +Supp. 2d 299, 307 (S.D.N.Y. 2003) (citing United States v. McGuinness, 764 F. Supp. 888, 894 +(S.D.N.Y. 1991)). As noted above, an item is "material to preparing the defense" under Rule 16 +"if it could be used to counter the Government's case or bolster a defense." Stevens, 985 F.2d at +1180-81. The defendant must "offer more than the conclusory allegation that the requested +evidence is material." Rigas, 258 F. Supp. 2d at 307 (internal citation omitted). +As the Supreme Court held in United States v. Armstrong, while Rule 16 authorizes +10 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 16 of 34 +defendants to examine records "material to the preparation of their defense against the +Government's case in chief," it does not authorize discovery for defenses that do not rebut the +"merits to the criminal charge itself." 517 U.S. 456, 462-63 (1996) (holding that Rule 16 does not +authorize discovery relating to a selective prosecution claim). For that reason, because evidence +that would be impermissibly used to encourage jury nullification does not relate to the merits of +the criminal charges, it is not discoverable under Rule 16. Id.; see also United States v. Defreitas, +No. 07 Cr. 543 (DLI), 2011 WL 317964, at *10 (E.D.N.Y. Jan. 31, 2011) (rejecting discovery +request related to something that is "not a defense" and has "nothing to do with the issues of +whether defendants ... committed the ... crimes charged"). Since jury nullification is "a practice +whereby a juror votes in purposeful disregard of the evidence," United States v. +116 F.3d +606, 614 (2d Cir. 1997), or "out of compassion or compromise," Standefer v. United States, 447 +U.S. 10, 22 (1980) (internal citation omitted), it is not error for a court to preclude evidence that is +"not a valid defense" aimed at nullification, United States v. +101 F.3d 17, 19-20 (2d Cir. +1996). See also United States v. Reese, 933 F. Supp. 2d 579, 583-84 (S.D.N.Y. 2013) (precluding +defense arguments or evidence related to "possible consequences for the defendant of conviction, +jury nullification, and the Government's motive and conduct in prosecuting [defendant]"); United +States v. Levin, No. 15 Cr. 101 (KBF), 2016 WL 299031, at *12 (S.D.N.Y. Jan. 25, 2016) (barring +evidence "intended to elicit sympathy" and attempts to "use jury nullification as a defense" as +"plainly improper"). Indeed, "trial courts have the duty to forestall or prevent jury nullification" +even where the defendant or the court may "strongly disagree|] with the government's charging +decisions and the attendant sentencing consequences." United States v. Manzano, 945 F.3d 616, +626-27 (2d Cir. 2019) (citations & quotation marks omitted). +11 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 17 of 34 +Discussion +motion makes clear that he intends for his principal defense at trial to be that— +irrespective of his guilt or innocence of the false statements charges—he should be acquitted +because the MCC was understaffed, +was overworked, his supervisors did not catch his +crime in the moment, and falsification of count slips is rampant within the BOP. (See Mot. 3 +("staffing issues, staffing shortages, supervisory lapses and the enforcement/interpretation of BOP +procedures go to the heart of his defense to the government's criminal allegations"); 9 ("Mr. +will assert that the rampant staffing shortages present at the MCC in August of 2019 led +to the conduct for which Mr. +is now criminally charged.")). +has failed to meet +his burden in establishing the materiality of discovery about these topics to preparing a valid +defense because the materials he seeks do not rebut the merits of the criminal charges and instead +would be impermissibly used to encourage jury nullification. +The purported reasons for +decision to falsify count slips-being tired, +overworked, or understaffed +—are not a valid legal defense, and therefore evidence related to those +issues is not relevant. Put simply, were the jury to find beyond a reasonable doubt that +intentionally made materially false statements and also that did so while tired or overworked, it +would still be required to convict him. See United States v. Carr, 424 F.3d 213, 221 (2d Cir. 2005) +(holding that "it was proper for the district court to instruct the jury that it had a duty to find [the +defendant] guilty if the government proved beyond a reasonable doubt every element of the offense +with which he was charged" (internal citation omitted)). +None of +proffered excuses relate to proving or rebutting the elements of a +violation of 18 U.S.C. § 1001(a)(3) as they do not concern whether a writing or entry was false, +whether it was material to a matter within the jurisdiction of the BOP, or whether he knowingly +12 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 18 of 34 +and willfully made a false statement. Nor are those excuses relevant to whether +had a +criminal agreement with his co-defendant. Indeed, evidence as to a defendant's purportedly +innocent motive in a false statement case is irrelevant to the question of intent. See United States +v. Washington, 705 F.2d 489, 493-94 (D.C. Cir. 1983) (holding that proof of a good or innocent +motive is not probative of intent where the mens +is "knowingly and willfully"); In re Terrorist +Bombings of U.S. Embassies in E. Africa, 552 F.3d 93, 154 n.49 (2d Cir. 2008) (citing Washington, +705 F.2d at 493, for "the irrelevance of a motive to the question of whether conduct is intentional"); +United States v. +, 786 F. Supp. 56, 64 (D.D.C. 1992) (rejecting the defendant's "context +argument" for why materials could be relevant to the crime charged). +For the same reasons, "other people were doing it" is not a defense to a false statements or +conspiracy charge because the conduct of other BOP employees is irrelevant to each of the +foregoing elements. +argues that because he was aware of incidents where BOP employees +falsified records and "their conduct did not lead to their indictment or incarceration," evidence of +what other BOP employees have done is relevant to his intent. (Mot. 6.) Not so. Whether +believed falsifying records was illegal or was subject to criminal penalties is not relevant to the +charges against him. See United States v. Southland Corp., 760 F.2d 1366, 1372 (2d Cir. 1985) +("Ignorance of the law is no defense to a charge of purposeful and intentional action."); United +States v. Rosenfield, 469 F.2d 598, 601 n.2 (3d Cir. 1972) ("As long as the inexcusable intent is +present, it is not necessary that the defendant know that his conduct is subject to criminal +penalties."). And in any event, it would be fundamentally inappropriate, and extremely prejudicial, +for the jury to consider other individuals not on trial or otherwise relevant to the conduct charged +here, in evaluating the guilt or innocence of the defendant. See United States v. Gibbons, 602 F.2d +1044, 1048 (2d Cir. 1979) (approving instruction that jury was not to consider individuals who +13 + + +Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 19 of 34 +were not on trial). +efforts to garner sympathy, put the Government on trial, and deflect blame for +his own criminal actions plainly sound in nullification. See Reese, 933 F. Supp. 2d at 583-84; +Levin, 2016 WL 2990831, at *12. +Evidence on those points does not relate to whether the +defendant committed the crimes charged, but rather is intended to elicit sympathy, compassion, or +compromise from the jury. The records +seeks are no more discoverable than the +nullification evidence precluded in Armstrong and its progeny. See Armstrong, 517 U.S. at 462- +63 (defendant not entitled to discovery on race of other narcotics defendants to aid in selective +prosecution claim); United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *4 +(S.D.N.Y. May 12, 2015) (rejecting defendant's "demands for general information and statistics +relating to the Government's use of sting operations"); United States v. Floyd, No. 99 Cr. 0234 +(DAB), 1999 WL 476438, at *2 (S.D.N.Y. July 7, 1999) (rejecting discovery request for +"background data, records and investigative reports" of the New York City Police Department +("NYPD") as well as information about NYPD officers' conduct in other cases); Defreitas, 2011 +WL 317964, at *10 (rejecting discovery demands related to a "factual impossibility" defense to a +conspiracy charge). It is the Court's "duty to forestall or prevent" jury nullification. Manzano, +945 F.3d at 627 (holding that "District courts have a duty to forestall or prevent [jury nullification +arguments] and the district court in this case abdicated its duty by ruling that defense counsel could +argue jury nullification."); see also United States v. Rosado, 728 F.2d 89, 93 (2d Cir. 1984) +(criticizing trial court for inviting nullification by permitting the defendants to mount a "political +defense" and stating that it was an "erroneous assumption that good motive for committing a crime +is inconsistent with criminal intent"). +In sum, much of the additional discovery +seeks in his motion relates to legally +14 + + +Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 20 of 34 +irrelevant matters, such as what "led" him to the criminal conduct or the broader "context" in +which he committed specific criminal acts. There is no basis to compel production of evidence +related to those matters under Rule 16, Brady, or Giglio because they are not material and because +the evidence sought is in furtherance of a transparent attempt at nullification. +motion +should be denied on this basis alone. +C. The Government is Not Required to Collect Materials From Agencies Who +Were Not Part of the Prosecution Team +asks the Court to compel the Government to produce "any reports, witness +statements, memorandum, and documents from any separate investigation conducted by the +BOP," "documents, reports, witness statements and disciplinary records of any and all MCC +employees who have engaged in the same or similar conduct," and any previously undisclosed +reports, witness statements, and documents created by "any other federal agencies that investigated +the circumstances surrounding the death of Jeffrey Epstein." (Mot. 4, 7 (emphasis added)). Even +if +had satisfied the materiality requirement under Rule 16 or Brady with respect to these +items—and he has not +motion would still fail because the materials he seeks are not +in the prosecution team's possession. +The BOP is not, and never has been, part of the prosecution team. Nor did the BOP conduct +an investigation jointly or in coordination with the prosecution team." To require the Government +to obtain and produce any records from the BOP from a separate investigation, as well as evidence +that would support +purported (and improper, for the reasons discussed in Part II.B, +" The defendant claims, based on a CNN article, that the U.S. Marshal Service ("USMS") +conducted an investigation. The Government is unaware of such an investigation, and in any +event, any such inquiry by the USMS was not conducted jointly or in coordination with th +prosecution team. +15 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 21 of 34 +supra) defenses, is not legally required and would impose a nearly insurmountable obligation on +the Government of marshaling and reviewing information and data in the possession of an entirely +separate entity. +Applicable Law +As described above, Rule 16, Brady, and Giglio apply to materials in the Government's +"possession." As a general matter, while "[a]n individual prosecutor is presumed ... to have +knowledge of all information gathered in connection with his office's investigation of the +case, ... knowledge on the part of persons employed by a different office of the government does +not in all instances warrant the imputation of knowledge to the prosecutor." United States v. +Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted). The imposition of such "an +unlimited duty on a prosecutor to inquire of other offices not working with the prosecutor's office +on the case in question would inappropriately require us to adopt a monolithic view of government' +that would 'condemn the prosecution of criminal cases to a state of paralysis." Id. (citation & +quotation marks omitted); see also Kyles v. Whitley, 514 U.S. 419, 437 (1995) (Government's +discovery and disclosure obligations extend only to information in the custody of the prosecutor +or "others acting on the government's behalf in the case"). Thus, discovery and disclosure +obligations only extend "information known to persons who are a part of the 'prosecution +team" +... who perform investigative duties or make strategic decisions about the prosecution of +the case," including "police officers and federal agents who submit to the direction of the +prosecutor and participate in the investigation." United States v. Barcelo, 628 F. App'x 36, 38 (2d +Cir. 2015) (citation omitted). Brady is not a basis to compel the Government to gather information +in the possession of third parties on behalf of the defense. See United States v. Yousef, 327 F.3d +16 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 22 of 34 +56, 112 (2d Cir. 2003) (defendants were not deprived of due process by any alleged failure of U.S. +government to help them obtain cooperation from foreign authorities). +In considering whether Rule 16 and Brady apply to records in the possession of another +government agency, a prosecutor's duty extends to reviewing such evidence only where the +Government conducts a "joint investigation" with that agency or branch of government. See +United States v. Rigas, 583 F.3d 108 (2d Cir. 2009) (affirming district court opinion holding that +there was "no joint investigation with the [Securities and Exchange Commission ("SEC")I" and +therefore the Government did not need to produce documents in the custody of the SEC); United +States v. Blaszczak, 308 F. Supp. 3d 736, 742-43 (S.D.N.Y. 2018) (holding that the Government +was not obligated to review SEC material for Brady where SEC was not involved in grand jury +presentation, did not attend every interview, did not review documents gathered only by +prosecution, and did not develop prosecutorial strategy); United States v. Middendorf, No. 18 Cr. +36 (JPO), 2018 WL 3956494, at *4-5 (S.D.N.Y. Aug. 17, 2018) (holding that the Government was +not required to conduct a search because the [Public Company Accounting Oversight Board +("PCAOB)] was not involved in witness interviews or developing prosecutorial strategy, and the +SEC was not involved in the grand jury presentation, reviewing the fruits of the Government's +investigation, or developing prosecutorial strategy; United States v. +409 F. Supp. 3d 228, +241-42 (S.D.N.Y. 2019) (no joint investigation between Government and SEC); United States v. +Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (Chin, J.) (no joint investigation between +Government and New York +Exchange ("NYSE")); United States v. Upton, 856 F. Supp. +727, 749-50 (E.D.N.Y. 1994) (holding that USAO and Federal Aviation Administration ("FAA") +did not conduct a "joint investigation" even though the FAA provided two inspectors to assist the +criminal investigation). +17 + + +Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 23 of 34 +Moreover, even where agents from a component of an agency are involved in an +investigation, that does not render the entirety of an agency part of the prosecution team. See, e.g., +United States v. +424 F. Supp. 2d 720, 723 (S.D.N. Y. 2006) ("While the prosecution's [Rule +16] disclosure obligation in some circumstances may extend to materials beyond the knowledge +of the individual prosecutors assigned to a case, it does not extend to the collective knowledge of +the entire United States government or even to the entire government agency concerned."); United +States v. Pelullo, 399 F.3d 197, 218 (3d Cir. 2005) ("[T]hat other agents in the ([Department of +Labor ("DOL")] participated in this investigation does not mean that the entire DOL is properly +considered part of the prosecution team."); see also United States v. Locascio, 6 F.3d 924, 949 (2d +Cir. 1993) (refusing, for Brady purposes, to impute to AUSAs prosecuting that action with the +assistance of certain FBI agents knowledge of reports prepared by FBI agents who were +"uninvolved in the investigation or trial of the defendants"); but see United States v. Ghailani, 687 +F. Supp. 2d 365, 372 (S.D.N.Y. 2010) (holding that, in the context of a speedy trial motion, other +members of the Department of Justice who were involved in making decisions about timing and +progress of the case were part of the "government" for Rule 16 purposes). +Thus, as the foregoing precedents recognize, the factors relevant in determining whether +an agency or a component of an agency are part of the prosecution team, and therefore their records +are in the "possession" of the Government include whether the agency or component: "(1) +participated in the prosecution's witness interviews, (2) was involved in presenting the case to the +grand jury, (3) reviewed documents gathered by or shared documents with the prosecution, (4) +played a role in the development of prosecutorial strategy, or (5) accompanied the prosecution to +court proceedings." Middendorf, 2018 WL 3956494, at *4. +18 + + +Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 24 of 34 +Discussion +As described above, the Government has produced Brady, Giglio, and Rule 16 material in +the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and +the DOJ-OIG who have worked on this investigation and prosecution. +seeks materials +that are not in the possession of the United States Attorney's Office or the case teams at the FBI +and DOJ-OIG who worked on this criminal investigation. +seeks a variety of records from the BOP. The BOP was not a member of the +prosecution team, and no employee of the BOP performed investigative duties or made strategic +decisions about the prosecution of the case. Indeed, the Government obtained records from the +MCC (a component of the BOP) pursuant to a grand jury subpoena to the institution and written +requests to the MCC's legal department. Likewise, the Government was not involved in any +internal BOP investigation into the circumstances surrounding Epstein's suicide. Notwithstanding +those facts, the defendant asserts that the BOP is "allied with the prosecution" and therefore the +Government's discovery and disclosure obligations extend to materials exclusively in the +possession of the BOP. That argument is not only belied by the facts, but it is settled law in this +Circuit that a prosecutor's duty extends to reviewing the materials in the possession, custody, or +control of another agency for Brady evidence only where the Government conducts a "joint +investigation" with that agency. +None of the indicia of a "joint" or "allied" prosecution, as +discussed in the foregoing case law, is present here. A straightforward application of those factors +considered by courts in this Circuit reveals that the investigation was in no way joint: the BOP did +not participate in the prosecution's witness interviews; it was not involved in presenting the case +to the grand jury; no BOP employees aided in the review of documents gathered by the +19 + + +Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 25 of 34 +Government; the BOP was not involved in the strategic decisions; and no BOP personnel +accompanied the prosecution to court proceedings. +Moreover, even if the BOP had conducted a joint investigation with the Government into +the events of August 9 and 10, 2019 (which they did not), +has offered no reason to believe +that most if not all of the records that he seeks—such as records of other instances of BOP +employees failing to conduct rounds and counts—would be part of the BOP's investigation. There +is simply no basis to seek an order compelling the Government to search for records in the +possession of the BOP, without any temporal limitation or factual nexus to the charged case, +regarding staffing shortages at the MCC, other instances where BOP employees failed to conduct +required rounds and counts, and disciplinary records for other BOP employees who have at other +times also allegedly falsified records. +The cases +cites do not support a contrary result. In United States v. Bryan, the +Ninth Circuit concluded that the government could not limit its discovery obligations to documents +located in the district of prosecution since the case came out of a single, nationwide IRS +investigation. 868 F.2d 1032, 1035-37 (9th Cir. 1989). In reaching that holding, the Circuit +explained that "a federal prosecutor need not comb the files of every federal agency which might +have documents regarding the defendant" and that Rule 16's disclosure requirements are cabined +to anything in the possession "of any federal agency participating in the same investigation of the +defendant." Id. at 1036 (emphasis added). Similarly, in United States v. Volpe, 42 F. Supp. 2d +204, 221 (E.D.N.Y. 1999), the court explained, in denying the defendant's discovery motion, that +"[c]ourts have construed the term "government" +•.. narrowly to mean the prosecutors in the +particular case or the governmental agencies jointly involved in the prosecution of the defendant, +and not the 'government' in general." And while the court in United States v. Libby, 429 F. Supp. +20 + + +Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 26 of 34 +2d 1, 9 (D.D.C. 2006), required the prosecutors to obtain records from the Office of the Vice +President and the Central Intelligence Agency, even though those parts of government did not +participate in the grand jury investigation, that holding was an outlier, which has never been cited +by another court, and the decision itself has never been cited in this Circuit. +Finally, even if such materials had any conceivable relevance to the charges at hand (which, +as discussed above, they do not), asking the Government to conduct a broad canvassing of the +BOP's records—including searching databases located out of state, reviewing large quantities of +documents, attempting to pull archived records going back as far as 2005, and parsing through +attorney work product—would be inordinately time consuming and burdensome for attorneys for +the Government, which does not have custody of the files, is not familiar with the files, and knows +of no effective way to search them. It would, as the Circuit warned against in Avellino, "condemn +the prosecution of criminal cases to a state of paralysis." 136 F.3d at 255. Such a result is not +legally required by Rule 16, Brady, or Giglio, and therefore +motion should be denied. +D. +Any Draft Inspector General Report is Not Subject to Disclosure +argues that any report by the Inspector General and related materials must be +produced because he speculates that such a report will address systemic issues at the BOP, +including purported staffing shortages at the MCC. (Mot. 5, 9-10). For the reasons set forth above, +any draft Inspector General Report is not discoverable because the issues +believes it will +discuss are not material to the preparation of a valid defense, see Part II.B, and the draft reports, +to the extent they exist, are protected from disclosure by the deliberative process privilege. While +the prosecution team has had no involvement in writing the Inspector General Report, the +Government understands that those attorneys from DOJ-OIG responsible for writing the Report +have not yet completed a draft, and do not anticipate completing the Report in the near term. As +21 + + +Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 27 of 34 +such, there are no drafts of the Report to disclose, and +motion can be denied on that +reason alone. Moreover, +request for draft versions of the Report—which do not yet +exist—fails for two additional reasons. +First, drafts of the Inspector General's Report, which has not been completed and will +likely make recommendations about reforms at the BOP, are protected from disclosure under the +deliberative process privilege, which "covers "documents reflecting advisory opinions, +recommendations and deliberations comprising part of a process by which governmental decisions +and policies are formulated.'"' Dep't of Interior v. Klamath Water Users Protective Ass'n, 532 +U.S. 1, 8 (2001) (quoting N.L.R.B. v. Sears, Roebuck d Co., 421 U.S. 132, 150 (1975)). The +privilege is applicable in criminal and civil cases involving the government. See, e.g.. United +States v. Fernandez, 231 F.3d 1240, 1246-47 (9th Cir. 2000) (government's death penalty +evaluation form and prosecution memoranda were shielded from discovery under the deliberative +process privilege); In re Sealed Case, 121 F.3d 729, 737-40 (D.C. Cir. 1997) (indicating that the +privilege applies to grand jury subpoenas); United States v. +8 F. Supp. 2d 253, 284 +(S.D.N.Y. 1998) (internal memoranda covered by privilege). "In order for the privilege to apply, +the agency record at issue must be (1) an inter-agency or intra-agency memorandum or letter; (2) +pre-decisional; and (3) deliberative." Nat'l Res. Def. Council v. U.S. Envtl. Prot. Agency, 954 F.3d +150, 155 (2d Cir. 2020). "It is well-settled that draft documents, by their very nature, are typically +pre-decisional and deliberative [because] [t]hey reflect only the tentative view of their authors; +views that might be altered or rejected upon further deliberation by their authors or by their +superiors." Color of Change v. U.S. Dep't of Homeland Sec., 325 F. Supp. 3d 447, 453 (S.D.N.Y. +2018) (quoting Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010)). +The Inspector General's Report is both pre-decisional and deliberative. A full draft has not +22 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 28 of 34 +been completed, let alone reached a point where the final version will be disclosed to the public. +It is also deliberative in that it will likely make recommendations about the BOP, and those +recommendations will be under discussion within the Office of the Inspector General prior to being +finalized and publicly announced. Internal deliberations are an important tool for agencies in +reaching decisions, including recommendations in DOJ-OIG reports. The ability to have these +discussions is important in identifying a broad range of policy and legal issues. Here, disclosure +of any draft report or other work product related to the preparation of the Report will undermine +the DOJ-OIG's ability to engage in meaningful discussions of the issues at the BOP relating to +inmate security and staffing, among other topics, and will potentially stifle rigorous discourse on +the issues. Accordingly, +motion should be denied for the reason that the materials +sought are protected by the deliberative process privilege. Klamath, 532 U.S. at 9. +Second, +has offered no support for his contention that drafts of the Inspector +General's Report itself (and any related work product)—as opposed to the underlying materials +upon which the Report is based +—are subject to disclosure. To the extent that the forthcoming +Inspector General's Report relies on information gathered during the instant investigation and +prosecution, those underlying materials—which focus primarily on the events of August 9 and 10, +2019, the incarceration of Jeffrey Epstein, and related MCC records—have already been disclosed +to the defendants. +contends that those tasked with preparing the Report may "possiblly]" +have generated additional witness statements and "other information" that has not been produced +by the Government to date. (Mot. S). +provides no support for such assertions besides +mere speculation. The prosecution has inquired of the Washington D.C.-based attorneys who are +preparing the Inspector General's Report. Based on those conversations, it is the prosecution's +understanding that those attorneys have not conducted any additional interviews or otherwise +23 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 29 of 34 +discovered any potential Brady material. As such, given that the prosecution has already produced +in discovery all of the materials it provided to the DOJ-OIG attorneys preparing the Report, the +underlying materials for the Report would be merely cumulative of information in the defendants +possession. Any analysis of those materials by the attorneys preparing the Inspector General's +Report is not subject to disclosure pursuant to Rule 16 and cannot constitute Brady material. See +United States v. +35 F.3d 148, 150 (4th Cir. 1994) (noting generally that "nothing contained +in [an] OIG report would ordinarily have been discoverable"). +At bottom, +has not cited a single authority requiring the production of a draft, +unpublished report by an inspector general or related work product, and such production is not +required by Rule 16, Brady, Giglio, or any other disclosure obligation. +E. +Has Not Carried His Burden With Respect to Discovery of Material +in Support of a Selective Prosecution Claim +seeks "information and statistics that show the conduct in which the defendant is +being charged with a crime were ... rampant throughout the BOP" and that the application of +criminal laws to him is "possibl[y] discriminatory." (Mot. 7.) This request, which is effectively a +demand for discovery in furtherance of a selective prosecution claim, should be denied not only +for the reasons set forth in Section II.B, but also because +has not made the requisite +showing that is necessary to obtain discovery for a selective prosecution claim. Indeed, +has failed to put forth any evidence that his prosecution was the result of discriminatory effect or +discriminatory purpose. +Applicable Law +"A selective-prosecution claim is not a defense on the merits to the criminal charge itself, +but an independent assertion that the prosecutor has brought the charge for reasons forbidden by +the Constitution." Armstrong, 517 U.S. at 468. The standard to prove this defense is "a demanding +24 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 30 of 34 +one," id., as the defendant must "overcome the strong presumption of regularity on the part of +federal prosecutors, and "in the absence of clear evidence to the contrary, courts presume that they +have properly discharged their official duties.'"' United States v. Sanders, 17 F. Supp. 2d 141, 144 +(E.D.N.Y. 1998) (quoting Armstrong, 517 U.S. at 464), aff'd, 211 F.3d 711 (2d Cir. 2000). +A defendant claiming selective prosecution must present "clear evidence" that the decision +to prosecute not only (1) "had a discriminatory effect" but was also (2) "motivated by a +discriminatory purpose." Armstrong, 517 U.S. at 465; United States v. Alameh, 341 F.3d 167, 173 +(2d Cir. 2003); United States v. Fares, 978 F.2d 52, 59 (2d Cir. 1992); United States v. Moon, 718 +F.2d 1210, 1229 (2d Cir. 1983). "The discriminatory effect prong requires a showing that +'similarly situated individuals of a different [classification] were not prosecuted." Alameh, 341 +F.3d at 173 (quoting Armstrong, 517 U.S. at 465). In other words, the defendant must show that +he has been "singled out" as a member of a protected class. Fares, 978 F.2d at 59 (quoting Moon, +718 F.2d at 1229). To establish discriminatory purpose, the defendant must show that the +Government's discriminatory "selection of the defendant for prosecution has been invidious or in +bad faith, i.e., based upon such impermissible considerations as race, religion, or the desire to +prevent his exercise of constitutional rights." Id. (internal quotation marks omitted; alteration +incorporated). Where a defendant "has not shown that the Government prosecuted him because +of" his protected status or conduct, his claim fails. Id. +In order to obtain discovery on a selective prosecution claim, the defendant must offer +"some evidence tending to show the existence of the essential elements of the defense." +Armstrong, 517 U.S. at 468 (quoting United States v. Berrios, 501 F.2d 1207, 1211 (2d Cir. 1974)); +United States v. Bass, 536 U.S. 862, 863 (2002) (per curiam) (to obtain discovery, a defendant +accordingly first "must show some evidence of both discriminatory effect and discriminatory +25 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 31 of 34 +intent"); Fares, 978 F.2d at 59 (same). "IT]he showing necessary to obtain discovery should itself +be a significant barrier to the litigation of insubstantial claims." Armstrong, 517 U.S. at 464. +"Mere assertions and generalized proffers on information and belief are insufficient" to meet this +burden. Fares, 978 F.2d at 59; see, e.g., Armstrong, 517 U.S. at 470 (affidavits "recount[ing] +hearsay and report[ing] personal conclusions based upon anecdotal evidence" are not sufficient to +justify discovery); Berrios, 501 F.2d at 1211 (affidavit from defendant and attorney that they +"believe[d]" there was improper motive and that "hundreds" of similarly situated individuals went +unprosecuted was insufficient); Alameh, 341 F.3d at 174 (defendant's statistical analysis was +insufficient to merit discovery on selective prosecution claim). +2. +Discussion +is not entitled to discovery that would relate to a selective procession or +"discriminatory application" claim. He has not carried his burden through a showing of any +evidence that his prosecution for the charges in the Indictment is discriminatory. +As to the first required prong (discriminatory effect), +has failed to put forth any +evidence that "others similarly situated have not generally been proceeded against because of +conduct of the type forming the basis of the charge against [him]." Fares, 978 F.2d at 59 (internal +quotation marks omitted). "A similarly situated offender is one outside the protected class who +has committed roughly the same crime under roughly the same circumstances but against whom +the law has not been enforced." United States v. +, 517 F.3d 20, 27 (1st Cir. 2008). +alleges that there was an "almost identical incident in 2005 or 2006 wherein officers failed to +conduct institutional counts or rounds and an inmate committed suicide," and one of the four +officers involved was given a suspension. (Mot. 6). But +is not charged with failing to +conduct counts, he is charged with making false statements about those counts. Even assuming +26 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 32 of 34 +those officers "in 2005 or 2006" did falsify count slips, | +has still not put forth any evidence +that those officers were "outside of the protected class," meaning of a different race, gender, +nationality, or other protected class than +In any event, even were the conduct similar, +that +can point to but a single other instance in which officers were not criminally +prosecuted for that type of conduct hardly rings of selectiveness. +Similarly, +points to the fact that "Officer-l" and "Officer-2" in the Indictment, +who falsified count slips along with Tova Noel for the 4 p.m. and 10 p.m. institutional counts on +August 9, 2019, respectively, were not prosecuted. (Mot. 10; Ind. Tl 15, 17, 19). Even assuming +arguendo that Officer-1 and Officer-2 were similarly situated to | +one count slip-while +falsified three +in that they each falsified +has failed to put forth any evidence that +either Officer-l or Officer-2 were outside of a "protected class" to which +belongs.? Nor +could he: Officer-1 and Officer-2 are the same race, gender, and nationality as +also questions why his supervisors or other MCC personnel who received and reviewed +false count slips were not also prosecuted with making false statements, but those supervisors or +personnel are not similarly situated to +because they did not actually make the false +statementsdid. In addition, Courts have repeatedly held that the "suspicion [and] +surmise" contained in +motion simply do not constitute "objective evidence" warranting +discovery. See United States v. +, 972 F.2d 16, 19 (2d Cir. 1992) (conclusory allegations as to +timing of indictment, Government's failure to follow internal guidelines, and improprieties of +In so noting, the Government does not intend to comment on its deliberative process or +the exercise of its prosecutorial discretion. It notes these facts simply in response to +claim that the lack of charges against Officer-1, Officer-2, or +supervisors is in and of +itself sufficient to meet the defendant's burden of establishing evidence of a similarly situated +defendant who was not charged. +27 + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 33 of 34 +prosecutors not "objective evidence" warranting discovery); Moon, 718 F.2d at 1230 ("to engage +in a collateral inquiry respecting prosecutorial motive, there must be more than mere suspicion or +surmise"). +failure to make an evidentiary showing in support of the first required prong +means that his motion for discovery on his selective prosecution claim must be denied. See, e.g., +Bass, 536 U.S. at 863. +As to the second required prong, +has failed to even allege, let alone establish, that +the decision to prosecute him was motivated by a discriminatory purpose. To make such a +showing, a defendant must establish that the Government's "selection of the defendant for +prosecution has been invidious or in bad faith, i.e., based upon such impermissible considerations +as race, religion, or the desire to prevent his exercise of constitutional rights." Fares, 978 F.2d at +59 (internal quotation marks omitted; alteration incorporated). +has not put forth any +evidence whatsoever that the Government's decision to prosecute +was based on anything +other than his guilt. Instead, +challenges the Government's decision to prosecute him at +all, based on his wholly unsupported claim that the criminal conduct with which he is charged is +"rampant" within the BOP. (Mot. 7). But the mere fact that other people were not prosecuted for +committing the crime that +committed does not mean that the Government harbored +discriminatory intent in prosecuting +8 Even if l +had not failed to carry his burden on his discovery motion (and he has +failed), he would still not be entitled to put such evidence or argument regarding selective +prosecution before a jury because the "selective prosecution defense is an issue for the court rather +than the jury." Regan, 103 F.3d at 1082. The Second Circuit's directive makes sense. A claim of +evidently "unrelated to factual innocence of the crime charged," which is the sole issue to be +decided by the jury, and, as a result, the Court alone must resolve a claim of selective prosecution. +Regan, 103 F.3d at 1082; see also United States v. Rosado, 728 F.2d 89, 93 (2d Cir. 1984) +(criticizing admission of evidence about the propriety of a prosecution "for turning the trial away + + +Case 1:19-Cr-00830-AT Document 35 Filed 04/24/20 Page 34 of 34 +Having failed to meet the "rigorous standard" required to obtain discovery on a selective +prosecution defense, +requests for discovery of any materials related to other incidents +in which officers were not prosecuted for falsifying count slips should be denied. Armstrong, 517 +U.S. at 464. +CONCLUSION +For the foregoing reasons, the defendant's motion to compel should be denied. +Dated: New York, New York +April 24, 2020 +By: +Respectfully submitted, +GEOFFREY S. BERMAN +United States Attorney +sl +Rebekah Donaleski +Jessica Lonergan +Nicolas Roos +Assistant United States Attorneys +rom a determination of whether the elements of the offense charged had been proved beyond i +easonable doubt into a wide-ranging inquiry into matters far beyond the scope of legitimate issues +in a criminal trial"). Accordingly, courts routinely and correctly preclude defendants from raising +these arguments at trial. See Regan, 103 F.3d at 1082 ("[W]e agree with the district court's +decision to resolve for itself whether the government's conduct was lawful and to prevent Regan +from presenting evidence on that subject."); United States v. Raniere, No. 18 Cr. 204 (NGG), Dkt. +622 (precluding argument regarding propriety of Government's prosecution), United States v. +Stewart, Cr. No. 03-717 (MGC), 2004 WL 113506, at *1 (S.D.N.Y. Jan. 26, 2004) (granting +motion to preclude the defendant from "presenting arguments or evidence that would invite the +jury to question the Government's motives in investigating and indicting" the defendant); United +States v. +1. No. 12-CR-319, 2017 WL 928915, at *3 (D. Nev. Mar. 8, 2017) ("Defendant will +be precluded from presenting evidence regarding the government's motive for prosecution in the +instant case as such evidence is not relevant."); United States v. Starks, No. 10-CR-0160, 2012 +WL 12878587, at *1 (N.D. Miss. July 20, 2012) (same). +29 diff --git a/vision-fixhub/court-05/5a1a430ec02eb914dd5749f3fe3ca00d80e884763bdb278b1ae8d37c9b2cdba1.receipt.json b/vision-fixhub/court-05/5a1a430ec02eb914dd5749f3fe3ca00d80e884763bdb278b1ae8d37c9b2cdba1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6335e8f65d963f33d1be9cc954191c792076f7c3 --- /dev/null +++ b/vision-fixhub/court-05/5a1a430ec02eb914dd5749f3fe3ca00d80e884763bdb278b1ae8d37c9b2cdba1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -434, + "dataset": "marble-joined", + "doc_id": "5a1a430ec02eb914dd5749f3fe3ca00d80e884763bdb278b1ae8d37c9b2cdba1", + "engine": "marble-apple-vision", + "event_count": 37, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "27f9d8e7a54386fca54237b934baa08c3ace7eccb719dadbb660f587258cf927", + "output_sha256": "48dfcc4d9aec7457345077215ccbd3b30427cbc4db82a5b0c331bb40ac01d524", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5a30aeb87b7c1fb479935a0e8374e451e3b4a9f2bc4e44215ee4d9cd3c776bd1.md b/vision-fixhub/court-05/5a30aeb87b7c1fb479935a0e8374e451e3b4a9f2bc4e44215ee4d9cd3c776bd1.md new file mode 100644 index 0000000000000000000000000000000000000000..899b5d21ac92e35c26e00402ee7ed9e15c57c0db --- /dev/null +++ b/vision-fixhub/court-05/5a30aeb87b7c1fb479935a0e8374e451e3b4a9f2bc4e44215ee4d9cd3c776bd1.md @@ -0,0 +1,49 @@ +Case 1:22-cv-10904-JSR Document 301 Filed 08/25/23 Page 1 of 2 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-cv-10904 (JSR) +JPMORGAN CHASE BANK, N.A.., +Defendant/Third-Party +Plaintiff. +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +JAMES EDWARD STALEY, +Third-Party +Defendant. +DECLARATION OF FELICIA H. ELLSWORTH IN SUPPORT OF JPMORGAN +CHASE BANK, N.A.'s MEMORANDUM OF LAW IN OPPOSITION TO UNITED +STATES VIRGIN ISLANDS' MOTION TO EXCLUDE EXPERT OPINIONS OF +KIMBERLY MEHLMAN-OROZCO, +FONESCA, AND CARLYN IRWIN +Pursuant to 28 U.S.C. § 1746, I, Felicia H. Ellsworth, declare under penalty of perjury as +follows: +1. I am a member in good standing of the bar of the Commonwealth of Massachusetts. I am +one of the attorneys representing Defendant JPMorgan Chase Bank, N.A. ("JPMC") in +the above-captioned action and have been admitted to this Court pro hac vice. I am a +Partner with the law firm of Wilmer Cutler Pickering Hale and Dorr LLP, 60 State Street, +Boston, Massachusetts 02109. I am familiar with the facts set forth herein, and if called +as a witness, I could and would competently testify thereto. +1 + + +Case 1:22-cv-10904-JSR Document 301 Filed 08/25/23 Page 2 of 2 +2. Attached as Exhibit 1 is a true and correct copy of excerpts of the transcript from the June +30, 2023, Deposition of Kimberly Mehlman-Orozco, designated confidential pursuant to +the Protective Order in this matter and filed under seal. +3. Attached as Exhibit 2 is a true and correct copy of excerpts of the transcript from the July +6, 2023, Deposition of +Fonesca, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +4. Attached as Exhibit 3 is a true and correct copy of excerpts of the transcript from the July +6, 2023, Deposition of Carlyn Irwin, designated confidential pursuant to the Protective +Order in this matter. +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and +correct. +Dated: August 25, 2023 +/s/ Felicia Ellsworth +Felicia H. Ellsworth +2 diff --git a/vision-fixhub/court-05/5a30aeb87b7c1fb479935a0e8374e451e3b4a9f2bc4e44215ee4d9cd3c776bd1.receipt.json b/vision-fixhub/court-05/5a30aeb87b7c1fb479935a0e8374e451e3b4a9f2bc4e44215ee4d9cd3c776bd1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c58d4e7d5e383c73da7a17524c1e409c3837a0c8 --- /dev/null +++ b/vision-fixhub/court-05/5a30aeb87b7c1fb479935a0e8374e451e3b4a9f2bc4e44215ee4d9cd3c776bd1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "5a30aeb87b7c1fb479935a0e8374e451e3b4a9f2bc4e44215ee4d9cd3c776bd1", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "40c7e87df17f5de8a2c04b535d60038487f36376adef32a597954f70ad18379d", + "output_sha256": "1dfc5b29aabf0aa619b02e4e3ccb2759bc32da54da9422cbad3f7a39ba19b72b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5a46f75951fa43d145075418f8b446de8759fec915dda65b3d0e235c812f8b40.md b/vision-fixhub/court-05/5a46f75951fa43d145075418f8b446de8759fec915dda65b3d0e235c812f8b40.md new file mode 100644 index 0000000000000000000000000000000000000000..88e642cfa07c37069b28d6a6f924eda4a62af078 --- /dev/null +++ b/vision-fixhub/court-05/5a46f75951fa43d145075418f8b446de8759fec915dda65b3d0e235c812f8b40.md @@ -0,0 +1,69 @@ +Case 1:22-cv-10904-JSR Document 186-57 Filed 06/14/23 + + + + +Case 1:22-cV-10904-JSR Document 186-57 Filed 06/14/23 Page 2 of 3 +Date: Wednesday. April 16 2014 11:43 PM +Subject: Fwd: VI Dental License Application +From: Cecile de Jongh < +To: +JEE : +Please see below. +@yahoo.com> +With warm regards, +Cecile +Sent from my iPhone and misspellings courtesy of iPhone. +Begin forwarded message: +From: Deborah Peter < +@gmail.com> +Date: April 16, 2014 at 7:26:16 PM GMT-4 +To: Cecile de Jongh 4 +@yahoo.com > +Subjeet: Re: VI Dental License Application +Good Day Mrs. deJongh, +I spoke with Mr. Epstien and he had a few questions that I had to confer with the board for a response. he said it +was okay to reply to you via email. +• The applicant will have to complete dental shool before she can sit for the VI Clinical Dental Exam; +• There are currently no established residency programs in the territory; +• The newly proposed Dental Practice Act is slated to go before the Senate Committee on health on May +9th, once that process is vetted the board will have a clearer idea on what her options are moving forward +I hope this helps and enjoy your Easter. +On Wed, Apr 16, 2014 at 11:05 AM, Cecile de Jongh • +@yahoo.com > wrote: +Thank you I will have him call you. +With warm regards, +Cecile +Sent from my iPhone and misspellings courtesy of iPhone. +On Apr 16, 2014, at 11:04 AM, Deborah Peter < +@gmail.com> wrote: +Good Morning Mrs. deJongh, +Yes, I'm available he can call me 773-1311 ext. 3047. +Enjoy your Easter, +Deborah +On Wed, Apr 16, 2014 at 10:17 AM, Cecile de Jongh ‹ +@yahoo.com > wrote: +Good morning Deborah, +Would you be available to speak with Mr. Jeffrey Epstein today about the Dental + +ESTATE_JPMO23450 + + +Case 1:22-cv-10904-JSR Document 186-57 Filed 06/14/23 Page 3 of 3 +Licensure procedure? +With warm regards, +Cecile +On Wednesday. April 2, 2014 12:43 PM, Deborah Peter < +@gmail.com > wrote: +Good Day Mrs. deJongh, +I attached the VI dental licensure information and application packet as promised. The Dental Board +revised and submitted a new practice act which will debut in the Senate Health Committee on May 9, +2014. If all goes well, there will be significant changes and allowances for reciprocity. Hope this +information helps and please let me know if you need further assistance. +Sincere Regards. +Deborah +-Peter, MPA +Dir.Professional Licensure & Health Planning +340 773-1311 xt 3047 + +ESTATE_JPM023451 diff --git a/vision-fixhub/court-05/5a46f75951fa43d145075418f8b446de8759fec915dda65b3d0e235c812f8b40.receipt.json b/vision-fixhub/court-05/5a46f75951fa43d145075418f8b446de8759fec915dda65b3d0e235c812f8b40.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2305963daa654bfd8b8b4273a163c611fa0626ad --- /dev/null +++ b/vision-fixhub/court-05/5a46f75951fa43d145075418f8b446de8759fec915dda65b3d0e235c812f8b40.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -82, + "dataset": "marble-joined", + "doc_id": "5a46f75951fa43d145075418f8b446de8759fec915dda65b3d0e235c812f8b40", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "8258aee7e704bad2756c22fed62f8c49a8b98fcb19146108ed64809bfed964d3", + "output_sha256": "24aab4560740ef3ddec962251ca103e9ae17ea3366eef1ea5119eeb7757dedd8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5a4c744987ed88d5990c82eaf4318014b954d00d481c7522f5583df13848e499.md b/vision-fixhub/court-05/5a4c744987ed88d5990c82eaf4318014b954d00d481c7522f5583df13848e499.md new file mode 100644 index 0000000000000000000000000000000000000000..f267bedce7d1ee43fa652a4d76466ab725e74c10 --- /dev/null +++ b/vision-fixhub/court-05/5a4c744987ed88d5990c82eaf4318014b954d00d481c7522f5583df13848e499.md @@ -0,0 +1,125 @@ +Case 1:22-cV-10904-JSR Document 285-49 Filed 08/15/23 Page 1 of 4 + + + +Case 1:22-cv-10904-JSR Document 285-49 Filed 08/15/23 + +From: +Sent: +To: +CC: +Subject: +mary.erdoes@jpmorgan.com [mary.erdoes@jpmorgan.com] +2/8/20088:52:41 PM +dorothy.litos@jpmorgan.com +Re: DALE +- Travel Request on Client's plane approved +Approved +" Dorothy C Litos +-- Original Message -... +From: Dorothy C Litos +Sent: 02/08/2008 10:49 AM PST +Io: Mary Erdoes +Cc: Andrew +Dale +Subject: DALE +- Travel Request on +Client's plane approved +Hello Mary, +I hope you are doing well. +Compliance is requesting an executive member's approval for the request below. I gave approval locally last +week for Dale +to accept the offer by Michael Ovitz to fly with him on his private plane to the JPM AIS +conference in Miami. +Please let me know your thoughts ... +Thank you, +Dots +Dorothy Litos +Vice President +JPMorgan Private Bank +Direct: (310) 407-2016 Los Angeles +-- Forwarded by Dorothy C Litos/JPMCHASE on 02/08/2008 10:08 AM ----- +Colleen P +Dooley/JPMCHASE +02/08/2008 09:07 AM +ToDorothy C Litos/JPMCHASE@JPMCHASE +ceStacey N +/JPMCHASE@JPMCHASE +SubjectRe: Fw: Travel Request on Client's plane approved CJ +Dots- as per the Code of Conduct section 6.5.2 (f) travel cannot be accepted without approval in writing from an +executive committee member or someone who reports to an executive committee member with a copy to the +Code Specialist (me). Please forward to me when you have the approval. + +JPM-SDNYLIT-00099558 + + +Case 1:22-cV-10904-JSR Document 285-49 Filed 08/15/23 Page 3 of 4 +Colleen P. Dooley +Vice President +Private Bank/Private Client Services Compliance +phone 404-926-2518 +fax 404-601-6882 +JPMCHASE +JPMorgan Private Bank +Dorothy C +Litos/JPMCHASE +01/29/2008 12:41 PM +ToPB Gift Exceptions@JPMCHASE +ccDale E +UPMCHASE@IPMCHASE, +1. Marbeth X +Sobray/JPMCHASE@JPMCHASE +SubjectTravel Request on Client's plane approved CJ +I have approved for Dale +• to accept an invitation by his client and personal friend, Michael Ovitz to round +trip on his personal plane to the JPM's Alternative Investment Summit in Miami. Mr. Ovitz is a long standing +client of the Bank bio below: +Ovitz has been a client of the client of the LA office for about a year after being a prospect for several +years. Through Jeffrey Epstein, Jes Staley has established a direct dialogue with Ovitz which has enabled +us to pursue various opportunities in connection with his Disney +options, his TV production company +and other entertainment-related projects. This new entity is the borrower on the restructuring of a credit +facility for which the borrower will be Artists Production Group (CKE Associates, LLC, Artists Management +Group, LLC, Artists Television Group, LLC were the original borrowers). Dale l +was Mr. Ovitz CFO for +the Ovtiz Family office prior to his employment as a Senior Banker at JPMorgan. In 2001 Ovitz shuttered +his television production company (ATG) and in 2002 sold his management company (AMG) to The Firm i +. He is currently producing films under the Artists Production Group (APG) banner and +providing management/agency services for a select hand full of clients (Tom Clancy, Michael Crighton). In +addition, he is actively pursuing an NFL team for Los Angeles by working with a local developer Bill +Geherity as a consultant. Ovitz recently negotiated a $10MM advance from the NFL to be used for Stadium +planning and feasibility testing. His involvement is unclear, but seems to be purely a consulting roll for the +stadium with hopes of having a piece of the stadium and a larger roll in a football team. Ovitz also +remains active in the art world buying, selling and collecting major art pieces. Ovitz maintains one of the +top 200 private art collections in the world. He has a very successful Japanese restaurant in west Los +Angeles, Hamasaku. He is considering opening another location in Hollywood area. He has several real +estate holdings, commercial and personal, and is planning to build a new residence in the Beverly hills +area. His wife Judy is actively building a horse ranch in the Ojai, California area. +Dorothy Litos +Vice President +JPMorgan Private Bank +Direct: (310) 407-2016 Los Angeles + +JPM-SDNYLIT-00099559 + + +Case 1:22-cV-10904-JSR Document 285-49 Filed 08/15/23 Page 4 of 4 +IRS Circular 230 Disclosure: +JPMorgan Chase & Co. and its affiliates do not provide tax advice. Accordingly, any discussion of U.S. tax +matters contained herein (including any attachments) is not intended or written to be used, and cannot be used, +in connection with the promotion, marketing or recommendation by anyone unaffiliated with JPMorgan Chase +& Co. +of any of the matters addressed herein or for the purpose of avoiding U.S. tax-related penalties. +" Dale E +JPMCHASE +Dale E +JPMCHASE +01/29/2008 09:08 +AM +To"Dorothy C. Litos" +cc +Subject +I have been invited to fly on ovitz plane with dreyer to miami and possibly back. Would you please approve? +Sent from my BlackBerry Wireless Handheld + +JPM-SDNYLIT-00099560 \ No newline at end of file diff --git a/vision-fixhub/court-05/5a4c744987ed88d5990c82eaf4318014b954d00d481c7522f5583df13848e499.receipt.json b/vision-fixhub/court-05/5a4c744987ed88d5990c82eaf4318014b954d00d481c7522f5583df13848e499.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0340ae6d6e7103b557cef3951a1211345132e344 --- /dev/null +++ b/vision-fixhub/court-05/5a4c744987ed88d5990c82eaf4318014b954d00d481c7522f5583df13848e499.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -94, + "dataset": "marble-joined", + "doc_id": "5a4c744987ed88d5990c82eaf4318014b954d00d481c7522f5583df13848e499", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "addbb342b9d94d36a77acb2be379bd681a2554666d61fe3bac3f096a0b0b42b1", + "output_sha256": "dcbb60f4e637315a7744df2cdfcfb8f76163d35479cb855a8075e1fb493aab53", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5aa412ae3483530fa66d19f73bda2b122a08979ddef5f64645db515c475c493b.md b/vision-fixhub/court-05/5aa412ae3483530fa66d19f73bda2b122a08979ddef5f64645db515c475c493b.md new file mode 100644 index 0000000000000000000000000000000000000000..b501841fbbe4f9972d0f15a7771025ce41aff4b6 --- /dev/null +++ b/vision-fixhub/court-05/5aa412ae3483530fa66d19f73bda2b122a08979ddef5f64645db515c475c493b.md @@ -0,0 +1,1350 @@ +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 1 of 46 +Attachment A + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 2 of 46 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +Case Number: 1:22-cv-10904-JSR +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +JAMES EDWARD STALEY +Third-Party Defendant. +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +MEMORANDUM OF LAW IN SUPPORT OF +MOTION FOR PARTIAL SUMMARY JUDGMENT + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 3 of 46 +TABLE OF CONTENTS +INTRODUCTION +LEGAL STANDARD.. +ARGUMENT.. +1 +3 +4 +I. JPMORGAN PARTICIPATED IN EPSTEIN'S SEX-TRAFFICKING VENTURE IN +VIOLATION OF TVPA 18 U.S.C. § 1591(a)(2). +A. Epstein Engaged in a Sex-Trafficking Venture. +B. JPMorgan Knew or Recklessly Disregarded that Epstein Ran a Sex-Trafficking Venture 5 +i. In 2006, JPMorgan Knew Epstein Was Engaged in Sex-Trafficking • +a. Epstein Admitted the Conduct (but Not the "Ages") to Staley +4 +4 +. 5 +6 +b. JPMorgan's Own Diligence Gave It Reason to Suspect Epstein and Ghislaine +Maxwell Early On.. +7 +c. JPMorgan Had Corroborating Information on +and +7 +9 +d. JPMorgan Had Information about Epstein's Cash Withdrawals. +ii. After July 2006, JPMorgan Learned More Information that Fed Its Knowledge of +Epstein's Sex-Trafficking, including that Epstein's High-Powered Lawyers Helped +Him Avoid Federal Sex-Trafficking Charges +10 +ili. JPMorgan Knew Epstein Was Connected to the MC2 Modeling Agency He Was +Accused of Using to Traffic and Abuse "Underage Models" +11 +iv. JPMorgan Knew of Reports that Epstein Settled Dozens of Civil Lawsuits Alleging +Child Sex-Trafficking • +v. JPMorgan Knew Epstein's 2008 Conviction Covered Sex-Trafficking Conduct. +vi. Based on Its Own Human Trafficking Work, JPMorgan Knew Epstein Was Engaged +Human Trafficking.. +, 12 +... 13 +13 +vii. In 2008, JPMorgan Knew the Feds Were Connecting Certain Transactions to +Epstein's Sex-Trafficking.......... +vili. JPMorgan Employees Had Personal Knowledge of Epstein's Sex-Trafficking... 15 +C. JPMorgan Participated in Epstein's Sex-Trafficking Venture +D. JPMorgan Benefited from Participation in Epstein's Sex-Trafficking Venture. +14 +16 +21 +II. JPMORGAN OBSTRUCTED ENFORCEMENT OF THE TVPA IN VIOLATION OF +18 U.S.C. § 1591(d). +24 +III. THE USVI'S REQUESTED RELIEF FOR VIOLATIONS OF THE TVPA +.... 27 +IV. JPMORGAN'S EQUITABLE AND FAULT-SHIFTING DEFENSES DO NOT APPLY +TO THE GOVERNMENT'S TVPA PARENS PATRIAE CLAIMS +27 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 4 of 46 +A. JPMorgan's Defenses are Barred as Applied to Sex Offender Registry Issues +30 +i. The Government's Investigations or Monitoring of Epstein Cannot Form the Basis of +Viable Affirmative Defenses ...... +.31 +ii. The Discretionary Act of Granting a Waiver of Notification Periods for Overseas +Travel is Not Grounds to Shift Fault to the Government. +33 +B. JPMorgan's Defenses are Barred as Applied to the Economic Development +Commission's Grant of Tax Benefits to Epstein's Companies +C. JPMorgan Has No Viable Defenses Based on Activity of Cecile De Jongh +CONCLUSION. +35 +38 +39 +ii + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 5 of 46 +TABLE OF AUTHORITIES +Cases +Alfred L. Snapp v. Puerto Rico, +458 U.S. 592 (1982) +27 +City of New York v. FedEx Ground Package System, Inc., +314 F.R.D. 348 (S.D.N.Y. 2016). +27, 29,30, 34 +Coffey v. C.I.R., +663 F.3d 947 (8th Cir. 2011). +35 +Donovan v. Fed. Clearing Die Casting Co., +655 F.2d 793 (7th Cir. 1981). +31 +FTC v. Crescent Publ. Grp., Inc., +129 F. Supp. 2d 311 (S.D.N.Y. 2001) +29 +Groh v. Ramirez, +540 U.S. 551 (2004) +31 +Harlow v. Fitzgerald, +457 U.S. 800 (1982) +35 +HH v. G6 Hospitality, Inc., +No 2:19-cv-755, 2019 WL 6682152 (S.D. Ohio Dec 6, 2019) +21 +Maldonado by and through Ochoa v. City of Sibley, +58 F.4th 1017 (8th Cir. 2023).. +34 +McGaughey v. District of Columbia, +684 F.3d 1355 (D.C. Cir. 2012) .. +34,37 +Olin Corp. v. Lamorak Ins. Co., +332 F. Supp. 3d 818, 839 (S.D.N.Y. 2018) (Rakoff, J.).. +.. 4 +v. Gov't of the Virgin Islands, +847 F.2d 104 (3d Cir. 1988). +34,36 +State of New York v. UPS, Inc., +160 F. Supp. 3d 629 (S.D.N.Y. 2016).. +30 +U.S. v. One +Crystal Covered Bat Tour Glove & Other Michael +Memorabilia, +2013 WL 12196595 (C.D. Cal. Aug. 19, 2013) +32 +United States v. Angell, +292 F.3d 333 (2d Cir. 2002) +29 +United States v. Philip Morris Inc., +300 F. Supp. 2d 61 (D.D.C. 2004) +29 +United States v. Vineland Chem. Co., Inc., +692 F. Supp. 415 (D.N.J. 1988) +30 +ili + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 6 of 46 +Statutes +14 V.I.C. § 1724 +14 V.I.C. § 1724(b)(4) +14 V.I.C. § 1728(a) ... +18 U.S.C. § 1591(a)(1) +18 U.S.C. § 1591(a)(2). +18 U.S.C. § 1591(c) .. +18 U.S.C. § 1591(d). +18 U.S.C. § 1595(d).. +26 U.S.C. § 934(b)(1) . +29 V.I.C. § 701(a). +29 V.I.C. § 701(c) +29 V.I.C. § 705(a) +29 V.I.C. § 708. +29 V.I.C. § 722(4). +29 V.I.C. § 1101(a) +29 V.I.C. § 1101(b) +Rules +Fed. R. Civ. P. 56(c). +Regulations +12 C.F.R. § 21.11(c)(2) +12 C.F.R. § 21.11(d). +31 +33 +...33 +4,7 +.. 3, 4,27 +... 7 +3,24,27 +29,30 +.. 35 +35 +37 +36 +37 +37 +35 +35 +3 +20 +20 +iv + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 7 of 46 +INTRODUCTION +In July 2006, after his arrest for felony sex crimes and extensive news coverage detailing +unlawful sex acts with underage girls, Jeffrey Epstein admitted to James (Jes) Staley (then CEO +Asset and Wealth Management ("A WM")), who reported it to Mary Erdoes (then CEO Global +Private Bank ("PB")), that he had engaged in sex with multiple young women for money, only +denying the girls' "ages." At that time, JPMorgan could have immediately exited Epstein-but the +Bank knew, from Douglas (Sandy) Warner, when he was head of JPMorgan, Epstein is "one of +the most connected people I know in New York." In 2003, Epstein was, by double, the top revenue +generator in the Private Bank, and the source of Google co-founder Sergey +(*one of the largest +[relationships] in the Private Bank, of +$4BN**), Glenn +(billionaire founder of Highbridge), +and many other ultra-wealthy clients and connections, which would come to include Bill Gates, +Black, Larry Summers, the Sultan of Dubai, Prince Andrew, Ehud Barak, +Pritzker, +Lord Peter Mandelson, and Prime Minister Netanyahu. In 2004, Epstein—together with Jamie +Dimon (then CEO-in-waiting) +—was an integral part of JPMorgan's game-changing acquisition of +Highbridge. The next year, +Epstein was too big to fail. +So, JPMorgan did not exit Epstein in 2006. Or 2007. Or 2008. Or 2009. Or 2010. Or 2011. +Or 2012. Or the first half of 2013, when it continued to open new accounts for him. SUF 9|386.' +And, even after his exit right up until his arrest in 2019, JPMorgan continued to work with Epstein. +Only months before his arrest in July 2019, Erdoes and Stacey +(General Counsel), +1 "SUF" references are to the Statement of Material Facts as to which Government of the United +States Virgin Islands Contends there is No Genuine Dispute (filed concurrently). + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 8 of 46 +excitedly received a referral from Epstein for Kathryn Ruemmler, former +House counsel +and, in +words, "a rock star litigator .. she would be a great client." +Rather than exit Epstein in 2006, JPMorgan handled millions of dollars in payments to +Epstein's other "rock star" lawyers who the Bank knew were working to discredit Epstein's +victims and help Epstein avoid federal sex-trafficking charges. Leading up to Epstein's plea deal +in 2007 and guilty plea in 2008, +years of +financial transactions, showing extensive payments to recruiters and victims, millions in cash +withdrawals, and information about dozens of potential recruiters, victims, and other material +witnesses. JPMorgan banked all the girls and women publicly alleged in 2006 to be recruiters, +accomplices, or victims, including +, and Ghislaine +Maxwell. JPMorgan knew that +- who Epstein was reported to have referred to as his +"Yugoslavian sex slave"—in fact came from Yugoslavia as a teenager in 2004 supposedly to work +as a "model" and was sponsored by Epstein. For years, JPMorgan handled Epstein business with +MC2 Model Management knowing Epstein was accused of using the supposed modeling agency +to traffic and abuse underage girls. +At the same time, and for the next seven years, JPMorgan—self-described as Epstein's "#1 +bank" at the time, SUF 9[174 continued to participate in Epstein's sex-trafficking venture. It +"really never stopped" handling his excessive cash withdrawals despite tying them to his felony +sex crimes; did not question his cash-for-fuel to travel to foreign countries explanation, even when +he was in jail and on house arrest; made millions of dollars more in payments to co-conspirators, +including Maxwell, recruiters and victims, including many girls and women with Eastern +European surnames or located in Eastern Europe, from where JPMorgan knew Epstein was +reported to have trafficked girls; and continued to extend the loan to MC2, which, for all it knew, +2 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 9 of 46 +was a "payment for services as a procurer." Even when JPMorgan knew that federal prosecutors +had subpoenaed Bear Stearns (which it acquired in 2008) for account and specific transaction +information tied to Epstein, JPMorgan +and +went right on handling many more. The entire time, the cynical jokes within the company also +never stopped-from +asking if Epstein was at a party with "Miley Cyrus," to +David Brigstocke (then CFO AWM) comparing another client's house to Epstein's: "Reminded +me of JE's house, except it was more tasteful, and fewer nymphettes." SUF 99181-82, 190, see +also SUF 19179-180, 183-89. Only in August 2019—after Epstein's arrest and death and when +there were no more referrals or other benefits to be had +-even though it had all the information +in real-time, not "[h]indsight" as Dimon (CEO) misrepresented to CNN. SUF 9[418. Accordingly, +the Government is entitled to judgment as a matter of law for JPMorgan's participation in Epstein's +sex-trafficking venture and obstruction of federal prosecutors' enforcement of the law in violation +of the Trafficking Victims Protection Act ("TVPA"), 18 U.S.C. §§ 1591(a)(2) and (d). +The Government also is entitled to judgment as a matter of law on JPMorgan's equitable +and fault-shifting affirmative defenses (Defenses 5 to 8). The legal deficiencies that left the Court +"skeptical" that the defenses would survive summary judgment persist and no facts have been +developed during discovery that would revive these deficient defenses. +LEGAL STANDARD +Summary judgment is appropriate "if the pleadings, the discovery and disclosure materials +on file, and any affidavits show that there is no genuine issue as to any material fact and that the +movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(c). "Where the moving party +3 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 10 of 46 +has documented particular facts in the record, the burden shifts to the opposing party to adduce +contrary record evidence sufficient to create a genuine dispute of material fact." Olin Corp. v. +Lamorak Ins. Co., 332 F. Supp. 3d 818, 839 (S.D.N.Y. 2018) (Rakoff, J.). "To do so, the opposing +party cannot merely make conclusory assertions to the contraryl.J" Id. +ARGUMENT +JPMORGAN PARTICIPATED IN EPSTEIN'S SEX-TRAFFICKING VENTURE +IN VIOLATION OF TVPA 18 U.S.C. § 1591(a)(2) +A. Epstein Engaged in a Sex-Trafficking Venture +JPMorgan does not dispute Epstein was engaged in sex-trafficking: "Epstein was engaged +in horrendous criminal activity, including sex trafficking. That's not something being contested at +all by JPMorgan." SUF 91. "Epstein's behavior was monstrous ... the survivors ... suffered +unimaginable abuse at the hands of this man ...[who] commit[ted] heinous crimes." SUF 92. +JPMorgan acknowledged +in its own due diligence, respectively, +that Epstein +and ran a "sex-trafficking ring." SUF 9913-5. +Epstein was arrested on July 6, 2019 on federal charges of sex-trafficking of minors and on August +10, 2019 died in prison. SUF 99I6-7. Ghislaine Maxwell was convicted in 2022 for conspiring with +Epstein to engage in sex-trafficking. SUF 98. In 2008, Epstein was convicted for solicitation of an +underage girl for prostitution, SUF T9, a covered act under the TVPA. 18 U.S.C. § 1591(a)(I). In +upholding his Level 3 sex offender status imposed with that conviction, a New York appeals court +found "clear and convincing" evidence Epstein had "committed multiple offenses against a series +of underage girls." SUF 9910-11. Over the years, many victims have come forward and described +being sex-trafficked by Epstein, including in the U.S. Virgin Islands ("USVI"). +4 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 11 of 46 +SUF 9912-31. JPMorgan also +handled millions of dollars in payments from Epstein to known co-conspirators, recruiters, victims, +girls and women until 2019, including payments to women in years that coincided with their trips +to the USVI. SUF 432 and infra Part I.C. +B. +JPMorgan Knew or Recklessly Disregarded that Epstein Ran a Sex- +Trafficking Venture +JPMorgan had "knowledge of Epstein's sex-trafficking venture, either directly or by +recklessly disregarding what was plainly to be seen." Op. and Order, May 1, 2023 (Dkt. 130) at +28 ("Order"). The Government uses "knew" or "knowledge" herein to mean direct knowledge or +reckless disregard. +In 2006, JPMorgan Knew Epstein Was Engaged in Sex-Trafficking +In July 2006, Epstein was indicted for felony solicitation of prostitution and arrested. +Numerous JPMorgan senior executives (including Staley, Erdoes, Catherine Keating (then CEO +US PB)) knew of Epstein's arrest and related news coverage, including a Palm Beach Post article +which stated: "Epstein paid to have underage girls and young women brought to his home, where +he received massages and sometimes sex" and "police thought there was probable cause to charge +Epstein with unlawful sex acts with a minor and lewd and lascivious molestation." SUF 9933, 41- +46. JPMorgan's own due diligence process required that it monitor news reports about customers. +SUF 19134-40. The Palm Beach Post article detailed evidence from police documents, including: +• A college student gave Epstein a naked massage and then "brought him six girls, ages 14 to +16, for massage and sex-tinged sessions" at Epstein's home. +• Police obtained statements from five alleged victims and 17 witnesses. Police contend Epstein +"had sex with the girls" on three occasions. +met Epstein at age 17 and was recruited to massage him. Epstein told her he +would "pay her to bring him more girls—the younger the better." She stated she once brought +5 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 12 of 46 +a 23-year-old woman to him and "Epstein said she was too old...." She brought six girls to +Epstein and said the girls were paid $200 for each session. +told police, "I'm like a Heidi Fleiss." +• A 27-year-old Epstein employee, +massage table. +would arrange the sessions and prepare the +• One 14-year-old victim recounted the details of her encounter in February 2005 including +being paid $300 for a massage in her bra and panties. For bringing this child to Epstein, +received $200. +• Police scoured the trash from Epstein's house and found notes with names and phone numbers, +sex toys and female hygiene products. Notes stated that one girl could not "come over at 7 p.m. +because of soccer. Another said a girl had to work Sunday—'Monday after school?' Another +said a girl leaves school at 11:30 a.m. and would come over the next day[.J" +SUF 9943-46. Another July 2006 news report said the police submitted arrest warrant requests for +and +The same report stated a girl told police she was paid by Epstein +to have sex with +as Epstein watched, and "Epstein bragged he brought +into the United States to be his Yugoslavian sex slave." SUF 99|48-49; see also SUF +950 (August news report). JPMorgan knew from its own work on human trafficking that "Sexual +Slavery" means "the coercion of the unwilling into various sexual practices." SUF 951. News +around the time of Epstein's arrest also reported that "It]wo of Epstein's former employees told +investigators that young-looking girls showed up to perform massages two or three times a day +when Epstein was in town." SUF 952. The news explained that Epstein paid $200 or $300 cash to +the girls and $200 cash to +a. +for recruiting the girls. SUF 1943, 45. +Epstein Admitted the Conduct (but Not the "Ages") to Staley +On July 25, 2006, Staley met with Epstein in person, and Epstein admitted to the alleged +conduct of engaging in sex for money with young women-only denying the "ages." SUF 953. +Staley communicated the exchange to Erdoes the next day: "I went and saw him last night. I've +never seen him so shaken. He also adamantly denies the ages." SUF 9|54. Solicitation of a minor +6 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 13 of 46 +for prostitution is a covered act under the TVPA, and Epstein "had a reasonable opportunity to +observe [the victim]," so it need not be proved "the defendant knew, or recklessly disregarded the +fact, that the person had not attained the age of 18 years." 18 U.S.C. $§ 1591(a)(1) and (c). Staley +also spoke to Dimon about the "very public" indictment of the Bank's client, Epstein. SUF 955. +JPMorgan's Own Diligence Gave It Reason to Suspect Epstein +and Ghislaine Maxwell Early On +By 2006, JPMorgan already had reason to suspect Epstein's sex-trafficking—and +Maxwell's involvement. In 2003, as part of the Bank's due diligence for an Epstein account, +JPMorgan reviewed the Vanity Fair profile "The Talented Mr. Epstein," which reported Epstein's +penchant for "young." "foreign," "model types," and his "best friend" Maxwell "summon[ing]" a +young woman for him and throwing a party attended by Prince Andrew and "filled" with "young +Russian models." SUF 99|56-59. In 2003, JPMorgan also knew that Maxwell was involved with +Epstein in structuring cash withdrawals, SUF 9960-62, a red flag for trafficking, SUF 9963-64. +Yet, the Private Bank opened an account for Maxwell in 2003, on Epstein's referral, noting +Maxwell was a "companion/long-time friend of Jeffrey Epstein." SUF 165. By Epstein's arrest, +JPMorgan knew it had made over $25 million in payments to Maxwell from Epstein. SUF 967. +News reports related to Epstein's 2006 arrest again described Epstein's relationship with Maxwell. +SUF 9|52. JPMorgan continued to handle payments from Epstein to Maxwell, including $7 million +for the purchase of a helicopter. SUF 9|223. Later reports again alleged Maxwell "solicited young +girls for Epstein"—identified as a "human rights" issue by JPMorgan. SUF 966. +c. +JPMorgan Had Corroborating Information on +and +JPMorgan had significant corroborating evidence of Epstein's sex crimes by July 2006 +and knowledge of ongoing conduct after July 2006. JPMorgan knew that alleged accomplice +7 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 14 of 46 +worked for Epstein and had +-just months prior to his arrest-communicated with +about Epstein setting up a meeting between Staley and the Sultan of Dubai. SUF 9|68. | +was +also a customer of the Bank. SUF 9969-70. JPMorgan, in 2005, made two separate $25,000 +payments from Epstein's accounts to +SUF 171. After police reports identified her as a +recruiter in 2006, JPMorgan continued to handle payments to | +totaling over $675,000 from +Epstein's accounts. SUF 9|72. +JPMorgan also had information related to trafficking victim and accomplice +also a customer of the Bank. SUF 9|73. In 2004, sponsored by Epstein, JPMorgan opened accounts +and credit cards for two teenagers, +another victim, SUF 9|23, and +"models in NYC and friends of Jeffrey Epstein." SUF 99|74, 75, 77. JPMorgan's Due Diligence +Report ("DDR") on +was approved by the Private Bank even though the report had no +birthdate, confirmed SSN, or a Passport or Driver's License Number. SUF 176. Epstein's Banker +at the time (Mary (Rieth) +never met +as JPMorgan's process contemplated +even after news reports that Epstein referred to her as his "Yugoslavian sex slave." SUF 976. +JPMorgan knew that Epstein said +came to the US from Yugoslavia and lived at a +building owned by Epstein's brother. SUF 1177, 79. Further, JPMorgan knew it had made more +than $36,000, $67,000, and $82,000 in payments from Epstein's account to +in 2004, +2005, and 2006, respectively, even though Epstein represented her net worth was $100,000 from +supposed "modeling assignments." SUF T180, 78. JPMorgan also knew +'s "debit +transactions" at the time—which AML compliance only reviewed more than four years later— +were "enlighting [sic] as compared to countless stories related to [Epstein's] escapades. Lots of +salon, lingerie shops, drug stores ny palm beach and in st +(his places of residence). Plus +lots of video like girls gone +and some other shops not fit for my good catholic upbringing!" +8 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 15 of 46 +SUF 181. JPMorgan's own Human Trafficking +paper discussed "upscale" sex-trafficking +operations "incurring] expenses such as jewelry, lingerie, cosmetics, [and] sex toys." SUF 982. +Even after she was identified in 2006, JPMorgan continued to handle payments to +totaling over $600,000 from Epstein's JPMorgan accounts. SUF 983. JPMorgan +SUF +for +99[84-85. JPMorgan also knew that Epstein sponsored credit cards for +and +"travel| ] through Paris, Europe and US Virgin Islands and US monthly." SUF 86. +JPMorgan Had Information about Epstein's Cash Withdrawals +On October 17, 2006, in light of the derogatory information related to Epstein's "felony +charges of soliciting underage prostitutes," JPMorgan Private Bank held a "Rapid Response" +meeting, which were "escalations of derogatory information to management." Private Bank +identified Epstein's frequent cash withdrawals as worthy of note in conjunction with his "felony +charges of soliciting underage prostitutes." "Cash withdrawals are routinely made in amounts for +$40,000 to $80,000 several times a month, which total over $750,000 year to date." SUF 99190-93. +JPMorgan compliance staff acknowledged Epstein was "known to pay cash for his massages" and +"minors are the issue." SUF 994. Three "massages" a day with girls paid $200-$300 cash and +recruiters paid $200 cash—as JPMorgan knew was reported—is about $40,000 cash per month. +JPMorgan knew that in the time period of the incidents investigated by the Palm Beach police, and +prior to Epstein's plea, it had handled nearly $1.75 million in cash withdrawals for Epstein. SUF +995. +SUF 1196-97. +9 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 16 of 46 +The large cash withdrawals "really never stopped"—and were ultimately the claimed +reason for JPMorgan's parting with Epstein in 2013 when "combined with his personal history." +SUF 9998-99. Epstein's 2011 explanation that the cash was for jet fuel for his foreign travel was +and not supported by any receipts +or other documentation. JPMorgan—unbelievably—just took convicted felon Epstein "at his +word." Further, JPMorgan knew Epstein was in jail and on house arrest from July 2008 through +July 2010 and thus not traveling overseas. SUF 991100-106. In any event, JPMorgan's diligence +cited reports that Epstein traveled to foreign countries to traffic young women, SUF 9|107, so +whether to pay for that travel, or to pay victims and recruiters, or both, JPMorgan knew the cash +was connected to Epstein's sex-trafficking. +ii. +After July 2006, JPMorgan Learned More Information that Fed Its +Knowledge of Epstein's Sex-Trafficking, including that Epstein's High- +Powered Lawyers Helped Him Avoid Federal Sex-Trafficking Charges +JPMorgan also knew that Epstein's wealth and "high-powered" lawyers allowed him to +escape more serious charges including federal sex-trafficking charges. In 2006, JPMorgan's +diligence included multiple news reports that Epstein "assembled a team of star lawyers"- +including Alan Dershowitz, Gerald Lefcourt, Roy Black, and Jack Goldberger—"to undermine the +credibility of the 14- to 17-year-old girls" and challenge the "distorted" view of the case "presented +by the Palm Beach Police." SUF 9Il 108, 110. Reports said Epstein used Black to hire private +investigators to "pos[e] as police officers" and to review with witnesses what to say to actual police +officers. SUF 9|110. In 2006 and 2007, JPMorgan reviewed reports that federal prosecutors were +looking to bring child sex-trafficking charges against Epstein and that his lawyers were +"negotiating a deal" to avoid those charges. SUF 9[112, see also SUF 150 (FBI considering +investigating for federal child sex crimes). JPMorgan later acknowledged reports that Epstein +10 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 17 of 46 +"supposedly bought his way to a lesser sentencing" and "paid a whole series of girls to stay quiet." +SUF 9113. JPMorgan was handling millions of dollars in payments to those lawyers at that timeincluding numerous +$100,000 payments—and continued to handle tens of millions in +payments to lawyers. SUF 99L 127. +On September 24, 2007, Epstein agreed to plead guilty to two prostitution charges in state +court, including the solicitation of a minor to engage in prostitution, in exchange for a federal nonprosecution agreement ("NPA") providing him with immunity from federal child sex-trafficking +charges. Under the NPA, Epstein also waived his right to contest liability and damages in civil +lawsuits by minor girls identified by the NPA. The NPA identified +, and Lesley +Groff as Epstein's co-conspirators in soliciting underage girls for commercial sex. SUF 99114, +118-21. JPMorgan knew of reports of the plea deal beginning in 2007. SUF 99115; see also SUF +99116-17 (2008). The NPA later became public, and JPMorgan was aware of it. SUF 99122-24. +In October 2007, Anne Verdon (then General Counsel PB) received requested information +about Epstein, his transactions, and the news coverage. This research connected the dots between +Epstein's financial transactions at the Bank—his large, frequent cash withdrawals, credit cards for +and +and transfers to +and his illegal conduct. The diligence showed +, who had talked to police ('T'm like a Heidi Fleiss"), had a "revoked" credit card, while +, who did not talk to police, still had an "active" credit card under Epstein. SUF 99l 125-27, +43. JPMorgan continued with business as usual. +ili. +JPMorgan Knew Epstein Was Connected to the MC2 Modeling Agency +He Was Accused of Using to Traffic and Abuse "Underage Models" +A news report surfaced in 2007 of industry speculation that massage maven Jeffrey +Epstein is a secret financial backer of the agency being run by scandal-scarred Jean-Luc Brunel, +who was once accused of taking advantage of underage models." "Epstein reportedly gave millions +11 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 18 of 46 +to start MC2, which opened in October 2005." "[Epstein's] a desperate old man that fantasizes and +takes advantage of young girls.'" Epstein's rep, Howard Rubenstein, said, "He has no business +relationship with [Brunel and MC2]." SUF 9[128. But JPMorgan knew at the time of the report that +Rubenstein was covering up for Epstein. In 2005, JPMorgan had extended a $1 million Stand By +Letter of Credit ("SBLC") for Epstein to backstop a loan to MC2. SUF 9129. +Only two weeks after the news about Epstein's ties to Brunel and MC2, +, among +others, discussed the MC2 SBLC, which the Bank renewed through March 2011. SUF 99 130-32. +Even though Epstein was set to plead guilty to felony sex crimes, JPMorgan did not determineand as late as 2011 still did not know—if the $1 million was a "payment for services as a procurer." +SUF 919138-39. JPMorgan would review multiple reports about child sex-trafficking by Epstein, +Brunel, and MC2—"Brunel, owner of MC2 and Jeffrey Epstein engaged in racketeering that +involved luring in minor children for sexual play for money"—all the while continuing to extend +the $1 million SBLC. SUF 99 130-31, 134-39. +-who JPMorgan was supposed to but +did not meet with- +SUF 9140, +iv. +JPMorgan Knew of Reports that Epstein Settled Dozens of Civil +Lawsuits Alleging Child Sex-Trafficking +Then came the reports of the civil lawsuits—another category of information that was +supposed to be part of JPMorgan's due diligence. SUF 914. In 2007, Epstein was "bracing for a +slew of lawsuits from as many as 40 young women[.J" SUF 9[142. By early 2008, Erdoes and Lisa +Waters (then a Managing Director AWM), among others, knew of multiple news outlets reporting +the first lawsuit "against JE- sexual abuse of minor etc. etc." Then the next: "the teen ... says she +was lured to Epstein's Palm Beach mansion and then sexually assaulted in his massage room." +SUF 99[143-45. In 2010, JPMorgan knew of reports that "Epstein had settled more than two dozen +12 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 19 of 46 +lawsuits and claims against him by teen-agers who say they were lured to his Palm Beach mansion +to give him sexually charged massages and/or sex in exchange for money." "These same civil +complaints allege that young girls from South America, Europe, and the former Soviet republics +... were recruited for Epstein's sexual pleasure." SUF 99137-38. +V. +JPMorgan Knew Epstein's 2008 Conviction Covered Sex-Trafficking +Conduct +On June 30, 2008, Epstein pled guilty to felony solicitation of prostitution and procurement +of a 14-year-old minor to engage in prostitution and was "sentenced to 18 months in jail" and +"required to register as a sex offender." SUF 9146-47. +I, as described above, +SUF 193-4, 148. In 2011, William Langford (then Global Head of Compliance) +communicated to Steve Cutler (then General Counsel) "concern about retaining Epstein as a +client. Cutler testified: "Those concerns are heightened, if you will, by the human trafficking +initiative that we're doing, given that he was convicted of these crimes." SUF 9149. +vi. +Based on Its Own Human Trafficking Work, JPMorgan Knew Epstein +Was Engaged Human Trafficking +Around the time of Epstein's conviction in 2008, JPMorgan's AML (Anti-Money +Laundering) compliance group (under Langford) created a "Human Trafficking Overview." The +overview reported that "nearly two-thirds of the women trafficked for prostitution worldwide come +from Eastern Europe" and "former Eastern bloc countries such as Albania, Moldova, Romania, +Bulgaria, Russia, Belarus and Ukraine have been identified as major trafficking source countries +for women and children." SUF 9151. JPMorgan knew and had assembled evidence that Epstein +had made at least tens of thousands of dollars of payments to +and was reported to refer +13 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 20 of 46 +to her as his "Yugoslavian sex slave." SUF 9148-50, 125-26. JPMorgan also knew it had made +more than $1.2 million in payments to girls or women, many with Eastern European surnames, +from Epstein's accounts from 2003 to 2008. SUF 9|225. JPMorgan continued to handle such +payments for years, even after Epstein left the Bank, totaling an additional nearly $3 million. SUF +991227, 229. Beginning in 2008, several payments were sent to high-risk locations, such as Belarus, +Lithuania, and Russia. SUF 9|230. +AML compliance—JPMorgan's in-house human trafficking experts—wanted Epstein +gone from the Bank. SUF 99|162-66. In 2010, when additional "news stories ... connected] Jeffrey +Epstein to human trafficking, " SUF 99152-53, AML compliance was concerned about continuing +to bank a human trafficker while trumpeting the Bank's efforts to rein in human trafficking through +the bank. "My fear is will all our touting of good will on the [Human Trafficking] work, if anyone +should ever say yet we bank Epstein, a known child sleaze." SUF II154-55, 159-60. "I sent you +an e-mail yesterday on that scum Epstein .... I reminded McCleerey [then Head of PB Risk +Management] that he listened to 2 days of [Human Trafficking] at the forum and this account could +be problematic in several ways." SUF 9157. AML compliance requested the Bank "responsor this +client in light of the new allegations of human trafficking which the firm has been actively assisting +law enforcement in uncovering others engaged in this practice." SUF 9158. Langford, the public +face of JPMorgan's human trafficking initiative and the Global Head of Compliance, believed +JPMorgan "should exit Jeffrey Epstein as a client." SUF 9164. But business—including Erdoes +(then CEO AWM)-decided otherwise. SUF I9[167-68, 260, 262-63. +vii. +In 2008, JPMorgan Knew the Feds Were Connecting Certain +Transactions to Epstein's Sex-Trafficking +JPMorgan also knew that it made many payments from Epstein's accounts that federal +prosecutors believed could be evidence of sex trafficking. In 2008, JPMorgan acquired Bear +14 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 21 of 46 +Stearns, where it knew Epstein conducted his brokerage business. SUF 99169-70. Around the time +of Epstein's guilty plea, Arthur Middlemiss, formerly a compliance officer at Bear Stearns, +assumed a similar role at JPMorgan and worked on Epstein investigations. SUF 99171-72. While +at Bear Stearns, Middlemiss was responsible for responding to a 2007 subpoena by the federal +prosecutors investigating Epstein for federal sex trafficking crimes. SUF 99173, 175. The AUSA +sought information related to Epstein's accounts and certain transactions of $1000 and $100,000 +because the police affidavit had detailed a $1000 "Christmas bonus" payment to one girl and a +suspicious $100,000 donation to a massage parlor. SUF 9I 176-77. At this time, JPMorgan knew +it had handled multiple $1000 or similar smaller dollar payments to girls or women, SUF 9236, +and, prior to July 2008, forty-five $100,000 payments from Epstein's accounts, SUF 99235, 178. +JPMorgan continued to handle such payments for Epstein for years. SUF 99235-36. +vili. +JPMorgan Employees Had Personal Knowledge of Epstein's Sex- +Trafficking +Many e-mails over JPMorgan e-mail between Staley and Epstein demonstrate that Staley +had personal knowledge of Epstein's sex-trafficking. SUF 19 195, 197-203. Staley met Epstein's +co-conspirators at Epstein's townhouse. SUF 4Il 204-06. +SUF 9207. JPMorgan handled more than $210,000 in payments to +from Epstein. SUF 9231. +JPMorgan admits Staley was "the senior person at JPMorgan with a business relationship with +Epstein," SUF 99|191-92, 208-13; thus, Staley's knowledge is imputed to JPMorgan. Order at 29. +Brigstocke (CFO of AWM) wrote Erdoes comparing a client's house to Epstein's: "Reminded me +of JE's house, except it was more tasteful, and fewer nymphettes." SUF 9190. +15 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 22 of 46 +C. JPMorgan Participated in Epstein's Sex-Trafficking Venture +Even if participation requires active engagement, Order at 24, there is no genuine dispute +that JPMorgan actively participated in Epstein's sex-trafficking venture from 2006 until 2019. The +Court found allegations that the Bank allowed Epstein to use its accounts to send dozens of +payments to then-known co-conspirators; +; provided excessive and unusual amounts of cash to Epstein; and structured +cash withdrawals so that those withdrawals would not appear suspicious "went well beyond merely +providing their usual [banking] services to Jeffrey Epstein and his affiliated entities" and were +sufficient to allege active engagement. Order at 25-26. The New York State Department of +Financial Services ("NYSDFS") entered into a Consent Order and issued a $150 million penalty +to Deutsche Bank for its "inexcusable fail[ure] to detect or prevent millions of dollars of suspicious +transactions" related to Epstein, including: payments to publicly alleged co-conspirators; +settlement payments and dozens of payments to law firms for legal expenses of Epstein and coconspirators; payments to Russian models, including for school tuition and hotel and rent expenses, +and to numerous women with +Eastern European surnames; and periodic suspicious cash +withdrawals totaling more than $800,000 over four years. SUF 4214. +Payments to Co-Conspirators +and +From August 2006 +through 2013, JPMorgan handled $678,741.57 and $607,804.30 in payments, respectively, from +Epstein's JPMorgan accounts to +and +Epstein's co-conspirators, +recruiters, and/or victim +D. SUF 19216, 218. Even after it decided to terminate +Epstein's accounts in July 2013, JPMorgan still handled a payment of $15,000 from Epstein's +JPMorgan accounts to +SUF 9|217. Further, after it terminated Epstein's accounts, +16 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 23 of 46 +JPMorgan continued to facilitate payments from Epstein's non-JPMorgan accounts to +SUF 99|220, 84. In addition to payments from Epstein, JPMorgan also opened credit +cards for +and +"through NES, LLC c/o Jeffrey Epstein" only months after +Epstein was indicted. NES, LLC is an Epstein entity for which JPMorgan had not conducted the +required due diligence, and +SUF 19186, 88-89, 60-61. +Payments to Co-Conspirator Ghislaine Maxwell: After August 2006, JPMorgan +continued to handle payments to Maxwell, who, by July 2006, it had reason to suspect was +involved with Epstein in the alleged sex crimes. See supra Part I(B)(i)(b). JPMorgan's payments +to Maxwell included more than $7 million to purchase a helicopter. SUF 99222-23. +Millions of Dollars in Payments to Girls and Women, Many with Eastern European +Surnames and/or Located in Eastern Europe: From 2006 through 2013, JPMorgan facilitated +millions of dollars in payments to girls and women, including many with Eastern European names +and/or located in Eastern Europe, SUF 4|226, despite numerous references in its own diligence that +Epstein recruited victims from Eastern Europe and its recognition of Eastern Europe as high-risk +for human trafficking, SUF 99107, 151, 153, 48-50, 125-26. JPMorgan sent several of the +payments by foreign wire to girls or women to locations in Eastern Europe including Belarus, +Lithuania, and Russia. SUF 230. JPMorgan also handled payments to women for school tuition +and rent expenses. SUF 11|232, 234. Even after it decided to terminate Epstein's accounts in July +2013, JPMorgan continued to make numerous payments to girls or women with Eastern European +names from Epstein's JPMorgan accounts in 2013. SUF 9|228. From 2013 until 2019, JPMorgan +still handled over $1 million in additional payments to girls or women, including many with +Eastern European names, from Epstein's non-JPMorgan accounts. SUF 9229. +17 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 24 of 46 +$1000 and Smaller Dollar Payments to Girls or Women and $100,000 Payments: From +August 2006 to 2013, JPMorgan made numerous non-cash payments of $200-$1000 to girls or +women, and 70 payments of $100,000 from Epstein's accounts. SUF 99|235-36. As explained +above, JPMorgan knew from the federal prosecutors' subpoena to Bear Stearns that law +enforcement considered these payments suspicious and evidence of Epstein's federal sex crimes. +SUF 49[1 76-177. +MC2 Modeling Agency SBLC: As described above, from 2005 to March 2011, JPMorgan +extended an SBLC to Brunel and MC2 despite reports it supported "payment for services as a +procurer." By 2007, there were reports that Epstein was engaged in sexual abuse of minors through +MC2, yet JPMorgan continued to extend the SBLC. JPMorgan also made payments from Epstein's +accounts to Epstein's rep, Howard Rubenstein, SUF 9237, who it knew was covering up Epstein's +involvement with MC2. See supra Part I(B)(iii). +Payments to "High-Powered" Lawyers Covering Up Epstein's Sex Crimes: Following +Epstein's arrest for felony sex crimes and confession to Staley and prior to the NPA, JPMorgan +handled more than $4 million in payments to Epstein's then known "high-powered" lawyers who +it knew were engaged in covering up Epstein's felony sex crimes and negotiating a plea for Epstein +to avoid federal sex-trafficking charges. SUF 99238-39. After the NPA through 2013, JPMorgan +continued to handle more than $40 million in payments from Epstein's accounts for legal expenses, +SUF 1240, suggesting ongoing investigations and litigation and settlements with victims. +Excessive and Unusual Cash Withdrawals: The NYSDFS found inexcusable Deutsche +Bank's failure to monitor "suspicious cash withdrawals [of] more than $800,000 over four years." +SUF 9214. Between September 2003 and November 2013, or approximately ten years, JPMorgan +handled more than $5 million in outgoing cash transactions for Epstein, SUF 4|242—ignoring its +18 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 25 of 46 +own policy discouraging large cash withdrawals, SUF 9241. From August 2006 to 2013, JPMorgan +facilitated nearly $2.5 million in cash withdrawals for Epstein, SUF 1247, even though it was +widely publicized that Epstein paid for sexual encounters with minors in cash and +See supra Part I(B)(i)(d). Even after JPMorgan made the decision to terminate Epstein for +his cash activity, it still facilitated for him more than $100,000 in cash withdrawals. SUF 9249. +JPMorgan did not seek an explanation for Epstein's excessive +cash withdrawals until 2011, again in violation of its own policy. SUF 1241. It was conveyed then +that the cash was for fuel payments when Epstein traveled to foreign countries. To provide cover +for Epstein's incredible and undocumented fuel explanation, Duffy (then CEO US PB) "did ask +him to withdraw this cash from his aviation account," Hyperion, instead of his personal account. +SUF 4|101; see also supra Part I(B)(i)(d). L +JPMorgan +must file SARs to report suspicious financial transactions "[w]henever the national bank detects +... a transaction or transactions conducted through the bank and involving or aggregating $5,000 +or more in funds or other assets where the bank believes... that it was used to facilitate a criminal +19 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 26 of 46 +transaction, and the bank has a substantial basis for identifying a possible suspect." 12 C.F.R. § +21.11(c)(2). JPMorgan must file a SAR "no later than 30 calendar days after the date of the initial +detection of facts that may constitute a basis for filing a SAR. 12 C.F.R. § 21.11(d). +From 2003 to 2013, JPMorgan helped Epstein withdraw over $5 million in cash, make +millions of dollars in payments to co-conspirators and accomplices, send more than $3 million in +wires to women and girls, and make numerous $1000 and $100,000 payments it knew were critical +to the federal investigation. +At the 2006 Rapid Response meeting following Epstein's indictment on "felony charges +of soliciting underage prostitutes," JPMorgan explicitly noted "[c] ash withdrawals ... made in +amounts for $40,000 to $80,000 several times a month" +See supra Part I(B)(i)(d) and (ii). +SUF 997. +20 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 27 of 46 +D. JPMorgan Benefited from Participation in Epstein's Sex-Trafficking Venture +JPMorgan argued the Government must allege that it received revenue from Epstein in +exchange for the Bank's furtherance of Epstein's sex-trafficking venture. The Court "is not +convinced that the benefit element should be read in this way," Order at 31, and, indeed, "the +statutory language imposes no such [causal relationship] requirement." HH v. G6 Hospitality, Inc., +No 2:19-cv-755, 2019 WL 6682152, at *2 (S.D. Ohio Dec 6, 2019). JPMorgan admits it received +fees and other revenue from providing services to Epstein and his affiliated entities. Order at 31; +SUF 991252-53. In any event, from at least 2006 to Epstein's arrest in 2019, JPMorgan knowingly +benefited from furthering Epstein's sex-trafficking venture. +In or about the 2000 time period, Sandy Warner, then head of JPMorgan, told Staley (then +head PB), "[YJou should meet Epstein. He's one of the most connected people I know of in New +York." SUF 1275. Warner was right. By 2003, Epstein introduced Staley and Google's founders, +Sergey Brin and Larry Page, and helped source billionaire hedge fund (Highbridge) owner Glenn +SUF 911280-81, 311, 314-16. By then, Epstein was also bringing in over $8 million in +revenues to the Private Bank +—the top revenue and nearly double the amount of the next highest +client. In 2003, "Epstein, through the trading of his accounts and that of Leslie Wexner, generates +one of the largest annual revenue flows of private clients in the private bank." SUF 991254-58. +The following year, Epstein facilitated JPMorgan's acquisition of Highbridge, a gamechanging acquisition for JPMorgan. Highbridge, a hedge fund with $7 billion in assets under +21 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 28 of 46 +management, was co-founded by Epstein's close friend +and Epstein was a founding +investor. Epstein advised both JPMorgan and Highbridge on the acquisition and worked with +Dimon, then CEO-in-waiting, Bill +, then CEO, and other "JPMorgan Chase Executive +Management" on the acquisition. Epstein was paid a $15 million consulting fee for his work on +the acquisition. SUF 99|370-381. Epstein also continued to facilitate introductions to the Bank, +including a meeting between Staley and the Sultan of Dubai. SUF 49333-35. +This sets the stage for 2006, after Epstein was arrested for felony sex crimes and confessed +his conduct to Staley, when JPMorgan could have exited Epstein but did not. Instead, at the Rapid +Response meeting, the Private Bank imposed a condition on his accounts supposedly to "mitigate +the risk" —he could remain a "banking" but not an investment client. SUF 99382-84. But, when it +later benefited the Bank, the restrictions were ignored, and by 2011, Epstein was the Private Bank's +investment arm's "biggest revenue producer." SUF 99|385, 267-72. The Rapid Response meeting +was a fiction in other respects. Though JPMorgan was supposedly considering terminating its +relationship with Epstein, at precisely the same time, the Bank was actively trying to find a New +York home for Epstein's accounts "as the advisor to the Google founders"—a relationship that +would become "one of the largest in the Private Bank, of +$4BN." SUF 991322, 314-327, 331-32. +The Bank was also actively growing the Epstein relationship-between post-indictment +and post-conviction Rapid Response meetings, Epstein's assets under management increased fourfold from $32 million to over $120 million. SUF 9I 259, 264. By September 3, 2008, when +Epstein's Private Banker +) thought his assets were a "probable outflow (pending Dimon +review)," Epstein's accounts were worth more than $156 million—and, needless to say, were not +"outflow[ed]." SUF TIl 265-66. Within months of public reports that Epstein was engaged in sexual +abuse of girls potentially tied to MC2, JPMorgan moved forward with renewing Epstein's loan to +22 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 29 of 46 +MC2. The Bank's only concern: "Are we comfortable taking on additional credit exposure just +ahead of his pending plea arrangement?" SUF 9133. +JPMorgan also kept banking Epstein, despite its knowledge of his sex-trafficking, because +it was trying to settle lawsuits he had against the bank—one related to his investments at Bear +Stearns and another in +In 2011, as JPMorgan had near-settled Epstein's +claims against Bear Stearns, Cutler wrote to Erdoes "I would like to put it and HIM behind us. Not +a person we should do business with - period." But—as Shenker (then General Counsel AWM), +explained to Erdoes—"[Cutler] at conclusion of JE approval [of Bear Stearns settlement], asked +when we are offboarding JE. I reminded him that we have the other matter outstanding." At the +time, the Bank was still trying to settle +SUF 991387-98. +In 2008, Bear Stearns, now part of JPMorgan, had made it known that it wanted to keep +Epstein as a brokerage client despite his felony conviction. Alan "Ace" Greenberg, former +Chairman of Bear Stearns (and now with JPMorgan), also "wanted to continue to do business with +Epstein" and sought an "exception to the felon policy," which, on paper, required that the GC +(Cutler) approve retaining Epstein. SUF 99399-403. In addition, throughout spring and summer +2011, Epstein helped Erdoes and Staley—who JPMorgan admits were involved in the decision to +maintain Epstein at the Bank—put together a proposal for a $100 billion Donor Advised Fund for +the Gates Foundation, which Erdoes and Staley presented to the Gates Foundation on August 31, +2011. Erdoes communicated frequently and familiarly with Epstein +during the DAF development and pitch process. SUF 91404-12. +Throughout, Epstein continued to connect JPMorgan with the world's dignitaries and +wealthiest people, including, among others, Gates, Boris Nikolic (advisor to Gates), Summers, the +Sultan of Dubai, Prince Andrew, Barak, Netanyahu, David Gergen (former advisor to Nixon, +23 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 30 of 46 +Reagan, and Clinton), Pritzker, and Mandelson. SUF 91|276-313. Epstein also continued to bring +in significant revenues to the Bank. SUF 99267-74. +Epstein was also a personal resource to Staley and Erdoes, two business executives who +JPMorgan does not dispute were involved in the decision to maintain Epstein at the Bank. Epstein +helped Staley with +In 2005, Erdoes personally +sought Epstein's help in resolving a $600 million tax issue for +In December 2008, after Bernie Madoff's investment scandal was uncovered, +Erdoes wrote Staley: "glenn and I have been going back and forth all night. We have HUNDREDS +of clients …... Can you call JE to get the scoop from down there?" SUF 9413-17. +Post-exit, JPMorgan continued to benefit from Epstein until months before his 2019 arrest. +Duffy (then CEO US PB) gave Epstein's former JPMorgan Banker (Justin Nelson) permission to +continue a relationship with Epstein as "a potential source of referrals." Nelson met with Epstein +8-10 times, twice as many times as +who had been his main Banker for a decade prior to his +exit, including about business with +Black, CEO of private equity behemoth Apollo Global +Management. SUF 99353-65, 369. In 2019, a few months before Epstein was arrested, JPMorgan +was still taking referrals from Epstein. Groff, Epstein's co-conspirator, wrote Erdoes offering to +introduce her to Kathryn Ruemmler, former +House counsel. Erdoes forwarded Groff's e- +mail to +to which +responded, "... she would be a great client." SUF 9I366-68. +All the while, JPMorgan continued to +Il. +JPMORGAN OBSTRUCTED ENFORCEMENT OF THE TVPA IN VIOLATION +OF 18 U.S.C. § 1591(d) +By 2007, JPMorgan knew of "an effort to enforce the TVPA" and "intentionally +obstruct|ed] or attemptled] to obstruct that enforcement effort." Order at 33. Though Epstein +24 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 31 of 46 +confessed the conduct (except the "ages"), JPMorgan +and, instead, actively handled payments to Epstein's lawyers who it knew were +discrediting the victims, hiring private investigators to target witnesses, and negotiating a deal +where federal prosecutors would (and did) defer prosecution of TVPA charges. Supra Part I(B)(ii). +Further, +Supra Part I. +JPMorgan +the payments to +and Maxwell; the credit cards to +and +, including for monthly travel "through +Paris, Europe and US Virgin Islands and US;" the revoked credit card to +who had talked +to police; the DDR information Epstein provided for +(or any of the other girls Epstein +referred to the Bank); the payments to the girls and women, including with Eastern European +names, or their names and location, which it also had. JPMorgan +that it helped Epstein financially back Brunel and MC2 since 2005. Supra Part I. In +2019, Brunel was charged with rape of minors and under investigation for trafficking tied to +Epstein and was widely known, including by JPMorgan, years earlier as "among the sleaziest +people in the fashion industry ... a conveyor belt, not a casting +" SUF 91421-22. +25 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 32 of 46 +Even when it knew that the feds had subpoenaed Bear Stearns for Epstein's account and +transaction information related to its investigation, +Supra Part I. In 2010, JPMorgan learned of new federal investigations of +Epstein for child sex-trafficking, but +Supra Part I. +JPMorgan's own due diligence on Epstein shows it knew that "names and contact +information of material witnesses and additional victims" would have been "extremely useful in +investigations and prosecuting the [federal] case." SUF 9|420. JPMorgan had the names and +information for dozens of accomplices, victims, and other material witnesses—including, for +example, his pilots, SUF 87, his assistants, and his accountant, who JPMorgan later +acknowledged "controlled the movement of Epstein funds that potentially assisted in facilitating +the sex trafficking ring," SUF 15, as well as the long list of dignitaries and ultra-wealthy men +Epstein referred or connected to the Bank- +Supra Part I. By Epstein's arrest in 2006, there should have been "a constant stream of +information from JPMC to the FBI about Epstein's ongoing +.... Human +trafficking is an ongoing crime, with harm incurred every day that the crime continues." +26 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 33 of 46 +there is no genuine +dispute Epstein would have been federally charged with sex-trafficking much earlier. SUF 9419. +III. THE USVI'S REQUESTED RELIEF FOR VIOLATIONS OF THE TVPA +Declaratory Judgment and Injunction: The Government requests that the Court declare +JPMorgan violated TVPA §§ 1591(a)(2) and (d) by participating in Epstein's sex-trafficking +venture and obstructing federal law enforcement efforts to enforce the TVPA against Epstein from +2006 to 2019. The Government seeks an injunction to prevent JPMorgan from participating in +trafficking ventures in the future and obstructing efforts to stop such ventures in violation of the +TVPA. See Alfred L. Snapp v. Puerto Rico, 458 U.S. 592, 598-99 (1982). +Civil Penalties: The Government has proven even greater participation by JPMorgan in +Epstein's sex-trafficking than the NYSDFS found against Deutsche Bank and seeks at least $150 +million in civil penalties. +Other Remedies: The Government defers its request for disgorgement, compensatory and +punitive damages, and other appropriate relief for JPMorgan's TVPA violations until trial. +IV. JPMORGAN'S EQUITABLE AND FAULT-SHIFTING DEFENSES DO NOT +APPLY TO THE GOVERNMENT'S TVPA PARENS PATRIAE CLAIMS +This is an action by the Government of the Virgin Islands to vindicate public rights. While +JPMorgan seeks to shift focus away from its own failings and point blame on the Government, +such equitable or fault-shifting defenses are legally barred. See, e.g., City of New York v. FedEx +Ground Package System, Inc., 314 F.R.D. 348, 357 (S.D.N.Y. 2016) (***[W]hen acting in a capacity +to enforce public rights in the public interest ... government entities are not subject to all equitable +defenses +-such as laches or estoppel—that could ordinarily be invoked against a private actor."") +(quoting State of New York v. UPS, Inc., 160 F. Supp. 3d 629, 640 (S.D.N.Y. 2016)); id. at 359 +27 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 34 of 46 +(contention that government plaintiffs were "negligent in their discretionary tax enforcement ... +is impermissible where the government seeks to vindicate the public interest via enforcement of a +public statutory right"). The Court therefore should grant summary judgment for the Government +on JPMorgan's Affirmative Defenses No. 5 ("in pari delicto"), 6 ("unclean hands"), 7 ("laches"), +and 8 ("comparative and contributory negligence or fault"). Answer and Affirmative Defenses +(Dkt. 124) at 26, because they seek to do precisely what the law prohibits—shift fault to a +government plaintiff bringing suit to vindicate public rights.? +JPMorgan's attempts to distract from its violations of the TVPA described above by +claiming that the Government should have done more are particularly galling. The Government +must comply with constitutional and legal principles that protect all individuals by ensuring that +investigations cannot proceed without concrete evidence. JPMorgan had that evidence-in +spades +- in its own files; the Government did not. JPMorgan knowingly handled virtually every +financial transaction Epstein needed to operate his sex-trafficking venture, from the millions in +cash withdrawals and payments to co-conspirators, recruiters, and victims, to the millions in +payments to lawyers and publicists for the ongoing cover-up. JPMorgan had virtually every +financial detail of Epstein's venture—from payments to young women in Lithuania and Russia, to +transfers for the purchase of a helicopter by Maxwell, to a "revoked" credit card for an alleged +recruiter who talked to the police—in real-time and kept virtually all of it, and thus its own outsized +role, under wraps until Epstein was dead and gone. Supra Part I. +2 The Government previously moved to strike these same defenses. See Dkt. 138, 139, 168, 205. +"he Court denied the motion to strike without prejudice to the USVI's right to move for summar +udgment on these defenses. Order (Dkt. 215) at 1 ("Although the Court is skeptical that some o +all of the defenses will survive summary judgment (let alone prevail at trial), the Court is satisfied +they should not be stricken as a matter of pleading."). +28 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 35 of 46 +The Government's causes of action against JPMorgan arise under the TVPA's parens +patriae provision for state attorneys' general, which provides that where: +[T]he attorney general of a State has reason to believe that an interest of the +residents of that State has been or is threatened or adversely affected by any person +who violates section 1591, the attorney general of the state, as parens patriae, may +bring a civil action against such person on behalf of the residents of the State in an +appropriate district court of the United States to obtain appropriate relief. +18 U.S.C. § 1595(d). The TVPA makes clear that a State Attorney General plaintiff brings suit not +as a private litigant on behalf of itself, but "as parens patriae" (i.e., the sovereign) "on behalf of +the residents of the State" to "obtain appropriate relief" for "an interest of [those] residents" that +"has been or is threatened or adversely affected" by JPMorgan's prohibited conduct. +In denying JPMorgan's motion to dismiss, the Court confirmed this plain reading of the +TVPA. The Court found that the Government satisfies the elements of parens patriae standing, +including that it "allege[s] an injury to a quasi-sovereign interest that affects a sufficiently +substantial segment of its population[.J" Order at 17 (citing Snapp, 458 U.S. at 607). The Court +explained that the Government's asserted interest in protecting residents "from the harmful effects +of criminal sex-trafficking enterprises flourishing in the Islands ... directly parallels the interest +that Puerto Rico successfully asserted in Snappl.J" Id. at 18 (cleaned up). Having found that the +Government alleges a quasi-sovereign interest and is vindicating public rights, the Court now +should hold that JPMorgan's equitable and fault-shifting defenses do not apply as a matter of law.? +3 See, e.g., United States v. Angell, 292 F.3d 333, 338 (2d Cir. 2002) ("[LJaches is not available +against the federal government when it undertakes to enforce a public right or protect the public +interest."); FedEr, 314 F.R.D. at 358 (striking laches, unclean hands, and in pari delicto defenses +as to Contraband Cigarette Trafficking Act ("CCTA"), 18 U.S.C. § 2346, public enforcement +claims); UPS, 160 F. Supp. 3d at 647 (same); United States v. Philip Morris Inc., 300 F. Supp. 2d +61, 75-77 (D.D.C. 2004) (granting government plaintiff partial summary judgment on equitable +defenses of, inter alia, laches, unclean hands, and in pari delicto); FTC v. Crescent Publ. Grp., +Inc., 129 F. Supp. 2d 311, 324 (S.D.N.Y. 2001) (**As a general rule ... neglect of duty on the part +of officers of the Government is no defense to a suit by it to enforce a public right or protect a +29 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 36 of 46 +The Government's TVPA claim under section 1595(d) is one exclusively pursued by state +governments, and not by private parties, just as under the CCTA in FedEx and UPS. The TVPA +makes this clear by predicating a state's claim upon its showing that "an interest of the residents +of that State has been or is threatened or adversely affected by any person who violates section +1591[.J"* 18 U.S.C. § 1595(d). The dismissal opinion makes it clearer still that the Government is +acting in a public enforcement capacity by holding that the Government "allege[s] an injury to a +quasi-sovereign interest" and "seek[s] relief to the territory's injury that would be unavailable to +individual plaintiffs." Order at 18. Since the Government is enforcing the TVPA in its capacity as +sovereign, not as a privately-interested litigant, JPMorgan's equitable and fault-shifting defenses +are barred as a matter of law and discovery has not shown otherwise. +JPMorgan has generally cited three issues forming the basis of its fault-shifting affirmative +defenses: (1) Epstein's registration as a sex offender; (2) the Virgin Islands Economic +Development Commission's ("EDC's") provision of tax benefits to Epstein's companies under a +federally-authorized tax benefit program; and (3) actions taken by Cecile de Jongh, whom Epstein +employed. As explained below, JPMorgan's claims of a Government-wide conspiracy to protect +Epstein are both legally unsound and factually unsupported. The defenses based on these +allegations cannot survive summary judgment. +A. JPMorgan's Defenses are Barred as Applied to Sex Offender Registry Issues +JPMorgan argues that the Government's purportedly improper enforcement of sexoffender registry requirements with respect to Epstein supports its equitable and/or fault-shifting +public interest."") (quoting Nevada v. U.S., 463 U.S. 110, 141 (1983)); United States v. Vineland +Chem. Co., Inc., 692 F. Supp. 415, 423 (D.N.J. 1988) (*[T]he equitable doctrine of unclean hands +may not be asserted against the United States when it acts in its sovereign capacity to protect the +public welfare."). +30 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 37 of 46 +defenses. See Opp'n Mot. Strike (Dkt. 157) ("MTS Opposition") at 8-11. This argument is without +basis. +i. +The Government's Investigations or Monitoring of Epstein Cannot +Form the Basis of Viable Affirmative Defenses +JPMorgan essentially argues that the Government should have more aggressively +investigated Epstein or monitored his whereabouts. But that argument suffers from a fatal flaw. +Even as a convicted sex offender, Epstein possessed constitutional rights that the Government was +required to respect. (Nothing, however, granted Epstein a constitutional right to conduct business +with JPMorgan or to be free from JPMorgan's scrutiny.) JPMorgan's attempts to equate its own +compliance failures with the Government's actions have no legal basis and thus amount to little +more than a brazen attempt to distract from its own regulatory failings. The officials within the +Virgin Islands Government responsible for sex offender registration and monitoring are not +responsible for Epstein's crimes. SUF 9|424. The laws required Epstein to register—which he did— +and to provide notification of travel overseas. 14 V.I.C. § 1724. But the Government could not +enter his island or conduct searches without concrete evidence that crimes were being committed. +All witnesses confirmed that the Government never received such evidence. SUF 99I429-30. +JPMorgan has attempted to point to news articles or complaints filed by anonymous victims +in other states as "evidence" that the Virgin Islands Government failed to pursue. But those +documents do not and cannot underpin a government investigation. The Government could not +search Epstein's property without a warrant, which can only issue upon probable cause. See, e.g., +Groh v. Ramirez, 540 U.S. 551, 557 (2004). Newspaper reports or anonymous statements do not +constitute sufficient basis for probable cause because "[m]ere journalistic prose is not the kind of +underlying factual data upon which a magistrate can exercise [appropriate] judgment." Donovan +v. Fed. Clearing Die Casting Co., 655 F.2d 793, 797 (7th Cir. 1981) ("We need not belabor the +31 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 38 of 46 +point that all newspaper reports are not of sufficient reliability to form the basis of Fourth +Amendment probable cause determination"); see also U.S. v. One Crystal Covered Bat Tour +Glove & Other Michael +_ Memorabilia, 2013 WL 12196595, at *4 (C.D. Cal. Aug. 19, +2013). These cases are consistent with the undisputed witness testimony confirming that the +Department of Justice could not initiate investigations or pursue warrants based upon these types +of hearsay statements. SUF 9|426-27. As witnesses confirmed, absent an actual complaint from a +victim or eyewitness evidence brought to the Department of Justice's attention, the Department +could not initiate investigations. SUF 9428. +JPMorgan's complaints concerning the adequacy of address verification checks fare no +better. No provision in the law requires the Virgin Islands to perform such checks, which are done +to confirm that the registrant resides at the address provided to the Government. The checks were +performed roughly annually in conjunction with U.S. Marshalls and other federal partners. SUF +9431. The applicable law required address checks to verify that an offender is living where +reported. They do not, however, authorize entry onto private property or dispense with the +requirements of the Fourth Amendment. Government officials may not enter a sex offender's +property or conduct a search absent consent or a warrant based on probable cause. SUF 9|432. +That protection is the reason that, in certain years, the U.S. Marshalls and Virgin Islands +officials did not proceed beyond Epstein's dock. If an offender refused entry, the government +officials performing the check did not possess authorization to enter. SUF 9433. One Virgin Islands +witness testified that she conferred with the federal government concerning this practice and was +told that it was similar to a situation where a landowner has placed a gate at the border to his +property. The officials were not permitted to proceed beyond that gate without a warrant. SUF +32 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 39 of 46 +9434. Nor was it improper or unusual for the Government to confirm addresses at a sex offender's +place of employment, as was done one year with Epstein. SUF 9435. +ii. +The Discretionary Act of Granting a Waiver of Notification Periods for +Overseas Travel is Not Grounds to Shift Fault to the Government +Following his conviction in Florida, Epstein was required to register as a sex offender with +the Virgin Islands Department of Justice. In 2012, the Legislature amended its sex offender laws, +in part to obtain federal funding for its sex offender unit. SUF 9436. The U.S. Government +approved the changes to the law in advance. SUF 9437. JPMorgan has sought to make of the +fact that Epstein's attorneys consulted with lawmakers concerning the proposed changes. But those +arguments prove nothing. The Legislature rejected Epstein's proposed changes. SUF 9|438. +The amended statute required that "[a]ll sex offenders required to register in this +jurisdiction shall appear in person at the Department of Justice at least twenty one (21) calendar +days prior to any intended travel outside of the United States and provide information about their +intended travel as provided in [14 V.I.C.] section 1726[.J" 14 V.I.C. § 1724(b)(4) (emphasis +added). The same provision then states that "that Attorney General may at his discretion reduce +this twenty-one (21) day notice requirement if a sex offender requests such a reduction and +provides information in support of his request." Id. (emphasis added). Other statutory provisions +confirm that "InJothing under this chapter shall be construed as a waiver of sovereign immunity +for the United States Virgin Islands, its departments and agencies." 14 V.I.C. § 1728(a). +Epstein applied for and received a discretionary waiver of his travel notification +requirements pursuant to these statutory provisions. SUF 9439. But this waiver does not constitute +misconduct or otherwise form the basis of a valid affirmative defense. The provision of streamlined +travel notice requirements upon satisfactory proof is statutorily mandated and/or vested in the +Attorney General's discretion. Caselaw is clear that such discretionary actions do not support +33 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 40 of 46 +shifting fault to the Government. See, e.g., City of New York v. FedEx, 314 F.R.D. at 359; see also +v. Gov't of the Virgin Islands, 847 F.2d 104, 107 (3d Cir. 1988) (Virgin Islands law +recognizes the "public duty doctrine," which "preclud[es] suit for governmental negligence based +only on the Government's failure to comply with a duty owed to the public in general[.I").* +The defense fails as a factual matter as well. The statutory waiver of which JPMorgan +complains applied only to international travel. 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 +federally-approved Virgin Islands statute required such notification. SUF 9442. Nor did the +provision of such a waiver somehow enable Epstein's crimes. Testimony is clear that Epstein never +failed to register as a sex offender and there is no evidence that he failed to notify of travel. SUF +9425. There is no evidence that permitting Epstein to email his international travel notifications 24 +hours in advance instead of appearing in person 21 days in advance somehow enabled him more +latitude to commit his crimes. Notifications are not authorizations or requests; the Government has +no ability to restrict his travel. SUF 9443. Moreover, entry into the Territory from overseas is +controlled by federal authorities, not the Virgin Islands Governments. SUF 9|444. +Any attacks on the granting of the waiver itself are meritless. Then-Attorney General +Frazer testified that he relied on representations of Epstein's counsel in forming his decision, and +that those "representations" were "satisfactory to conclude that there was not an undue risk to the +community" that would arise from the waiver. SUF 9440. Epstein's lawyers represented to Mr. +* See also Maldonado by and through Ochoa v. City of Sibley, 58 F.4th 1017, 1022 (8th Cir. 2023) +(IT]he public-duty doctrine generally applies when the government fails to adequately enforce +criminal or regulatory laws for the benefit of the general public or ... protect the general public +from somebody else's instrumentality.") (cleaned up); McGaughey v. District of Columbia, 684 +F.3d 1355, 1358 (D.C. Cir. 2012) (public duty doctrine barred claims against government for +failure to investigate rape allegation: "Courts and juries are ill-equipped to review legislative and +executive decisions about how to allocate limited municipal resources to best protect the public."). +34 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 41 of 46 +Frazer that other states permitted Epstein to provide email notification of his travels and affirmed +that "there is no public safety necessity in requiring Epstein to notify the Department in person +each time he travels to or from the jurisdiction." SUF 9441. JPMorgan's defense thus rests not on +whether the decision was authorized under law—it most certainly was—but on whether the +Attorney General in 2012 exercised sufficient discretion in granting the waiver. This is precisely +what the caselaw cited above precludes. Cf. Harlow v. Fitzgerald, 457 U.S. 800, 817-818 (1982) +("[G]overnment officials performing discretionary functions generally are shielded from liability +for civil damages insofar as their conduct does not violate clearly established statutory or +constitutional rights of which a reasonable person would have known"). +B. +JPMorgan's Defenses are Barred as Applied to the Economic Development +Commission's Grant of Tax Benefits to Epstein's Companies +The EDC operates under the umbrella of the USVI Economic Development Authority +("EDA"), which is a "semi-autonomous instrumentality of the Government" and is governed by a +board of individuals appointed by the Governor. 29 V.I.C. § 1101(a). The EDA "is a public +corporation having legal existence and personality separate and apart from the Government of the +Virgin Islands and the officers controlling it." 29 V.I.C. § 1101(b). Thus, to the extent JPMorgan +conflates entities and treats EDC actions as attributable to the Government, see MTS Opp'n at 2, +its arguments find no support in Virgin Islands law. +The tax benefits are authorized by a federal statute (26 U.S.C. § 934(b)(1)), pursuant to +which, the EDC administers "a unique economic development program for the USVI," allowing +residents of the Territory to exempt certain income if it is "connected with the conduct of a trade +or business within the Virgin Islands."" Coffey v. C.I.R., 663 F.3d 947, 949 (8th Cir. 2011) (quoting +26 U.S.C. § 934(b)(1)). The substance and procedures for the EDC's provision of tax benefits are +set by statute and regulation. See, e.g., 29 V.I.C. § 701(a) ("I)t is the policy and determination of +35 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 42 of 46 +the Government of the Virgin Islands that certain industrial development benefits should be made +available for development and expansion of such industrial or business activities as are determined, +pursuant to this subchapter, to be in the public interest by advancing the growth, development +and/or diversification of the economy of the Territory of the Virgin Islands."); 29 V.I.C. § 705(a) +("The Commission shall[.J [b]ased upon the investigation and recommendations of the Director, +review all applications for economic development benefits, hold public hearings thereon as +provided in section 717 of this chapter, and (1) grant certificates for same, or (2) deny such +certificate, subject to reconsideration in accordance with section 717."). The provision, +continuation, and/or revocation of economic development-related tax benefits thus is statutorily +mandated and/or vested in the EDC's discretion, not evidence of government misconduet or +grounds for fault-shifting. See +847 F.2d at 107.5 +The factual record bears this out. The EDC granted tax incentives to two of Epstein's +companies: Financial Trust Company and Southern Trust Company. SUF 9445. The first grant of +benefits to an Epstein-owned company occurred in 1999 to Financial Trust. SUF 9446. In 2009, +Financial Trust applied for and received an extension of benefits. SUF 9[447. Epstein formed a new +company—Southern Trust—which applied for and received tax benefits in 2012. SUF 9[448. In +each of those cases, the grant of benefits was performed in compliance with all statutory and +regulatory procedures and requirements. The companies submitted applications for the benefits. +SUF 9449. EDC held public hearings during which the benefits were discussed and the applicants +were provided the opportunity to present their case and answer questions. SUF 9450. The EDC +then held decision meetings where the board considered the applications and rendered decisions. +S The EDC's grant of economic development-related tax benefits to Epstein also is irrelevant. The +Government has abandoned claims for damages based on lost revenues from the grant of tax +benefits. See USVI Letter-Brief (Dkt. 205) at 1; USVI Opp'n Mot. Sanctions (Dkt. 200) at 2. +36 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 43 of 46 +SUF 9451. To the extent JPMorgan questions the reasoning behind those decisions, that is +precisely the type of second-guessing the law precludes. See McGaughey, supra, 684 F.3d at 1358 +("Courts and juries are ill-equipped to review legislative and executive decisions about how to +allocate limited municipal resources to best protect the public."). +Once benefits are granted, Virgin Islands law limits the EDC's ability to modify them. +"The Commission may not require an applicant to meet qualifications or requirements in excess +of those representations made by the applicant to the Commission during the application process +as a condition of granting an initial certificate." 29 V.I.C. § 708. Indeed, the law specifies that +benefits granted are "consider[ed] ... as being in the nature of a contract between [the] government +and the beneficiary." 29 V.I.C. § 701(c). +The EDC could not revoke, suspend or modify the benefits based upon a felony conviction +unless it concerned conduct "connected with the operation of the beneficiary's business or +industry." 29 V.I.C. § 722(4). Thus, Epstein's Florida conviction was not grounds for revocation +at that time because no evidence was available to the EDC that Epstein's solicitation of a minor +for prostitution in Florida was "connected with the operation" of his USVI businesses. SUF 9452. +Unlike JPMorgan, the EDC did not have access to Epstein's companies' daily financial +transactions, and was not aware of any connection between his conduct and the operations of his +business. SUF 9|453. Indeed, the EDC reached out to Epstein's attorney in January 2015 to inquire +whether media reporting regarding allegations of misconduct had any connection to the business +of Epstein's Southern Trust Company. His attorney responded to confirm "[w]e do not believe that +these media discussions will have any impact on the business activities of STC." SUF 9[454. +JPMorgan has pointed to a "cost-benefit" ratio that purportedly shows in many years that +the Territory (not the Government) received less in benefits than it gave up in tax revenue. Fact +37 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 44 of 46 +witness testimony, however, shows this analysis to be irrelevant because it uses an artificial +baseline. A long-tenured EDC employee who was personally involved in the granting of benefits +testified that the ratio "doesn't give the full picture" and "can be misleading" because, unless the +business already operated in the Territory, the Government would not receive the tax revenue in +the first place and has not "lost" anything. SUF 991455-56. This analysis applies to both the initial +grants of benefits to both companies and to Financial Trust's extension request. During a March +2009 public hearing, Epstein's attorney explained that a denial of an extension would likely cause +"a responsible business person ... to seriously consider relocating the business" if another territory +offered similar benefits. SUF 9|458. Thus, the EDC could not assume that it would collect Epstein's +tax revenue if the benefits were not extended. SUF 9459. The ratio further ignores ancillary +benefits that accrue to the Territory from the presence of high-net-worth individuals, who engage +in economic activity unrelated to their businesses that benefits the territory. SUF |457.° +C. JPMorgan Has No Viable Defenses Based on Activity of Cecile De Jongh +JPMorgan also argues that the activity of Cecile de Jongh, former First Lady of the U.S. +Virgin Islands and Office Manager for Epstein, supports its defenses. MTS Opp'n at 20. Not so. +As First Lady, Ms. de Jongh had no statutory or regulatory authority. Ms. de Jongh +confirmed that "there's 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. SUF 9[461. Moreover, the factual record shows that during the time her husband was +Governor, Ms. de Jongh was widely known and recognized to be employed by Epstein's +businesses and acting on their behalf. SUF 9|462. Unlike the information that JPMorgan +" To the extent JPMorgan may allege that EDC gave Epstein favorable treatment compared to other +applicants, the record evidence shows otherwise. SUF 9460. +38 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 45 of 46 +de Jongh's employment with Epstein was widely reported and numerous witnesses +confirmed their familiarity with her employment. SUF 9|463. +Most importantly, Ms. de Jongh had no responsibility for governmental decisions that form +the basis of JPMorgan's flawed affirmative defenses. She had no contact with Department of +Justice personnel responsible for sex offender registration and monitoring. SUF 9|464. Decisions +concerning tax benefits were made by the EDC's board members. SUF 9|465. Although the law at +the time required the Governor (her husband) to sign tax benefit certificates, that process was a +formality and could not happen without the EDC's recommendation in the first place. SUF 9|465. +Ms. de Jongh vehemently denied knowing about or facilitating Epstein's crimes in the +Virgin Islands. SUF 9467. Although JPMorgan has pointed to emails about arranging an ESL class +for women in the Virgin Islands, Ms. de Jongh testified that she was not aware these individuals +were potential trafficking victims, and documents make clear that the University merely agreed to +offer an existing class for them. SUF 91468-69. Although Ms. de Jongh's emails may have +provided salacious fodder for JPMorgan, she ultimately was not responsible for any government +decisions. +CONCLUSION +For the foregoing reasons, the Court should grant the Government's motion for partial +summary judgment. +39 + + +Case 1:22-cv-10904-JSR Document 285-1 Filed 08/15/23 Page 46 of 46 +Dated: July 24, 2023 +ARIEL +. ESQ. +ATTORNEY GENERAL +Is/ Mimi Liu +MIMI LIU +Admitted Pro Hac Vice +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +mliu@motleyrice.com +VENETIA VELAZQUEZ +Admitted Pro Hac Vice +Acting Chief, Civil Division +Virgin Islands Department of Justice +Office of the Attorney General +213 Estate La Reine, RR1 Box 6151 +Kingshill, St. Croix +U.S. Virgin Islands 00850 +Tel: (340) 773-0295 ext. 202481 +venetia.velazquez@ doj.vi.gov +LINDA +(Admitted Pro Hac Vice) +DAVID I. ACKERMAN +PAIGE BOGGS (Admitted Pro Hac Vice) +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Isinger@motleyrice.com +dackerman@motleyrice.com +pboggs@motleyrice.com +Attorneys for Plaintiff Government of the +United States Virgin Islands +40 diff --git a/vision-fixhub/court-05/5aa412ae3483530fa66d19f73bda2b122a08979ddef5f64645db515c475c493b.receipt.json b/vision-fixhub/court-05/5aa412ae3483530fa66d19f73bda2b122a08979ddef5f64645db515c475c493b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..45c6abe923acf6958d47db4100c70cd410fa82fb --- /dev/null +++ b/vision-fixhub/court-05/5aa412ae3483530fa66d19f73bda2b122a08979ddef5f64645db515c475c493b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -566, + "dataset": "marble-joined", + "doc_id": "5aa412ae3483530fa66d19f73bda2b122a08979ddef5f64645db515c475c493b", + "engine": "marble-apple-vision", + "event_count": 53, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "bf6a8e742d2893f6fa24c97e0e3059d9e8bdac479cfc5d620a940ad4ce4c2e81", + "output_sha256": "30c62c76fd4efcf5e9b2f6d1bba8bc12e96c3b078392a8b058c1993c23b48d12", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5abdd60894a4ac7464a0402d19e3df9ee85ff58663322ec94ab023d01b89f37e.md b/vision-fixhub/court-05/5abdd60894a4ac7464a0402d19e3df9ee85ff58663322ec94ab023d01b89f37e.md new file mode 100644 index 0000000000000000000000000000000000000000..ce63d30211b0891006863ddb7f62edb028eed0db --- /dev/null +++ b/vision-fixhub/court-05/5abdd60894a4ac7464a0402d19e3df9ee85ff58663322ec94ab023d01b89f37e.md @@ -0,0 +1,25 @@ + + + +Date: 2/27/2017 7:38:10 PM +From: "Turbull, Karen" +To: "Cecile de Jongh" +Ce : "McCollum, Sharon" +Subject: Discussion with Jeffrey Epstein +Good Afternoon Mrs. de Jongh: +This serves as a follow up to an email that | forwarded regarding the Education Summit held February 15, 2017. I +trust you received the information regarding the K-3 Literacy Initiative that the Virgin Islands Department of +Education is undertaking. Additionally, Commissioner McCollum requested that I contact you relative to your +assurance to speak with Mr. Jeffrey Epstein regarding other individuals who the Department of Education can +possibly contact for funding. Thank you. +Karen Pulliam Turnbull +Office of the Commissioner +Department of Education +340-774-2810 +Confidentinlity Notice The information in this e-mail and any attachments thereto is intended for the named recipient(slonly. Thise-mail, including ay attachments, may contain informatior +that is privileged and confdentiol and subject to legal restrictions and penelties regarding its unauthorized disclosure or otheruse. Ifyou are not the intended recipient, you are hereby sotified +that any disclosure, copying, distribation, or the taking ofeny oction orioaction in reliance on the contents ofthis e-meil and ony ofits ettachments is STRICTLY PROHIBITED Ifyou bave +received this e-mail in error, please immediately notif the sender via return e-mail; delete this e-mail and oll ottachments from your e-mail system and your computersystem and network and +destroy any paper coples you may have in your possession. Thankyou foryour cooperation + +ESTATE_JPM065842 diff --git a/vision-fixhub/court-05/5abdd60894a4ac7464a0402d19e3df9ee85ff58663322ec94ab023d01b89f37e.receipt.json b/vision-fixhub/court-05/5abdd60894a4ac7464a0402d19e3df9ee85ff58663322ec94ab023d01b89f37e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..58e1acac4e55a8e51428494fcb21111248a4e22e --- /dev/null +++ b/vision-fixhub/court-05/5abdd60894a4ac7464a0402d19e3df9ee85ff58663322ec94ab023d01b89f37e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "5abdd60894a4ac7464a0402d19e3df9ee85ff58663322ec94ab023d01b89f37e", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "fed6a6d466574e374ed5c460b3ee3c116e624775929df845702b27d886e7962b", + "output_sha256": "359aa2a19a3ecbb314e48e419c0d02489c43864cc8e57f2fffdacb088bbad414", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5acf49c622c65481a5da22b65c029cdcf4e95147195fc0c9616c0c275cf53c83.md b/vision-fixhub/court-05/5acf49c622c65481a5da22b65c029cdcf4e95147195fc0c9616c0c275cf53c83.md new file mode 100644 index 0000000000000000000000000000000000000000..b13c388ba0a5664ae5dcf5fb62b7a576ae057afc --- /dev/null +++ b/vision-fixhub/court-05/5acf49c622c65481a5da22b65c029cdcf4e95147195fc0c9616c0c275cf53c83.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 237-13 Filed 07/25/23 +_Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/5acf49c622c65481a5da22b65c029cdcf4e95147195fc0c9616c0c275cf53c83.receipt.json b/vision-fixhub/court-05/5acf49c622c65481a5da22b65c029cdcf4e95147195fc0c9616c0c275cf53c83.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..50238b508d5ea7d7b395189c6c5ba4051db199da --- /dev/null +++ b/vision-fixhub/court-05/5acf49c622c65481a5da22b65c029cdcf4e95147195fc0c9616c0c275cf53c83.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "5acf49c622c65481a5da22b65c029cdcf4e95147195fc0c9616c0c275cf53c83", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "4681ff2c76b1c21657e2aa728086928a41d4f852d535c541c3d38b5d2f7bbf29", + "output_sha256": "8f16f8d6e2173621c6162a601bf87486a2ecc2993ba6008b797bb440dc717b94", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5ad940f2521bbc23e4232881aa29fe8a976697397b138a26a7e7ecc54362c8cf.md b/vision-fixhub/court-05/5ad940f2521bbc23e4232881aa29fe8a976697397b138a26a7e7ecc54362c8cf.md new file mode 100644 index 0000000000000000000000000000000000000000..7bb57132bc712ebb7f24efe56540faecb25385e1 --- /dev/null +++ b/vision-fixhub/court-05/5ad940f2521bbc23e4232881aa29fe8a976697397b138a26a7e7ecc54362c8cf.md @@ -0,0 +1,445 @@ +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 1 of 15 + + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 2 of 15 +IN RE: +INVESTIGATION OF +JEFFREY EPSTEIN +NON-PROSECUTION AGREEMENT +IT APPEARING that the City of Palm Beach Police Department and the State +Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, +the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey +Epstein (hereinafter "Epstein"); +IT APPEARING that the State Attorney's Office has charged Epstein by indictment +with solicitation of prostitution, in violation of Florida Statutes Section 796.07; +IT APPEARING that the United States Attorney's Office and the Federal Bureau of +Investigation have conducted their own investigation into Epstein's background and any +offenses that may have been commitled by Epstein against the United States from in or +around 2001 through in or around September 2007, including: +(1) +knowingly and willfully conspiring with others known and unknown to +commit an offense against the United States, that is, to use a facility or means +of interstate or foreign commerce to knowingly persuade, induce, or entice +minor females to engage in prostitution, in violation of Title 18, United States +Code, Section 2422(b); all in violation of Title 18, United States Code, Section +371; +(2) +knowingly and willfully conspiring with others known and unknown to travel +in interstate commerce for the purpose of engaging in illicit sexual conduct, as +defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, +United States Code, Section 2423(b); all in violation of Title 18, United States +Code, Section 2423(e): +(3) +using a facility or means of interstate or foreign commerce to knowingly +(4) +traveling in interstate commerce for the purpose of engaging in illicit sexual +conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation + + +EXHIBIT 1) +Erdues 39 +3/15/23 +JDoe_JPMC_003010 + +JDoe_JPMC_003010 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 3 of 15 +of Title 18, United States Code, Section 2423(b); and +(5) knowingly, in and affecting interstate and foreign commerce, recruiting, +enticing, and obtaining by any means & person, knowing that the person had +not attained the age of 18 years and would be caused to engage in a +commercial sex act as defined in 18 U.S.C. § 1591(c)(I); in violation of Title +18, United States Code, Sections 1591(a)(1) and 2; and +IT APPEARING that Epstein seeks to resolve globally his state and federal criminal +liability and Epstein understands and acknowledges that, in exchange for the benefits +provided by this agreement, he agrees to comply with its terms, including undertaking certain +actions with the State Attorney's Office; +IT APPEARING, after an investigation of the offenses and Epstein's background by +both State and Federal law enforcement agencies, and after due consultation with the State +Attorney's Office, that the interests of the United States, the State of Florida, and the +Defendant will be served by the following procedure; +THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for +the Southern District of Florida, prosecution in this District for these offenses shall be +deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the +following conditions and the requirements of this Agreement set forth below. +If the United States Attorney should determine, based on reliable evidence, that, +during the period of the Agreement, Epstein willfully violated any of the conditions of this +Agreement, then the United States Attorney may, within ninety (90) days following the +expiration of the term of home confinement discussed below, provide Epstein with timely +notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its +prosecution on any offense within sixty (60) days' of giving notice of the violation. Any +notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the +United States learning of facts which may provide a basis for a determination of a breach of +the Agreement. +After timely fulfilling all the terms and conditions of the Agreement, no prosecution +for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have + + +JDoe_JPMC_003011 + +JDoe_JPMC_003011 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 4 of 15 +Terms of the Agreement: +Epstein shall plead guilty (not nolo contendere) to the Indictment as +currently pending against him in the 15th Judicial Circuit in and for +Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging +one (1) count of solicitation of prostitution, in violation of Fl. Stat. § +796.07. In addition, Epstein shall plead guilty to an Information filed +by the State Attorney's Office charging Epstein with an offense that +requires him to register as a sex offender, that is, the solicitation of +minors to engage in prostitution, in violation of Florida Statutes Section +796.03; +2. +Epstein shall make a binding recommendation that the Court impose a +thirty (30) month sentence to be divided as follows: +(a) +Epstein shall be sentenced to consecutive terms of twelve (12) +3. +4. +(b) +imprisonment; and +Epstein shall be sentenced to a term of twelve (12) months of +community control consecutive to his two terms in county jail +as described in Term 2(a), supra. +This agreement is contingent upon a Judge of the 15th Judicial Circuit +accepting and executing the sentence agreed upon between the State +Attorney's Office and Epstein, the details of which are set forth in this +agreement. +The terms contained in paragraphs 1 and 2, supra, do not foreciose +Epstein and the State Attorney's Office from agreeing to recommend +any additional charge(s) or any additional terms) of probation and/or +incarceration. +Epstein shall waive all challenges to the Information filed by the State +6. +Epstein shall provide to the U.S. Attorney's Office copics of all + + +JDoe_JPMC_003012 + +JDoe_JPMC_003012 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 5 of 15 +7. +8. +10. +proposed agreements with the State Attorney's Office prior to entering +into those agreements. +The United States shall provide Epstein's attorneys with a list of +individuals whom it has identified as victims, as defined in 18 U.S.C. +§ 2255, after Epstein has signed this agreement and been sentenced. +Upon the execution of this agreement, the United States, in consultation +with and subject to the good faith approval of Epstein's counsel, shall +select an attorney representative for these persons, who shall be paid for +by Epstein. Epstein's counsel may contact the identified individuals +through that representative. +If any of the individuals referred to in paragraph (7), supra, elects to +file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the +jurisdiction of the United States District Court for the Southern District +of Florida over his person and/or the subject matter, and Epstein waives +his right to contest liability and also waives his night to contest damages +up to an amount as agreed to between the identified individual and +Epstein, so long as the identified individual elects to proceed +exclusively under 18 U.S.C. § 2255, and agrees to waive any other +claim for damages, whether pursuant to state, federal, or common law. +Notwithstanding this waiver, as to those individuals whose names +appear on the list provided by the United States, Epstein's signature on +this agreement, his waivers and failures to contest liability and such +damages in any suit are not to be construed as an admission of any +criminal or civil liability. +Epstein's signature on this agreement also is not to be construed as an +admission of civil or criminal liability or a waiver of any jurisdictional +or other defense as to any person whose name does not appear on the +list provided by the United States. +Except as to those individuals who elect to proceed exclusively under +18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's +signature on this agreement, nor its terms, nor any resulting waivers or +settlements by Epstein are to be construed as admissions or evidence of +11. Epstein shall use his best efforts to enter his guilty plea and be + + +JDoe_JPMC_003013 + +JDoe_JPMC_003013 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 6 of 15 +12. +sentenced not later than October 26, 2007. The United States has no +objection to Epstein self-reporting to begin serving his sentence not +later than January 4, 2008. +Epstein agrees that he will not be afforded any benefits with respect to +gain time, other than the rights, opportunities, and benefits as any other +inmate, including but not limited to, eligibility for gain time credit +based on standard rules and regulations that apply in the State of +Florida. At the United States' request, Epstein agrees to provide an +accounting of the gain time he earned during his period of +incarceration. +13. The parties anticipate that this agreement will not be made part of any +public record. If the United States receives a Freedom of Information +Act request or any compulsory process commanding the disclosure of +the agreement, it will provide notice to Epstein before making that +disclosure. +Epstein understands that the United States Attorney has no authority to require the +State Attorney's Office to abide by any terms of this agreement. Epstein understands that +it is his obligation to undertake discussions with the State Attomney's Office and to use his +best efforts to ensure compliance with these procedures, which compliance will be necessary +to satisfy the United States' interest. Epstein also understands that it is his obligation to use +his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding +recommendation regarding the sentence to be imposed, and understands that the failure to +do so will be a breach of the agreement. +In consideration of Epstein's agreement to plead guilty and to provide compensation +in the manner described above, if Epstein successfully fulfills all of the terms and conditions +of this agreement, the United States also agrees that it will not institute any criminal charges +against any potential co-conspirators of Epstein, including but not limited to +, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this +agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury +investigation will be suspended, and all pending federal Grand Jury subpoenas will be held +defendant likewise agrees to withdraw his pending motion to intervene and to quash certain +roguesed by or dies ly raped to the Brom ury in beni and a pointy eleca + + +JDoe_JPMC_003014 + +JDoe_JPMC_003014 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 7 of 15 +By signing this agreement, Epstein asserts and certifies that each of these terms is +material to this agreement and is supported by independent consideration and that a breach +of any one of these conditions allows the United States to elect to terminate the agreement +and to investigate and prosecute Epstein and any other individual or entity for any and all +federal offenses. +By signing this agreement, Epstein asserts and certifies that he is aware of the fact that +the Sixth Amendment to the Constitution of the United States provides that in all criminal +prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further +is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court +may dismiss an indictment, information, or complaint for unnecessary delay in presenting +a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein +hereby requests that the United States Attorney for the Southern District of Florida defer such +prosecution. Epstein agrees and consents that any delay from the date of this Agreement to +the date of initiation of prosecution, as provided for in the terms expressed herein, shall be +deemed to be a necessary delay at his own request, and he hereby waives any defense to such +prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of +the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the +United States to a speedy trial or to bar the prosecution by reason of the running of the statute +of limitations for a period of months equal to the period between the signing of this +agreement and the breach of this agreement as to those offenses that were the subject of the +grand jury's investigation. Epstein further asserts and certifies that he understands that the +Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all +felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees +and consents that, if a prosecution against him is instituted for any offense that was the +subject of the grand jury's investigation, it may be by way of an Information signed and filed +by the United States Attorney, and hereby waives his right to be indicted by a grand jury as +to any such offense. +111 +/// +11/ + + +JDoe_JPMC_003015 + +JDoe_JPMC_003015 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 8 of 15 +By signing this agreement, Epstein asserts and certifies that the above has been read +and explained to him. Epstein hereby states that he understands the conditions of this Non- +Prosecution Agreement and agrees to comply with them. +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +Dated: +Dea 1/e10z +By: +À. +IL VILLAFAÑA +ASSISTANT U.S. ATTORNEY +Dated: +GERALD LEFCOURT, ESQ. +COUNSEL TO JEFFREY EPSTEIN +Dated: +1, ESQ. + + +JDoe_JPMC_003016 + +JDoe_JPMC_003016 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 9 of 15 +By signing this agreement, Epstein asserts and certifies that the above has been read +and explained to him. Epstein hereby states that he understands the conditions of this Non- +Prosecution Agreement and agrees to comply with them. +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +Dated: +By: +AL +ILL VILLAFANA +ASSISTANT U.S. ATTORNEY +Dated: +Dated: 9/24/07 +JEFFREY EPSTEI +Pall Fount +EFCOURT/ES +COUNSEL TO JEFFREY EPSTEIN +Dated: +, ESQ. + + +JDoe_JPMC_003017 + +JDoe_JPMC_003017 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 10 of 15 +By signing this agreement, Epstein asserts and certifies that the above has been read +and explained to him. Epstein bereby states that he understands the conditions of this Non- +Prosecution Agreemeut and agrees to comply with them. +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +Dated: +By: +VILLAFANA +ASSISTANT U.S. ATTORNEY +Dated: +JEFFREY EPSTEIN +Dated: _ +GERALD LEFCOURT, ESQ. +COUNSEL TO JEFFREY EPSTEIN +Dated: 9-2407 +ILLY ANN SANCHE +EZ, ESQ. + + +JDoe_JPMC_003018 + +JDoe_JPMC_003018 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 11 of 15 +IN RE: +INVESTIGATION OF +JEFFREY EPSTEIN +ADDENDUM TO THE NON-PROSECUTION AGREEMENT +IT APPEARING that the parties seck to clarify certain provisions of page 4, paragraph 7 +of the Non-Prosecution Agreement (hereinafter "paragraph 7"'), that agreement is modified as +follows: +7A. The United States has the right to assign to an independent third-party the responsibility +for consulting with and, subject to the good faith approval of Epstein's counsel, selecting +the attorney representative for the individuals identified under the Agreement. If the +United States elects to assign this responsibility to an independent third-party, both the +United States and Epstein retain the right to make good faith objections to the attorney +representative suggested by the independent third-party prior to the final designation of +the attorney representative. +7B. +The parties will jointly prepare a short written submission to the independent third-party +regarding the role of the attorney representative and regarding Epstein's Agreement to +pay such attorney representative his or her regular customary hourly rate for representing +such victims subject to the provisions of paragraph C, infra. +7C. +Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney +representative selected by the independent third party. This provision, however, shall not +obligate Epstein to pay the foes and costs of contested litigation filed against him. Thus, +if after consideration of potential settlements, an attorney representative clects to file a +contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested +remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney +representative, as opposed to any statutory or other obligations to pay reasonable +attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney +representative, shall cease. + +JDoe_JPMC_003019 + +JDoe_JPMC_003019 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 12 of 15 +By signing this Addendum, Epstein asserts and certifies that the above has been read and +explained to him. Epstein hereby, states that he understands the clarifications to the Non- +Prosecution Agreement and agrees to comply with them. +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +By: +Dated: +Dana 21/17 +I VILLAPANA +ASSISTANT U.S. ATTORNEY +SEFEREY PPSTEIN +Dated: +GERALD LEFCOURT, ESQ. +COUNSEL TO JEFFREY EPSTEIN +Dated: _ +ESQ. + +JDoe_JPMC_003020 + +JDoe_JPMC_003020 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 13 of 15 +By signing this Addendum, Epstein asserts and certifies that the above has been read and +explained to him. Epstein heroby states that he understands the clarifications to the Non- +Prosecution Agreement and agrees to comply with them. +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +Dated: +By: +A. +VILL-AFANA +ASSISTANT U.S. ATTORNEY +Dated: +on 10/0907 +JEFFREY EPSTEIN +COUNSEL TO JEFFRÉY EPSTEIN +Dated: _. +, ESQ. + +JDoe_JPMC_003021 + +JDoe_JPMC_003021 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 14 of 15 +By signing this Addendum, Epstein asserts and certifies that the above has been read and +explained to him. Epstein hereby states that he understands the clarifications to the Non- +Prosecution Agreement and agrees to comply with them. +.. ALEXANDER ACOST +NITED STATES ATTORNE +Dated: +By: +A. +VILLAFARA +ASSISTANT U.S. ATTORNEY +Dated: +JEFFREY EPSTEIN +Dated: +GERALD LEFCOURT, ESQ. +COUNSEL TO JEFFREY EPSTED +Dated: 10-29-07 +LILLY ANN SANCHEZ, BSQ +ATTORNEY FOR JEPFREY EPSTEIN + +JDoe_JPMC_003022 + +JDoe_JPMC_003022 + + +Case 1:22-cv-10904-JSR Document 239-19 Filed 07/25/23 Page 15 of 15 +Dwc-07-OT +04:55pm +Froe-Fowler-White Burnett + +T-986 +P. 003/304 +F-S75 +Affirmation +I, Jeffrey B. Epstein do hereby re-affirm the Nob-Proscoation Agreement and Addendum to +same dared Octobar 30, 2007. + +JDoe_JPMC_003023 + +JDoe_JPMC_003023 \ No newline at end of file diff --git a/vision-fixhub/court-05/5ad940f2521bbc23e4232881aa29fe8a976697397b138a26a7e7ecc54362c8cf.receipt.json b/vision-fixhub/court-05/5ad940f2521bbc23e4232881aa29fe8a976697397b138a26a7e7ecc54362c8cf.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ce17b4895cd74e3344c4d9c7a0fd3525179b06de --- /dev/null +++ b/vision-fixhub/court-05/5ad940f2521bbc23e4232881aa29fe8a976697397b138a26a7e7ecc54362c8cf.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -821, + "dataset": "marble-joined", + "doc_id": "5ad940f2521bbc23e4232881aa29fe8a976697397b138a26a7e7ecc54362c8cf", + "engine": "marble-apple-vision", + "event_count": 55, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "c532e3dbc40cc69ba19ea1c890920867f986b443e3ed80ebe6b0265877ab24f1", + "output_sha256": "8ccba2f323469f086c28c71570f941fff45be42b0d491bbb618dc8d12bff7db9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5adbc092faa2b1a088f029a95e294542d8d3218e4e6d51de3ea36b65d6d5b6ea.md b/vision-fixhub/court-05/5adbc092faa2b1a088f029a95e294542d8d3218e4e6d51de3ea36b65d6d5b6ea.md new file mode 100644 index 0000000000000000000000000000000000000000..26930ed9ec53d3ab6c3c0fd4d9fd2106e32e2eb4 --- /dev/null +++ b/vision-fixhub/court-05/5adbc092faa2b1a088f029a95e294542d8d3218e4e6d51de3ea36b65d6d5b6ea.md @@ -0,0 +1,36 @@ +Case 1:22-cv-10904-JSR Document 42-3 Filed 02/03/23 Page 1 of 2 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiffs, +Case No. 22-cv-10904-JSR +[PROPOSED| ORDER FOR +ADMISSION PRO HAC VICE +V. +JPMORGAN CHASE BANK, N.A., +Defendant. +The motion of Rachel S. Morse for admission to practice pro hac vice in the abovecaptioned action is granted. +Applicant has declared that she is a member in good standing of the bar of the state of +Illinois, and that his contact information is as follows: +Massey & Gail LLP +50 East Washington Street, Suite 400 +Chicago, IL 60602 +Tel.: (312) 283-1590 +rmorse@masseygail.com +Applicant having requested admission pro hac vice to appear for all purposes as counsel +for Defendant JPMorgan Chase Bank, N.A. in the above-captioned action, +IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the +above-captioned case in the United States District Court for the Southern District of New +York. + + +Case 1:22-cv-10904-JSR Document 42-3 Filed 02/03/23 Page 2 of 2 +All attorneys appearing before this Court are subject to the Local Rules of this Court, +including the Rules governing discipline of attorneys. +Dated: +_, 2023 +New York, NY +The Honorable Jed S. Rakoff +United States District Judge +2 diff --git a/vision-fixhub/court-05/5adbc092faa2b1a088f029a95e294542d8d3218e4e6d51de3ea36b65d6d5b6ea.receipt.json b/vision-fixhub/court-05/5adbc092faa2b1a088f029a95e294542d8d3218e4e6d51de3ea36b65d6d5b6ea.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e9a0a39a5d1d5aac4fa93aa8c09ce29e59824821 --- /dev/null +++ b/vision-fixhub/court-05/5adbc092faa2b1a088f029a95e294542d8d3218e4e6d51de3ea36b65d6d5b6ea.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "5adbc092faa2b1a088f029a95e294542d8d3218e4e6d51de3ea36b65d6d5b6ea", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "5ba3deedeedb610e6fb54cb0bc1ad9508d6e9f7fc8b76e253419e78df3c7a4ba", + "output_sha256": "a0d5a0d338001dfba18f2dc33562435e74ea848f2f6ccaa97c49b803085c6504", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5afbc572008f77b4f176c89748cb2cb45810c135f8d5342606fe4e54a3511177.md b/vision-fixhub/court-05/5afbc572008f77b4f176c89748cb2cb45810c135f8d5342606fe4e54a3511177.md new file mode 100644 index 0000000000000000000000000000000000000000..fd31a66c171803b0f947e3c678560d77d400afc5 --- /dev/null +++ b/vision-fixhub/court-05/5afbc572008f77b4f176c89748cb2cb45810c135f8d5342606fe4e54a3511177.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 226-18 Filed 07/24/23 + + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/5afbc572008f77b4f176c89748cb2cb45810c135f8d5342606fe4e54a3511177.receipt.json b/vision-fixhub/court-05/5afbc572008f77b4f176c89748cb2cb45810c135f8d5342606fe4e54a3511177.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ef942d00f10fa591d77ce4295caafe4999ddd301 --- /dev/null +++ b/vision-fixhub/court-05/5afbc572008f77b4f176c89748cb2cb45810c135f8d5342606fe4e54a3511177.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "5afbc572008f77b4f176c89748cb2cb45810c135f8d5342606fe4e54a3511177", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "7670374f34019b654d1d8915358265915ac2ada47c2a1da05f80d6ce69ede508", + "output_sha256": "ec6b6b2936407cbed25a0eb51504978c25dc3c83356cca35ca728788f8aeb8d0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5b180250541ad33683e724e8b55a9f7ba256d35c512e3538676e914b782f8e3f.md b/vision-fixhub/court-05/5b180250541ad33683e724e8b55a9f7ba256d35c512e3538676e914b782f8e3f.md new file mode 100644 index 0000000000000000000000000000000000000000..1af7f3399ac2ff7692b922794060576f2a823750 --- /dev/null +++ b/vision-fixhub/court-05/5b180250541ad33683e724e8b55a9f7ba256d35c512e3538676e914b782f8e3f.md @@ -0,0 +1,180 @@ +Case 1:22-cv-10904-JSR Document 61-2 Filed 02/28/23 Page 1 of 6 + + + +Case 1:22-cv-10904-JSR Document 61-2 Filed 02/28/23 Page 2 of 6 +From: +To: +Cc: +Subject: +Date: +Linda +Butts, John; Ellsworth, Felicia H; dackerman@motleyrice.com; pboggs@motleyrice.com; Aguiniga, Sara; Carol +:bnarwold@motleyrice.com +WHJPMCService +RE: USVI v. JPMC -- Discovery Correspondence +Sunday, February 12, 2023 9:01:13 AM +EXTERNAL SENDER +John: +We appreciate the effort to reach a compromise. In that spirit, we are willing to withdraw our +request for Matusow, McCleerey, and O'Hanlon. That leaves three custodians in dispute: Budhu, +Cutler, and Dimon. +We provided a letter on Friday with regard to Mr. Dimon's unique personal knowledge and believe +that JPMorgan is obligated to produce his documents. +Steven Cutler was also a key decisionmaker with respect to Epstein's accounts. In one 2008 DDR, +JPMorgan noted: "Jes Staley conferred with Stephen Cutler and the decision was made to keep him +[JEE] as a PB client." Mr. Cutler also was included in at least one Rapid Response meeting related to +new information regarding Epstein's human trafficking. Rapid Response emails noted: "[client] will +require re-approval by Steve Cutler if it is determined that the relationship will be retained." Mr. +Cutler was also Vice Chairman of JPMorgan at a time when the bank's BSA/AML program would have +been actively monitored in the follow up to the OCC's consent order and the Madoff scandal. We +therefore think there is non-privileged information regarding the handling of Epstein's accounts, Mr. +Staley's role, and the bank's compliance program that is discoverable. As you know, the +Government has noticed Mr. Cutler's deposition. +Ms. Budhu was a Business Analyst & Reporting Specialist and conducted the security services review +for Epstein DDRs in 2003, 2004, 2008, and 2011, among other Epstein entities. +Please let us know whether you will agree to produce documents for these custodians. Otherwise, +we should arrange to call +on Monday to discuss how the Court would like to handle +briefing on the disputed custodians. +Best, +Linda +Linda +Attorney at Law +401 9th St. NW, Suite 630, Washington, DC 20004 + + +Case 1:22-cv-10904-JSR Document 61-2 Filed 02/28/23 Page 3 of 6 +o. 202.386.9626 f. 202.386.9622 +singer@motleyrice.com +From: Butts, John +Sent: Friday, February 10, 2023 7:26 PM +To: Ellsworth, Felicia H ; | +Linda +; Ackerman, David ; Aguiniga, Sara ; Carol | +P; Narwold, Bill +Cc: WHJPMCService +Subject: RE: USVI v. JPMC -- Discovery Correspondence +CAUTION:EXTERNAL +Counsel, +Further to Felicia's email below, we are responding to the letter Plaintiffs sent earlier this week +seeking additional JPMC ESI custodians. As noted previously, we do not think any additional +custodians are appropriate given the slate we previously proposed, the discovery JPMC will provide +from centralized sources, and the aggressive discovery schedule. Nevertheless, in the hope of +avoiding a dispute, we propose the following additional custodians and time periods as a +compromise. +• Ann Boroweic (2006-2010) +• John Duffy (2011-2013) +• Elizabeth Hogan (2006-2013) +• Prashant Khanjo (2006-2013) +• Bonnie +(2006-2013) +• Lisa Waters (2006-2013) +• Marcus Sheridan (2006-2013) +• Valerie-Leila Jaber (2012-2013) +We are happy to discuss it further on Tuesday's call. +John +From: Ellsworth, Felicia H +Sent: Wednesday, February 8, 2023 1:05 PM +To: Isinger@motleyrice.com; dackerman@motleyrice.com; pboggs@motleyrice.com; Aguiniga, Sara +; Carol | + +Subject: USVI v. JPMC -- Discovery Correspondence + + +Case 1:22-cv-10904-JSR Document 61-2 Filed 02/28/23 Page 4 of 6 +Counsel - +Iam writing in response to various discovery issues. +1. +ESI Custodians / Search Terms +We received your letter dated Monday, February 6, providing explanations for why you believe JPMC +should expand the list of 12 ESI custodians in its search protocol to include an additional 13 +custodians. Your unilateral deadline to resolve this issue by today and threat to contact +if +it is not, is not realistic, and seems aimed at needlessly trying to force issues to the Court that the +parties should be able to resolve without burdening the Court. +Your demand is especially unwarranted in light of the fact that JPMC is the only party that has +identified its custodians and search terms or produced any documents. To that end, please provide +the custodians and search terms the USVI plans to use as soon as possible, and please confirm that +USVI will be making its initial production of documents this week. +In response to your question regarding how JPMC developed this proposal, without addressing each +custodian in detail, JPMC's initial proposal was the result of an effort to include a broad array of +custodians in a variety of divisions and functions across JPMC who are likely to possess relevant +documents. As you are aware, the goal of a reasonable search is not to identify every possible +document that might bear some tangential relevance to an issue in this case (or to search the files of +every individual who might possess a relevant document), but, instead, to develop a targeted and +achievable set of custodians and search terms that will locate the most relevant and pertinent +documents sought by plaintiffs while avoiding unnecessary duplication and burden. While we have +not completed collection and cannot provide precise hit counts, based on what we have collected +thus far, we estimate that the 12 custodians and approximately 70 search terms we proposed will +capture more than 300,000 documents, which we estimate would require a review of approximately +2 million pages. +Reviewing such a substantial volume of documents is an extraordinary undertaking, particularly +considering the discovery schedule in this case. JPMC cannot blindly double its custodian count and +burden. That is especially so in a case in which the USVI has not identified any damages in its initial +disclosures and we believe it has none (particularly after recovering $105 million from the Epstein +estate and other defendants in the Indyke litigation). +Having said that, JPMC is not rejecting your proposed custodians out of hand. It is evaluating those +requests as well as your assertions about their purported relevance. Although we believe JPMC's +initial proposal was appropriate, we are looking into ways to expand our proposal and expect that +we will accept a number of the requested custodians. One thing we are assessing is whether burden +can be managed by individual time periods where, for example, a custodian interacted with Epstein +accounts for only a portion of the period at issue. +We are working through those issues as quickly as we can and expect to have a counter proposal on +custodians to you by Thursday, February 9. We propose a meet and confer on Friday, February 10, +at which we can also discuss USVI's progress with respect to its discovery obligations, including when +it will be producing documents and USVI's own proposed custodians and search terms, that we +expect you will provide in advance as requested. Through further discussion we are confident that + + +Case 1:22-cv-10904-JSR Document 61-2 Filed 02/28/23 Page 5 of 6 +the parties can narrow, if not resolve these issues. Any attempt by the USVI to burden the Court +before the parties can reasonably complete these discussions is premature and inappropriate. +2. +Depositions +The parties still need to reach an agreement on deposition limits and procedures, and we will be +back in touch with both sets of Plaintiffs with regard to the proposal you made on Friday afternoon +during the meet and confer. +In the meantime, we are looking for March dates for Mary Erdoes and will also do so for Mary +.. As we stated, we do not believe that Jamie Dimon is an appropriate deponent. +With regard to the USVI's 30(b)(6) notice, which we received on Wednesday and discussed with you +on Friday afternoon, it is objectionable in many respects, including that it seeks testimony on 28 +topics (many of which have numerous sub-topics) and each spans 24 years. The breadth of the +notice takes some time for us to evaluate, but we plan to have written responses and objections to +you early next week. +Also, as we stated on Friday, we expect that the USVI and Doe plaintiffs would join any request for +30(b)(6) testimony such that both can be discussed at the same time. +3. +Privilege Logs +As stated during Friday's meet and confer, JPMC disagrees with the USVI's characterization of the +privilege logs JPMC provided in connection with the Indyke litigation that was pending in the USVI +and is now resolved. Those privilege logs-provided under the rules that governed that action— +complied fully with JPMC's obligations. The USVI (and you) have had those logs for well over a year +and cannot reasonably ask JPMC to amend them now, particularly after the Indyke litigation has +been resolved. JPMC will not do so. +JPMC is, however, willing to discuss privilege logs for newly produced documents in this matter (as +opposed to a re-production of a production from another matter like the Indyke litigation). In that +regard, we note that Local Rule 26.2 states that it is "presumptively proper" to provide categorical +privilege logs. That presumption is especially appropriate here given the case schedule. +Redactions +We are assessing your proposal from Friday evening, and will be responding later this week. +Thank you, i +Felicia +Felicia H. Ellsworth | WilmerHale +she/her/hers +60 State Street +Boston, +02109 USA ++1 617 526 6687 (o) ++1 617 501 5676 (c) + + +Case 1:22-cv-10904-JSR Document 61-2 Filed 02/28/23 Page 6 of 6 +felicia.ellsworth @wilmerhale.com +This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be +privileged. If you are not the intended recipient, please notify us immediately—by replying to this message or by sending an email to +postmaster @wilmerhale.com—and destroy all copies of this message and any attachments. Thank you. +For more information about WilmerHale, please visit us at http://www.wilmerhale.com. + diff --git a/vision-fixhub/court-05/5b180250541ad33683e724e8b55a9f7ba256d35c512e3538676e914b782f8e3f.receipt.json b/vision-fixhub/court-05/5b180250541ad33683e724e8b55a9f7ba256d35c512e3538676e914b782f8e3f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3bc82dc02af4d6e8b5d2d351f0e41cf6a248de17 --- /dev/null +++ b/vision-fixhub/court-05/5b180250541ad33683e724e8b55a9f7ba256d35c512e3538676e914b782f8e3f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -105, + "dataset": "marble-joined", + "doc_id": "5b180250541ad33683e724e8b55a9f7ba256d35c512e3538676e914b782f8e3f", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.privileged-attorney-work-product\"]", + "idempotent": true, + "input_sha256": "d7d21ad399a427de9ae6f14893262c14ee8ac0cae65ef7f30f21255840ae3b10", + "output_sha256": "ae394b4e25bbe50581e89fde385076953ba324e7a6248153ee177f05271b2b7a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5b1d896d4efb236e909565a5fd2e4f6c2189bae393336587233b235b8f956f9e.md b/vision-fixhub/court-05/5b1d896d4efb236e909565a5fd2e4f6c2189bae393336587233b235b8f956f9e.md new file mode 100644 index 0000000000000000000000000000000000000000..6f1281627fc896727770be919a07f78e118643c6 --- /dev/null +++ b/vision-fixhub/court-05/5b1d896d4efb236e909565a5fd2e4f6c2189bae393336587233b235b8f956f9e.md @@ -0,0 +1,24 @@ +Case 1:22-cv-10904-JSR Document 44-3 Filed 02/08/23 Page 1 of 1 +* +DO BAR +COURT OF APPEALE +On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals, +the District of Columbia Bar does hereby certify that +Mimi Liu +was duly qualified and admitted on May I!, 2001 as an attorney and counselor entitled to +practice before this Court; and is, on the date indicated below, an Active member in good +standing of this Bar. +In Testimony Whereof. +I have hereunto subscribed my +name and affixed the seal of this +Court at the City of +Washington, D.C., on February 08, 2023. +Gula carele +JULIO A CÁSTILLO +Clerk of the Court +Issued By: +David +- Director, Membership +District of Columbia Bar Membership +For questions or concerns, please contact the D.C. Bar Membership Office at 202-626-3475 or email +memberservices@dcbar.org- diff --git a/vision-fixhub/court-05/5b1d896d4efb236e909565a5fd2e4f6c2189bae393336587233b235b8f956f9e.receipt.json b/vision-fixhub/court-05/5b1d896d4efb236e909565a5fd2e4f6c2189bae393336587233b235b8f956f9e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f26a823ae849f7279acd620588bc7d8a2ee8f2dd --- /dev/null +++ b/vision-fixhub/court-05/5b1d896d4efb236e909565a5fd2e4f6c2189bae393336587233b235b8f956f9e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "5b1d896d4efb236e909565a5fd2e4f6c2189bae393336587233b235b8f956f9e", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1e1dcc2174b71e8452cbe6879465d07405de8392d1bd51f794fa08ad22fcab33", + "output_sha256": "e9213c801e29b10c5f0b32ce9e288be771aed3ed49dfbbc880d6331419a06f49", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5b209c530512b4b212cb35ad5f9ee3e27ab9dfad3cb8e7ff22d80e608295ce3b.md b/vision-fixhub/court-05/5b209c530512b4b212cb35ad5f9ee3e27ab9dfad3cb8e7ff22d80e608295ce3b.md new file mode 100644 index 0000000000000000000000000000000000000000..75848290e1319716364de5f17591aecfcb47700c --- /dev/null +++ b/vision-fixhub/court-05/5b209c530512b4b212cb35ad5f9ee3e27ab9dfad3cb8e7ff22d80e608295ce3b.md @@ -0,0 +1,67 @@ +Case 1:22-cV-10904-JSR Document 263-56 Filed 08/07/23 Page 1 of 3 + + + +Case 1:22-cV-10904-JSR Document 263-56 Filed 08/07/23 Page 2 of 3 +Reputational Risk Meeting +August 4, 2011 +Existing Client - Jeffrey Epstein +A Reputational Risk Meeting was held on August 4, 2011. Participants included John Duffy, +Anne Verdon, Kevin McCleerey, Marc Sheridan, Mary I +1, Paul Morris, Jim Dalessio, and +Bonnie +who served as secretary of the meeting. +Reason for Meeting: +John Duffy requested the meeting more as a formal review. +Summary: +Mr. Epstein has been a client since 1985. The relationship consists of accounts for his personal +investment company - Financial Trust Company and personal banking and asset accounts. +Mr. Epstein was a money manager for wealthy individuals up until his indictment and +subsequent conviction on July 3, 2008 for solicitation of a prostitute and procuring a person +under age 18 for prostitution. +At the time of Mr. Epstein's indictment, internal discussions were held between Mary Erdoes, +Jes Staley, Catherine Keating, John Duffy, and Mary | +and the decision had been made at +that time to keep Mr. Epstein solely as a banking client and on a "reactive", client service basis +New investment business would not be proactively solicited from him. The same conclusion +was made at subsequent check-point meetings. +Excerpts from the Press +Committee members reviewed recent press releases, summarized below: +• Miami Daily Business Review 4/21/11 Attorneys fight to keep plea discussions private; +Victims say they were kept out of the loop; Jeffrey Epstein Case +The two women identified in court papers only as Jane Doc 1 and Jane Doc 2 say the agreement should be +invalidated because they were not adequately informed of the plan not to file federal charges against +Epstein. +The defense attorneys' motion to intervene states the sanctity of plea talks would be undermined if U.S. +District Judge Kenneth Marra in West Palm Beach allows the correspondence to be used in the third-party +civil action brought by the alleged victims. +• Feds: We treated Epstein victims fairly 4/9/11 +The U.S. Attorney's Office says it didn't violate the Crime Victims Rights Act regarding Jeffiey Epstein's +victims because -- with no federal criminal charges filed -- it never triggered the act. + +JPM-SDNYLIT-00127928 + + +Case 1:22-cv-10904-JSR Document 263-56 Filed 08/07/23 Page 3 of 3 +Instead, the federal government deferred to the state in charging the Palm Beach and New York +billionaire with sex crimes. +Assistant U.S. Attorney Dexter Lee filed court papers Friday in a response to a request by victims Jane +Doc#1 and Jane Doe #2 to overturn a federal non-prosecution agreement with Epstein. The agreement +absolved him of any federal crimes that he could have been charged with if he successfully served his +state jail sentence and year of probation. +The agreement also provided for restitution to Epstein's victims and said he would pay attorneys' fees if +the cases settled before trial. +Unlike a plea agreement, a non-prosecution agreement is not subject to judicial pre-approval and is +"largely unreviewable," Lee wrote. +In addition to the absence of federal criminal charges, Lee argued that the U.S. Attorney's Office did its +best to treat the victims fairly. He also argued that they failed to pursue the civil Crime Victims Rights +Act case after it was originally filed on July 7, 2008, and that too much time has passed. +On behalf of the victims, attorneys Brad +According to the motion, the U.S. Attorney's Office sent "false notification" letters in January 2008 and +May 2008 to the victims, saying the case "is currently under investigation" after the government had +signed the agreement with Epstein in September 2007. +Conclusion: +The client will remain flagged as high risk and we will proceed with business as usual. The client will +remain a "banking" client only. +Respectively Submitted, +Bonnie K. diff --git a/vision-fixhub/court-05/5b209c530512b4b212cb35ad5f9ee3e27ab9dfad3cb8e7ff22d80e608295ce3b.receipt.json b/vision-fixhub/court-05/5b209c530512b4b212cb35ad5f9ee3e27ab9dfad3cb8e7ff22d80e608295ce3b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f5295206897d96130040c8391f31e2934d0dba28 --- /dev/null +++ b/vision-fixhub/court-05/5b209c530512b4b212cb35ad5f9ee3e27ab9dfad3cb8e7ff22d80e608295ce3b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -59, + "dataset": "marble-joined", + "doc_id": "5b209c530512b4b212cb35ad5f9ee3e27ab9dfad3cb8e7ff22d80e608295ce3b", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "5f1d6486df54b5d5dab0fea9e456df5a9f4a66956f2c86c95901aaccc75bf5b0", + "output_sha256": "3152562801347e196014d2e86bbdefb8a1c92af81e1798f30fe0e15164be3f02", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5b2eb739d7cb9d466ea20cd6b1e4c413f436ab6286ae309025a4d1fe7cbe81e9.md b/vision-fixhub/court-05/5b2eb739d7cb9d466ea20cd6b1e4c413f436ab6286ae309025a4d1fe7cbe81e9.md new file mode 100644 index 0000000000000000000000000000000000000000..43f815cc73130b4ab07961ac1ebf783d951b3ead --- /dev/null +++ b/vision-fixhub/court-05/5b2eb739d7cb9d466ea20cd6b1e4c413f436ab6286ae309025a4d1fe7cbe81e9.md @@ -0,0 +1,32 @@ +Case 1:22-cv-10904-JSR Document 86 Filed 03/10/23 Page 1 of 1 +AO 458 (Rev. 06/09) Appearance of Counsel +UNITED STATES DISTRICT COURT +for the +Southern District of New York +Government of the United States Virgin Islands, +Plaintiff +V. +JPMorgan Chase Bank, N.A. +Defendant +Case No. 22-cv-10904-JSR +APPEARANCE OF COUNSEL +To: +The clerk of court and all parties of record +I am admitted or otherwise authorized to practice in this court, and 1 appear in this case as counsel for: +Plaintiff Government of the United States Virgin Islands +Date: +03/10/2023 +s/Michael J. Quirk +Attorney's signature +Michael J. Quirk, 3032778 +Printed name and bar number +Motley Rice LLC +40 West Evergreen Avenue, Suite 104 +Philadelphia, PA 19118-3324 +Address +mquirk@motleyrice.com +E-mail address +(610) 579-9932 +Telephone number +(856) 667-5133 +FAX number diff --git a/vision-fixhub/court-05/5b2eb739d7cb9d466ea20cd6b1e4c413f436ab6286ae309025a4d1fe7cbe81e9.receipt.json b/vision-fixhub/court-05/5b2eb739d7cb9d466ea20cd6b1e4c413f436ab6286ae309025a4d1fe7cbe81e9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f1990495def35daac70a1345fe4d801238c03f1b --- /dev/null +++ b/vision-fixhub/court-05/5b2eb739d7cb9d466ea20cd6b1e4c413f436ab6286ae309025a4d1fe7cbe81e9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "5b2eb739d7cb9d466ea20cd6b1e4c413f436ab6286ae309025a4d1fe7cbe81e9", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1ebd4ea52dfab40cd22106a88ac1e05673c56489851e123c3d568d88abe9d882", + "output_sha256": "42151667b65ef228100e4a9f70fdf0cddaa1e1191ca50428edc5e56b3530b03b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5b31a21c3e6a0773a818d346bc5e4b49fa13a43cab7666031fedb18b307804da.md b/vision-fixhub/court-05/5b31a21c3e6a0773a818d346bc5e4b49fa13a43cab7666031fedb18b307804da.md new file mode 100644 index 0000000000000000000000000000000000000000..801f0f9c91658554c468a6cc3527e04b0c59d931 --- /dev/null +++ b/vision-fixhub/court-05/5b31a21c3e6a0773a818d346bc5e4b49fa13a43cab7666031fedb18b307804da.md @@ -0,0 +1,56 @@ +Case 1:22-cV-10904-JSR Document 265-27 Filed 08/07/23 Page 1 of 3 + + + +From: +To: +CC: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 265-27 Filed 08/07/23 Page 2 of 3 +jes.staley@jpmorgan.com +Jeffery Epstein +rosa.m.dasilva@jpmorgan.com +12/31/2008 6:37:38 PM +Re: +I may try nest week. Rosa, is there a day that works? +----- Original Message -...- +From: "Jeffrey Epstein" [jeevacation@ gmail.com] +Sent: 12/31/2008 01:14 PM EST +To: Jes Staley +Subject: Re: +better +but try to come soon +On Wed, Dec 31, 2008 at 11:04 AM, wrote: +I think I will head back. If something changes, let me know. Otherwise I've asked Rosa to make a date free in early January for me to visit +the Palm Beach office and spend some time with you. +I will call later. +Jes +----- Original Message -..-- +From: "Jeffrey Epstein" [jcevacation@ gmail.com| +Sent: 12/30/2008 07:24 PM EST +To: Jes Staley +sunday will not work for me .., everyone is gone except the housekeepers, you are more than welcome to use the +house. you will be well looked after. the chef from paris is there +Generally, this communication is for informational purposes only and it is not intended as an offer or solicitation +for the purchase or sale of any financial instrument or as an official confirmation of' any transaction. In the event +you are receiving the offering materials attached below related to your interest in hedge funds or private equity, +this communication may be intended as an offer or solicitation for the purchase or sale of such fund(s). All +market prices, data and other information are not warranted as to completeness or accuracy and are subject to +change without notice. Any comments or statements made herein do not necessarily reflect those of JPMorgan +Chase & Co., its subsidiaries and affiliates. This transmission may contain information that is privileged, +confidential, legally privileged, and/or exempt from disclosure under applicable law. If you are not the intended +recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained +herein (including any reliance thereon) is STRICTLY PROHIBITED. Although this transmission and any +attachments are believed to be free of' any virus or other defect that might affect any computer system into which +it is received and opened, it is the responsibility of the recipient to ensure that it is virus free and no responsibility +is accepted by JPMorgan Chase & Co., its subsidiaries and affiliates, as applicable, for any loss or damage arising +in any way from its use. If you received this transmission in error, please immediately contact the sender and +destroy the material in its entirety, whether in electronic or hard copy format. Thank you. Please refer to + +JPM-SDNYLIT-00004661 + + +http://www.jpmoas.edi?pages203900s8toriscussures 292ing toFUR egalenties Page 3 of 3 + +JPM-SDNYLIT-00004662 \ No newline at end of file diff --git a/vision-fixhub/court-05/5b31a21c3e6a0773a818d346bc5e4b49fa13a43cab7666031fedb18b307804da.receipt.json b/vision-fixhub/court-05/5b31a21c3e6a0773a818d346bc5e4b49fa13a43cab7666031fedb18b307804da.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f9732f41958ebd472c3d3c4e929c41dee7a48e17 --- /dev/null +++ b/vision-fixhub/court-05/5b31a21c3e6a0773a818d346bc5e4b49fa13a43cab7666031fedb18b307804da.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -59, + "dataset": "marble-joined", + "doc_id": "5b31a21c3e6a0773a818d346bc5e4b49fa13a43cab7666031fedb18b307804da", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "d481c284f1db197d87fba666546483360605125dbac5e38bcd495462677ef8d4", + "output_sha256": "3e28640c58e867f6778934836942b32fc1630bf3cc58d9b67c855a6628dbf58a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5b5cbdb1185ee53a2d3116af040f18a049184a5e7ea8b9acf7c83b7834de4571.md b/vision-fixhub/court-05/5b5cbdb1185ee53a2d3116af040f18a049184a5e7ea8b9acf7c83b7834de4571.md new file mode 100644 index 0000000000000000000000000000000000000000..beb3b15b71e2bae04d71cc2f9c92ffa8a6ed78c4 --- /dev/null +++ b/vision-fixhub/court-05/5b5cbdb1185ee53a2d3116af040f18a049184a5e7ea8b9acf7c83b7834de4571.md @@ -0,0 +1,103 @@ +Case 1:20-cr-00330-PAE Document 679 +Filed 06/26/22 Page 1 of 4 +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +June 26, 2022 +By ECF +The Honorable Alison J. Nathan, Sitting by Designation +United States District Court +Southern District of New York +United States Courthouse +40 Foley Square +New York, New York 10007 +Re: +United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) +Dear Judge Nathan: +The Government respectfully submits this letter in response to the Court's June 25, 2022 +Order directing the Government to confer with the Warden of the Metropolitan Detention Center +("MDC") regarding the defendant's access to legal materials and counsel.' This morning, the +Government spoke directly with the Warden and the Chief Psychologist of the MDC. Based on +that conversation, the Government understands that the defendant currently has access to all of her +legal documents in hard copy and is able to confer with defense counsel. Accordingly, there is no +basis to adjourn sentencing in this matter. +' The Government first learned of the defendant's newly raised concerns about her conditions of +confinement through the publicly filed letter from defense counsel last night. (Dkt. No. 677). +Defense counsel did not confer with or seek assistance directly from the Government before filing +that letter. +1 + + +Case 1:20-cr-00330-PAE Document 679 Filed 06/26/22 Page 2 of 4 +Based on information provided by the Warden and the Chief Psychologist of the MDC this +morning, the Government understands the following regarding the defendant's current status and +conditions at the MDC. On Friday, June 24, 2022, the Warden of the MDC was informed that the +Bureau of Prisons Inspector General's Office (the "IG") had received an email directly from the +defendant from within the MDC claiming to be in fear for her safety. Apparently the defendant +claimed to the IG that she feared MDC staff members were threatening her safety. The Warden +and the Chief of Psychology felt obligated to remove the defendant from general population and +investigate the defendant's claim. Ordinarily, an inmate raising such a safety concern would be +placed in a single cell of the Special Housing Unit ("SHU") of the MDC. In circumstances where +the facility is concerned that the inmate is at heightened risk of self-harm, however, the MDC will +instead place the inmate on suicide watch. The Warden and Chief Psychologist indicated that at +least two other inmates have recently been placed on suicide watch in similar circumstances. +Here, the Warden and Chief Psychologist assessed that the defendant is at heightened risk +of self-harm, particularly given her upcoming sentencing and sex offender status. As a result, they +are not comfortable placing the defendant in the SHU, but they also need to remove the defendant +from general population to investigate the threat she reported to the IG. Accordingly, the defendant +was placed on suicide watch. Although the defendant has claimed to psychology staff that she is +not suicidal, she has refused to answer psychology staff's questions regarding the threat she +reported to the IG. While she claimed to the IG to be in fear for her safety, she refused to tell +psychology staff what that fear is. Given the defendant's inconsistent accounts to the IG and to +psychology staff, the Chief Psychologist assesses the defendant to be at additional risk of selfharm, as it appears she may be attempting to be transferred to a single cell where she can engage +2 + + +Case 1:20-cr-00330-PAE Document 679 Filed 06/26/22 Page 3 of 4 +in self-harm. The defendant will remain on suicide watch until the MDC assesses that she is no +longer at heightened risk of self-harm. That status will be reevaluated daily. At the same time, +the Warden will oversee an investigation into the safety concern that the defendant reported to the +IG. +In the meantime, the Warden and Chief Psychologist have confirmed that the defendant +will be able to continue to prepare for sentencing unencumbered. After the defendant complained +that she was missing certain legal materials on suicide watch, MDC staff asked where in her +property the papers she needed were located. In response, the defendant said the materials were +in her property but refused to provide specifics about where within her property the materials were +located. To ensure that the defendant has everything she could possibly need, MDC staff gathered +all papers within the defendant's property, including bins of papers, and put them all in her cell on +suicide watch. As a result, the defendant now has all of her legal paperwork with her. If she +believes she is missing any items, she can inform MDC staff. +Additionally, the defendant continues to have access to counsel. The defendant had a legal +visit yesterday. The Warden and Chief Psychologist confirmed that the defendant will continue to +be permitted to visit in person with counsel while on suicide watch. If counsel does not visit the +defendant today, then she will be given a legal call so that she may confer with her counsel by +phone. +With respect to the defendant's complaints about her conditions more generally, the +Warden and Chief Psychologist confirmed that the defendant was given clothing this morning and +is no longer required to wear a smock. They further indicated that the lighting at night on suicide +watch is similar to the lighting at night in the general population unit where the defendant was +3 + + +Case 1:20-cr-00330-PAE Document 679 Filed 06/26/22 Page 4 of 4 +previously housed. Accordingly, there is no reason the defendant cannot get the same amount of +sleep while on suicide watch as she did in general population. +Given the defendant's continued access to her legal documents and to counsel, there is no +reason to adjourn sentencing in this matter. The Government respectfully submits that sentencing +should proceed as scheduled on June 28, 2022. +Respectfully submitted, +DAMIAN | +United States Attorney +By: +s/ +Maurene Comey +Alison Moe +Lara Pomerantz +Indrew Rohrback +Assistant United States Attorney: +Southern District of New York +Ce: Defense Counsel (by ECF) +4 diff --git a/vision-fixhub/court-05/5b5cbdb1185ee53a2d3116af040f18a049184a5e7ea8b9acf7c83b7834de4571.receipt.json b/vision-fixhub/court-05/5b5cbdb1185ee53a2d3116af040f18a049184a5e7ea8b9acf7c83b7834de4571.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9bbaf24bf65a00880bcdce17d0e9278465ea3b30 --- /dev/null +++ b/vision-fixhub/court-05/5b5cbdb1185ee53a2d3116af040f18a049184a5e7ea8b9acf7c83b7834de4571.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -50, + "dataset": "marble-joined", + "doc_id": "5b5cbdb1185ee53a2d3116af040f18a049184a5e7ea8b9acf7c83b7834de4571", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "0cdfc728679cd4c6bd380759f1f0a1d9bc7eade9f500eefb402ad2dbf1bc6648", + "output_sha256": "17eca6155669de22fde23391fd0726bf31b0ebd87039edfeadd92e0172875e28", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5b7867c8c36923af721be4e3903653a579f70e3f3cad592b71710cf36aa73723.md b/vision-fixhub/court-05/5b7867c8c36923af721be4e3903653a579f70e3f3cad592b71710cf36aa73723.md new file mode 100644 index 0000000000000000000000000000000000000000..4d1856be90cb3671c54b0bbfdb007d4ad35944e6 --- /dev/null +++ b/vision-fixhub/court-05/5b7867c8c36923af721be4e3903653a579f70e3f3cad592b71710cf36aa73723.md @@ -0,0 +1,411 @@ +AO 98 (Rev. 12/11) Appearance Bond +Filed 11/19/19 + +UNITED STATES DISTRICT COURT +for the +Southern +District of New York +ORIGINAL +United States of America +V. +) +) +19 CR 830 (AT) +MICHAEL +Defendant +) +) +APPEARANCE BOND +2004 8 +Defendant's Agreement +I, +Michael +(defendant), agree to follow every order of this court, or any +court that considers this case, and I further agree that this bond may be forfeited if I fail: +(X) to appear for court proceedings; +(X) if convicted, to surrender to serve a sentence that the court may impose; or +(X) to comply with all conditions set forth in the Order Setting Conditions of Release, +US. DISTRICT COLAT +FILED +Type of Bond +@NOV 192019 +$100,000.00 +S.D. OF N.Y. +(X) (1) This is a personal recognizance bond. +(X) (2) This is an unsecured bond of $ +(D) (3) This is a secured bond of $ +, secured by: +(D) (a) $ +, in cash deposited with the court. +(• ) (b) the agreement of the defendant and each surety to forfeit the following cash or other property +(describe the cash or other property, including claims on it - such as a lien, mortgage, or loan - and attach proof of +ownership and value): +If this bond is secured by real property, documents to protect the secured interest may be filed of record. +(D) (c) a bail bond with a solvent surety (attach a copy of the bail bond, or describe it and identify the surely): +Forfeiture or Release of the Bond +Forfeiture of the Bond. This appearance bond may be forfeited if the defendant does not comply with the above +agreement. The court may immediately order the amount of the bond surrendered to the United States, including the +security for the bond, if the defendant does not comply with the agreement. At the request of the United States, the court +may order a judgment of forfeiture against the defendant and each surety for the entire amount of the bond, including +interest and costs. + + +Case 1:19-Cr-00830-AT Document 8 Filed 11/19/19 Page 2 of 10 +AO 98 (Rev. 12/1 1) Appearance Bond +Release of the Bond. The court may order this appearance bond ended at any time. This bond will be satisfied and the +security will be released when either: (1) the defendant is found not guilty on all charges, or (2) the defendant reports to +serve a sentence. +Declarations +Ownership of the Property. I, the defendant - and each surety - declare under penalty of perjury that: +(1) all owners of the property securing this appearance bond are included on the bond; +(2) the property is not subject to claims, except as described above; and +(3) +I will not sell the property, allow further claims to be made against it, or do anything to reduce its value +while this appearance bond is in effect. +Acceptance. I, the defendant - and each surety - have read this appearance bond and have either read all the conditions of +release set by the court or had them explained to me. I agree to this Appearance Bond. +I, the defendant - and each surety - declare under penalty of perjury that this information is true. (See 28 U.S.C.§ 1746.) +ALEC THOMS +Surety/property owner- printed name +Defendant's signature Michael | +Surety/property owner - signature and date +Surety/property owner - printed name +Surety/property owner - signature and date +Surety/property owner — printed name +Surety/property owner - signature and date +Approved. + + +Case 1:19-cr-00830-AT Document 8 +Filed 11/19/19 Page 3 of 10 +• NO 98 (Rev. 12/11) Appearance Bond +Release of the Bond. The court may order this appearance bond ended at any time. This bond will be satisfied and the +security will be released when either: (1) the defendant is found not guilty on all charges, or (2) the defendant reports to +serve a sentence. +Declarations +Ownership of the Property. I, the defendant - and each surety - declare under penalty of perjury that: +(1) +all owners of the property securing this appearance bond are included on the bond; +(2) the property is not subject to claims, except as described above; and +(3) +I will not sell the property, allow further claims to be made against it, or do anything to reduce its value +while this appearance bond is in effect. +Acceptance. I, the defendant —and each surety - have read this appearance bond and have either read all the conditions of +release set by the court or had them explained to me. I agree to this Appearance Bond. +I, the defendant - and each surety - declare under penalty of perjury that this information is true. (See 28 U.S.C.§ 1746.) +Date: +11/19/2019 +ALRC THOmAS +Swret property owner - printed name +Defendant's signature Michael +Alle +R. Thomet +Surety/property owner - signature and date +Surely/property owner - printed name +Suretyproperty owner - signatire and date +Suretyproperty owner - printed name +Surety property owner - signature and date +Date:_11/19/2019 +Approved. +Date:_11/19/2019 +Aulene thus, + + +Case 1:19-Cr-00830-AT Document 8 Filed 11/19/19 Page 4 of 10 +• AO 98 (Rev. 12/11) Appearance Bond +Release of the Bond. The court may order this appearance bond ended at any time. This bond will be satisfied and the +security will be released when either: (1) the defendant is found not guilty on all charges, or (2) the defendant reports to +serve a sentence. +Declarations +Ownership of the Property. I, the defendant - and each surety - declare under penalty of perjury that: +(1) all owners of the property securing this appearance bond are included on the bond; +(2) the property is not subject to claims, except as described above; and +(3) I will not sell the property, allow further claims to be made against it, or do anything to reduce its value +while this appearance bond is in effect. +Acceptance. I, the defendant - and each surety - have read this appearance bond and have either read all the conditions of +release set by the court or had them explained to me. I agree to this Appearance Bond. +I, the defendant - and each surety - declare under penalty of perjury that this information is true. (See 28 U.S.C.§ 1746.) +Date:_ 11/19/2019 +ALEC Thoms +Surety/property owner - printed name +Qadriyyah -Lora +Suretyproperty owner - printed name +Defendant's signature Michael +Surety/property owner - signature and date +saradhuan All-hora +Sur property owner - signature and date +Newest, +Stretyproperty owner - printed name +Surety/property owner - signature and date +Approved. +Date: +11/19/2019 +M. DIXOW +USDE-NT Depily Check +12/9/19 + + +Filed 11/19/19 Page 5 of 10 +AO 199A (Rev. 12/11) Order Setting Conditions of Release +UNITED STATES DISTRICT COURT +for the +Southern +District of New York +Page 1 of +Pages +United States of America +V. +Michael +Defendant +Case No. +19 CR 830 (AT) +ORDER SETTING CONDITIONS OF RELEASE +IT IS ORDERED that the defendant's release is subject to these conditions: +(1) The defendant must not violate federal, state, or local law while on release. +(2) The defendant must cooperate in the collection of a DNA sample if it is authorized by 42 U.S.C. § 14135a. +(3) The defendant must advise the court or the pretrial services office or supervising officer in writing before making +any change of residence or telephone number. +(4) The defendant must appear in court as required and, if convicted, must surrender as directed to serve a sentence that +the court may impose. +The defendant must appear at: +Place +on +Date and Time +If blank, defendant will be notified of next appearance. +(5) The defendant must sign an Appearance Bond, if ordered. + + +Case 1:19-cr-00830-AT Document 8 +Filed 11/19/19 Page 6 of 10 +AO 199B (Rev. 12/11) Additional Conditions of Release +Page +of +Pages +ADDITIONAL CONDITIONS OF RELEASE +IT IS FURTHER ORDERED that the defendant's release is subject to the conditions marked below: +(D) (6) The defendant is placed in the custody of: +Person or organization +Address (only if above is an organization) +City and state +Tel. No. +who agrees to (a) supervise the defendant, (b) use every effort to assure the defendant's appearance at all court proceedings, and (c) notify the court immediatel +if the defendant violates a condition of release or is no longer in the custodian's custody. +Signed: +Custodian +Date +(X) (7) The defendant must: +(2) (a) submit to supervision by and report for supervision to the PRETRIAL SERVICES +telephone number +, no later than +(• ) (b) continue or actively seck employment. +(O) (c) continue or start an education program. +(X) (d) surrender any passport to: +PRETRIAL SERVICES +(X) +(e) not obtain a passport or other international travel document. +(2) +(f) abide by the following restrictions on personal association, residence, or travel: +SDNY / EDNY / DISTRICT OF NEW JERSEY +(O) (g) +avoid all contact, directly or indirectly, with any person who is or may be a victim or witness in the investigation or prosecution, +including: +(D) (h) get medical or psychiatric treatment: +(D) 0) +return to custody each +or the following purposes: +o'clock after being released at +o'clock for employment, schooling, +(0) 0 +maintain residence at a halfway house or community corrections center, as the pretrial services office or supervising officer considers +necessary. +(2X) (k) +not possess a firearm, destructive device, or other weapon, +(X) ( +not use alcohol ( • ) at all (2) excessively. +(D) (m) not use or unlawfully possess a narcotic drug or other controlled substances defined in 21 U.S.C. § 802, unless prescribed by a license +medical practitioner. +(L) (n) submit to testing for a prohibited substance if required by the pretrial services office or supervising officer. Testing may be used with randor +frequency and may include urine testing. +the wearing of a sweat patch, a remote alcohol testing system, and/or any form of prohibite +substance screening or testing. The defendant must not obstruct, attempt to obstruct, or tamper with the efficiency and accuracy of prohibite +substance screening or testing. +(D) (o) +participate in a program of inpatient or outpatient substance abuse therapy and counseling if directed by the pretrial services office ( +supervising officer. +(L) (p) participate in one of the following location restriction programs and comply with its requirements as directed. +(O) (i) Curfew. You are restricted to your residence every day ( []) from +to +_. or ( C) as +directed by the pretrial services office or supervising officer; or +(O]) (i) Home Detention. You are restricted to your residence at all times except for employment; education; religious services; medica +substance abuse, or mental health treatment; attorney visits; court appearances; court-ordered obligations; or other activitic +approved in advance by the pretrial services office or supervising officer; or +(O) (iii) Home Incarceration. You are restricted to 24-hour-a-day lock-down at your residence except for medical necessities and court +appearances or other activities specifically approved by the court. +(D) (9) submit to location monitoring as directed by the pretrial services office or supervising officer and comply with all of the program +requirements and instructions provided. +(L) You must pay all or part of the cost of the program based on your ability to pay as determined by the pretrial services office or +supervising officer. +(D) (r) report as soon as possible, to the pretrial services office or supervising officer, every contact with law enforcement personnel, including +arrests, questioning, or traffic stops. + + +Case 1:19-Cr-00830-AT Document 8 Filed 11/19/19 Page 7 of 10 +ADDITIONAL CONDITIONS OF RELEASE +(2) (s) $100,000 Personal Recognizance Bond; To be co-signed by 2 financially +responsible persons; Travel restricted to Southern and Eastern District of New +York, and District of New Jersey; Surrender travel documents and no new +applications; Pretrial supervision as directed by Pretrial Services; Defendant no +to possess firearm, destructive device, and other weapon; Defendant to be +released on own signature; Remaining conditions to be met by 11/26/2019; No +excessive use of alcohol; No contact with co-defendant unless in the presence +of counsel. + + +Filed 11/19/19 Page 8 of 10 +AO 199C (Rev. 09/08) Advice of Penalties +Page +of +Pages +ADVICE OF PENALTIES AND SANCTIONS +TO THE DEFENDANT: Michael' +19 CR 830 (AT) +YOU ARE ADVISED OF THE FOLLOWING PENALTIES AND SANCTIONS: +Violating any of the foregoing conditions of release may result in the immediate issuance of a warrant for your arrest, a +revocation of your release, an order of detention, a forfeiture of any bond, and a prosecution for contempt of court and could result in +imprisonment, a fine, or both. +While on release, if you commit a federal felony offense the punishment is an additional prison term of not more than ten +and for a federal misdemeanor offense the punishment is an additional prison term of not more than one year. This sentence will be +consecutive (i.e., in addition to) to any other sentence you receive. +It is a crime punishable by up to ten years in prison, and a $250,000 fine, or both, to: obstruct a criminal investigation; +tamper with a witness, victim, or informant; retaliate or attempt to retaliate against a witness, victim, or informant; or intimidate or +attempt to intimidate a witness, victim, juror, informant, or officer of the court. The penalties for tampering, retaliation, or +intimidation are significantly more serious if they involve a killing or attempted killing. +If, after release, you knowingly fail to appear as the conditions of release require, or to surrender to serve a sentence, +you may be prosecuted for failing to appear or surrender and additional punishment may be imposed. If you are convicted of: +(1) an offense punishable by death, life imprisonment, or imprisonment for a term of fifteen years or more - you will be fined +not more than $250,000 or imprisoned for not more than 10 years, or both; +(2) an offense punishable by imprisonment for a term of five years or more, but less than fifteen years - you will be fined not +more than $250,000 or imprisoned for not more than five years, or both; +(3) any other felony - you will be fined not more than $250,000 or imprisoned not more than two years, or both; +(4) a misdemeanor - you will be fined not more than $100,000 or imprisoned not more than one year, or both. +A term of imprisonment imposed for failure to appear or surrender will be consecutive to any other sentence you receive. In +addition, a failure to appear or surrender may result in the forfeiture of any bond posted. +Acknowledgment of the Defendant +I acknowledge that I am the defendant in this case and that I am aware of the conditions of release. I promise to obey all +conditions of release, to appear as directed, and surrender to serve any sentence imposed. I am aware of the penalties and sanctions +set forth above. +anders Released +els. +11/19/12 +Defendant's Signature +City and State +Directions to the United States Marshal +( C) The defendant is ORDERED released after processing. +(LI) The United States marshal is ORDERED to keep the defendant in custody until notified by the clerk or judge that the +defendant has posted bond and/or complied with all other conditions for release. If still in custody, the defendant must be +produced before the appropriate judge at the time and place specified. +Judicial Officer's Signature +Printed name and title + + +Case 1:19-cr-00830-AT Document 8 | +Filed 11/19/19 Page 9 of 10 +AO 199C (Rev. 09/08) Advice of Penalties +Page +of +DISTRIBUTION: +COURT +DEFENDANT +PRETRIAL SERVICE +U.S. ATTORNEY U.S. MARSHAL +Pages +Dutchess +Sullivan +Orange +Dutnam +Scuthern District of New Yerk +The Bronx +Manhattan +Westchester +Reckland +Dutchess +Orange +Putnam +Eastern District of New York +Ereeklyn (Kines County) +Queens (Queens County) +Staten Island (sachmend County) +Lene Island (Nassau & Suffelk) +Westchester +Rockland +Suffolk +Mottan +Queens +Erocklyn + + +Case 1:19-Cr-00830-AT Document 8 Filed 11/19/19 Page 10 of 10 +...... +• DOCKET No. 19 Cr 830 (AT) +DEFENDANT Michael +AUSA Nicolas Roos +INTERPRETER NEEDED +• Rule 5 +• Rule 9 • Rule 5(c)(3) • Detention Hrg. +• Other: +DEF.'S COUNSEL Montel Eiggins. +I RETAINED • FEDERAL DEFENDERS OCJA PRESENTMENT ONLY +• DEFENDANT WAIVES PRETRIAL REPORT +DATE OF ARREST 11/19/2019 +Z VOL. SURR. +TIME OF ARREST +DON WRIT +TIME OF PRESENTMENT +BAIL DISPOSITION +• SEE SEP. ORDER +• DETENTION: RISK OF FLIGHT/DANGER •SEE TRANSCRIPT +• DETENTION ON CONSENT W/O PREJUDICE +• DETENTION HEARING SCHEDULED FOR: +• AGREED CONDITIONS OF RELEASE +• DEF. RELEASED ON OWN RECOGNIZANCE +Z$100.000 +_PRB 22 +_FRP +• SECURED BY $ +CASH/PROPERTY: +ZI TRAVEL RESTRICTED TO SDNY/EDNY/District of New Jersey +O TEMPORARY ADDITIONAL TRAVEL UPON CONSENT OF AUSA & APPROVAL OF PRETRIAL SERVICES +7 SURRENDER TRAVEL DOCUMENTS (& NO NEW APPLICATIONS) +2 PRETRIAL SUPERVISION: OREGULAR OSTRICT ZAS DIRECTED BY PRETRIAL SERVICES +• DRUG TESTING/TREATMT AS DIRECTED BY PTS •MENTAL HEALTH EVAL/TREATMT AS DIRECTED BY PTS +- DEF. TO SUBMIT TO URINALYSIS; IF POSITIVE, ADD CONDITION OF DRUG TESTING/TREATMENT +• HOME INCARCERATION •HOME DETENTION •CURFEW •ELECTRONIC MONITORING OGPS +• DEF. TO PAY ALL OF PART OF COST OF LOCATION MONITORING, AS DETERMINED BY PRETRIAL SERVICES +] DEF. TO CONTINUE OR SEEK EMPLOYMENT [OR] L DEF. TO CONTINUE OR START EDUCATION PROGRAM +VI DEF. NOT TO POSSESS FIREARM/DESTRUCTIVE DEVICE/OTHER WEAPON +• DEF, TO BE DETAINED UNTIL ALL CONDITIONS ARE MET +• DER. TO BE RELEASED ON OWN SIGNATURE, PLUS THE FOLLOWING CONDITIONS: +_ REMAINING CONDITIONS TO BE MET BY: U/24/19 +ADDITIONAL CONDITIONS/ADDITIONAL PROCEEDINGS/COMMENTS: +No excessive ure of cohol. +No louther with co-defendant unders in the +presence of counsel. +I DEF. ARRAIGNED; PLEADS NOT GUILTY +• DEF. WAIVES INDICTMENT +/ SPEEDY TRIAL TIME EXCLUDED UNDER 18 U.S.C. § 3161(b)(7) UNTIL 11/25/2019 +or Rule 5(c)(3) Cases +] IDENTITY HEARING WAIVEI +• PRELIMINARY HEARING IN SDNY WAIVED +• DEFENDANT TO BE REMOVED +• CONTROL DATE FOR REMOVAL: +IZ CONFERENCE BEFORE D.J. ON 11/25/2019 +PRELIMINARY HEARING DATE: J2/19/2049 +_ DON DEFENDANT'S CONSENT +DATE: 11/19/2019 +Ill (original) - COURT FILE +lev'd 2016 +EINK - US. ATTORNEY'S OFFICE +UNITED STATES MAGISTRATE JUDGE, S.D.N.Y. +YELLOW-U.S. MARSHAL +|I - PRETRIAL SERVICES AGENCY \ No newline at end of file diff --git a/vision-fixhub/court-05/5b7867c8c36923af721be4e3903653a579f70e3f3cad592b71710cf36aa73723.receipt.json b/vision-fixhub/court-05/5b7867c8c36923af721be4e3903653a579f70e3f3cad592b71710cf36aa73723.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2abaa1bb52508b4552b49f8542f424fc4a1a3eb2 --- /dev/null +++ b/vision-fixhub/court-05/5b7867c8c36923af721be4e3903653a579f70e3f3cad592b71710cf36aa73723.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -338, + "dataset": "marble-joined", + "doc_id": "5b7867c8c36923af721be4e3903653a579f70e3f3cad592b71710cf36aa73723", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "4b132241b567cb3658ce9142c16cfe20b3843ce7f4743d6a0c0c3537bdb0bfc4", + "output_sha256": "2e56ee3d75839a6536c595363eb7a012cde012f3f39138cd1f06f12bd43a3958", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5b7c84622bfab9c90e2b6f7563cbaa67f0f7e263397c12bb2692d44ee3432042.md b/vision-fixhub/court-05/5b7c84622bfab9c90e2b6f7563cbaa67f0f7e263397c12bb2692d44ee3432042.md new file mode 100644 index 0000000000000000000000000000000000000000..5850dd6fbe1df102075c367c21b88aafc404a298 --- /dev/null +++ b/vision-fixhub/court-05/5b7c84622bfab9c90e2b6f7563cbaa67f0f7e263397c12bb2692d44ee3432042.md @@ -0,0 +1,2269 @@ +Case 1:22-cv-10904-JSR Document 326-19 Filed 09/08/23 Page 1 of 45 + + + +1 +2 +UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +4 +5 VS. +1:22-CV-10904-JSR +6 JPMORGAN CHASE BANK, N.A., +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Defendant/Third- +Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party +Plaintiff, +VS. +JAMES EDWARD STALEY, +Third-Party +Defendant. +MONDAY, JULY 10, 2023 +CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER +- +- +Videotaped deposition of Stephen M. +Cutler, held at the offices of Milbank LLP, +55 Hudson Yards, New York, New York, +commencing at 12:33 p.m. Eastern, on the +above date, before Carrie A. +Registered Diplomate Reporter, Certified +Realtime Reporter, Illinois, California & +Texas Certified Shorthand Reporter, Missouri, +Kansas, Louisiana & New Jersey Certified +Court Reporter. +- - +- +GOLKOW LITIGATION SERVICES +877.370. DEPS +deps@golkow.com +Page: 1 + + +1 proceeding, but I think it was enough to make +2 people +feel that indeed Mr. Staley had +communicated with the media beyond what he +4 +was authorized to do. +5 +Were there allegations of +6 +improper conduct by Mr. Staley in connection +with the London Whale incident that were +8 +unrelated to these unauthorized +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +communications? +I don't think so. +Between 2007 and 2012, what was +your understanding of Mr. Staley's +relationship with Jeffrey Epstein? +My understanding at that time +was that he had a close business +relationship, that he was the primary +interface with Mr. Epstein among JPMorgan +personnel, that he liked Mr. Epstein, that he +trusted Mr. Epstein, and he thought highly of +Mr. Epstein. +Q. +In your experience, did +Mr. Staley's views of Mr. Epstein evolve over +time between 2007 and 2012? +I don't remember that. +Q. +To your knowledge, how did +Page: 13 + + +1 +Mr. Staley come to know Mr. Epstein? +2 +I don't know. +3 +Do you know how long they had +4 known each other? +5 +I believe they had known each +6 other since before I arrived at JPMorgan, +7 +which was in 2007. +8 +Q. +Did you understand Mr. Staley +9 +to be personal friends with Epstein? +10 +I don't think I thought of them +11 +as personal friends. I know that sometimes +12 the line between sort of client relationship +13 +and personal relationship can get blurry at +14 +times, +and this one may have been one of +15 +those relationships where that line was +16 +blurry. But I really thought of them as +17 +business colleagues, but close business +18 +colleagues. +19 +Did you understand at the time +20 +that that line may have been blurry? +21 +I know that Mr. Staley had a +22 +close business relationship, and that's how I +23 +would have thought of it at the time. +24 +e. +Did you understand Mr. Staley +25 +to have a closer relationship with +Page: 14 + + +1 Mr. +Epstein than with other clients of the +2 bank? +3 +I think so. Certainly he had a +4 closer +relationship with Mr. Epstein than he +5 did with some other clients. I don't know +6 that his relationship -- I didn't know at the +7 time that his relationship with Mr. Epstein +8 was markedly different from other clients +9 +with whom Mr. Staley had a close business +10 relationship. +11 +To your knowledge, did +12 +Mr. Staley and Mr. Epstein socialize with one +13 +another? +14 +I don't think I knew one way or +15 +another. I don't remember knowing. +16 +To your knowledge, did +17 +18 +Mr. Staley visit Mr. Epstein's house in +New York? +19 +I think that occurred. I think +20 +that there was enough of a close relationship +21 +22 +that Mr. Staley did visit Mr. Epstein, and I +believe I was aware of that at the time. +23 +Yes. +24 +e. +What was your understanding of +25 +how many times he had visited Mr. Epstein's +Page: 15 + + +1 +2 +house? +4 +5 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +20 +21 +22 +23 +24 +25 +I don't think I had an +understanding of that. +e. +To your knowledge, did +Mr. Staley visit Epstein's property in the +6 Virgin Islands? +I don't remember. +e. +What about -- +I now know that to be the case +from things that I've read, but I don't +remember whether I knew that at the time. +What about his property in New +Mexico? +I would say no. +You were not aware that he had +visited the property in New Mexico? +I don't think I knew there was +a property in New Mexico, and that's why I +19 think I can say I was unaware that he visited +it. +In your experience, is it +unusual for JPMorgan bankers to meet with +clients outside of JPMorgan's offices? +I don't think it's -- I don't +think it's highly unusual. +Page: 16 + + +1 +e. +That was a fairly common +2 +occurrence? +3 +I wouldn't say that either. I +4 don't know that it was common, but I wouldn't +5 +say it was rare either. +6 +e. +It's not something that would +• pique your attention? +8 +I don't think so. I think for +9 +close business relationships, there would be +10 +11 +socializing and, you know, business lunches +or dinners or entertainment outside of +12 +JPMorgan's premises. +13 +You used the term "close +14 +business relationship." +15 +What do you mean by that? +16 +I mean a business relationship +17 +18 +that was more than perfunctory or one in +which the JPMorgan person would call once a +19 +quarter. I had the sense that it was closer +20 than that. +21 +22 +Did you have the sense that +they were in daily communication? +23 +No. +24 +25 +e. +Did you have the sense that +they were in weekly communication? +Page: 17 + + +1 +I don't think so. I don't +2 +think I thought about frequency of +communication. +4 +What was your understanding of +5 +Mr. Staley's position vis-à-vis the bank's +6 Epstein relationship? +7 +I don't know what you mean. +8 +e. +Who, to your understanding, +9 +oversaw the Epstein relationship in the 2007 +10 to 2011 time period? +11 +Well, I think -- as I said +12 before, I think Mr. Staley was the primary +13 +interface with Mr. Epstein. That was, from +14 my perspective, consistent throughout the +15 time that I was +-- had any involvement in the +16 +Epstein account. But there would be others +17 +at the firm that were also a part of the +18 +relationship between JPMorgan and +19 +Mr. Epstein. +20 +Q. +Who were those others? +21 +22 +Mary Erdoes. I can't remember +who the heads of the private bank would have +23 +been when Ms. Erdoes acceded to the head of +24 +asset management, but whoever those people +25 +were. +Page: 18 + + +1 my impression at the time was, I don't think +2 Mr. Staley cared much about whether my +3 position was independent or not independent. +4 He just wanted me to come out to the same +5 conclusion +that Mr. Staley was expressing to +6 me, that Mr. Epstein should remain a client +7 of the firm. +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +But Mr. Staley never did +anything to prevent you from formulating your +own independent judgment about Epstein, +correct? +Not that I was aware of. +Did he tell me everything he +knew? I don't know. That's part of what +this lawsuit is about, I suspect. +But was I aware that Mr. Staley +was throwing roadblocks in my way? I was +not. +Mr. Staley never encouraged you +not to review information relating to +Mr. Epstein's accounts, +correct? +MR. GAIL: +objection. +THE WITNESS: I don't remember +that. +Page: 31 + + +Case 1:22c99 ełfBi alocumen3?&de Eiled 096823t Page 37a45 +1 +not trying to -- I'm just trying to +2 +understand the distinction. +3 +MR. GAIL: It was young. +4 +MR. L +: Let me -- +5 +MR. EDELMAN: Why don't you ask +6 +a new question. +7 +8 +MR. L +QUESTIONS BY MR. +: Thank you. +9 +e. +You would have expected +10 Mr. Staley to tell you if he saw young women +11 at Epstein's properties? +12 +I would have. I would have +13 +expected Mr. Staley to tell me about any +14 +activity that in light of Mr. Epstein's +15 +conviction might have cast doubt on whether +16 +there were continuing issues of concern. +17 +Q. +And the presence of young women +18 +in Mr. Epstein's -- at Mr. Epstein's +19 properties is one of those things you would +20 have expected him to tell you? +21 +It might depend on a bunch of +22 +other circumstances as well. And, for +23 +example, what were those women doing, and +24 +what interaction did Mr. Staley have with +25 +them, +and what interactions did Mr. Staley +Page: 38 + + +Case 1:22 c99 dełfBi alocumen3?&de Eiled 096823t Page błat45 +1 +Not that I can recall. +2 +e. +Did you have any conversations +3 with Mr. Staley about Mr. Epstein in 2010? +4 +No. +5 +Did you have any conversations +6 with anyone at JPMorgan about Mr. Epstein in +7 those two years? +8 +I'm trying to remember the +9 +timeline. He was convicted or pled guilty in +10 +2008. I don't believe I had conversations +11 +with people at JPMorgan about Mr. Epstein in +12 +2009 and 2010. I think -- I think it wasn't +13 +until 2011 that I had discussions about +14 +Mr. Epstein. +15 +e. +And the 2011 discussions arose +16 +17 +when Mr. Langford brought the issue to your +attention? +18 +That's how I remember it. +19 +What happened when Mr. Langford +20 +21 +brought the Epstein relationship to your +attention in 2011? +22 +What I remember is Mr. Langford +23 +raising the issue about Mr. Epstein and the +24 +press surrounding Mr. Epstein. I think +25 +Mr. Langford also talked about the +Page: 58 + + +Case 1:22099 dełfBi alocumen3?&de Eiled 996823t Page bzaAr +1 +anti-trafficking initiative. +2 +I also remember at the same +3 time talking to Mr. Staley, and I think it +4 was following Mr. Langford raising the issue +5 with me. I think Mr. Staley, passing along a +6 request of Mr. Epstein's, asked that we +• contact Mr. Epstein's lawyer. +8 +As I recall it, Mr. Staley +9 thought that the lawyer would vouch for +10 Mr. Epstein in some way, and maybe it was to +11 speak to the question of whether there was, +12 +13 +in fact, an ongoing investigation. +I do remember Mr. Staley asking +14 +me to reach out to the lawyer for +15 +Mr. Epstein. +16 +And your understanding was that +17 he was doing that at the request of +18 +Mr. Epstein? +19 +That's how I understood it. +20 +21 +e. +Did Mr. Staley add his own +comments or thoughts at the time, or was he +22 +merely conveying the request of Mr. Epstein? +23 +I think at this time and +24 +subsequently Mr. Staley made clear that, you +25 +know, Mr. Epstein had turned a page, he +Page: 59 + + +Case 1:22c99 dełfRi alocumen3?&de Eiled 096823t Page bratA5 +1 had -- and these are words that Mr. Staley +2 used +-- had paid his debt to society and that +we ought to be continuing to bank Mr. Epstein +4 at JPMorgan. +5 +You recall Mr. Staley using +6 those words in 2011? +7 +The -- I definitively remember +8 the words "he paid his debt to society." +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +You know, do I remember the +other words precisely coming out of +Mr. Staley's mouth that way? No, but those +words I remember. +But do you remember him using +those words generally, or you remember him +using them specifically in 2011? +I believe it was in 2011. +Had he expressed a similar +sentiment in 2008? +Well, in 2008, I don't think +the debt was paid, if you will. I don't +think Mr. Epstein had served a sentence. +But in 2011, he had served a +sentence and, as I remember it, Mr. Staley +used those words. +25 +(Cutler Exhibit TX38 marked for +Page: 60 + + +Case 1:22c99 dełfRi alocumen3?&€ Eiled 096823t Page btalA5 +1 talked to Mr. Epstein's lawyers. +2 +I can't remember what other +3 information was +in the mix, but I think at +4 that point in time my view was there was too +5 much reputation risk associated with +6 Mr. Epstein. +7 +l. Was your assessment of the +8 Epstein relationship based entirely on +9 +reputation risk or did you also evaluate +10 +legal risk and compliance risk? +11 +I don't remember legal risk or +12 +compliance risk being presented to me as the +13 +issue here; that the issue was one of +14 +reputation. And that's how it was framed for +15 / +me. +16 +Q. +When you arrived at the view +17 that the bank should off-board Mr. Epstein, +18 +19 +who did you communicate that to? +I remember communicating it to +20 +Mr. Staley. I believe I communicated it to +21 +Mr. Langford and Mr. +and potentially +22 +to Ms. Shenker. I don't recall communicating +23 +it to others. +24 +e. +What did Mr. Staley say when +25 +you communicated that view? +Page: 76 + + +Case 1:22c99 eł§Ri alocumen3?8 Eiled 096823t Page 35a645 +1 +Steve is looking for the relationship to be +terminated, +so I'm going to back out." +3 +Do you see that? +4 +I do. +5 +And Ms. Shenker responds, "Is +6 +7 +Jes going to talk to Mary to execute the +termination?" +8 +Do you see that? +9 +I do. +10 +11 +12 +13 +And then Mr. +responds, +"I don't think he has any plans to do so. He +understands that Steve is quite firm on the +subject and is stepping back and letting +14 AM/PB handle it as it sees fit." +15 +Do you see that? +16 +17 +18 +19 +I do. +Who do you understand AM to +reference in that e-mail? +Asset management. +20 +Q. +Do you recall that in April +21 +22 +of 2011 that Mr. Staley did, in fact, step +back from the Epstein relationship? +23 +I don't recall that. +24 +You don't recall it one way or +25 +the other? +Page: 103 + + +Case 1:22c99 dełSRi alocumen3?&de Eiled 996823t Page bEatA5 +1 +I don't remember a point in +2 time in which I had any involvement in +3 Epstein in which Jes Staley was not involved. +4 +Was there a point -- +5 +Inclusive of the April time +6 period, the July time period that encompasses +7 the e-mail that we discussed earlier, and +8 then in subsequent involvement that I had +9 +with the Epstein account, Mr. Staley was +10 involved every step of the way. +11 +Was there a point when +12 Ms. Erdoes became increasingly involved in +13 the Epstein relationship? +14 +In 2011? I just don't recall +15 that happening. +16 +17 +18 +Was there any point in time +where Ms. Erdoes became increasingly involved +in managing the Epstein relationship? +19 +20 +21 +Well, I know when Mr. Staley +left the firm, at that point, I'm quite sure +that Ms. Erdoes became more involved than she +22 +would have been previously. +23 +24 +Q. +So you have no recollection of +Ms. Erdoes being involved in the Epstein +25 +relationship before Mr. Staley left the firm? +Page: 104 + + +Case 1:22c99 dełfRi alocumen3?&de Eiled 096823t Page bratA5 +1 +or the other whether you were having +2 one-on-one phone calls with Ms. Erdoes about +3 the Epstein relationship in this same time +4 frame? +5 +I don't remember doing that, +6 and I would think I would remember if I did, +7 but I don't remember it. +8 +But I see this, and I +9 +certainly -- I have no reason to doubt that I +10 +sent this e-mail that says, "I would like to +11 put it," meaning the litigation, "and him," +12 +13 +meaning Epstein, "behind us. Not a person we +should do business with, period." +14 +And I communicated that to +15 +Ms. Erdoes in this e-mail. +16 +And Mr. Staley was not copied? +17 +He was not. +18 +19 +You testified, I think, that +you remember a couple of conversations with +20 +21 +22 +Mr. Staley from 2011, one in the March, April +time frame, and then one in the latter part +of the year when he asked you to meet with +23 +Mr. Epstein. +24 +Is that right? +25 +Let me just make sure I'm clear +Page: 110 + + +Case 1:22c99 ełfBi alocumen3?&de Eiled 096823t Page bratA5 +1 about this. +2 +I think in the March, April +3 time period there were two conversations: +4 one in which Mr. Staley asked that we call +5 Mr. Epstein's lawyer, and then a subsequent +6 conversation in which I relayed my advice to +7 Mr. Staley that we should exit the account. +8 So call that the early 2011 time period. +9 +10 +And then later in 2011, at +Mr. Staley's request, I met with Mr. Epstein. +11 That was +-- the request was, would you please +12 +hear him out. Again, to be clear, the +13 +request was from Mr. Staley was, would I +14 please hear out Mr. Epstein. +15 +Q. +And you don't recall any +16 +conversations with Mr. Staley in July of 2011 +17 +18 +around the time period of these settlement +discussions? +19 +I don't. It's possible that I +20 +21 +had one or more, but I don't have a specific +recollection. +22 +23 +Q. +What do you recall specifically +about the conversation in late 2011? +24 +25 +MR. EDELMAN: Which one? +MR. I +: The one you had +Page: 111 + + +Case 1:22c99 eł§Ri alocumen3?82 Eiled 996823t Page 37a645 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +you expressed to them about the Gates +Foundation arrangement? +I think I need to consult with +JPMorgan's lawyers on privilege before I can +answer +that question. +MR. EDELMAN: Okay. +MR. L +: Okay. +MR. GAIL: Do you want to come +back? Do you want to skip and do +other stuff, or do you want to break +and do this? +MR. I +1: Let's go to the +subsequent conversation about meeting +with Mr. Epstein, and then we'll come +back to the Gates Foundation. +THE WITNESS: Okay. +QUESTIONS BY MR. I +So what do you recall about +that request to meet with Mr. Epstein in the +second half of 2011? +Again, I remember those words, +"would you please hear him out." +And I -- the -- again, the +frame for this conversation was, I think -- +I, Mr. Staley, think that we should maintain +Page: 114 + + +Case 1:22c99 dełfBi alocumen3?&de Eiled 996823t Page 27a645 +1 +an account for Mr. Epstein. Why don't you +2 hear him out. +3 +That's the essence of the +4 +conversation as I recall it. +5 +Q. +Your recollection is that he +6 reiterated at that time specifically that he +7 thought the bank should maintain a +• relationship with Epstein? +9 +Yes. In one -- in one way or +10 another, that was the context for the request +11 that I hear out Mr. Epstein. +12 +Why did he want to maintain +13 that relationship as expressed to you? +14 +I think Mr. -- as I understood +15 +it at the time, Mr. Staley simply thought -- +16 +again, I'm repeating what I said earlier, and +17 I think what Mr. Staley expressed earlier in +18 +19 +the year, he paid his debt to society, he is +trusted by a lot of people. It was in the +20 +frame of, gee, it would somehow be unfair for +21 +22 +JPMorgan to jettison the Epstein account, and +won't you hear him out. +23 +Did he say specifically what +24 +Epstein was -- wanted to talk to you about? +25 +I actually don't remember. I +Page: 115 + + +Case 1:22c99 dełfRi alocumen3?&de Eiled 096823t Page 8łatA5 +1 don't remember that. It's possible he did, +2 but I don't remember him saying, he wants to +3 tell you about X, Y or Z. +4 +e. +And was your understanding at +5 the time that this was Mr. Staley's idea that +6 you sit down with Epstein or was this +7 Epstein's idea? +8 +I don't remember. I don't +9 +remember whether I thought it was -- and +10 Mr. Staley thought -- clearly thought it was +11 a good idea. I don't -- I don't remember +12 +13 +14 +whether I thought, gee, this was initiated by +Mr. Epstein or it was initiated by +Mr. Staley. I can't remember. +15 +16 +17 +18 +19 +20 +21 +Q. +Why do you say he clearly +thought it was a good idea? +He wanted me to do it. +Why do you know he wanted you +to do it as opposed he's passing along a +request from Epstein? +MR. EDELMAN: Objection to +22 +form. +23 +THE WITNESS: The clear +24 +sentiment that I got, in words or +25 +substance, was, I'd like you to do +Page: 116 + + +Case 1:22c99 eł§Ri alocumen3?8 Eiled 996823t Page 87a645 +this. I think he deserves a hearing. +QUESTIONS BY MR. +e. +And you subsequently met with +4 Mr. Epstein? +1 +2 +3 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +I did. +How many times? +I know I met with him in person +once. I then had a follow-up that I -- I +just can't remember whether that follow-up +was in person or over the phone. +And what did you ultimately +conclude after those meetings? +I concluded that I thought that +we should exit the account. +Did you communicate that to +Mr. Staley? +I did. +When? +Following the second meeting. +e. +Which was when? +I want to say a month after the +first meeting, thereabouts. It could have +been six weeks, two months. +In late 2011? +I think so. +Page: 117 + + +Case 1:22c99 dełfBi alocumen3?&€ Eiled 096823t Page 37a645 +1 +And when you communicated that +2 view to Mr. Staley, what did he say? +3 +I don't remember. I know he +4 didn't agree with my view. I just -- it +5 doesn't +I can't -- I can't sum it up what +6 he said or communicated to me at that time. +7 +Q. +Do you remember anything about +8 that conversation? +9 +I remember saying, I haven't +10 +changed my mind. I think it's a bad idea. I +11 +would not keep him as a client. +12 +I don't remember if Mr. Staley +13 +said, that's outrageous. +I doubt he -- +14 that's not -- that's not the way Jes would +15 +speak. I don't remember what he communicated +16 +in response. +17 +I know he didn't agree with my +18 +advice. +19 +20 +Q. +seeking your advice? +Did he tell you why he was +21 +At that point? I don't -- I +22 +don't think so. I -- no, he did not. +23 +Did you tell Mr. Staley -- what +24 +specifically did you tell him about +25 +off-boarding Mr. Epstein? Did you tell him +Page: 118 + + +1 the bank should do it? The bank needed to do +it? +3 +I'm certain that I would have +4 said, I don't think we should maintain this +account. I don't think I would have said, we +are required to exit this account. +Q. +After that conversation with +8 Mr. Staley, when was the next discussion you +had with him about Mr. Epstein? +I don't recall having another +7 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +one. +e. +So that may have been your last +conversation with Mr. Staley about +Mr. Epstein? +It may have been. It's +possible I had a subsequent one; I just don't +remember it. +You don't have any specific +recollection of either e-mail or voice +communications with Mr. Staley about Epstein +in 2012 or 2013? +No, I do not. And if there was +an e-mail, I suspect you would have it. +e. +What happened with the Epstein +relationship in 2012? +Page: 119 + + +1 +exit the account. +2 +I don't know what Mr. Staley +3 did at that point, and I don't remember +4 why -- or what happened to cause the account +5 to remain open for 2012 and into 2013. +6 +e. +In 2011, both early 2011 and +7 late 2011 when you had these conversations +8 with Mr. +Staley about the Epstein +9 +relationship -- +10 +Uh-huh. +11 +e. +-- in either of those +12 +conversations, did you tell Mr. Staley that +13 +the bank must off-board the Epstein +14 relationship? +15 +I don't think I would have put +16 +it that way. I don't think I at the time +17 +would have said, gee, there's a legal +18 +requirement that we off-board this account of +19 there's a legal impediment to maintaining the +20 +account. +21 +22 +My view was, based on the +reputation associated with Mr. Epstein's +23 +account and reputation risk associated with +24 +the account, that we shouldn't. But I don't +25 +think I would have said, we must not. +Page: 122 + + +Case 1:22 obł990eł§Ri alocumen3?&d€ Eiled096823t Page 29a645 +1 +Q. +You never communicated to +2 Mr. Staley or anyone else that you were +revoking your approval for the account, +4 +correct? +5 +I don't even think I thought +6 +about the -- that as a thing. +7 +Why not? +8 +well, the approval was what it +9 +was. Now we were looking at the account for +10 +reputation risk reasons. +11 +12 +13 +What additional factors, you +know, weighed into your approval of him under +the felon policy in addition -- besides +14 +reputational risk factors? +15 +I'm sorry, back in 2008? +16 +17 +18 +19 +well, under the felon approval +policy at the bank, what was your +understanding of the factors that you were +supposed to consider in deciding whether to +20 +approve a convicted felon? +21 +I'm not sure I understand the +22 +question. +23 +24 +25 +I'm going to say this -- +MR. EDELMAN: Okay. Why don't +we get a new question that you +Page: 123 + + +Case 1:22 obł990eł§Ri alocumen3?&d€ Eiled9968&3t Page 87a645 +1 +understand. +2 +THE WITNESS: Okay. +3 +QUESTIONS BY MR. L +4 +e. +You testified earlier that +5 +you're familiar with the bank's felon +6 +approval policy, right? +7 +Correct. +8 +e. +And under that policy, you were +9 +required, or the chief risk officer was +10 +required, to approve a relationship with a +11 +convicted felon, correct? +12 +Correct. +13 +What was your understanding of +14 +the factors that you or the chief risk +15 +officer were supposed to consider in deciding +16 +whether to give that approval? +17 +I think it was pretty +18 +open-ended. +19 +What -- +20 +21 +I mean, the policy itself +didn't lay out factors. No one ever said to +22 +23 +24 +25 +me, you must consider X or Y or z. +e. +What are the factors that you +actually considered when making that +determination under the policy? +Page: 124 + + +1 +2 +3 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22 ob990eł§Ri alocumen3?&d€ Eiled 096823t Page ZRa645 +Back in 2008, I just don't +remember. I just don't remember. +Was it -- do you think it would +4 have been something beyond reputational risk +factors? +MR. GAIL: Objection. +THE WITNESS: I don't know. +QUESTIONS BY MR. L +e. +Had the reputational risk +situation materially changed from 2008 to +2011? +I believe it had, actually. +The media coverage increased significantly. +The number of lawsuits that Mr. Epstein had +settled. +Q. +You had the authority at that +time to revoke the approval that you had +given in 2008, correct? +MR. GAIL: +objection. +THE WITNESS: I don't know +where you're getting that from. +QUESTIONS BY MR. I +You don't think you had the +approval to revoke -- you had the authority +to revoke your approval? +Page: 125 + + +Case 1:22c99 eł§Ri alocumen3?&€ Eiled 096823t Page 27a645 +1 +Again, I think that the -- as I +2 understood this policy, the requirement was +3 that the GC or chief risk officer approve at +4 the time of the -- of the conviction, or at +5 the time the account was entering the firm, I +6 suppose, if it were a previous conviction, +7 but didn't contemplate that you would, like, +8 have forever more a veto power over the +9 +account. That's not how I understood the +10 policy. It certainly didn't get presented to +11 me that way. +12 +13 +14 +15 +And so the -- in 2011, the +question was, did we think that this was -- +from a reputation risk perspective, did we +think it was okay to maintain that account. +16 +17 +And my view was, I didn't. And I +communicated that. +18 +19 +Q. +You didn't understand the felon +approval policy to give you and the chief +20 +21 +risk officer veto power over accounts +relating to convicted felons? +22 +Forever more? +23 +24 +25 +MR. EDELMAN: Objection. Form. +THE WITNESS: No, I did not. +If that's what the policy +Page: 126 + + +Case 1:22 ob990eł§Ri alocumgn3?&d€ Eiled 096823t Page 37a645 +1 +2 +3 +4 +5 +6 +7 +8 +contemplated, it would have said that. +QUESTIONS BY MR. L +Well, the policy doesn't say +anything about a one-time approval either, +does it? +Well -- +MR. GAIL: Objection. +MR. EDELMAN: Objection to +form. +10 +11 +12 +THE WITNESS: You know, I think +that's what the policy means. +QUESTIONS BY MR. I +13 +That's how you interpreted the +14 policy? +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. EDELMAN: Objection to +form. +QUESTIONS BY MR. I +: +That's how you interpreted the +policy? +I never understood -- +MR. EDELMAN: Well, do you have +the policy in front of you? +THE WITNESS: I don't. +MR. EDELMAN: Is this -- +THE WITNESS: Yeah. +Page: 127 + + +Case 1:22 ob990eł§Ri alocumen3?&d€ Eiled 096823t Page 3Ła645 +1 +MR. EDELMAN: You may want to +2 +take a look at the policy. +THE WITNESS: Okay. I actually +4 +don't have that. +5 +MR. EDELMAN: Is it -- do I +6 +have it? +7 +THE WITNESS: Is this the copy? +8 +MR. GAIL: It's Cutler 5. +9 +MR. EDELMAN: It's page 7. +10 +THE WITNESS: Yeah, I -- as I +11 +read this, I would say it does not +12 +contemplate that you -- that one +13 +serving in the role as general counsel +14 +or chief risk officer has forever +15 +16 +more, after a decision is made to +accept a client, to then reject the +17 +18 +client based on this policy. +QUESTIONS BY MR. I +: +19 +Is there language in here that +20 +you read to provide for a one-time approval +21 +and no subsequent re-approval? +22 +I -- it doesn't say anything +23 +about re-approval, and it contemplates the +24 +approval. I would naturally read that to be +25 +a one-time approval. +Page: 128 + + +Case 1:22c99 eł§Ri alocumen3?6 Eiled 996823t Page 37a645 +1 +And I would also add, by +2 practice, it simply didn't work the way +3 you're +suggesting. No one on any client came +4 to me and said, ah, okay, now you should +5 +withdraw your approval, and if you don't +6 reapprove, we can't do the account. Or you +7 +should revoke your approval. No one ever +8 suggested that to me. +9 +e. +So your understanding in 2011 +10 +was that you did not have the authority to +11 +off-board the Epstein account? +12 +Not based on the considerations +13 +14 +that were framed for me and at issue in 2011, +no. I didn't have that singular authority. +15 +If you believed that the +16 +17 +business was making a decision inconsistent +with the best interests of JPMorgan, what in +18 +your mind was the proper recourse? +19 +MR. GAIL: Objection. Form. +20 +THE WITNESS: As a hypothetical +21 +matter? +22 +Yeah. If the business +23 +24 +disagreed with me about a judgment +that I had, it -- the recourse that I +25 +had might depend on the nature of the +Page: 129 + + +Case 1:22-04990/ełfRi alocumen3?&d€ Eted096823t Page 33 ae45 +1 +issue at hand. +2 +And again, if -- you know, +3 there invariably would be times where +4 the business wouldn't necessarily +5 agree with my judgment, and I'd say, +6 okay. I mean, I suppose you do that +1 every day as a lawyer, too. There are +8 times +when you will say, well, I think +9 +this, but I understand. If you want +10 to do something else, you can do it. +11 +It's not illegal. I wouldn't do that. +12 +You might -- you know, along +13 the spectrum, you might say, you know, +14 +absolutely not. Over my dead body. +15 +You might say, it's illegal, in which +16 +case I think I would have the final +17 +word. +18 +19 +But, you know, again, there may +be occasions where you would say, I +20 +understand; we have a difference; I +21 +think this; you think differently. +22 +There might be an occasion +23 +24 +where I would say, I think this, you +think differently, and, you know, I'm +25 +going to do something about that +Page: 130 + + +Case 1:22c499 eł§Ri alocumen3?&€ Eiled 996823t Page 34a645 +1 +because I think differently. +2 +There might be an occasion +3 +where I'd say, I think differently +4 +because I think it's unlawful. +5 +QUESTIONS BY MR. I +6 +e. +In the context of reputational +7 +risk concerns, there could be reputational +8 risks that you considered so grave that you +9 +would escalate your concerns to someone else, +10 +fair? +11 +I could. I don't remember +12 +circumstances where that occurred, but I +13 +suppose I could. +14 +I mean, you could escalate any +15 +issue. +16 +Q. +Your concerns with the Epstein +17 +18 +19 +relationship, fair to say, weren't so +significant that you thought it was worth +escalating them above Mr. Staley and +20 +Ms. Erdoes? +21 +A. I wouldn't characterize it that +22 +way, but I -- in fact, I didn't escalate it. +23 +I understood that someone could have a +24 +different view than I had. I articulated a +25 +strong view, that I didn't think we should do +Page: 131 + + +Case 1:22 obł990eł§Ri alocumen3?&d€ Eiled 0968&3t Page 37a645 +1 it. +2 +I couldn't say to Mr. Staley, I +3 think what you're doing is illegal, and I +4 didn't think it was -- at the time, based on +5 what I knew, I didn't think it was +6 absolutely, incredibly, awfully the worst +decision ever made. I understood that he +8 could have a different view, and he did. +9 +e. +And you thought that his view +10 +was not so unreasonable that it warranted +11 +escalating it to someone +else? +12 +I don't remember escalating it. +13 +I understood that he had a different view +14 +than I did, and I didn't think it was crazy. +15 +I disagreed with it, and I told him I +16 +disagreed with it. +17 +Q. +Did you talk to Ms. Erdoes +18 +about her views on whether the relationship +19 +should be off-boarded? +20 +21 +Again, I don't remember a +direct communication, but you pointed out the +22 +e-mail in which I clearly expressed that +23 +sentiment. I don't remember having an actual +24 +in-person or on-the-phone dialogue about it. +25 +I just don't remember. It's possible that I +Page: 132 + + +Case 1:22 ob7990eł§Ri alocumen3?&d€ Eiled9968&3t Page 3fa645 +1 +to try to find that document so I can remind +2 +myself. +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Of course. It was Cutler 31. +Okay. Yep. I got it. Hold +on. +And I apologize. +I said a few +days. It's three weeks later. +Okay. +e. +But you don't have any +recollection one way or the other of whether +Ms. Erdoes became more involved in the +Epstein relationship in the weeks and months +after Ms. Staley {sic) said he was going to +step back? +MR. EDELMAN: Objection to +form. +THE WITNESS: well, I don't +actually know that Mr. Staley said he +was going to step back. And I know +Mr. Staley didn't step back. +I don't know if Ms. Erdoes +stepped up her involvement, and I +don't know whether this communication +or series of e-mails I had with +Ms. Erdoes relates to whether we were +Page: 141 + + +Case 1:22c99 dełfRi alocumen3?&€ Eiled 996823t Page 37a645 +1 +going to maintain the account or what +2 +our position was on settling +3 +litigation with Mr. Epstein. I just +4 +don't +-- or something else. I just +5 +don't know. +6 +QUESTIONS BY MR. +7 +And your basis for saying that +8 Mr. Staley didn't step back from the Epstein +9 +relationship after April of 2011 is that you +10 had -- is that he came to you in late 2011 +11 and asked you to speak with Mr. Epstein at +12 +Mr. Epstein's request? +13 +Certainly that. I also don't +14 +15 +remember him ever saying to me, I'm out. I'm +not going to participate in the Epstein +16 +relationship. +17 +18 +And I certainly, now having +seen some of the e-mail communications, don't +19 +see an e-mail response from him to any +20 +communication that I'm sending about Epstein +21 +saying, please don't copy me on these because +22 +I want nothing to do with this. +23 +So I had no indication that +24 +Mr. Staley ever somehow recused himself or +25 +removed himself from the Epstein account. +Page: 142 + + +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22c99 dełfBi alocumen3?82 Eiled 096823t Page 39a645 +1 +e. +So your testimony is that if +2 Mr. Staley were stepping back, he should have +told you not to copy him on any future +correspondence? +He sure should have. +MR. EDELMAN: Objection. +Objection to the form. +THE WITNESS: Yes, he should +have. That is my view. +If he -- if he was somehow +recusing himself or was not to be +involved, then he should have said, +I'm out on this. Don't include me in +these e-mails. +QUESTIONS BY MR. I +Where does the word "recuse" +come from? +well, I just gave it to you. +Okay. +But, look, if he was somehow +removing himself from consideration of the +account, the disputes that JPMorgan had with +the account, I would expect that he would +say, I am not to be involved. +Q. +But you don't know one way or +Page: 143 + + +Case 1:22c99 dełfBi alocumen3?6 Eiled 096823t Page 37a645 +the other whether he was in actuality +deferring to the judgment of Ms. Erdoes or +others about what to do with the Epstein +account? +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. EDELMAN: Objection to +form. +Asked and answered at length. +THE WITNESS: It was my +impression that he was not deferring +to anybody, but actually in some ways +he was putting his stamp on the +question of whether we should - - how +we should interact with Mr. Epstein. +So I had the impression that +was the opposite of removal from +consideration or deference to others. +QUESTIONS BY MR. L +And the basis for the statement +you just made is that in late 2011 he asked +you to speak with Mr. Epstein? +MR. GAIL: Asked and answered. +THE WITNESS: Among other +things. +QUESTIONS BY MR. I +e. +What were the other things? +Yeah. I remember -- +Page: 144 + + +Case 1:22c99 dełfBi alocumen3?&€ Eiled 096823t Page 67a45 +MR. EDELMAN: Asked and +1 +2 +answered. +3 +THE WITNESS: -- communications +4 +during the summer that he was involved +5 +in about the Gates Foundation, about +6 +litigation, and I just do not have any +7 +recollection of his -- of his somehow +8 +stepping away or stepping back, or use +9 +whatever formulation you want to. I +10 +didn't think he was ever doing that. +11 +QUESTIONS BY MR. I +12 +If Mr. Staley didn't need your +13 +approval for the Epstein relationship, why +14 did you understand he was coming to you for +15 +your views in 2011? +16 +You'll have to ask Mr. Staley +17 +that. +18 +I'm asking what was your +19 +understanding at the time of why Mr. Staley +20 +was coming to you, if your approval didn't +21 +matter. +22 +Well, I think my advice should +23 +have mattered, and maybe he was concerned +24 that I would, in fact, at some point say, +25 +absolutely not, you cannot, not you should +Page: 145 + + +Case 1:22c99 dełfRi alocumen3?&de Eiled 096823t Page 8łatA5 +1 +that you were relying on? +2 +In other words -- +3 +I think I understand the +4 question. I think I relied on Mr. -- 1o0k, +I trusted Mr. Staley. You asked me before +6 did I have +reason to believe Mr. Staley would +• lie. +Or +those aren't your exact words, +8 but in substance, I did not. +9 +I think I relied on, you know, +10 Mr. Staley's sense of the client because +11 Mr. Staley was in close -- had a close +12 relationship with him. +13 +I think I relied on +14 Mr. Staley's view that it was important that +15 +Mr. Epstein had all of these relationships +16 +with others in the world at large. You know, +17 I think I used the shorthand before, sort of +18 +important people in the financial sector who +19 +placed their trust in Mr. Epstein. I mean, +20 +that came directly from Mr. Staley. +21 +I don't remember Mr. Staley +22 +saying to me, you know, X or Y or Z, except +23 +that at some point Mr. Staley said, 1ook, he +24 +25 +has -- not in words, but in substance, he's +turned a corner. He's turned a page. He +Page: 163 + + +Case 1:22-0x990tełfRi alocumen3?ede Eted0968Ł3t Page 6z ale45 +1 served his time. +2 +I mean, I -- you know, would +3 you characterize those as facts? I don't +4 know. +But, you know, Mr. -- it was important +5 to me that Mr. Staley felt quite strongly, in +6 a way that I thought was genuinely felt by +7 him, that Mr. Epstein had served his +8 sentence, paid his debt to society, was now +9 +doing the -- was on the straight and narrow +10 and, again, had all of these other people who +11 relied on him. +12 +But you ultimately disagreed +13 with Mr. Staley's views of Mr. Epstein, +14 right? +15 +I did. +16 +17 +So is it fair to say that you +considered Mr. Staley's views, as you just +18 +expressed, but ultimately didn't rely on them +19 and rejected them? +20 +No, I don't think -- well, at +21 +the end of the day, I disagreed with +22 +Mr. Staley. +23 +Did I -- was it -- was it +24 +unimportant to me that Mr. Staley thought, +25 +this is someone we should do business with? +Page: 164 + + +Case 1:22c99 eł§Ri alocumen3?8 Eiled 996823t Page 67a645 +THE WITNESS: I did rely on his +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +views. +Again, I reached a judgment +that was not the same judgment that +Jes reached. But did I rely on his +views? Absolutely I did, and I think +quite appropriately. +He was a respected member of +the operating committee. He had run +the asset management business. He +had -- he was running the investment +bank. He knew this client. +So those views were important +to me and I think formed an important +backdrop for my ultimate advice, even +though, again, it wasn't the advice +that Jes would have wanted to hear and +even though it was a conclusion that +Jes didn't agree with. +QUESTIONS BY MR. I +e. +Would your ultimate advice have +been different if Mr. Staley hadn't expressed +his own personal views about the Epstein +relationship? +It might have been, actually. +Page: 167 + + +Case 1:22c99 dełfBi alocumen3?62 Eiled 096823t Page 84al45 +1 +e. +How so? +2 +Because it might have been a +stronger articulation of the advice. +4 +Or let me actually put it this +5 +way. +If Jes had not had a strong view about +6 maintaining Epstein as a client, we simply +7 +wouldn't have done it, period. They wouldn't +8 have needed to come to me at all. +9 +10 +Right. +My question is -- +11 +The only reason I was involved +12 at all is that Jes felt so strongly that we +13 +should continue to do business with +14 +Mr. Epstein. That's why -- that's why people +15 +came to me. +16 +17 +18 +19 +Q. +My question is whether your +ultimate -- your view of Mr. Epstein would +have been any different had Jes not expressed +his own views. +20 +MR. GAIL: Asked and answered. +21 +MR. I +: Asked. +22 +23 +THE WITNESS: No, I think I -- +I think I've also answered the +24 +question. I think it might have +25 +affected the -- you know, how far +Page: 168 + + +Case 1:22c99 dełfBi alocumen3?8 Eiled 996823t Page 878645 +1 +along the spectrum the "we should not +2 +do business" would have gone. +QUESTIONS BY MR. I +e. +So there was some conceivable +world in which you may have insisted that +6 Epstein be removed as a client in 2011? +I think if there was no one at +8 the bank who was willing to stand up and +vouch for the guy, I think we would have +exited the account. I do. +And Jes Staley was vouching for +4 +5 +7 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +him. +Exhibits 30 and 31 +introduced.) +QUESTIONS BY MR. I +I'm going to show you two +documents which were previously marked as +Exhibits 30 and 31 in the Bonnie +deposition. +I know we took a break not long +ago, Mr. Warner, but after -- and I don't +need to do it while these documents are in +front of me, but after we get through these +two documents, I'd love a bathroom break. +That's fine. +Page: 169 \ No newline at end of file diff --git a/vision-fixhub/court-05/5b7c84622bfab9c90e2b6f7563cbaa67f0f7e263397c12bb2692d44ee3432042.receipt.json b/vision-fixhub/court-05/5b7c84622bfab9c90e2b6f7563cbaa67f0f7e263397c12bb2692d44ee3432042.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dddb7964958fded572ea4ccaf6efcdf113f4ea71 --- /dev/null +++ b/vision-fixhub/court-05/5b7c84622bfab9c90e2b6f7563cbaa67f0f7e263397c12bb2692d44ee3432042.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -2069, + "dataset": "marble-joined", + "doc_id": "5b7c84622bfab9c90e2b6f7563cbaa67f0f7e263397c12bb2692d44ee3432042", + "engine": "marble-apple-vision", + "event_count": 47, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "e38c5fbecd963ef0872d77d46499ec658ca15ce33a42de7c5d1c23c29490d0e6", + "output_sha256": "bbbf5c6715331efe99aa2ebe7cbfe0ec4ee6d39431f8468ec8f7752f7b7604bf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5ba02ff8aec8d22db18810f0786f1c0db35e0e5da39a818460a46bddf026db32.md b/vision-fixhub/court-05/5ba02ff8aec8d22db18810f0786f1c0db35e0e5da39a818460a46bddf026db32.md new file mode 100644 index 0000000000000000000000000000000000000000..199b1bc4bd01fc0ed48048bdd1280732eb566cf0 --- /dev/null +++ b/vision-fixhub/court-05/5ba02ff8aec8d22db18810f0786f1c0db35e0e5da39a818460a46bddf026db32.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 311-5 Filed 08/25/23 Page 1 of 1 + +Filed Under Seal diff --git a/vision-fixhub/court-05/5ba02ff8aec8d22db18810f0786f1c0db35e0e5da39a818460a46bddf026db32.receipt.json b/vision-fixhub/court-05/5ba02ff8aec8d22db18810f0786f1c0db35e0e5da39a818460a46bddf026db32.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3dbaae3b0577edcc3a43b93c68e605b303fd7623 --- /dev/null +++ b/vision-fixhub/court-05/5ba02ff8aec8d22db18810f0786f1c0db35e0e5da39a818460a46bddf026db32.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "5ba02ff8aec8d22db18810f0786f1c0db35e0e5da39a818460a46bddf026db32", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "c495d2dd2d6a67c98686efae63ec5bdf1aa1d3b8602b6a163f5bc0c19817ef8a", + "output_sha256": "e745109886f68e64b8a96c532cf1fe6ece95c7bc01a75e3aa1b2121c8ae8f81d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5ba5ac4f1d7c9d666986da1c290e79a97875b9eb2ad05bbce2b63fa7db06c786.md b/vision-fixhub/court-05/5ba5ac4f1d7c9d666986da1c290e79a97875b9eb2ad05bbce2b63fa7db06c786.md new file mode 100644 index 0000000000000000000000000000000000000000..049f583be05e7820c762f1ad5f077198f74ff7d6 --- /dev/null +++ b/vision-fixhub/court-05/5ba5ac4f1d7c9d666986da1c290e79a97875b9eb2ad05bbce2b63fa7db06c786.md @@ -0,0 +1,1469 @@ +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 1 of 33 + + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 2 of 33 +MAY 2009 +JPMORGAN CHASE & Co. + +JPM-SDNYLIT-00149115 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 3 of 33 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 4 of 33 +INTRODUCTION +Our integrity and reputation depend on our ability to do the right thing, even when it's not the +casy thing. The Code of Conduct is a collection of rules and policy statements intended to assist +employees and directors in making decisions about their conduct in relation to the firm's +business. The Code is based on our fundamental understanding that no one at JPMorgan Chase +should ever sacrifice integrity -- or give the impression that they have -- even if they think it +would help the firm's business. +Each of us is accountable for our actions, and each of us is responsible for knowing and abiding +by the policies that apply to us. Managers have a special responsibility, through example and +communication, to ensure that employees under their supervision understand and comply with +the Code and other relevant policies. +You can look to the Code of Conduct to guide your decisions in a variety of circumstances. +However, no rulebook can anticipate every situation. Ultimately, the personal integrity and +honesty of every JPMorgan Chase employee define the character of our company. Never +underestimate the importance of your own ethical conduct to the business and success of +JPMorgan Chase. + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 5 of 33 +TABLE OF CONTENTS +1. ADMINISTRATION OF THE CODE OF CONDUCT +1.1. Persons subject to the Code of Conduct.. +1.2. Consultants, agents and temporary workers. +1.3. Consequences of violating the Code ... +1.4. Questions about the Code….... +1.5. Obligation to report violations …......... +1.6. Current version of the Code ... +1.7. Affirmation..... +2. DIVERSITY. +3. CONFIDENTIAL INFORMATION, PUBLIC COMMUNICATION, DATA PRIVACY +3.1. Information about the firm, its customers, its employees, and others... +3.2. Prior employer's confidential information and trade secrets ......... +3.3. Special rules regarding customer information and data privacy legislation... +3.4. Publications, speeches, internet postings, and other communications relating to JPMorgan +Chase's business.. +4. INSIDE INFORMATION AND THE POLICY ON INFORMATION BARRIERS.. +4.1. Inside Information... +4.2. The Policy on Information Barriers and other restrictions on sharing information +5. OTHER BUSINESS CONDUCT +5.1. Assets of the firm... +5.2. Intellectual property +5.3. +Telephones, e-mail, internet, and other electronic communications devices +5.4. +Internal controls, record-keeping, and reporting. +5.5. Limits of your authority +5.6. +Business relationships. +5.6.1. Fair dealing; respect for human rights... +5.6.2. Customer, supplier, and employee relationships +5.7. Money laundering and the USA PATRIOT Act +5.8. Conduct with competitors; tying of products.. +5.9. Bribery and the Foreign Corrupt Practices Aet.. +5.10. International boycotts and economic sanctions.. +5.12. Poher protoysion obliensibis of some employes. +OUTSIDE ACTIVITIES, GIFTS, AND OTHER POTENTIAL CONFLICTS OF INTEREST +6.1. Personal relationships... +6.2. Personal finances.. +6.3. Outside business and not-for-profit activities; outside employment +6.3.1. General... +6.3.2. +Required pre-clearance of outside activities +6.4. +Political Activities +2 +2 +4 +5 +6 +6 +:7 +7 +8 +8 +8 +9 +9 +10 +10 +11 +11 +11 +11 +. 12 +12 +, 12 +12 +. 13 +.13 +13 +13 +14 +. 15 +16 + +JPM-SDNYLIT-00149118 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 6 of 33 +6.4.1. Political campaign activities and contributions by employees. +6.4.2. Political contributions and related activities by JPMorgan Chase. +6.5. Accepting gifts, meals, and entertainment from customers, suppliers, and others doing business +or seeking to do business with JPMorgan Chase +6.5.1. What you may accep............ +6.5.2. What you may not accept ...... +6.5.3. Approval of nonconforming gifts +6.5.4. Required reporting of gifts..... +6.6. Providing gifts, meals or entertainment +6.7. Solicitations at work; charitable contributions by the firm +16 +....17 +17 +.18 +..19 +20 +.20 +,20 +21 +7. PERSONAL SECURITIES AND OTHER FINANCIAL TRANSACTIONS +7.1. General investment principles... +7.2. Persons and accounts subject to policies +7.3. Trading in JPMorgan Chase securities.. +7.3.1. Policies applicable to all employees. +7.3.2. Employees subject to the "window" and "Senior-level employees" +7.4. Trading in securities of clients and suppliers.... +Additional policies for certain groups of employees. +21 +21 +.22 +.22 +.22 +23 +...23 +23 +Definitions and Examples + + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 7 of 33 +1. ADMINISTRATION OF THE CODE OF CONDUCT +The Code of Conduet (the "Code") sets forth certain minimum expectations that JPMorgan Chase has for +you. You are expected to conduct the firm's business in full compliance with both the letter and the spirit +of the law, the Code, and any other policies and procedures that may be applicable to you. The "firm" +and "JPMorgan Chase" as used throughout the Code mean JPMorgan Chase & Co. and all its direct and +The Code is intended to provide general guidance regarding your conduct as an employee or director of +JPMorgan Chase. Note that other policies and procedures are listed at the end of many Code sections, +with an electronic link on the intranet edition of the Code. These listed items provide more detailed +information about the relevant subject and may include additional requirements with which you must +comply. However, these lists are not an exhaustive consideration of all policies and procedures that may +be applicable to you, and you are responsible for knowing which policies and procedures (whether or not +listed here) apply to you, and for understanding and complying with them. You should refer to these +documents where appropriate. Consult any of the persons listed in Section 1.4 if you have questions. +On the Code home page (and at the end of the printed edition of the Code), you will find a section of +Definitions and Examples. +Any waiver of the provisions of this Code for an executive officer or a director must be made by the +Board of Directors and will be promptly disclosed to JPMorgan Chase & Co. stockholders. +The Corporate Secretary may provide interpretations of the Code, in consultation with the General +Counsel where appropriate. +The Code of Conduct does not create any rights to continued employment and is not an employment +contract. +1.1. Persons subject to the Code of Conduct +The Code applies to employees and directors of JPMorgan Chase & Co. and its direct and indirect +subsidiaries. Employees of joint ventures and entities in which JPMorgan Chase holds private equity +investments are not subject to the Code except to the extent the Legal and Compliance Department +determines otherwise. The provisions of the Code described in Section 5.11 also apply to former +employees. +If any provision contravenes or is less restrictive than the applicable law of any jurisdiction, the local law +will apply. Similarly, certain business units have policies that are more restrictive than the Code, and +those more restrictive policies will apply to those units. You are responsible for understanding and +complying with these laws and policies. +1.2. Consultants, agents and temporary workers +in general, consultants, agents and temporary workers are expected to comply with the underlying +principles of the Code. Specific arrangements with such persons will vary depending on their relationship + +JPM-SDNYLIT-00149120 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 8 of 33 +to the firm. Consult your Compliance officer or your Code Specialist if you have questions about your +obligations or those of others. +1.3. Consequences of violating the Code +Compliance with the Code and with other policies and procedures applicable to you is a term and +condition of employment by JPMorgan Chase. Violations of any laws that relate to the operation of our +business, the Code, or other applicable policies and procedures, or failure to cooperate as directed by the +firm or to provide complete and accurate information in connection with any internal or external +investigation or litigation matter relating to the firm's business, may result in corrective action, up to and +including immediate termination of employment. The firm will take all reasonable actions to enforce the +Code. In cases where a violation of the Code could cause the firm irreparable harm, it may seck injunctive +relief in addition to monetary damages. +1.4. Questions about the Code +Each line of business and support group has been assigned at least one "Code Specialist," generally a +Compliance officer, to act as a resource for all employees in the area on Code-related issues. Contact +information for these officers is included in the Code Specialists List, and employees can contact their +Code Specialist for assistance with any questions regarding the Code. +Employees who have questions about the Code or other policies and procedures, or about how a particular +rule applies in a specific situation, can also contact: +• their manager +• their local Compliance officer +• the Legal and Compliance Department +• their Human Resources Business Partner or Employee Relations +• the Office of the Secretary +Contact information is included in the Code Contacts List. +The following lists some of the common situations in which you may have obligations under the Code +and refers you to the relevant section(s) of the Code. You should not use this list as a substitute for +familiarity with all provisions of the Code. +Situation +Unethical or illegal behavior: +You observe conduct by another employee, a supplier, a customer, or +another person doing business with the firm that you believe to be +unethical, illegal, or contrary to the Code of Conduct. +Discriminatory or harassing conduct: +You experience or observe conduct that you believe violates the firm's +policies prohibiting employment discrimination or harassment. +Confidential information: +You wish to disclose confidential information about the firm, a +customer, a fellow employee, or another person or entity doing business +with the firm. +Publications: +You wish to write and publish a book, article, or other work relating to +the business of JPMorgan Chase. +Code Section +2 +3 and 4 +3.4 +2 + +JPM-SDNYLIT-00149121 + + +Case 1:22-CV-10904-JSR Document 326-52 Filed 09/08/23 Page 9 of 33 +Situation +Speaking engagements and public testimony: +You wish to give a speech or provide testimony on a subject relating to +the firm's business. +Media inquiries: +You have received an inquiry from a member of the media on a subject +related to the firm's business, or in a situation in which you might be +seen as speaking for the firm. +Endorsements: +A customer, supplier, or other person or entity doing business with the +firm has asked you to provide an endorsement or testimonial. +Post-employment obligations: +You anticipate leaving JPMorgan Chase, and you are not certain what +continuing obligations you may have after your employment is ended. +Potential conflict of interest: +You are in a situation that presents a potential conflict of interest or +appearance of a conflict of interest. +Outside business or other for-profit activities: +You wish to become involved with an outside business or to accept a +second job. +Outside not-for-profit activities: +You wish to become a director, trustee, or officer of a not-for-profit +organization. +lolding political office or other governmental positior +ou wish to run for political office or accept appointment to an +governmental position. +Political activities: +You wish to become involved with a political campaign, lobbying +effort, or other political activity. +Gifts or entertainment offered or provided by persons doing +business with JPMorgan Chase: +You are offered or receive a gift from a customer, supplier, or other +party doing business with JPMorgan Chase. +Gifts to customers, suppliers, or others doing business with +JPMorgan Chase: +You wish to make a gift or extend an invitation to a person doing +business with JPMorgan Chase. +Charitable solicitations at work: +You wish to ask co-workers, customers, or suppliers to contribute to a +charitable cause with which you are involved. +Personal investment activity: +You, or a member of your family, are making personal investments that +may be subject to the firm's policies and procedures regarding personal +account trading. +Code Section +3.4 +3.4 +3.4 +5.11 +6.3 +6.3 +6.3 and 6.4 +6.4 +6.5 +6.6 +6.7 +3 + +JPM-SDNYLIT-00149122 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 10 of 33 +1.5. +Obligation to report violations +You must promptly report any known or suspected violation of the Code, any internal firm policy, or any +law or regulation applicable to the firm's business, whether the violation involves you or another person +subject to the Code. In addition, you should report any illegal conduct, or conduct that violates the +underlying principles of the Code, by any of our customers, suppliers, contract workers, business partners, +or agents. If something doesn't look right, say something. +Report violations as follows: +Matters involving harassment or discrimination must be reported to your manager, to the +Employee Relations Unit of Human Resources, or to your HR Business Partner or Employee +Relations. +Matters involving fraudulent acts, including acts by third parties against the firm or personal +dishonesty by an employee, must be reported to the Global Security and Investigation +Department. +If you believe that an official at a high level of the firm is involved, report to the General Auditor. +All other matters should be reported to the Legal and Compliance Department. +If the persons to whom you report a violation are not responsive, or if there is reason to believe that +reporting to the persons indicated above is inappropriate in a particular case, then you should contact the +firm's General Counsel, any other Executive Committee member, or the General Auditor. +To call the Global Security and Investigation Department, dial: +from within the U.S.. Canada and Latin America (toll free) +1-888-282-5867 +from EMEA +all locations (toll call) ++44-207-325-9082 or 9261 or 1110 (reverse charge calls accepted during normal +business hours) +UK, Belgium, Luxemburg, Spain, Switzerland, Italy. South Africa, Germany, Ireland, +and Russia (toll frec) +00800 3247 5869 (confidential freephone) +all other EMEA locations (toll free) ++44 207 325 9082 or 9261 or 1110 (reverse charge calls accepted during normal +business hours if toll free calls are not permitted from your dialing location) +from Asia Pacific +all locations (toll call) ++852 2800 1656 or 8780 (reverse charge calls accepted during normal business +hours) +China, Hong Kong, Japan, Malaysia, South Korea, Singapore, Thailand, Taiwan, and +Australia (toll free) +800 5784 5784 (confidential international freephone) +all other Asia Pacific locations (toll free) ++852 2800 1656 or 8780 (reverse charge calls accepted during normal business +hours if toll free calls are not permitted from your dialing location) +You may also contact the Global Security and Investigation Department either +4 + +JPM-SDNYLIT-00149123 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 11 of 33 +by mail: +from North America +from all other locations +or by e-mail: +from North America +from Asia Pacific +from all other locations +1 Chase Manhattan Plaza, 21" Floor, New York, NY 10081 +125 London Wall, 16" Floor, London EC2Y5AJ England +fraud.prevention.and.investigation@jpmchase.com +FPI-ASIAPACIFIC@jpmorgan.com +FPI-EMEA@jpmorgan.com +If you have a particular concern regarding accounting, internal accounting controls, auditing matters, or +financial reporting practices that you wish to bring to the attention of the Audit Committee of the Board +of Directors, you may do so by mail sent to: JPMorgan Chase & Co., Attention: Audit Committee +Chairman, c/o Global Security and Investigation Department at one of the addresses listed above, or by +calling the Global Security and Investigation Department at any of the telephone numbers listed above. +You may report your concerns anonymously, if you wish. We will respect the confidentiality of those +who raise concerns, subject to our obligation to investigate the concern and any obligation to notify third +parties, such as regulators and other authorities. We strictly prohibit retaliation against employees for the +reporting of any actual or suspected violations of the Code. +You must immediately report to your Human Resources Business Partner or Employee Relations any +misdemeanor (other than a minor traffic violation), criminal charge, or arrest involving you personally, +whether it relates to the business of the firm or not. See HR's policy on Criminal Convictions, linked +Employees in France are subject to other reporting provisions, which are included in either the | +Compliance Manual (linked below) or the +Code of Conduct (available from Human Resources in +France). +1.6. Current version of the Code +The current edition of the Code is posted on the intranet. It may be amended from time to time, and all +amendments are effective immediately upon posting. It is your responsibility to review the Code from +time to time to ensure that you are in compliance. +1.7. Affirmation +You are required to affirm, either in writing or electronically, that you have read and understood the Code +and that you will comply with it. This affirmation is required of new employees when they are hired and +of new directors when they are elected to office. In addition, periodically all employees will be required +to re-affirm their understanding of and compliance with the then-current Code. +2. +DIVERSITY +JPMorgan Chase is committed to providing an inclusive and nondiscriminatory working environment in +which all employees are valued and empowered to succeed. The firm prohibits discrimination or +harassment on the basis of race, color, national origin, citizenship status, creed, religion, religious +affiliation, age, sex, marital status, sexual orientation, gender identity, disability, veteran status, and any +other status protected under any applicable law. Each of us is responsible for ensuring implementation of +this policy and maintaining a business environment free of harassment and intimidation. +5 + +JPM-SDNYLIT-00149124 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 12 of 33 +Likewise, you may not unlawfully discriminate in your dealings with current or prospective customers +and suppliers. +The firm's Travel and Entertainment Policies preclude reimbursement from, or payment by, JPMorgan +Chase for membership in or expenses incurred at organizations with discriminatory practices. +3. CONFIDENTIAL INFORMATION, PUBLIC COMMUNICATION, DATA PRIVACY +We are all responsible for the safeguarding of confidential information, whether it is information +entrusted to us by our customers, information regarding JPMorgan Chase's businesses and activities, or +information about other employees. +3.1. Information about the firm, its customers, its employees, and others +You may have access to confidential information related to the firm's business. Information related to the +firm's business includes information about the firm, as well as information related to the firm's customers, +counterparties, or advisory clients (all of which the Code refers to as customers), business partners, +suppliers, and your fellow employees. +You may not, either during your period of service or thereafter, directly or indirectly, use or disclose to +anyone any such confidential information, except as permitted by the Code and other policies applicable +You must observe the following principles when dealing with information relating to the firm's business: +(a) +Assume that information that you have about the firm and its business, or about its past, +present, or prospective customers, suppliers, and employees, is confidential, unless the +contrary is clear. +(b) +(c) +Treat all personal information about individuals as confidential. +Before sharing confidential information with others in the firm, be sure that you are +permitted to do so. Do not disclose confidential customer information to other employees +who are not involved with the transaction or service for which the information was +provided to the firm --- even if you believe the disclosure might be useful in the context +of other firm business --- unless you are authorized to do so. +(d) +Do not disclose confidential information to anyone outside the firm unless you are +authorized to do so. Where such disclosure is authorized, a confidentiality or privacy +agreement may be required; check with the Legal and Compliance Department. +(e) +If you are permitted to share confidential information, use your judgment to limit the +amount of information shared and disclose it only on a need-to-know basis in order to +provide the services we are engaged to provide. Ensure that the recipient knows the +information is confidential and has been instructed about restrictions on further use and +dissemination. +(f) +Comment or provide information on matters related to the firm's business only if it is part +of your job function or you are otherwise authorized to do so. +(g) +Protect confidential information when communicating electronically -- for instance, by e- +mail or through the internet. +(h) +Remember that all forms of communication are covered, including written, telephonic, +and electronic communications such as website chatrooms, e-mail, and instant +messaging. (See Section 3.4 for more on internet communications.) +6 + +JPM-SDNYLIT-00149125 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 13 of 33 +(i) Consult your manager or your Compliance officer if you have any question about +whether information can be shared. +3.2. Prior employer's confidential information and trade secrets +Do not disclose to JPMorgan Chase, or use during your employment at JPMorgan Chase, any confidential +information or trade secret of a prior employer, unless the information or trade secret is then public +information through no action of your own. +3.3. Special rules regarding customer information and data privacy legislation +Each of us has a special responsibility to protect the confidentiality of information related to customers. +This responsibility may be imposed by law, may arise out of agreements with our customers, or may be +based on policies or practices adopted by the firm. Certain jurisdictions have regulations relating +specifically to the privacy of individuals and/or business and institutional customers. Various business +units and geographic areas within JPMorgan Chase have internal policies regarding customer privacy. +You should be familiar with those that apply to you. Customer information should never be disclosed to +anyone outside the firm except as permitted by law and in the proper conduct of our business, where +disclosure is required by legal process, or where the Legal and Compliance Department otherwise +determines it is appropriate. +3.4. +Chase's business +Publications, speeches, internet postings, and other communications relating to JPMorgan +You should not comment on or provide information relating to JPMorgan Chase's businesses, or to any +subject matter that relates to your job responsibilities or expertise at JPMorgan Chase, in public forums +(including internet chatrooms, networking sites, bulletin boards, blogs, etc.) unless you are specifically +authorized to do so. The concept of "relating to JPMorgan Chase's businesses" is broadly defined and +generally includes anything related to the financial services industry; the firm itself and its businesses; +such matters as the firm's security, +technology support, procurement practices, +legal/regulatory/compliance issues, ete.; and the firm's customers, employees, or vendors. +You should also be alert to situations in which you may be perceived as representing or speaking for the +firm. You should not make any statements on behalf of JPMorgan Chase unless you are authorized to do +so. Refer all media inquiries to the Media Relations Office. +Public testimony (as an expert witness or otherwise), publications and speaking engagements relating to +the firm's business are subject to pre-clearance. Subpoenas, requests from law enforcement or regulatory +relevant policies and procedures. Procedures for pre-clearance of these activities are included in the +policy on Communication on Matters Relating to the Company's Business. +If you will be paid for any of these activities, you will also need pre-clearance under Section 6.3.2 +(outside activities); consult your Code Specialist. +7 + +JPM-SDNYLIT-00149126 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 14 of 33 +4. +INSIDE INFORMATION AND THE POLICY ON INFORMATION BARRIERS +Buying or selling securities while in possession of material non-public information is prohibited, as is the +communication of that information to others. +4.1. +Inside Information +If you are aware of inside information, +(a) +you may not buy or sell securities (including equity securities, bonds and other debt +securities, convertible securities, derivatives, options, any | +index including any such +security as an element, and any other financial instruments) that may be affected by that +information, either for your own account or any account over which you exercise control, +alone or with others. +(b) +you may not pass along any inside information expressly or by way of making a +recommendation for the purchase or sale of such securities based upon inside +information. +"Inside information" is material, nonpublic information about the securities, activities, or financial +condition of a corporation, public entity, or other issuer of securities. Material, nonpublic information +concerning market developments may also be construed to be inside information. +Information is "material" if it could have an impact on the market price of securities involved or if it is +likely that a reasonable investor would consider the information important in deciding whether to +purchase or sell the securities. Information may be material to one issuer but not to another, or to certain +securities of an issuer but not to all securities of that issuer. +Information should be considered "nonpublic" unless it is clearly public. Information is deemed public +once it has been publicly announced or otherwise disseminated in a manner that makes the information +available to investors generally. +Likewise, you may not buy or sell securities if you have knowledge of proposed customer trades, trades +by JPMorgan Chase, or forthcoming research reports regarding those securities or the issuer of those +securities, and you may not pass along this information to others in any way. +These prohibitions are applicable no matter how you acquired the inside information. They are applicable +to the securities of JPMorgan Chase as well as to those of other companies. +These prohibitions do not apply to qualified transactions pursuant to certain planned acquisition or selling +programs, such as so-called 10b5-1 programs. These prohibitions also do not apply to legally permissible +transactions with the issuer of the securities, or with other persons having the same information you have +(a circumstance likely to be relevant only in the context of private securities). Before engaging in any +transactions you believe to be permissible under this paragraph, you must consult with your Compliance +officer. +4.2. The Policy on Information Barriers and other restrictions on sharing information +The firm's Policy on Information Barriers refers to a system of information barriers (also known as +Chinese Walls) designed to limit the flow of inside information from areas that routinely have access to +such information, such as Investment Banking, Capital Markets, Commercial Lending, Credit, +Restructuring, and Mergers and Acquisitions ("insider areas"), to those areas that trade in or sell securities +8 + +JPM-SDNYLIT-00149127 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 15 of 33 +or provide investment advice regarding securities, such as Sales, Trading, Research, and Asset +Management ("public areas"). The Policy on Information Barriers prohibits anyone in an insider area +from communicating inside information, however obtained, to anyone in a public area, subject to limited +exceptions approved by the relevant Compliance officer. +In addition, some business areas within the firm require procedures that address more specifically the +information flows within those business areas. These are also referred to as information barriers (or as +Chinese walls). +Employees subject to the firm's Policy on Information Barriers, or to other information barriers designed +to meet specific business needs, are responsible for compliance with the provisions of applicable policies. +5. OTHER BUSINESS CONDUCT +We are all expected to conduct the firm's business in accordance with the highest ethical standards, +respeeting the firm's customers, suppliers, and other business counterparties, dealing responsibly with the +firm's assets, and complying with applicable legal and regulatory requirements. +5.1. Assets of the firm +You are expected to protect the firm's assets as well as the assets of others that come into your custody. +The firm's assets include not only financial assets such as cash and securities and physical assets such as +furnishings, equipment and supplies, but also customer relationships and intellectual property such as +information about products, services, customers, systems and people. All property created, obtained, or +compiled by or on behalf of the firm ... including customer lists, directories, policies and procedures, +files, reference materials and reports, computer software, data processing systems, computer programs, +and databases --- belongs to the firm. +The firm's assets should be used only for the conduct of the firm's business, except where limited +incidental personal use is authorized by the Code or other applicable policies. +5.2. Intellectual property +Any invention, discovery, development, concept, idea, process, or work related to the firm's business, +written or otherwise, whether or not it can be patented or copyrighted, that you develop alone or with +others during your employment with the firm (all of which are referred to as "Company Inventions") +belongs to the firm. If a Company Invention is something that can be copyrighted and you create it as a +part of your job with the firm or because the firm asks you to create it, it is a "work made for hire." The +firm is not required to acknowledge your role in the creation of any Company Inventions or to have your +permission to modify, expand, or benefit from it. +As a condition of your employment, you assign exclusively to the firm all of your right, title and interest +in Company Inventions. You further agree to assist the firm in obtaining for its own benefit intellectual +property rights, including any patents and copyrights, in the Company Inventions and agree to deliver any +documents that may be requested to assure, record or perfect your assignment of the Company Inventions +to the firm. +9 + +JPM-SDNYLIT-00149128 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 16 of 33 +5.3. Telephones, e-mail, internet, and other electronic communications devices +Telephones, electronic mail (e-mail) systems and other electronic communications devices provided by +JPMorgan Chase, whether in the workplace or elsewhere, are the property of the firm and should be used +for business purposes; however, limited incidental personal use is permitted, consistent with the Code and +all other policies of the firm. +The use of e-mail, the firm's intranet and the internet must conform to the policies of JPMorgan Chase. +E-mail and internet systems may be used to transmit or provide access to confidential information only +when such information is adequately protected and transmitting such information is necessary for +business purposes. +Among other things, the following are prohibited in electronic communications: +statements, which, if made in any other forum, would violate any of our policies, +including policies against discrimination and harassment; participation in impermissible +or illegal activities (such as gambling or the use and sale of controlled substances); and +the misuse of confidential information. +(b) +accessing, downloading, uploading, saving, or sending sexually oriented or other +offensive materials. +JPMorgan Chase considers all data and communications transmitted through, received by, or contained in +the firm's electronic or telephonic equipment and systems to be JPMorgan Chase's property. Subject to +applicable laws and regulations, JPMorgan Chase reserves the right to monitor, review, and disclose all +such data and communications as it deems appropriate. You should have no expectation of privacy when +using such resources. +5.4. Internal controls, record-keeping, and reporting +Internal accounting controls and record-keeping policies have been established in order for JPMorgan +Chase to meet both legal and business requirements. You are expected to maintain and adhere to these +controls and policies. +The falsification of any book, record, or account relating to the business of JPMorgan Chase, its +customers, or its suppliers, or to the disposition of assets of the firm, its customers, or its suppliers +(including without limitation the submission of any false personal expense statement, claim for +reimbursement of a non-business expense or a false employee record or claim under an employee benefit +plan), is prohibited. +The firm's record-keeping policies include policies for records and document retention and destruction. +Notwithstanding any other provision of document retention policies, no document or record may be +destroyed if you have been advised or otherwise should recognize that it may be relevant to a pending or +threatened legal or regulatory proceeding, except in accordance with procedures approved by the head of +the Litigation Group in the Legal Department or one of his/her direct reports. +It is of critical importance that JPMorgan Chase's filings with regulatory authorities be accurate and +timely. Information provided to those involved in preparation of the firm's disclosures to regulators and +investors should be complete, accurate, and informative. +10 + +JPM-SDNYLIT-00149129 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 17 of 33 +5.5. Limits of your authority +Your authority to act on behalf of JPMorgan Chase is limited by various laws, regulations, corporate +charters, by-laws, and board resolutions, and by internal policies and procedures. You may not sign any +Jocuments, or otherwise represent or exercise authority, on behalf of any JPMorgan Chase entity unless +you are specifically authorized to do so. Be aware of limits on your authority and do not take any action +that exceeds those limits. +Delegation of authority, where permissible under corporate policies and otherwise appropriate, should be +reasonably limited in scope and subject to appropriate ongoing oversight. +5.6. Business relationships +5.6.1. Fair dealing; respect for human rights +In addition to strict compliance with applicable laws, rules, and regulations, JPMorgan Chase expects its +employees and directors to conduct themselves in accordance with general standards of ethical behavior. +In particular: +(a) +(b) +You should always endeavor to deal fairly and in good faith with the firm's customers, +suppliers, competitors, business partners, regulators, and employees. It is our policy not +to take unfair advantage of others through manipulation, concealment, abuse of +privileged information, misrepresentation of material facts, or any other unfair dealing +practice. +You should observe the firm's Human Rights Statement, where it is applicable to your +business dealings. +5.6.2. Customer, supplier, and employee relationships +During your employment you may not, directly or indirectly: +solicit for a competitor, or divert or attempt to divert from doing business with JPMorgan +Chase, any customer, identified prospective customer, supplier, or other person or entity +with whom JPMorgan Chase has or had a business relationship. +(b) +solicit JPMorgan Chase's employees for employment or engagement elsewhere or solicit +or induce any employee, consultant, independent contractor, agent, or supplier to leave +JPMorgan Chase. +5.7. Money laundering and the USA PATRIOT Act +JPMorgan Chase has established policies, procedures and internal controls designed to assure compliance +with international laws and regulations regarding money laundering and terrorist financing, including +relevant provisions of the Bank Secrecy Act and the USA PATRIOT Act in the United States and similar +legislation in other countries. You should be familiar with, and comply with, these policies, procedures +and controls. You should also understand your obligations to: +(a) +know your customers and your customers' use of the firm's products and services. +(b) +get proper training if you are identified as being in a job that poses a risk of money +laundering or terrorist financing. +(c) +be alert to and report unusual or suspicious activity to the designated persons within your +line of business or region, including your Compliance officer or Risk Manager +responsible for anti-money laundering compliance. +11 + +JPM-SDNYLIT-00149130 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 18 of 33 +5.8. Conduct with competitors; tying of products +United States antitrust laws and the laws of many other jurisdictions prohibit certain conduct that is +deemed collusive or anti-competitive, such as agreements among competitors to affect prices of goods or +services (price fixing), reduce competition in a bidding process (bid rigging), divide up customers or +markets, limit availability of products or services, or refuse to deal with a specific business counterparty. +If your work involves interacting with a competitor of JPMorgan Chase or if you communicate about +pricing with parties other than clients, you should be familiar with relevant firm policies. +"Tying" arrangements, under which the availability or price of one product is conditioned on the +customer's purchase of another product, are illegal under some circumstances. United States Federal laws +govern tying arrangements involving bank subsidiaries of JPMorgan Chase & Co. You are responsible for +being familiar with these rules if they apply to you. +If you have any question as to whether any conduct may be collusive or anti-competitive, or may violate +the prohibitions against tying, consult with the Legal and Compliance Department. +5.9. Bribery and the Foreign Corrupt Practices Act +Federal and other laws in the United States and the laws of many other countries prohibit giving, offering, +r promising, directly or indirectly, anything of value to corruptly influence any government officia +ncluding any officer of a political party or a candidate for political office, for the purpose of obtaining o +retaining business or to secure an improper advantage (such as favorable regulatory or judicial action). +Offering or paying such remuneration to any such person, either directly or through any intermediaries +such as agents, attorneys or other consultants, is strictly prohibited. +In addition, you may not accept any such payments in connection with any business decision or +transaction, even if such payments are customary in the particular country involved. +5.10. International boycotts and economic sanctions +The U.S. antiboycott law prohibits certain actions to comply with or support an unsanctioned foreign +boycott against a country friendly to the United States. The prohibited actions include refusing to do +business in a certain country, furnishing information about a person in response to a boycott-related +request, and implementing a letter of credit that contains a condition related to any of the prohibited +The U.S. economic sanctions regulations prohibit U.S. persons, including U.S. financial institutions and +their foreign branches and non-U.S. affiliates, from exporting financial services to certain foreign +governments and their specially designated nationals named by the Office of Foreign Assets Control +(OFAC). These regulations also require that assets of these governments and persons be frozen. All +their customers (and potential customers) are not on the OFAC list. You should be familiar with the +policies and procedures that apply to you. +5,11. Post-employment responsibilities +As a condition of continued employment with JPMorgan Chase, employees will have certain +an obligation to return all firm assets in their possession, maintain the confidentiality of information +12 + +JPM-SDNYLIT-00149131 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 19 of 33 +Chase, and, if requested, assist JPMorgan Chase with investigations, litigation, and the protection of +intellectual property relating to their employment. Senior-Level Employees have additional obligations +for one year after they leave JPMorgan Chase, including prohibitions on the solicitation and hiring of +JPMorgan Chase employees and solicitation of certain customers. Certain employees are subject to other +post-employment restrictions. You are responsible for knowing which post-employment restrictions and +requirements apply to you. +5.12. Other professional obligations of some employees +Some employees have additional obligations relating to their positions with the firm, including employees +who are considered to be finance professionals, certain employees acting as attorneys for the firm, and +certain officers in the Investment Bank and Asset Management. If you are subject to any of these +additional requirements, you should be familiar with and comply with them. +6. +OUTSIDE ACTIVITIES, GIFTS, AND OTHER POTENTIAL CONFLICTS OF +INTEREST +Employees must never permit their personal interests to conflict with or to appear to conflict with the +interests of the firm. When faced with a situation involving a potential conflict, ask yourself whether +public disclosure of the matter could embarrass JPMorgan Chase or you, or would lead an outside +observer to believe a conflict exists, whether or not one actually does. You must disclose to the Office of +the Secretary all potential conflicts of interest, including those in which you may have been placed +inadvertently due to either business or personal relationships with customers, suppliers, business +associates, or competitors of JPMorgan Chase, or with other JPMorgan Chase employees. +6.1. Personal relationships +In general, you may not act on behalf of JPMorgan Chase in any transaction or business relationship +involving yourself, members of your family, or other persons or organizations with which you or your +family have any significant personal connection or financial interest. These matters should be handled by +an authorized unrelated employee. +You may not engage in self-dealing or otherwise trade upon your position with JPMorgan Chase or accept +or solicit from a client or supplier any personal benefit that is not generally available to other persons or +that is made available to you due to your position with JPMorgan Chase (except in accordance with our +policies regarding the occasional acceptance of gifts). +Negotiating with JPMorgan Chase on behalf of others with whom you or your family have a significant +connection should be avoided if there is a risk that your involvement would be perceived as self-dealing +or trading upon your position with the firm. +Hiring or working with relatives, or someone with whom you have a romantic relationship, is subject to +specific restrictions. You should be aware of those limitations if they apply to you. +6.2. Personal finances +Because of the nature of our business, any improper handling of your personal finances could undermine +our credibility and that of JPMorgan Chase. Also, a precarious personal financial position might appea +o influence actions or judgments you make on behalf of JPMorgan Chase +13 + +JPM-SDNYLIT-00149132 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 20 of 33 +You may not borrow money (other than nominal amounts) from or lend money to other employees, +customers or suppliers, or act as a guarantor, co-signer, or surety or in any other similar capacity for +customers, suppliers, or other employees. You should borrow only from reputable organizations that +regularly lend money. If you borrow from any financial institution, the loan must be obtained on nonpreferential terms. +In general, you may not participate in any other personal financial transactions with fellow employees, +customers, or suppliers. This prohibition includes shared investments (unless they are either widely held +or held pursuant to firm sponsored co-investment plans) and investment clubs. +The foregoing limitations do not apply to: +borrowing from, or acting as guarantor, co-signer, or surety for, relatives or close +personal friends (generally, friendships formed outside the context of any JPMC business +relationship). +(b) +borrowing on non-preferential terms from a customer that is in the financial services +(c) +making consumer credit purchases on non-preferential terms from a customer or supplier +in the normal course of that customer/supplier's business. +6.3. Outside business and not-for-profit activities; outside employment +6.3.1. General +Your outside activities must not reflect adversely on JPMorgan Chase or give rise to a real or apparent +conflict of interest with your duties to the firm. You must be alert to potential conflicts of interest and be +aware that you may be asked to discontinue any outside activity if a potential conflict arises. You may +not, directly or indirectly: +(a) accept a business opportunity from someone doing business or seeking to do business +with JP +Chase that is made available to you because of your position with the +firm. +(b) +take for yourself a business opportunity belonging to the firm. +(c) engage in a business that competes with any of the firm's businesses. +In general, employees may not work for, or serve as a director or officer of or adviser to, a competitor of +the firm. Competitors include unrelated financial services companies of any kind, and others engaged in +any business The firm is involved in, such as banks, asset managers, depository institutions, credit unions, +lenders, investment banks, insurers, insurance agencies, and securities brokers, dealers, and underwriters. +Employees should also not invest in a competitor (other than investments in securities of publicly traded +companies). +Dutside activities must not interfere with your job performance or require such long hours as to affec +our physical or mental effectiveness. Your job at JPMorgan Chase should always be your first worl +priority. +You may accept appointments as a personal fiduciary only for family members and close personal friends. +However, you may not act as a personal fiduciary for a personal friend if the friendship developed in the +context of a JPMorgan Chase customer relationship. +14 + +JPM-SDNYLIT-00149133 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 21 of 33 +6.3.2. Required pre-clearance of outside activities +Pre-clearance is required for certain outside activities by employees, as described below. +1. Outside business activities +Subject to the exclusions listed below, you are required to pre-clear: +(1) +any outside activity for which you will be paid, including a second job and any +paid service to a not-for-profit organization. +(li) +whether or not you will be paid, any affiliation with another business as a +director, officer, advisory board member, general partner, owner, consultant, +holder of 5% or more of the business' voting equity interests, or in any similar +position. +However, you are not required to pre-clear the following activities under this Section (although +these matters may be subject to clearance or reporting requirements of your business unit or of +other sections of the Code): +(a) +certain types of appointments specifically excluded from Section 6.3.2 by the +Office of the Secretary because they are undertaken at the request of JPMorgan +Chase in the normal course of a business in which the firm is routinely engaged. +(b) +(c) +(d) +(e) +any unpaid affiliation with a trade association, professional association, or other +such organization related to your position at JPMorgan Chase (however, if the +organization is involved in lobbying activities relating to the business of the firm +and you are either (i) an executive officer or board member of the organization, +or (ii) directly involved in the government relations activities of the organization, +you should discuss the affiliation with the Government Relations Department in +advance). +unpaid positions with co-op boards, condominium associations, and similar +entities the sole business of which is to hold title to and/or manage real property +in which you can or do reside. +unpaid positions with holding companies, trusts, or other non-operating entities +established solely for purposes of your or your family's estate or tax planning or +to hold your or your family's real estate or other investments that would not +otherwise require pre-clearance under this Section 6.3.2. +an unpaid position on the customer advisory board of a JPMorgan Chase +vendor/supplier that is approved in accordance with Section 3.4 and the policy on +Communication on Matters Relating to the Company's Business. +2. Not-for-profit activities +Unpaid not-for-profit activities generally do not require pre-clearance. However, employees are +required to pre-clear any board or official position with a not-for-profit entity if: +(a) +the not-for-profit entity is a customer of the firm, other than for routine branch +banking services. +(b) +you have been requested to serve in that capacity by a customer or supplier of +your business unit. +(c) +your service would otherwise present a conflict of interest or the appearance of a +conflict of interest. +As noted above, positions with trade associations, professional associations, or other such +organizations related to your position at JPMorgan Chase need not be pre-cleared. +15 + +JPM-SDNYLIT-00149134 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 22 of 33 +3. Governmental activities +You are required to pre-clear any government position, whether paid or unpaid, including as an +elected official and as a member, director, officer, or employee of a governmental agency, +authority, advisory board, or other board (a public school or library board, for example). You +must obtain pre-clearance before becoming a candidate for elective office. +Procedures and forms for pre-clearance of these activities are available in the JPMorgan Chase +Procedures and Forms for Pre-Clearance of Outside Activities. You must seck a new clearance for a +previously approved activity whenever there is any material change in relevant circumstances, whether +arising from a change in your job with JPMorgan Chase or in your role with respeet to that activity or +organization. You must also notify the Office of the Secretary when any approved outside activity +terminates. +Note also that publications and speaking engagements relating to the business of JPMorgan Chase must +be pre-cleared under Section 3.4 of the Code. +6.4. Political Activities +6.4.1. Political campaign activities and contributions by employees +Volunteering for a political campaign. If you wish to volunteer for a political campaign, you must do so +on your own time and as an individual, not as a representative of the firm or any of its affiliates. You may +not use any JPMorgan Chase staff, facilities, equipment, supplies, or mailing lists. +When acting as a fundraiser for a candidate or political event, be certain that your activities cannot be +viewed as connected with your position with JPMorgan Chase, especially when communicating with +colleagues, customers, or suppliers. Contact the Government Relations Department for further guidance +on such activity. +(Note that running for public office is covered by Section 6.3.2.) +Soliciting others. Employees may not contact other employees during work hours or on firm premises to +solicit political contributions or volunteer political activity (including "grassroots" activity such as +encouraging others to contact elected representatives regarding specific legislation). Employees may not +use firm resources (stationery, e-mail or phones, facilities, client or employees lists, etc.) to contact +anyone, including employees, customers and vendors, for these purposes at any time. These prohibitions +do not apply to solicitations by the JPMorgan Chase Political Action Committees (the PACs) or to +candidate events, fundraisers, and other activities organized by Government Relations and approved by +Legal & Compliance. Any other exceptions to these prohibitions require the prior approval of both +Government Relations and the Government Entities Compliance Group of the Legal and Compliance +Department. +Political contributions. You have the right to participate in the political process by making personal +contributions from personal funds, subject to applicable legal limits. However, you cannot be reimbursed +or otherwise compensated by JPMorgan Chase for any such contribution. +Certain business units (for example, Tax Exempt Capital Markets, Investment Management, and others +that sell products and services to government entities) may have additional policies regarding employees' +16 + +JPM-SDNYLIT-00149135 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 23 of 33 +personal contributions; you are responsible for being aware of, and complying with, any rules applicable +to your business unit. +Additionally, you must contact the Government Relations Department or your local Compliance officer +with respect to a personal political contribution that could violate, or create the appearance of a violation +of, the Foreign Corrupt Practices Act or local law. (See Section 5.9 for a discussion of the Foreign +Corrupt Practices Act and the firm's Anti-Corruption Policy.) Employees need to be especially sensitive +when giving to officials who are part of the decision-making process with respect to any matters relating +6.4.2. Political contributions and related activities by JPMorgan Chase +Political contributions and gifts. It is improper to offer or give anything to a public official, either directly +or through an intermediary, in an effort to secure an advantage that would not have been granted if the +offer or gift had not been made. In the U.S., political contributions by corporate entities are strictly +regulated by laws at the federal, state and local levels. These laws often prohibit or limit direct monetary +contributions made from corporate funds (such as a contribution check or purchase of fundraising event +tickets) as well as in-kind contributions (such as the use of corporate facilities or staff, and even the +granting of loans or other products at preferential rates). Local law in jurisdictions outside the U.S. can +also impose restrictions. Therefore, both within and outside the U.S., +(a) +all requests for firm support (either through monetary or in-kind contributions) of +political events, political candidates and their campaigns, political parties, or political +committees must be pre-approved and processed by the Government Relations +Department. +(b) +political contributions proposed to be made by or on behalf of the firm must be precleared by the Government Relations Department. +(c) +all gifts to governmental officials to be made by or on behalf of the firm (including items +of value, transportation, lodging, meals, entertainment, and services, and including +invitations to non-profit or other special events for which the firm has paid) must comply +with rules applicable to the relevant jurisdiction and with JPMorgan Chase's policies. +Note that many jurisdictions prohibit or restriet such gifts. For information on gifts to +officials in the United States, see Government Entities Compliance (GEC); for +information on gifts to officials outside the U.S., see the Anti-Corruption Policy (which +covers the Foreign Corrupt Practices Act). Contact the local Compliance unit in the +relevant jurisdiction(s) for further guidance. +Lobbying by or on behalf of JPMorgan Chase. All lobbying activities, including the retention of outside +lobbyists, must be pre-cleared through the Government Relations Department. Note that the federal +government and each state has its own definitions and regulations regarding lobbying of governmental +employees, and what might seem like a simple meeting could trigger a reporting requirement; if in doubt, +contact Government Relations. +6.5. Accepting gifts, meals, and entertainment from customers, suppliers, and others doing +business or seeking to do business with JPMorgan Chase +A gift may take many forms. For the purposes of the Code, the term "gift" includes anything of value for +which you are not required to pay the retail or usual and customary cost. A gift may include meals or +refreshments, goods, services, tickets to entertainment or sporting events, or the use of a residence, +vacation home, or other accommodations. +17 + +JPM-SDNYLIT-00149136 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 24 of 33 +Note that, where one of the firm's business units or groups has a business/"client" relationship with +another (c.g., trade executions by an IB desk for clients of another IB desk or an AM sales group) or +where one unit or group serves a control function for another (e.g., Legal & Compliance, Audit, Risk +Management, Operations), gifts between the two units/groups, or between individuals in the two +units/groups, are covered by the gift policies of this Section 6.5 (in addition to any other policies that may +be applicable to such units/groups). +Gifts given by others to members of your family, to those with whom you have a close personal +relationship, and to charities designated by you, are considered to be gifts to you for purposes of the +Code. +You may never, except as provided in the Code: +(a) solicit, for yourself or for anyone else (other than the firm), or accept anything of value +from anyone doing business with the firm. +(b) solicit, for yourself or for anyone else (other than the firm), or accept anything of value +from anyone in return for any business, service, or confidential information of the firm. +(c) +solicit, for yourself or for anyone else, or accept anything of value, directly or indirectly +(other than bona fide salary, wages, awards, and fees paid by or to the firm), from anyone +in connection with the business of the firm, either before or after a transaction is +discussed or consummated. +Note that the restrictions in this section 6.5 are not intended to apply to gifts based on obvious family +relationships (such as your parents, children, or spouse) or close personal friendships developed outside +the context of a JPMorgan Chase customer or vendor relationship, where the circumstances make it clear +that it is the relationship rather than the firm's business that is the motivating factor. +You are responsible for being familiar with any additional restrictions that may be applicable to your +business unit. +6.5.1. What you may accept +Acceptance of gifts of any kind (including entertainment and hospitality) from any customer, supplier, or +other party doing or seeking to do business with JPMorgan Chase (including identified prospective +customers) is generally prohibited. However, subject to the prohibitions in Section 6.5.2 and to any +more restrictive policies vour business unit may have. the following gifts may be accepted on +infrequent occasions from such a person if it is clear that the person is not trying to influence or +reward vou inappropriately in connection with any business decision or transaction and the gift is +unsolicited: +(a) +(b) +(c) +(d) +gifts having a retail value not exceeding U.S. $100 (or such lesser amount as is +established by your local Compliance unit) that are given on an occasion when gifts are +customary (on a birthday or major holiday, or on the occasion of a promotion or +retirement, for example; note that gifts given in appreciation for good service, or as +thanks for our business, are not permitted). +advertising or promotional material having a retail value not exceeding U.S. $100 (or +such lesser amount as is established by your local Compliance unit), such as pens, +pencils, note pads, key chains, calendars, and similar items. +discounts and rebates on merchandise or services that are offered to the general public, or +to all employees under a plan negotiated by JPMorgan Chase. +customary mementos at closing dinners, permitted golf outings, and similar functions. +18 + +JPM-SDNYLIT-00149137 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 25 of 33 +(e) +civic, charitable, educational, or religious organization awards for recognition of service +and accomplishment having a retail value not exceeding U.S. $100 (or such lesser +amount as is established by your local Compliance unit). +meals, refreshments, and entertainment in the course of a meeting or other occasion, +provided: +(i) +the purpose is business-related, +(ii) your host is present, +(ill) +your attendance is related to your duties with JPMorgan Chase, +(iv) +the level of expense is reasonable and customary in the context of your business +and the relationship with the host, and +the frequency of such invitations from one host is not excessive. +If you have questions about whether a specific invitation may be accepted under this item +--- whether, for example, it is business-related, or reasonable and customary in the +context of your business with the host --- discuss it with your Code Specialist or your +Compliance officer. +(g) +gifts of food or beverage items that are not easily returned, if they are: +given on an occasion when gifts are customary (on a birthday or major holiday, +or on the occasion of a promotion or retirement, for example; note that gifts +given in appreciation for good service, or as thanks for our business, are not +permitted), +(ii) +not extravagant, and +(iii) +shared among members of your business unit. +If you have questions about whether a gift of food or beverage items is extravagant, +discuss it with your manager, your Code Specialist, or your Compliance officer. +Where this Section refers to "a retail value not exceeding U.S. $100," the relevant Compliance unit will +determine the approximate equivalent in local currency for use in jurisdictions outside the U.S. +Whenever you receive a gift, or an offer of a gift, that is not specifically permitted by this Section 6.5.1, +make every effort to refuse or return it. If that isn't possible, notify your Compliance officer or your +Code Specialist to discuss how to deal with the gift. +6.5.2. What you may not accept +Except as approved pursuant to Section 6.5.3, you may not accept the following from any current or +identified prospective customer, supplier, or other party doing business with JPMorgan Chase: +(a) +gifts of cash or cash equivalents (such as gift certificates, gift checks, or securities), in +(b) +(c) +(d) +(e) +(f) +any amount. +discounts not available to the general public or to all employees under a plan negotiated +by JPMorgan Chase. +gifts to be delivered in installments. +bequests or legacies. +invitations to parties, sports outings, and similar events solely for groups of more than ten +JPMorgan Chase employees sponsored by parties that do business with JPMorgan Chase, +including golf or other sports or similar outings, year-end parties, group dinners, or +departmental entertainment, unless they have been approved in writing by a member of +the Executive Committee or an officer who reports directly to an Executive Committee +member, with a copy to your Code Specialist. +travel or accommodation expenses, unless they have been approved in writing by a +member of the Executive Committee or an officer who reports directly to an Executive +19 + +JPM-SDNYLIT-00149138 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 26 of 33 +(g) +Committee member, with a copy to your Code Specialist (travel and accommodations are +not considered gifts and may be accepted if they are agreed as part of a business +transaction between the party providing the travel or accommodations and JPMorgan +Chase). +tickets for sports competitions, concerts, or other events for your personal use, other than +as permitted under Section 6.5.1, whether you pay for them or not. +6.5.3. Approval of nonconforming gifts +An Executive Committee member, your Code Specialist, and the Office of the Secretary together may +approve, on a case-by-case basis, the acceptance of a gift that is not specifically permitted under Section +6.5.1, or that is prohibited under Section 6.5.2. Any such approval must be in writing and pursuant to full +written disclosure of all relevant facts, including the name of the donor, the circumstances surrounding +the offer and acceptance, the nature and approximate value of the gift, and the reason why it cannot or +should not be returned. (Use the Nonconforming Gift Approval Request and Report Form filed under +Section 6.5.4, signed by each of the Executive Committee member, your Code Specialist, and the Office +of the Secretary, for this purpose.) +6.5.4. Required reporting of gifts +You are required to file a Nonconforming Gift Approval Request and Report Form with respect to: +any gift that is not permitted under Section 6.5.1 or that is listed in Section 6.5.2, if the +gift has not been refused or returned (even if acceptance has been approved in accordance +ith Section 6.3.3). (Note that you must refuse or return any such gift unless it has bec +ecifically approved in writing as specified in Section 6.5.3: the Nonconforming Gi +Approval and Report Form should be used to evidence that approval.) +(b) +the offer or receipt of any gift that is so lavish it could give rise to an inference of +impropriety, whether or not you refuse or return it. +(c) +the offer or receipt of frequent gifts from one source, whether or not you refuse or return +them. +The Nonconforming Gift Approval and Report form, indicating the disposition of the gift, must be signed +by an Executive Committee member, your Code Specialist, and the Office of the Secretary. The Office of +the Secretary will maintain a record of all reported gifts. +6.6. Providing gifts, meals or entertainment +Local laws or industry-specific regulations often limit or prohibit the giving of gifts by JPMorgan Chase +to an employee of a current or prospective customer or supplier or any other person or entity doing +business or seeking to do business with the firm. For example, broker-dealers and asset managers are +generally subject to regulatory restrictions on providing gifts. +Some lines of business have very restrictive gift-giving policies, and others have prohibited gifts entirely. +You are responsible for knowing and complying with the policies that apply to you. +The giving of gifts to governmental officials is in many cases strictly limited by law or regulation. See +Section 6.4.2 for additional guidance. +Business-related gifts not prohibited by law or firm policies should be reasonable and customary in the +context of the relationship with the recipient of the gift, appropriate for the occasion, and in conformity +20 + +JPM-SDNYLIT-00149139 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 27 of 33 +with the Code, JPMorgan Chase's Travel & Entertainment Policies & Procedures, and all other applicable +policies. +6.7. Solicitations at work; charitable contributions by the firm +While the firm encourages its employees to become involved with charitable organizations, there are +restrictions on solicitation of customers, suppliers, and fellow employees for contributions. You should +become familiar with the relevant policies before engaging in any such activities. +In general the firm's charitable contributions are made through the JPMorgan Chase Foundation. +Occasionally customers or suppliers ask that JPMorgan Chase make a contribution to a charity or not-forprofit organization. If it is necessary for business development purposes to make a contribution, please +refer to the approval guidelines specific to your line of business. You can contact Global Philanthropy if +you need assistance in determining the appropriate level of support, including consideration of whether +the firm has already made a contribution to the organization. +7. PERSONAL SECURITIES AND OTHER FINANCIAL TRANSACTIONS +Your personal investment activities should always be conducted with the Company's reputation in mind +and in compliance with all applicable laws and regulations. +7.1. General investment principles +Employees are expected to devote their workdays to serving the interests of our elients and JPMorgan +Chase. Accordingly your personal securities and other financial transactions must be oriented towards a +philosophy of investment as distinguished from short-term or speculative trading. +In addition to complying with all other Code provisions and relevant policies and procedures, you should +observe the following general investment principles in carrying out personal transactions in securities and +other financial instruments. (All references to securities should be understood to include all financial +instruments, such as equity securities, bonds and other debt securities, convertible securities, derivatives, +options, and any l +index.) +(a) +While in possession of inside information about the issuer of any securities or the +securities themselves, never buy, sell, or recommend the purchase or sale of such +securities for your account or the accounts of others, regardless of whether the inside +information is gained through the scope of your employment or elsewhere. If in doubt, +don't trade. +(b) +Do not buy or sell securities with knowledge of proposed client trades, trades by +JPMorgan Chase or forthcoming research reports. +(c) +(d) +Your trading and investment activities must be within your financial means. +Do not ask for or accept any preferential terms or conditions in connection with any +personal trading or investments, unless the terms are available to all persons having +comparable portfolios and creditworthiness, or to all employees under a plan negotiated +by JPMorgan Chase. +(e) +Limit the risks in your personal account trading. Do not engage in excessive trading +activities that represent a high degree of financial risk. +(f) Trading and investment activities should be for investment purposes and not for shortterm trading profits. +(g) Do not engage in speculative trading, such as trading based on rumors. +21 + +JPM-SDNYLIT-00149140 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 28 of 33 +(h) +In general, employees should not invest in a competitor (other than investments in +securities of publicly traded companies). Competitors include unrelated financial services +companies of any kind, and others engaged in any business the firm is involved in, such +as banks, asset managers, depository institutions, credit unions, lenders, investment +banks, insurers, insurance agencies, and securities brokers, dealers, and underwriters. +7.2. Persons and accounts subject to policies +All personal investment policies that apply to you also apply to transactions in any account, whether +domestic or foreign, +(a) that is established or maintained by you or by your spouse, domestic partner, minor children, +or any other person to whom you provide significant financial support, +(b) over which you, or any of the other persons referred to in (a), have the power, directly or +indirectly, to make investment decisions, regardless of beneficial interest, or +(c) that is established or maintained by you or with your consent or knowledge and in which you +have a direct or indirect financial interest. +These are referred to as "employee-associated accounts." +7.3. +Trading in JPMorgan Chase securities +1.3.1. Policies applicable to all employees +Purchases and sales of JPMorgan Chase & Co.'s common +or other securities are subject to the +general investment principles set forth above. These principles are applicable to the following +transactions (as they are to your other investment activities): +(a) +direct purchases and sales of JPMorgan Chase securities. +(b) +elections involving the JP| +Chase & Co. common +fund in any retirement +investment account (such as a 401(k) plan in the US), deferred compensation plan, or +Employee +Purchase Plan, including decisions to increase or decrease contributions +or elections that result in increasing or decreasing amounts credited to any common +account under an employee benefit plan. +(c) +sales of JPMorgan Chase securities to meet a margin call, with or without your personal +involvement. +(d) +(e) +placing, canceling, or amending limit orders with respect to JPMorgan Chase securities. +ntering into, canceling, or amending sales plans sometimes referred to as 10b-5(1) plan: +in the United States, with respect to JPMorgan Chase securities +However, these principles do not affect automatic purchases of JPMorgan Chase +previously made benefits elections and acquisitions of JPMorgan Chase +in accordance with +through dividend +reinvestment. +Purchases and sales of JPMorgan Chase & Co.'s common +more restrictive personal trading policies applicable to your business unit. +or other securities are also subject to any +In addition, the following restrictions apply to transactions in JPMorgan Chase securities: +You may not engage in short selling of JPMorgan Chase securities, except for short sales +against a long position already held by you (sometimes referred to as a short sale against +(ii) +You may not engage in derivative transactions related to JPMorgan Chase securities +except as part of JPMorgan Chase's compensation and benefits programs, or when used +for bona fide hedging purposes against a long position already held by you, or as +otherwise approved by the Office of the Secretary. +22 + +JPM-SDNYLIT-00149141 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 29 of 33 +(iii) +(iv) +(V) +No transactions in JPMorgan Chase securities, including derivative transactions, may be +made in fully managed accounts (accounts over which you have no trading discretion), +except dispositions of shares permissibly transferred to the account. Any transfer of +securities into a managed account is subject to any restrictions applicable to a sale of such +securities. +Subject to any other JPMorgan Chase policies on personal securities trading applicable to +you, you may enter, cancel, or amend limit orders for the purchase or sale of JPMorgan +Chase securities. +Your transactions in JPMorgan Chase securities may be halted at any time the Company +finds it necessary or advisable to halt trading by all employees or certain groups of +employees. +7.3.2. Employees subject to the "window" and "Senior-level employees" +Certain employees are restricted from engaging in transactions in JPMorgan Chase securities except +during quarterly window periods and are subject to certain other restrictions and requirements with +spect to transactions in JPMorgan Chase securities. This policy affects only those persons who a +pecifically notified by their management or by the Office of the Secretary that they are subject to i +Senior-level employees (whether subject to the window restrictions or not) must discuss planned +transactions in JPMorgan Chase securities with a manager in advance. This requirement applies only to +those persons who are listed as "Senior-level employees" by Human Resources, whether by title such as +SVP/MD, or otherwise. +These requirements exist to ensure compliance with, among other things, our insider trading policies, and +are not intended to discourage appropriate investment diversification. +7.4. Trading in securities of clients and suppliers +As a general rule, you should not invest in any securities of a client with which you have or recently had +significant dealings or responsibility on behalf of JPMorgan Chase if such investment could be perceived +as based on confidential information. You may be subject to broader restrictions imposed by your +business unit. +If you have information about or are directly involved in negotiating a contract material to a supplier of +JPMorgan Chase you may not invest in the securities of such supplier. +If you own the securities of a company with which we are dealing and you are asked to represent +JPMorgan Chase in such dealings you must: +(a) disclose your securities ownership to your department head and your Compliance unit; +and +(b) obtain prior approval from your Compliance unit before selling such securities. +7.5. Additional policies for certain groups of employees +Any area of JPMorgan Chase may impose more restrictive policies on its employees, and you should +consult your Compliance officer or your Code Specialist on whether any such policies apply to you. +Employees of the following areas are subject to the Global Personal Trading Policy and Procedure as well +as any applicable supplemental policies: +23 + +JPM-SDNYLIT-00149142 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 30 of 33 +Asset Management +Commercial Banking +Private Equity +Audit +Legal and Compliance +Executive Management and the Executive Committee +Risk Management +Global Technology Infrastructure, IT Risk Management, and Resiliency Risk +Management groups of Central Technology +Corporate Resources and Media Relations Groups of Marketing & Communications +• +any other group or individual specifically notified as being subject to the policy and/or a +supplemental policy +These policies establish trading limitations and include requirements for pre-clearance of personal +securities transactions and, in some jurisdictions (including the U.S.), the use of designated brokers. + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 31 of 33 +Definitions and Examples +Assets of the Firm: Examples of assets of the firm are: +• furnishings, equipment, supplies and services, such as telephone, the firm's intranet, internet, +and Bloomberg access +• JPMorgan Chase inventions +• any property created, obtained, or compiled by or on behalf of JPMorgan Chase, including +customer lists, directories, files, reference materials and reports, computer software, data +processing systems, computer programs and databases +• trade secrets +• security and other business practices or processes, policies, procedures, and know-how +• cost, pricing, or financial information +• employee compensation, health, or personnel records +• business or marketing plans +• research +• business relationships +• products and services +• any other information that the firm considers to be proprictary or confidential information +Information Barrier: The term "information barrier" usually refers to the policies that create a system of +information barriers designed to limit the flow of inside information from areas that routinely have access +to such information to those areas that trade in or sell securities or provide investment advice regarding +securities. Certain business areas within JPMorgan Chase require procedures that address more +specifically the information flows within such business areas. These are sometimes also referred to as +information barriers. +Code Specialist: Each line of business and support group has been assigned at least one "Code +Specialist," generally a Compliance officer, to act as a resource for all employees in the area on Coderelated issues. Contact information for these officers is included in the Code Contacts List, and employees +can contact their Code Specialist for assistance with any questions regarding the Code. +Confidential information: Examples of confidential information: +• trade secrets, security and other business practices or processes, policies, procedures, or +know-how +• internal and external audit reports +• nonpublic portions of bank examination reports and other reports or information filed with +regulators +• software, data processing programs, databases +• customer or supplier lists, telephone or other contact lists, and other information about +customers +• customer presentations +• information about employees of customers or suppliers +• cost, pricing, or financial information +• employee directories, lists, telephone numbers, or other information about employees +• employee compensation, health, or personnel records +• business or marketing plans and research +• information posted on the firm's internal websites + +JPM-SDNYLIT-00149144 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 32 of 33 +Examples of other confidential information about customers: +• the same kind of information that the firm considers confidential about itself +• information obtained from requests or applications for our products or services or as a result +of "know your customer" due diligence, such as a personal identification number (for +example, depending on the location, a passport, social security, or national health number), +birth date or financial information disclosed in a loan application +• information about transactions with the firm, such as account balances, mortgage loans, or +other lending, capital markets, or trading transactions +• information obtained from consumer reporting agencies (credit bureaus), such as a person's +credit history +• information provided in connection with an advisory assignment, such as financial +projections +• any assessment by the firm of a customer's creditworthiness +• the fact that a person is a customer +• information collected through an information collection device from a web server (such as a +cookie or a beacon) +Supplier or other third party information that you should assume to be confidential: +the same kind of information that the firm considers confidential about itself +• information received from others such as financial reports or projections and information +about its business plans, customers, suppliers, or creditors +Firm: JPMorgan Chase & Co. and its direct and indirect subsidiaries. +Gift: Anything of value for which you are not required to pay the retail or usual and customary cost. A +gift may include meals or refreshments, goods, services, tickets to entertainment or sporting events, or the +use of a residence, vacation home, or other accommodations. +Inside information: Confidential information that is material, nonpublic information about the securities, +activities, or financial condition of a corporation, public entity, or other issuer of securities or financial +instruments. Material, nonpublic information concerning market developments may also be construed to +be inside information. +JPMorgan Chase: JPMorgan Chase & Co. and its direct and indirect subsidiaries. +Material information: Information is "material" when it could have an impact on the market price of +securities involved or if it is likely that a reasonable investor would consider the information important in +deciding whether to purchase or sell the securities. Information may be material to one issuer but not to +another. Information may be material to certain securities of an issuer but not material to all securities of +that issuer (e.g., to equity, but not to debt). Examples of information that could be material include: +mergers, acquisitions, tender offers and restructurings +• substantial nonperforming loans or impending bankruptcy +securities offerings and repurchases +a change in earnings and dividends (or estimates of same) +significant new business products, discoveries, and services, or the loss of any of these +a change in an issuer's credit rating by a rating agency +• significant shifts in operating or financial circumstances, such as cash-flow reductions, major +write-offs, changes in accounting methods and strikes at major plants +• voluntary calls of debt or preferred +issues + +JPM-SDNYLIT-00149145 + + +Case 1:22-cv-10904-JSR Document 326-52 Filed 09/08/23 Page 33 of 33 +• significant litigation or litigation developments +• governmental developments that could affect securities markets +• changes in control or management +• developments regarding customers or suppliers (e.g. loss or acquisition of a contract) +Need-to-know: Persons with a "need-to-know" information require access to that information in order to +perform the services we are engaged to provide to the party who provided the information to us --. for +example, lawyers, accountants and other experts, Compliance officers, credit personnel, and senior +management personnel. Who "needs to know" any particular information will depend on the specific +facts and circumstances; if in doubt, consult the Legal and Compliance Department. Justification of +communicating confidential information does not exist simply because the information is helpful to +another department in activities that are unrelated to the service or transaction for which the information +was obtained. In some circumstances, legal counsel may determine that limited disclosure is required by +law (in response to a subpoena, for example) or is otherwise appropriate. These decisions should be made +only by the Legal and Compliance Department. +Nonpublic/Public information: Information should be considered nonpublic unless it is clearly public. +Information is deemed public once it has been publicly announced or otherwise disseminated in a manner +that makes the information available to investors generally. For example, limited disclosure over a +private wire service for institutional investors is not considered full disclosure to the public. Information +disclosed in a press release distributed through a widely circulated news or wire service would generally +be considered public. +Personal fiduciary: A person who has undertaken to act primarily for another's benefit, such as a trustee, +executor, attorney-in-fact, or guardian, outside the scope of your normal job responsibilities at JPMorgan +Chase. +Routine branch banking services: In general, branch banking services (checking or savings accounts, +etc.) would be considered routine banking services. Whether any other service is "routine" will be a casespecific determination, based on factors such as the size of the transaction, the extent of the relationship +with the customer, and whether the service(s) provided are subject to variable pricing for different +customers. If in doubt about whether a customer relationship with a not-for-profit organization triggers +the pre-clearance requirements of Section 6.3.2(2)(a), discuss the situation with your Code Specialist. +Senior-Level Employee: A Senior-Level Employee is any employee whose (a) annual base salary rate is +US$150,000 (or the local currency equivalent) or higher, OR (b) annual total cash compensation is +US$250,000 (or the local currency equivalent) or higher. "Annual total cash compensation" means the +employee's annual base salary rate plus job/shift differentials as of the last preceding August 1, plus cash +earnings under any incentive plans or programs (c.g., annual bonus, commissions, draws, overrides, and +special recognition payments or incentives) that are paid to or deferred by the employee during the 12- +month period ending the last preceding July 31. It does not include overtime pay. (For US employees, +annual total cash compensation is the same as benefits pay for medical purposes, as shown in the +employee's last annual benefits enrollment materials.) +Trade association, professional association, or other such organization: A not-for-profit organization +the main purpose of which is to make available to its members opportunities for education, exchange of +ideas and information, networking, etc., such as a bar association or industry professionals' group. The +term does not apply to entities that engage in business activities, exchanges, trading platforms, or clearing +systems, for example. + +JPM-SDNYLIT-00149146 \ No newline at end of file diff --git a/vision-fixhub/court-05/5ba5ac4f1d7c9d666986da1c290e79a97875b9eb2ad05bbce2b63fa7db06c786.receipt.json b/vision-fixhub/court-05/5ba5ac4f1d7c9d666986da1c290e79a97875b9eb2ad05bbce2b63fa7db06c786.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f891050803188c806367e9b8ac633989cf525b91 --- /dev/null +++ b/vision-fixhub/court-05/5ba5ac4f1d7c9d666986da1c290e79a97875b9eb2ad05bbce2b63fa7db06c786.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -793, + "dataset": "marble-joined", + "doc_id": "5ba5ac4f1d7c9d666986da1c290e79a97875b9eb2ad05bbce2b63fa7db06c786", + "engine": "marble-apple-vision", + "event_count": 70, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "40c9d5f2ad4790e6c23528fde85c18deb85f59a0388248079a3c6db93d56a629", + "output_sha256": "7e39589637aadc355ab3edb1ba05bb2699ef383e2a9eaa80acdd896013e003ce", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5be09663c0fc5979fe151212c71010d34f6ffc12219458b0bbb55d1c2bc45545.md b/vision-fixhub/court-05/5be09663c0fc5979fe151212c71010d34f6ffc12219458b0bbb55d1c2bc45545.md new file mode 100644 index 0000000000000000000000000000000000000000..31b41b764ea0d1a95d06c89cd7433771d091a22f --- /dev/null +++ b/vision-fixhub/court-05/5be09663c0fc5979fe151212c71010d34f6ffc12219458b0bbb55d1c2bc45545.md @@ -0,0 +1,54 @@ +Case 1:19-cr-00830-AT Document 49 +Filed 03/10/2#sD83940f1 +DOCUMENT +ELECTRONICALLY FILED +DOC #: +DATE FILED: 3/10/2021 +The Law Offices of +MONTELL FI +17 Academy Street, Suite 305 +Newark, New Jersey 07102 +Phone: (973) 242-4700 +Fax: (973) 242-4701 +www.figginslaw.com BRANCH +OFFICES: +140 East Ridgewood Avenue +Paramus, NJ 07640 +Reply to Newark Office [X] +30 Wall Street 8® Floor +New York, NY 1005 +Of Counsel +Douglas Mitchell, Esq. +Linda Childs, Esq. +March 10, 2021 +SENT VIA ECE +Honorable Analisa Torres +U.S. Southern District of NY +500 Pearl Street +New York, NY 10007 +Re: USA v Michael +1, et al. +Docket No.: 1:19-cr-00830 +Request for Emergency Out of State Travel +Your Honor, +This firm represents Defendant, Michael +seeking the courts permission for Michael +, in the above-captioned matter. We are +to take an emergency trip to the State of +Georgia to tend to his sick father. +Kristen McKeown, his pre-trial services officer, does not oppose his emergency travel. +Respectfully yours +/s/ Montell Figgins +Montell Figgins, Esq. +Attorney for Defendant Michael +CC: +Nicolas Roos, Esq., Counsel for Plaintiff +Rebekah Donaleski, Esq., Counsel for Plaintiff +Jessica Lonergan, Esq., Counsel for Plaintiff +Jason Erroy Foy, Esq. Counsel for Defendant Noel +GRANTED. +SO ORDERED. +Dated: March 10, 2021 +New York, New York +ANALISA +United States District Judge diff --git a/vision-fixhub/court-05/5be09663c0fc5979fe151212c71010d34f6ffc12219458b0bbb55d1c2bc45545.receipt.json b/vision-fixhub/court-05/5be09663c0fc5979fe151212c71010d34f6ffc12219458b0bbb55d1c2bc45545.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..347d3868b015d980971c9a502c24b7e4e35fae37 --- /dev/null +++ b/vision-fixhub/court-05/5be09663c0fc5979fe151212c71010d34f6ffc12219458b0bbb55d1c2bc45545.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "5be09663c0fc5979fe151212c71010d34f6ffc12219458b0bbb55d1c2bc45545", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e700ae36711b0d8ccc27d426e8844f8bbbaa616d7240e9748b6882a621406729", + "output_sha256": "38569db4978f82d8c321567e5efd98fc3fa85d67f5d84ae0be96d9fe85a57f9b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5befed9035437b8093bc71b9ab89ac5a43c33d775517e8448f31cdff8644ba06.md b/vision-fixhub/court-05/5befed9035437b8093bc71b9ab89ac5a43c33d775517e8448f31cdff8644ba06.md new file mode 100644 index 0000000000000000000000000000000000000000..61771912ade0f488510ffc92ad7b37938e588954 --- /dev/null +++ b/vision-fixhub/court-05/5befed9035437b8093bc71b9ab89ac5a43c33d775517e8448f31cdff8644ba06.md @@ -0,0 +1,29 @@ +Case 1:22-cV-10904-JSR Document 263-22 Filed 08/07/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 263-22 Filed 08/07/23 Page 2 of 2 +From: +Sent: +To: +Subject: +Duffy, John R [john.r.duffy@jpmorgan.com] +9/20/2013 9:20:48 PM +Erdoes, Mary E [mary.erdoes@jpmorgan.com] +Spoke with him. +Good conversation. +Told JE no on sole trustee or POA, yes for advisory role without +discretion. +Yes for custody in the client's name. +hard to get through its Take co-banding with ase should sin discuss meet teas talk He be +hard to get through - its +Let's talk. He +John R. Duffy +J.P. +CEO, U.S. Private Bank +270 Park Avenue +New York, NY 10017 +Tel: 212-464-1468 +Email: john.r.duffy@jpmorgan.com +J.P. L +Securities LLC diff --git a/vision-fixhub/court-05/5befed9035437b8093bc71b9ab89ac5a43c33d775517e8448f31cdff8644ba06.receipt.json b/vision-fixhub/court-05/5befed9035437b8093bc71b9ab89ac5a43c33d775517e8448f31cdff8644ba06.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0b230e5ebee8a6d5ddbe374dbaa60cb53a063791 --- /dev/null +++ b/vision-fixhub/court-05/5befed9035437b8093bc71b9ab89ac5a43c33d775517e8448f31cdff8644ba06.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "5befed9035437b8093bc71b9ab89ac5a43c33d775517e8448f31cdff8644ba06", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "07c2644486882b54bce74bcb17e93718a19b42ed1acba0e927c4e41f137421b6", + "output_sha256": "9f1650d2b52ecac08afde7a6ea8c8e986ecbda9d4c368bff9410019aa8cee969", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5c001622818c5444f70e37b8cda4f749fe70bf5940f0cb0a1a373c460f4923b3.md b/vision-fixhub/court-05/5c001622818c5444f70e37b8cda4f749fe70bf5940f0cb0a1a373c460f4923b3.md new file mode 100644 index 0000000000000000000000000000000000000000..0534f91ec836a8e2666de74b93f5d0ecf46fed1e --- /dev/null +++ b/vision-fixhub/court-05/5c001622818c5444f70e37b8cda4f749fe70bf5940f0cb0a1a373c460f4923b3.md @@ -0,0 +1,96 @@ +Case 1:22-cv-10904-JSR Document 34 Filed 01/26/23 Page 1 of 3 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +MOTION FOR ISSUANCE OF LETTER OF REQUEST +FOR DOCUMENT PRODUCTION +NOW COMES, the Plaintiff, in the above referenced action, and moves for the Issuance of +a Letter of Request (Letter Rogatory) pursuant to F.R.C.P. 28 requesting an order requiring +Barclays Bank PLC, located at 1 Churchill Place, London E14 5HP, United Kingdom, to produce +discovery documents requested by Plaintiff, which are set forth in the Letter of Request for +Document Production and Schedule A attached hereto, in digital and/or hard copy form. +As grounds for this Motion, the Plaintiff states the following: +The above captioned case is currently pending in the United States District Court for the +Southern District of New York. The Government of the United States Virgin Islands +("Government") brought this civil action against JPMorgan Chase Bank, N.A. ("JPMorgan") as +part of its ongoing effort to protect public safety and to hold accountable those who facilitated or +participated in, directly or indirectly, the trafficking enterprise Jeffrey Epstein ("Epstein") helmed. +The Government's investigation revealed that JPMorgan knowingly, negligently, and unlawfully +provided and pulled the levers through which recruiters and victims were paid and was +1 + + +Case 1:22-cv-10904-JSR Document 34 Filed 01/26/23 Page 2 of 3 +indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial +institutions can connect—or choke—human trafficking networks, and enforcement actions filed +and injunctive relief obtained by attorneys general are essential to ensure that enterprises like +Epstein's cannot flourish in the future. +Former JPMorgan senior executive Jes Staley ("Staley") developed a close relationship +with Epstein when Staley was the head of JPMorgan's Private Bank. Between 2008 and 2012, +Staley exchanged approximately 1,200 emails with Epstein from his JPMorgan email account. +These communications show a close personal relationship between the two men, and that Staley +nonetheless played a role in JPMorgan's compliance decisions with respect to Epstein. They also +reveal that Staley corresponded with Epstein while Epstein was incarcerated and visited Epstein's +Virgin Islands residence on multiple occasions. Staley left JPMorgan in 2013 and became the Chief +Executive Officer of Barclays Bank PLC in 2015 until he resigned in November 2021 after the +Financial Conduct Authority began a preliminary investigation into Staley's relationship with +Epstein. It has been publicly reported that Barclays Bank PLC produced documents to the +Financial Conduct Authority as part of its investigation into Staley's relationship with Epstein. +These documents are equally applicable to the Government's case. This evidence will assist the +Court in resolving the disputed issues presented in the civil action before it. +WHEREFORE Plaintiff respectfully requests that this Honorable Court allow this Motion +and issue a Letter of Request for Document Production. A proposed Letter of Request for +Document Production is attached to this Motion as Exhibit 1. +Dated: January 26, 2023 +CAROL +1, ESQ. +ACTING ATTORNEY GENERAL +Is/Linda +LINDA +2 +(NYS Bar #2473403) + + +Case 1:22-cv-10904-JSR Document 34 Filed 01/26/23 Page 3 of 3 +Admitted Pro Hac Vice +Motley Rice LLC +401 gth Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Isinger@motleyrice.com +CAROL +(NYS Bar #2941300) +Admitted Pro Hac Vice +Acting Attorney General of the United States +Virgin Islands +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +St. +_. U.S. Virgin Islands 00802 +Tel.: (340) 774-5666 ext. 10101 +DAVID I. ACKERMAN (NYS Bar #4110839) +Motley Rice LLC +401 9* Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 849-4962 +dackerman@motleyrice.com +PAIGE BOGGS +Molley die Hac Vice +401 9t* Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 386-9629 +pboggs@motleyrice.com +CERTIFICATE OF SERVICE +I hereby certify that on January 26, 2023, the foregoing Plaintiff's Motion for Issuance of +Letter of Request for Document Production was filed with the Clerk's Office using the CM/ECF +system. Notice of this filing will be sent to all parties of record by operation of, and parties may +access this filing through, the Court's CM/ECF system. +Is/Linda +Linda +3 diff --git a/vision-fixhub/court-05/5c001622818c5444f70e37b8cda4f749fe70bf5940f0cb0a1a373c460f4923b3.receipt.json b/vision-fixhub/court-05/5c001622818c5444f70e37b8cda4f749fe70bf5940f0cb0a1a373c460f4923b3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d95084bdb99642fc80201740b75df5f2a3d61b8d --- /dev/null +++ b/vision-fixhub/court-05/5c001622818c5444f70e37b8cda4f749fe70bf5940f0cb0a1a373c460f4923b3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "5c001622818c5444f70e37b8cda4f749fe70bf5940f0cb0a1a373c460f4923b3", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ca595439de4cb690471ac41f8013941311adbc826a66180eded424b5b23f772e", + "output_sha256": "6b7404f3564b0cff283a72065b0b4d6b5ea86af926eb7ea5d42907e8b8be256c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5c1daa5039a852085dc4174386e906e2b2cfed27a2baf433c462b3bd6d83f6b7.md b/vision-fixhub/court-05/5c1daa5039a852085dc4174386e906e2b2cfed27a2baf433c462b3bd6d83f6b7.md new file mode 100644 index 0000000000000000000000000000000000000000..3dd555c3e18fee3e04cae33eb9b85d6d4bc2a35d --- /dev/null +++ b/vision-fixhub/court-05/5c1daa5039a852085dc4174386e906e2b2cfed27a2baf433c462b3bd6d83f6b7.md @@ -0,0 +1,31 @@ +Case 1:22-cv-10904-JSR Document 11 Filed 01/06/23 Page 1 of 1 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +) +Case Number: 1:22-cv-10904 JSR +MOTION FOR ADMISSION +PRO HAC VICE +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and +Eastern Districts of New York, I, Elizabeth Paige Boggs, hereby move this Court for an Order for +admission to practice Pro Hac Vice to appear as counsel for Plaintiff, the Government of the United +States Virgin Islands, in the above-captioned action. +I am in good standing of the bars of the states of Illinois, Indiana, and the District of +Columbia and there are no pending disciplinary proceedings against me in any state or federal +court. I have never been convicted of a felony. I have never been censured, suspended, disbarred +or denied admission or readmission by any court. I have attached the affidavit pursuant to Local +Rule 1.3. +Dated: January 5, 2023 +Respectfully Submitted, +lisaleth raise boo +ELIZABETH PAIGE BOGG +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +(202) 386-9629 phone / (202) 386-9622 fax +pboggs@motleyrice.com diff --git a/vision-fixhub/court-05/5c1daa5039a852085dc4174386e906e2b2cfed27a2baf433c462b3bd6d83f6b7.receipt.json b/vision-fixhub/court-05/5c1daa5039a852085dc4174386e906e2b2cfed27a2baf433c462b3bd6d83f6b7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0568abe5c06d7a363d34f91e3131a07ea980dc07 --- /dev/null +++ b/vision-fixhub/court-05/5c1daa5039a852085dc4174386e906e2b2cfed27a2baf433c462b3bd6d83f6b7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "5c1daa5039a852085dc4174386e906e2b2cfed27a2baf433c462b3bd6d83f6b7", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", 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+1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 761 + +2296 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-x +UNITED STATES OF AMERICA, +V. +20 CR 330 (AJN) +GHISLAINE MAXWELL, +Defendant. +-x +Before: +HON. ALISON J. NATHAN, +Jury Trial +New York, N.Y. +December 16, 2021 +8:55 a.m. +District Judge +APPEARANCES +DAMIAN WILLIAMS +United States Attorney for the +Southern District of New York +BY: +Assistant United States Attorneys +HADDON MORGAN AND FOREMAN +Attorneys for Defendant +BY: JEFFREY S. PAGLIUCA +LAURA A. MENNINGER +-and- +BOBBI C. STERNHEIM +COHEN & GRESSER +BY: CHRISTIAN R. EVERDELL +Also Present: +FBI +NYPD +Paralegal, U.s. Attorney's Office +paraledber Haddon Morgan and Foremar + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | + +2297 +(Trial resumed; jury not present) +THE COURT: All right. We have a number of issues to +take up. I've gotten letter briefing on several issues over +the past few days, including some new issues that came in last +night. I did address the issue of defense witness anonymity by +order last night, which will be docketed this morning when +docketing puts it up, denying the defense request for anonymity +for the reasons indicated. +As to the remaining issues, so there's the prior +inconsistent statements issue. I received the letter with the +government objections close to 11 p.m. last night. I haven't +had the ability to yet go through all of them, and I haven't +heard any responses from the defense. +What's the timing of anticipated witnesses here? +MR. EVERDELL: Your Honor, for the witness order? +THE COURT: Well, when might we get to a witness who +implicates the prior inconsistent statements? And I gather +there's been some effort to work through stipulation and +narrowing. +MR. EVERDELL: Yes, your Honor. +There have been some efforts, and I think there's +going to be continued efforts there. I don't think we have a +witness until after lunch that is going to implicate the prior +inconsistent statements. +THE COURT: Okay. That may be what we're doing during + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 3 of 246 +2298 +lunch then. +MR. EVERDELL: Yes, your Honor. +THE COURT: I think this is an area ripe for narrowing +and stipulation when feasible. +Okay. Next is the attorney witness issue. I am +prepared to give guidance on that. +Okay. So I have the defense's letter to call +attorneys Jack Scarola, Brad +and Robert Glassman to +testify during the defense case-in-chief. And I've looked +quite carefully at these arguments and proffers. Obviously +I've had the one related to Mr. Glassman the longest. +The defense argues that the testimony of the attorneys +is relevant to show how and why the alleged victims cooperated +with the prosecution in this case, which it argues is relevant +to motive to testify and bias. I think the government concedes +that, with the exception of Mr. Glassman's requested testimony +as to whether he told Jane that cooperating would "help her +case, " other than that, I think the government agrees that the +proffered testimony is not -- at least as framed -- +attorney-client privilege. +I still have to exercise caution in considering the +ability of defense to call these witnesses, since they are +attorneys for witnesses who testified, and the boundary to +privileged communications can be easily crossed. I do think as +a general matter, to the extent the defense has established + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2299 +that any of these witnesses will testify to relevant +nonprivileged information that is not outweighed by prejudice, +it's possible to get such testimony. +After careful consideration, with one exception, the +information the defense seeks to elicit from the three +attorneys, I conclude, +is either not relevant under Rule 401, +is duplicative of information elicited on cross-examination +and, therefore, outweighed by prejudice, or is only potentially +marginally relevant to the limited inference of impeachment so +as to be outweighed by 403 prejudice. +The one question I intend to permit is the one I +suggested the parties stipulate to testimony from Mr. Glassman. +I will permit Mr. Glassman to be asked the following: Did you +tell the government that you told Jane that cooperating with +the government and testifying in this case would help her civil +case against Epstein's estate and Ms. Maxwell and/or her claim +to the victims' compensation fund? +The question does not elicit privileged information +directly because it seeks only to know what Mr. Glassman told +the government. Unlike the other proffers, this testimony is +relevant because Mr. Glassman's testimony, if the answer is +yes, could contradict Jane's testimony and allow an inference +to the jury that at least at one point she may have been under +the impression that testifying would help her civil case +against Ms. Maxwell and her claim to the fund. With this + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 761 Filed 08/10/22 + +2300 +inference, the jury could find that Mr. Glassman's testimony +tends to impeach Jane either as to motive to testify or +impeachment by contradiction or both. So that is my guidance +on the issue of the attorney -- the witness attorney testimony. +Any questions? +MR. +: None from the government, your Honor. +MR. PAGLIUCA: I just want to be clear, your Honor. +You're precluding testimony from Mr. Scarola and +Mr. +THE COURT: Yes. +MR. PAGLIUCA: The only reason I'm asking that +question is we can release them and not have them appear. +THE COURT: Yes, on the 401/403 grounds. +MR. PAGLIUCA: Understood. +And that may speed things up a little bit here, since +we're releasing a couple of witnesses. +THE COURT: Okay. Thank you. +All right. Making progress. +There's a government objection to preclude, pursuant +to Rule 16, an exhibit that I gather purports to be a sale +agreement for the defendant's home in -- house in London at 44 +Kinnerton Street dated 1996. Does that have a trial mark for +identification, that exhibit? +MR. EVERDELL: It does now, I believe, your Honor. +THE COURT: Okay. Just in time. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2301 +MR. EVERDELL: Yes. This is going to be MG -- one of +the MG exhibits, the agreement for sale. +We're just checking +which one it is, your Honor. It's marked as MG-2 now, your +Honor. +We're going to have to hand up, I think, to the Court +some of these things. I'm sorry, we have them in Trial +Director now, +so we'll be able to -- +THE COURT: You have them what? +MR. EVERDELL: We have these marked exhibits in Trial +Director; we'll be able to put them on the screen. +THE COURT: I don't have a -- do you have a paper +copy? +MR. EVERDELL: Of that particular exhibit? +THE COURT: Yes. +MR. EVERDELL: We can bring it for the Court. +THE COURT: Okay. Do you have a copy in front of you, +Mr. Everdell? +MR. EVERDELL: I don't, because that's a witness +that's coming later. But let me see if I can find one. +THE COURT: Okay. Well, maybe we can see what else we +can get to. +MR. +: Your Honor, I have a paper copy. +THE COURT: Okay. +MR. EVERDELL: Put it on the screen. +THE COURT: That's fine. +MR. EVERDELL: Put MG-2 on the screen, please, for the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2302 +Court, for the judge, and the deputy. +THE COURT: I'm sorry, give me again the trial mark. +MR. EVERDELL: MG-2, your Honor. +THE COURT: Okay. There it is. Okay. +Is this you, Mr. Everdell? +MR. EVERDELL: No, this is going to be Ms. Sternheim. +THE COURT: Okay. +MS. STERNHEIM: Judge, I do have a copy if you'd like +to see it. +THE COURT: Okay. Great. Thank you. +All right. And we're marking this MG-2. +I'm sorry, I meant the cover letter. +MR. EVERDELL: The cover letter that's dated 2010? +THE COURT: Yes. +MR. EVERDELL: Okay. +We removed that from the marked +exhibit; it's just the agreement of sale that's underneath +that. +THE COURT: +1, you're just seeking to move the -- +MR. EVERDELL: Your Honor, there are a number of +documents that we're going to try to introduce through -- it's +actually slightly more complicated now. So Mr. Grumbridge, who +is going to be -- +THE COURT: What has been simple? +MR. EVERDELL: Nothing's been simple. +Mr. Grumbridge is unable to come because of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +professional reasons. He would be available Tuesday. But +we're going to try to do this a different way. +We have a notary named Keith Rooney who we plan to +call today who has gone to the land registry and has obtained +certified copies of the land registry entries for this property +showing when the title transferred to Ms. Maxwell. And I have +copies of those documents, if you'd like to see those. +THE COURT: Not yet, but maybe. +MR. EVERDELL: Okay. He's also gone to the consulate, +I believe, and got it apostilled to make it a foreign public +document, certified as a foreign public record that could be +admitted, self-authenticating by itself. But we'd like to call +him to explain the process that he went through to get these +documents and admit them that way. +He is also going to -- we were going to seek to admit +Mr. Grumbridge's records through them as well, because he's +gone to Mr. Grumbridge's office in London, checked his files, +seen the copies of the agreement for sale and the other +documents we were going to admit through Mr. Grumbridge in his +files, has certified that they exist in his files, and can +authenticate those documents and introduce those as well. +THE COURT: All of this is in an effort to prove that +Ms. Maxwell did not live at this address before 1996? +MR. EVERDELL: That's correct. +THE COURT: So let's go back to the letter, if we +2303 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 9 of 246 +2304 +could, the cover letter. Do we know why it's dated 2010? +MR. EVERDELL: Your Honor, I think that's a separate +record. Because I think that record reflects that there was an +opportunity to purchase the leasehold outright in 2010. It's a +little bit of a complicated title. It's actually a leasehold. +She does own the lease; it's effectively owning it, b.ut this +land, I think, has been in the possession of the +of +Westminster since, you know, 1500. It's a very complicated +chain of title in the UK. +But the way it works is you pass the leasehold from +one person to another. And that is effectively ownership under +the land registry records. And that leasehold passed in -- the +contracts were exchanged in '96, and the deal closed in '97, in +January '97; and it was registered in a land registry as a +transfer of that title in March of '97. +THE COURT: And again, my question is not that it's to +prove when Ms. Maxwell purchased the home, but the defense's +proffer from counsel is that it is to prove that she did not +live there before 1996? +MR. EVERDELL: That's right. We have a witness, +who says -- she didn't live there before 1997, because that's +when she actually took possession of the property, right. +We have a witness, +who has testified to events +that allegedly took place in the Kinnerton Street property in +'94 and '95. And these records show that she didn't own that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 10 of 246 +2305 +place; that she wasn't living in that place -- +THE COURT: Well, they show she didn't own it, I +suppose. +MR. EVERDELL: Correct. +THE COURT: It sounds like there are different stages +in the purchase process. +MR. EVERDELL: Well, yes. +But the records also reflect in the land registry that +the ownership existed with this couple whose last time is +O'Neill. They owned it under the land registry records as of +1992. That title passes then to Ms. Maxwell in 1997. These +are both land registry entries which I have here, if the Court +would like to see them. +And what Mr. Grumbridge's records -- the agreement for +sale, for example, just shows the process of that contracting, +right. So in December of '96, the parties exchange contracts; +Mr. and Mrs. O'Neill and Ms. Maxwell entered into contract for +sale for this property. And that deal closed as of January +1997. That's reflected in the agreement for sale. And then +the notice is given to the land registry to make it an official +land record by March of '97. So there's a record on file in +the land registry recording that the title has passed from the +O'Neills to Ms. Maxwell as of March Of '97. +So there's a couple of documents that we think are +relevant that we think Mr. Rooney could enter into evidence. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 11 of 246 +2306 +The first is the actual land registry records, which +are here, which show -- and I can pass them up if the Court +would like, which show the first ownership, which belongs to +the O'Neills as of '92; and then title passing to Ms. Maxwell +as of '97. That's here. There's also a land registry record +which shows the actual transfer of title which describes all of +this as well. +And then there are the records that are found in +Mr. Grumbridge's files, because he was the attorney who +represented Ms. Maxwell in this transaction, which include that +agreement for sale, because that's a private document, but it +exists in his files, it's still there. And Mr. Rooney has seen +it in his files in London. And he's prepared to testify to +that because he's here today. And a few other documents that +were in his files that relate to this sale of the property and +the transfer of title at that time. +THE COURT: Okay. Mr. +MR. +: I think that the point Mr. Everdell +just made about how this is confusing and complicated +reinforces two of the government's arguments. +First of all, putting this confusing set of land +transfers and leaseholds that speaks to when the defendant took +ownership of the property would confuse the jury into having to +understand British real estate law and actually says nothing +about when she, in fact, occupied the property for the reasons + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 12 of 246 +2307 +the government explained in its letter, including the +deposition -- +THE COURT: So the government indicates that Ms. +Maxwell's 2019 deposition indicates that she lived in the home +beginning in '92 or '93? +MR. +Yes, your Honor. +THE COURT: Would the government seek to introduce +that testimony if I let in the legal documents? +MR. +: Yes, we would, your Honor. +THE COURT: Okay. So we're going to have a trial +on -- we're going to have a little mini trial on whether -- on +whether Ms. Maxwell lived -- not owned, but lived in that house +prior to 1997? +MR. EVERDELL: Your Honor, this is, I think, hardly a +mini trial. This is extremely probative -- +THE COURT: What about the testimony, deposition +testimony, in which she said she lived there beginning in '92 +or '93; it comes in, doesn't it? +MR. EVERDELL: We can argue that, I suppose, your +Honor. But even if it does come in, they can argue that that +shows that she's - +THE COURT: Well, that goes directly to when she lived +there. Your evidence goes to when she owned it. Right? +MR. EVERDELL: That's right. But -- +THE COURT: So when she -- I see the relevance for + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 13 of 246 2308 +impeachment as to when she lived there. What is the relevance +to when she owned it? +MR. EVERDELL: Your Honor, the records show that the +O'Neills owned that property until 1997, some family of the +O'Neills, not Ms. Maxwell. +THE COURT: They don't rent places in London? +MR. EVERDELL: That's something that the government, +I'm sure, could argue to the jury. But this is extremely +relevant. We're equally able to argue to the jury that this +shows that she owned it, and what +couldn't have happened because -- +is testifying to +THE COURT: Well, again, it shows ownership. I get +that. The relevant question is residence. The government has +testimony from Ms. Maxwell that she lived there beginning in +1992. What evidence do you have as to whether or not she lived +there prior to ownership? +MR. EVERDELL: Your Honor, if I may have a moment. +THE COURT: You may. +(Counsel conferred with defendant) +MR. EVERDELL: Your Honor, I think the solution to +this problem -- and this would not be a mini trial -- is for us +to be able to admit the records showing the ownership records. +And if the government wants to admit the testimony to be able +to argue the opposite point, then okay. But that's hardly a +mini trial. And then each side gets to argue their point. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE l + +2309 +THE COURT: I was sort of leaning that way when I +thought the attorney was going to come testify who could be +crossed on this precise question. But you want it to just come +in -- you want a fact not in issue, which is the ownership +question, you want an inference from ownership -- ownership is +confusing; but the inference from the timing of ownership as to +when she lived there, which is contradicted by deposition +testimony that would come in from Ms. Maxwell. +MR. EVERDELL: Your Honor, I think we have records +which we'd have to find and anticipate this being the issue. +But Ms. Maxwell had another place in London at a street called +Stanhope Mews, I think it was 69 Stanhope Mews. And we may be +able to find the title records that she sold it, because she +had that prior to the Kinnerton Street residence. And I think +if you have -- we'd have to look for those. I think we +probably can find them. But they would show that she had +another place until she bought this new place. +So I think that is a fair inference to say that if +somebody owned another place and didn't buy another place until +later, that they are not living at that new place if they owned +the other place. That's just common sense. +THE COURT: And why can't the attorney who you had +proffered as the witness for this testify? +MR. EVERDELL: Your Honor, if we need the attorney, we +can try to get him here, but we just couldn't get him here + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 15 of 246 +Thursday or Friday. So if you give me a moment on that, I can +check on the status of that. +THE COURT: Okay. +(Counsel conferred) +MR. EVERDELL: Your Honor, I'm told he has a court +appearance on Monday, and he's only going to be able to get on +a plane Monday night and would only be available to testify +Tuesday. +We can consider a stipulation to his testimony too, +but I think these are all relevant and we should be able to +admit these to the jury to argue the inference. +THE COURT: I think the point of cross is whether he +has knowledge of whether -- of who lived at the residence +prior. +2310 +Mr. +the complication of ownership aside, +what is the government's view as to the relevance of facts +regarding who lived in the home prior to 1997? +MR. +: So who lived in the home might have +marginal impeachment value, but the government's view is that +it's only marginal. The proffer we have from the defense now +is that, at most, the defendant lived in a home nearby before +she moved to the 44 Kinnerton Street home. So to the extent +that that's true -- and again, it's contradicted by the +defendant's under-oath deposition testimony -- it would have +only marginal impeachment value. It would mean that, if true, +it would mean that +| identified a nearby, but incorrect, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 16 of 246 +address for the first time she went to the defendant's house, +at most. That's minimal impeachment value. +THE COURT: I think what makes sense here to talk +about is a stipulation as to the timing of ownership of the +Kinnerton -- 44 Kinnerton, the timing of ownership. And then +that can come in with the government's deposition -- with the +deposition of Ms. Maxwell saying she lived there beginning in +'92 or '93. Then both sides can argue to the jury what they +want. +2311 +MR. +: Yes, your Honor. +The government would -- I'd like to confer with the +team, but I think the government would probably agree to a +stipulation that included both the ownership fact and the +deposition testimony, so they'll both come in. +MR. EVERDELL: We'll have to confer on this, Judge, +but I understand what the Court's position is. +THE COURT: Okay. It sounds like that gives you what +you want, which was the fact of ownership timing from which you +can argue to the jury that because she didn't own it until a +certain date, she couldn't have lived there before that date. +And you can then argue, therefore, +wasn't accurate or +testified falsely or however you want to phrase it, that she +was in that -- she believed Ms. Maxwell lived there prior to +'97. +MR. EVERDELL: Just to preview for the Court, I think + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 17 of 246 +2312 +we would also like to include, which is information that +Mr. Grumbridge would have about the Stanhope Mews ownership +prior to this, because he was the lawyer and solicitor involved +in that transaction as well, from my understanding. So I think +it's -- to make the same point. But if we're going to lose his +testimony, because I think it's relevant testimony, I would +like to get in all parts of his testimony that I think are +relevant to this issue of ownership. +MR. +: We're happy to confer with defense +counsel and try to work something out. I would just note that +defense counsel has not produced any records to the government +showing this prior ownership of Stanhope Mews. +THE COURT: All right. +MR. +: We'll confer with the defense and try +to work out a stipulation. +THE COURT: Great. Thank you. +Okay. All right. Moving on to the Dr. Loftus +testimony. So I got the letter dated December 15th in which +the government seeks to exclude two aspects of Dr. Loftus's +anticipated expert testimony on suggestive activities: Her +testimony on the use of leading questions by government +investigators, and her anticipated testimony on the therapist +technique of response pressure to provide more detail about a +patient's experience. +In an order dated November 21st, 2021, I ruled that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 18 of 246 +2313 +Dr. Loftus's opinions on suggestive activities are generally +admissible. +The government argues that the above two opinions, +however, lack a foundation in the record. I'm going to deny +the government's motion to preclude here, but with guidance. +First, as we've discussed and I've made clear, Dr. +Loftus is testifying, I understand, as a blind expert, meaning +that she'll provide relevant expert opinion, but not apply it +to the facts of the case. And just as Dr. Rocchio offered +testimony that included examples of grooming, variety of +grooming examples or factors that might make a child vulnerable +to sexual abuse, it seems comparable to me that Dr. Loftus can +offer examples of suggestive activity, including the two +examples the government seeks to exclude. So long as her +testimony does not state that those activities occurred in this +case or go into any specifics of the case, that would be beyond +the bounds of a blind expert. +Second, I think there is -- the defense has provided +an adequate foundation for expert opinion on suggestive +questioning by the government by cross-examining witnesses +about the questions they were asked. For example, the defense +on cross-examination of Jane asked about the government asking +her the same question three times +in the same interview, trial +transcript at 515. And Jane testified that the government, +quote, communicated to her through her attorney that The Lion +didn't come out until 1997, which the defense also + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 19 of 246 +believes to be an example of suggestion. This testimony +provides a sufficient basis for the jury to consider the +relevance of Dr. Loftus's opinions on suggestive questioning +techniques. So that's my basis for that ruling. +There was argument regarding Agent Young testimony +that -- I don't know the government's general views on Agent +Young's testimony and I don't need to reach a conclusion on +that for purposes of this ruling. So I don't have further +guidance on that now. +All right. Questions on that? +MR. +: Nothing from the government, your +2314 +Honor. +MS. STERNHEIM: Nothing at this time. +THE COURT: Okay. Thank you. +All right. Motion to preclude Alexander +•. STERNHEIM: We'd like to get Broadway tickets for +everyone. That's the best we can do. +THE COURT: It really is - yes. It was +in +Federal '78 that said, We just have judgment, not will nor +force, just judgment. So I guess this calls for judgment. +So I have the defense response with respect to this +witness that came in at 12:31 a.m. this morning. I haven't had +a chance to work through the issue yet. +What's the timing on this witness? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | +Document 761 Filed 08/10/22 Page 20 of 246 2315 +MS. STERNHEIM: The timing on this witness is that the +witness has COVID. So the witness will not be here unless the +Court permits his testimony to be versus via WebEx. And I have +cited another case in this district where I, in fact, was sent +to London when a government witness was too ill to come to the +district. +And certainly given what the courts have been +utilizing through COVID, there certainly is a legitimate basis +for that request. +He cannot travel. He is quarantined. Provided he is +not incapacitated -- and I understand he would be able to give +testimony from his home -- that would be the request, if the +government was not willing to work out a stipulation based upon +the declaration that had been disclosed orally and had been +provided in written form. +MR. +: Your Honor, assuming the Court lets in +the testimony at all, the government is not going to agree to a +stipulation. We think this witness needs to be subject to +cross-examination. It may be possible -- I know the Court has +done before a procedure by which a witness can testify by +WebEx, but the Court would have to make certain findings first. +As part of that, we think that the witness would have to +produce the positive COVID test to demonstrate to the Court -- +THE COURI: I thought the letter said that you've got +that. +MS. STERNHEIM: I do, but I didn't think it was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 21 of 246 +2316 +necessary to make it part of a public record. +THE COURT: All right. +Why don't you work out - Mr. +• you think a +finding other than Ms. Sternheim's -- you think a record beyond +Ms. Sternheim's proffer that she has a positive COVID test, +would the government -- you said the court has done this +before; you mean a colleague has done it. I haven't done it. +MR. +My understanding is that before the +COVID era, the Court may have done -- taken -- permitted a +witness to testify remotely or at least considered the issue +before. Maybe not permitted actually, your Honor. +My understanding is in general that the courts follow +the factors in Rule 15 for depositions in order to make this +determination; and so the Court would have to find that witness +is unavailable, that it's in the interest of justice before +permitting it. +THE COURT: Okay. And the government wants -- well, +it seems to me if there's a positive COVID test -- +MR. +We would not resist that the witness is +unavailable if there's a positive COVID test, your Honor. +THE COURT: Okay. +MR. +: To be clear, I don't think the +government is resisting on any of those factors. Under Rule 15 +we would -- and we could come back at a break and elaborate on +exactly what the stretches are. We just would ask the Court to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 22 of 246 +2317 +make the full record of the reasons for permitting the witness +to testify through WebEx. +THE COURT: Okay. +You don't disagree with that, do you? +MS. STERNHEIM: No. But I would just note that in the +case that I've cited, United States v. Al-Fawwaz, there was +less of a showing in that case as to the unavailability of the +witness who was available to come to the site where he was +deposed by myself and government counsel. +Here, we do have a definitive positive test for COVID, +and I think that speaks for itself. He certainly would not +even be able to get on a plane, let alone enter the United +States. +THE COURT: I think the unavailability on the +defense's proffer is established. So why don't you work out +the -- if a further record is required and logistics. I don't +think I let a witness testify remotely. I let a juror +deliberate remotely. +MR. +: I think the Court is right. I think +the Court considered and applied the Rule 15 factors, but did +not allow the witness to testify remotely is my recollection, +your Honor. +THE COURT: I'll look at it. But I anticipate this +witness will be permitted to testify by WebEx. So you'll work +out what we need to do to effectuate that. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 23 of 246 +2318 +MS. STERNHEIM: Thank you. +THE COURT: Okay. +What other open issues do we have +that we can deal with now, counsel? +MR. EVERDELL: Your Honor, I think there are some +issues with this first witness that I just want to raise with +the Court first. +THE COURT: That I have briefing on? +MR. EVERDELL: These are things that we've tried to +talk with the government about. I don't think it's going to be +a major dispute. +THE COURT: Okay. I just wanted to make sure I hadn't +missed it. +MR. EVERDELL: You did not miss anything. +THE COURT: Okay. Go ahead. +MR. EVERDELL: The first witness is +THE COURT: Right. +MR. EVERDELL: So the first issue, which I think the +government and the defense agree on, is that there's a line of +cross that we ask the government if they plan to get into, and +they have agreed that they won't. And that's related to the +following, which is that [ +was a defendant in a civil +lawsuit by one of the Epstein -- not one of the accusers in +this case, but a different person. And so I've asked the +government that they not get into that; they've agreed that +they won't cross +about that. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 24 of 246 +LCGVMAX1 +2319 +THE COURT: Okay. +MR. EVERDELL: I don't think there's any dispute about +that. +THE COURT: Agreement on that? +MS. +: Yes, your Honor. +THE COURT: Thank you, Ms. +MR. EVERDELL: And the second issue is we were just +given by +some photographs that we would like to +admit into evidence. She brought them with her today, so we +just obtained them. I've shown them to the government. +I can describe them for the Court. +It's a series of photographs from the soap opera of +Jane's -- that Jane was on, because +was a fan of the soap opera. And after Jane went +and became a soap opera star, Jane sent her these photographs. +And one is of her and there's some of other cast members as +well. And she has the envelope as well. And we would like to +admit those photographs and the envelope as exhibits in her +testimony. +I've shown them to the government. They were deciding +whether or not they had an objection to this, but I was going +to flag that for the Court. +MS. +: Your Honor, the government remains of +the view it doesn't understand the relevance of these +particular proffered exhibits; and would also note that this + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 25 of 246 +2320 +isn't impeaching her -- wouldn't be impeaching her testimony in +any way. We just don't understand the relevance of these +exhibits. +MR. EVERDELL: Your Honor, it's evidence that she +maintained a relationship with the people in her abuser's -- +alleged abuser's office. I mean, if she claims that she left +New York and she fled this life with Epstein and didn't want +anything more to do with it, this is evidence that she was +keeping contact with people in his orbit. +worked +in his office and was there with him in the office every day. +So it goes to show that there was a continuing +relationship. She voluntarily sent these photographs to her +showing that she maintained that relationship voluntarily, +which I think is the opposite of what you would do if what you +wanted to do was put all this behind you and not be a part of +this world anymore. +MS. +: Your Honor, my recollection of Jane's +testimony was that she herself acknowledged that she had +maintained a relationship with some of the individuals and +their orbit on direct examination and in the course of her +testimony. So, again, I don't understand the relevance of +these photographs. +THE COURT: So just to be clear, you're saying that +evidence came in already that she maintained a relationship; +correct? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 26 of 246 +2321 +MS. +: Your Honor, yes. There's no dispute +about that. This wouldn't impeach her. +THE COURT: I understand it wouldn't impeach, but +first we start with the relevance question. That's already in. +MS. +: Yes, your Honor. +THE COURT: Okay. +MR. EVERDELL: Your Honor, we don't simply have to +take the witness's testimony. +We are allowed to show that same +point through other evidence. And these photographs show that +the relationship continued. And we are entitled to argue not +just from the witness's testimony, but from these photographs, +that there was a continuing relationship and what that means in +the defense's estimation, how we view -- how we can argue to +the jury what that means in terms of her state of mind. +THE COURT: All right. That the point is already in +establishes relevance. I don't think it's 403 prejudice to +have duplicative evidence of the nature of the relationship. I +don't hear an argument for prejudice otherwise. So obviously +mindful of the need to continue to protect the anonymity of the +witness, I would allow it. +MR. EVERDELL: Yes, your Honor. +And I've met with the witness and I've impressed upon +her that she should only use the name Jane. And if she's +referring to Jane's family members, say the mother or the +brothers, she will say it that way, Jane's mother, Jane's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 27 of 246 +2322 +brothers. And she will only refer to the soap opera, not the +particular name of the soap opera. +THE COURT: All right. What else? +MR. EVERDELL: I don't think anything from the defense +at the moment, your Honor. +MR. +Nothing from the government, your +Honor. +THE COURT: We have one more juror we're waiting on. +, while we have a moment, so I did work out +logistics for the charging conference. We can do Saturday at 9 +a.m. in this courtroom. And as I said, the DE and other +courthouse staff will ensure significant public access. We'll +have room in the courtroom and in overflow courtrooms for the +charging conference. +Anything else? +MR. EVERDELL: Sorry, I did forget one thing. +With respect to those photos, your Honor, if they do +get admitted, there's only one copy of each. So my plan on +publishing them to the jury would be to just walk down the jury +row with the photos so they can see them, because we don't have +physical - we just got them this morning; we don't have copies +of the photos. +THE COURT: You can't run off some copies? +MR. EVERDELL: We can try in the meantime. +THE COURT: Okay. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 28 of 246 +2323 +MR. EVERDELL: But -- +THE COURT: I just think we have a standard for how +we're doing this; and the need to make some photocopies isn't a +sufficient burden to -- +MR. EVERDELL: +Well, we don't really have the +resources +MS. +Your Honor, the government is happy to +make the copies. +THE COURT: We'll do the copying. +MR. EVERDELL: All right. That's fine. +I wish we did have a copier in our room, but we don't. +we have a two-minute break? +THE COURT: Yes. +MS. STERNHEIM: Thank you. +THE COURT: We'll adjourn until we have our jury. +Thank you. +(Recess) +THE COURT: All right. We have our jury. +Anything to take up before I bring them in? +MS. STERNHEIM: Just very quickly, Judge. +THE COURT: Sure. Please be seated. +MS. STERNHEIM: This has to do with a witness that may +be coming in. It may be Dr. Loftus. We would like to be able +to use the screen which you can draw on. And the technical +people have assisted us in doing it. The only thing is this + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2324 +equipment does not save anything. So I would ask permission +that we would be able to take a picture of it for the record. +It's a demonstrative; it's not being put into evidence. But if +the Court wished it to be part of the record, the only way to +preserve it would be by a copy of it. +THE COURT: What's an example? Usually you just use +words to describe for the record what's being indicated. +MS. STERNHEIM: There's an opportunity for her to do a +demonstrative for the jury. If we weren't in COVID, she would +get up, she would stand before the jury with a whiteboard. We +cannot do that under these circumstances. And the equipment is +for that very purpose. It's been done in other cases; it's +just that this equipment -- +THE COURT: So it would be like a whiteboard. +MS. STERNHEIM: Yes. +THE COURT: Whiteboard doesn't come into evidence. +MS. STERNHEIM: I'm not saying it's coming into +evidence. +THE COURT: She can draw on it, but I don't see a need +to take a picture. +MS. STERNHEIM: I'm only saying if the Court wished +there to be a - part of the record. But if the Court does +not, that's fine. +THE COURT: I'm sorry, I misunderstood. I thought you +were asking for it to be part of the record. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 30 of 246 +2325 +MS. STERNHEIM: No. I'm just saying that there's —- +she will be describing it and we will make sure it gets in the +record. But I did not know if the Court wished there to be it +as sort of a marked exhibit for identification just for the +record, not in the record. +THE COURT: I've never done that. +MS. STERNHEIM: Then that's fine. I'm just -- +THE COURT: If somebody requests it, I'm happy to hear +the request, but it's not something I've ever -- +MS. STERNHEIM: Then it's not necessary. I did not +know if the Court would prefer that. +THE COURT: All right. +MR. EVERDELL: Your Honor, if the Court would like, I +have just 3500 material for the witness in paper copy. +THE COURT: Okay. Thank you. +MR. EVERDELL: I also have a copy for the witness +which I can put in the box. +THE COURT: Yes. +Okay. +Can we get our jury. Yes. Thank you, +Who will call the witness, just so I can designate the +right person to call the first witness? +MR. EVERDELL: I will be calling the first witness. +THE COURT: All right. Thank you, Mr. Everdell. +MR. EVERDELL: Your Honor, I'll check if the witness +is there. + + +Document 761 Filed 08/10/22 Page 31 of 246 +2326 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE MARSHAL: Are you ready for her? She's outside. +MR. PAGLIUCA: Your Honor, we'll check -- +THE COURT: 01 course. Thank you. +Not yet. Thank you. +Bring in the jury. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 32 of 246 +- direct +2327 +(Jury present) +THE COURT: +Thank you, everyone. Please be seated. +Good morning, members of the jury. Nice to see you. All +right. I hope everyone is well. We will proceed with the next +phase of the case. +Mr. Everdell, the defense may call its first witness. +MR. EVERDELL: Thank you, your Honor. The defense +calls Kimberly Espinoza. +THE COURT: +may come forward. +called as a witness by the Defendant, +having been duly sworn, testified as follows: +THE COURT: Come forward into the box, you can take +your seat, you may remove your mask, and please state and spell +your name for the record. +THE WITNESS: My name is +and it's +spelled C-i-m-b-e-r-1-y E-s-p-i-n-o-s-a. +THE COURT: Thank you. I will ask you, if you can, +pull up as close to the mic as you can and please speak +directly into the microphone. Thank you. +Mr. Everdell, you may inquire. +MR. EVERDELL: Thank you, your Honor. +DIRECT EXAMINATION +BY MR. EVERDELL: +2. Good morning, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +A. Good morning. +Filed 08/10/22 Page 33 of 246 +- direct +2328 +how old are you? +A. 55. +Q. And where do you live? +A. I live in California. +Q. How far did you go in school? +A. About a year and a half of college. +Q. Are you married? +l. And do you work currently? +Q. What is your current job? +A. I'm an executive assistant to the CEO of a global company. +Q. Is that in California? +l. And how long have you been doing that job? +A. It will be 10 years. +l. I want to direct your attention now to October of 1996. +A. Okay. +l. About how old were you in October 1996? +A. 28. +l. And where were you living around that time? +A. I was living in Midtown. +THE COURT: Pausing for technical issues. Thank you +very much. Go ahead, Mr. Everdell. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 34 of 246 +LCGCmax2 +- direct +2329 +MR. EVERDELL: Thank you, your Honor. +I actually want to jump back for a second. +You mentioned your current job is an executive assistant for a +CEO; is that right? +A. Correct. +Q. Can you describe generally what you do in that position. +A. I am basically the gatekeeper for the CEO. All +appointments are scheduled through me, I book a lot of travel, +book a lot of meetings. I'm also, I guess, the senior +executive assistant supervising about six other executive +assistants for the company. +l. Now I will direct your attention back to October of 1996. +Say again where you were living around that time. +A. Well, I moved from California to New York, and when I first +moved to New York, I lived on the Upper East Side. I +previously said Midtown, but that's because I moved from the +Upper East Side to Midtown during my employment. +2. But you started out on the Upper East Side. Okay. +Did you get a job when you came to New York? +Q. And what job did you get at that time? +A. I was hired by J. Epstein & Co. for the legal team, legal +counsel being Jeff Schantz and Darren Indyke. I was hired as +the legal assistant, the legal admin. +Q. And J Epstein & Co. was whose company? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmax2 +Filed 08/10/22 Page 35 of 246 +- direct +A. Jeffrey Epstein's company. +Q. And had you held any jobs as of this type of assistant +before working for Mr. Epstein? +A. Yes. I was previously -- before I came here, I was an +executive assistant to the CEO of a small startup technology +company for about two years before I moved here. +And how did you find the job with Jeffrey Epstein's +company? +A. One of the papers, either the New York Times or the Daily +News, I'm not sure, but it was an ad that I answered or +responded to by calling a job agency, and I interviewed with +the job agency who sent me to two or three places to interview +in a day and one of them was J. Epstein & Co. +l. Did you have to interview with anybody at the J. Epstein +company to get the job? +l. Who did you interview with? +A. I interviewed with four people. First it was Jeff and +Darren themselves -- +l. Let me pause you there. Can you say their full names? +A. Jeff Schantz and Darren Indyke. +e. Who were they? +A. They were the legal counsel representing Jeffrey Epstein. +l. And who else, who were the other two? +A. And then I passed the cut, I guess, from Darren and Jeff, +2330 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 36 of 246 +LCGCmaxZ +- direct +2331 +and was asked to interview with Ghislaine Maxwell. +Q. And can you describe that interview. +A. Yeah. +It was rather unique. She had been running around +doing errands and wasn't able to make it up to the office where +I had been interviewed with Jeff and Darren, and so she had +asked if -- the receptionist asked me if it would be okay if I +can come down and have the interview in the back of the sedan +that was driven by a chauffeur. So our interview took place +driving around Manhattan in the back of a limousine. +l. And how did that interview go? +A. It went well. It was a different interview than I had +experienced before, so I liked it, it was fun and I liked +meeting Ghislaine. +l. Did you meet with anybody else or interview with anybody +else after your interview with Ghislaine? +A. Yes. After I passed that test, I was allowed to meet with +Jeffrey Epstein, who would make the final decision on whether I +would be hired or not. +l. And how did that interview go? +A. And I interviewed back at the office with Jeffrey Epstein +after waiting for a few hours for him. And when he came, we +had a normal interview, if will you, and I left. And I found +out the next day that I was given a job offer. +l. Now you mentioned that you were -- did you take the job? +Okay. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 37 of 246 +LCGCmaxZ +- direct +2332 +THE COURT: I'm sorry. Could you state the answer. +A. Yes, I did take the job. +Q. Be sure to state the answer as we can't do nodding. +A. Okay. +e. You mentioned before that the job you got was with the +legal counsel with Jeffrey Epstein? +Q. Did your job change at any point? +A. It did. +l. How did it change? +A. One day, Ghislaine's assistant had called in sick or was on +vacation a day or -- a day or a week or something and I was +filling in for Ghislaine. After my fill-in, she decided that +she would like me to support her. +So I switched after getting +conversations with Jeff and Darren to make sure they were okay +that I go and work for Ghislaine instead. +l. And so your position changed at that point? +2. And what was the new position? +A. It would be the executive assistant to Ghislaine. +l. And how long did you work as Ghislaine's executive +assistant? +A. I would say approximately six years. +l. So from roughly when to when in years? +A. Probably November of 1996 to the end of the summer of 2002. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 38 of 246 +LCGCmaxZ +- direct +2333 +Something like that. Summer to fall. +Q. In the roughly six or so years that you worked with +Ghislaine, about how much time did you spend with her and work +with her? +A. I spent a lot of time with her in the office. So she would +come into the office almost every day. I was in the office +every day. We worked together just about every day. +Q. And you mentioned the office. Where was the office? +A. The office on 457 Madison Avenue. +Q. In the time that you worked with her, did you get to know +her during that time? +l. What was your impression of Ghislaine? +A. I highly respected Ghislaine. I kind of -- no, not kind +of. I looked up to her very much. And I actually learned a +lot from her as far as administrative and being able to handle +a lot of calls, a lot of duties. It was a very high-volume +work - lots of work to do as far as arrangements to be made. +I attribute my career right now as an executive assistant to +what I learned at supporting Ghislaine. +l. And how did she treat you as an employee? +A. She treated me fair and nice and it was fun. +2. What did you think of your experience working for +Ghislaine? +A. Well, she was demanding, in a way, where, you know, every + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmax2 +Filed 08/10/22 Page 39 of 246 +- direct +task that was given needed to be done as soon as possible, if +not yesterday, and I enjoyed that challenge. But I was able to +do my job and do everything that was needed to be done in a +day. So it worked well. +e. Did you have any contact with Ghislaine after you stopped +working as her assistant? +A. Yes, I did. +Q. What sort of contact did you have? +A. Kind of milestone contacts, birthday wishes, Christmas +wishes. I asked for a couple of letter of references, personal +references for future jobs after I left Epstein & Co. +l. You mentioned birthday wishes. Do you remember when +Ghislaine's birthday was? +A. Absolutely. +Q. When was it? +A. Christmas day, 12/25. +Q. Do you remember what year that was? +A. She's about five years older than me, so '61. +l. Would you recognize Ghislaine today? +A. Of course. +2. Would you look around the courtroom, please, +and do you see Ghislaine Maxwell in the courtroom today? +A. I do. +l. Will you please point her out and identify an article of +clothing she's wearing. +2334 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 40 of 246 +- direct +2335 +A. She is right across from me right there in what appears to +be a purple-hue turtleneck. +MR. EVERDELL: Let the record reflect that the witness +has identified Ghislaine Maxwell. +THE COURT: It may so reflect. Thank you. +when you were working for Jeffrey Epstein's +company, where, physically, did you work? +A. In the office, 457 Madison. +Q. That's in Manhattan? +2. Did you work there the whole time that you were working for +Mr. Epstein? +l. Did you work anywhere else? +A. Maybe just a handful of times I would work at Ghislaine's +residence, but that was towards the end of my career there. +l. And about how much time did you actually spend in +Ghislaine's residence, all tolled, roughly? +A. Maybe a week or two, max. Not straight. It was just a day +here, a day there. +l. Over the course of your whole six years? +A. Yup. +Manhattan? +l. Did you ever work out of Jeffrey Epstein's residence in +A. No. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 41 of 246 | +2336 +- direct +Q. What were your typical working hours in the office? +A. Typical working hours for me were about 9:30 to 6:30. +Q. Now, I want to focus your attention on the time period when +you started your job, so the mid to late '90s, '96, '97, '98. +Who were the people who worked in the office in that time +period? +A. We had Jeff Schantz and Darren Indyke, the legal team. +There was another attorney, Amanda Milroy. There was an +accounting team, Harry Beller, Eric Gany, a woman by the name +of Bella, I don't remember her last name. Also another woman +named Gee, I don't remember her last name. We had a +receptionist, +• Jeffrey Epstein had his executive +assistant, at the time was a woman named Maureen when I first +started. We had -- did I say the receptionist? +Q. You mentioned, I think, +was a receptionist. Do +you remember +I last name? +A. +Q. Were there any other receptionists you recall? +A. Yes, there was a +that came after +l. And you mentioned, I think, Mr. Epstein's executive +assistants; is that right? +left. +l. Is that separate or the same as the receptionists? +A. Separate. +Q. And you mentioned a Maureen. Were there any other + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 42 of 246 +LCGCmaxZ +- direct +executive assistants that were there during your time in the +office? +A. Yes, Leslie Roth and Suann Pisap. +Q. Who came before who, Suann or Leslie? +A. Suann was before Leslie. +Q. Was Leslie there when you left? +Q. Were there any other people in the office that you recall +working there in any of the offices there? +A. On a daily basis, I can't remember if there was anybody +else there working on a daily basis. We did have other +personal assistants come through and hang out, not necessarily +all day, but kind of like pit stops. That would be +and +Q. So with respect to +on the 1996, '97, '98. Do you recall seeing +1. I'm focusing your attention +during +that time period? +A. I don't recall when I first saw her. I don't know. I +would say it was the middle of my time there, in the middle of +that time. +l. You also mentioned a l +you started seeing +Do you remember when +A. That was more towards the end. +l. So in the time period, '96, '97, '98, do you recall seeing +2337 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 43 of 246 +LCGCmaxZ +- direct +2338 +A. Hard to say, but I don't think so. +Q. We'll talk about those folks in a minute. +Can you describe the layout of the office space at +Madison Avenue from when you get off the elevator. +A. Sure. So you get off the elevator and immediately to your +left were the restrooms. Immediately in front of you was the +accounting +team office, then the reception desk would just be +kind of pitched to the right. Behind the reception desk was a +hallway where the offices were. The legal team sat on the +left-side office, and that was followed by Jeffrey's office, +which was a corner. Directly next to Jeffrey's office and +directly behind the receptionist at the end of the hall would +have been Jeffrey Epstein's assistant, and then I sat to the +left of Jeffrey Epstein's assistant. So we were, like, in a +row. If all doors were open, I could see Jeffrey in the +corner, his assistant, myself. And then in my office, which +was Ghislaine's office, there were three desks - one was +Ghislaine's, one was mine, and one was the legal assistant's. +2. Do you remember the legal assistant's name when you were +there? +A. Lauren Quitner (ph.). +l. Lauren Quitner? +l. So in the office where you sat and where Ghislaine sat, how +many people actually sat in that office? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmax2 +Filed 08/10/22 Page 44 of 246 +- direct +2339 +A. Three. +Q. Were there cubicles or was it a shared space? +A. Shared space. +Shared open space. +Q. In your time there, do you recall Ghislaine having her own +private office, ever? +A. No. +Q. When you started the job, did you have to sign any legal +documents or agreements? +Q. What did you have to sign? +A. A nondisclosure agreement. +l. Did you have any particular reaction -- withdrawn. +What did the nondisclosure agreement mean to you? +A. Just not to repeat any of my work. My work was my work not +to be shared with the privacy and out of respect and privacy +for Jeffrey Epstein, you know, not to share who his clients are +or anything that I might be privy to. +Q. In your work as an executive assistant for other CEOs, did +you ever have to sign a nondisclosure agreement for them? +l. That's happened in the past? +l. Did you have any particular reaction to signing these NDAs? +A. No. +2. Were you ever given any instructions about how you could or + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 45 of 246 +- direct +2340 +could not interact with other employees in the office? +A. No. +l. Were you ever given any instructions about how you could or +could not interact with Jeffrey Epstein? +A. No. +Q. I want to talk to you in a little bit more detail about +your duties and responsibilities at the office. We'll start +first with the job you briefly had as the admin to the lawyers. +What were your responsibilities there? +A. A lot of photocopying, filing. That was the gist of it. +And taking messages for them if they weren't available for a +phone call. +Q. And do you know what sort of functions the lawyers +performed for Mr. Epstein, from your observations? +A. I don't know exactly what they performed, but I know that +they were pretty important to Jeffrey Epstein. +l. And about how soon after you started your job did you +transition to becoming Ghislaine's executive assistant? +A. I would say it was within a month. It was kind of quick. +l. What were your responsibilities as Ghislaine's executive +assistant? +A. Making arrangements. We had kind of a routine where she +would come in, I'd sit at her desk, she'd give me a laundry +list of tasks to do for the day, people she needed to talk to, +things I needed to have shipped, things I needed to have + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 46 of 246 +- direct +2341 +purchased, reservations to be made. It could have been a list +of anywhere from 25 to 50 things in a day. +Q. And what +was Ghislaine's employment role in the office, +what jobs did she perform? +A. She was the estate manager, in my mind. She ran the +properties for Jeffrey Epstein. +l. And did you assist her with those jobs? +A. I did. +l. And I'll get to the estates in a second, but as compared to +the other people in the office, where, in your mind, did +Ghislaine would fall in terms of importance? +A. Ghislaine was very important to me. She was obviously +important to Jeffrey Epstein because of his personal +residences. I can't really say in Jeffrey Epstein's eyes what +her importance was, but, again, to me, she was quite important. +l. Well, if Ghislaine managed Jeffrey's properties, were there +other people in the office who handled other aspects of his +life? +A. Absolutely. +e. Like who? +A. Like his finance people handling the money and his +attorneys handling his business affairs. +l. Io your knowledge, did Ghislaine have any role in managing +those aspects of Jeffrey Epstein's life? +A. Not to my knowledge. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 47 of 246 +2342 +LCGCmaxZ +- direct +Q. Now you mentioned the properties, right. How many +properties did Jeffrey Epstein own when you started working in +the office? +A. When I started working, he had already owned Zorro Ranch, 9 +East 71st Street, and El Brillo, I believe. +Q. You mentioned Zorro Ranch, where was that? +A. That was in New Mexico. +Q. 9 East 71st Street was where? +A. New York. +l. And El Brillo was where? +A. Florida. +l. Did there come a time when he acquired any additional +properties while you were there? +A. Yes. I believe he acquired a Paris apartment, and he also +purchased the island, St. +l. Do you remember the name of the island? +A. It was Little Saint James, but the name was changed to +Little Saint Jeffs. +Q. Was that purchased, the island, at the time you were there? +A. Yes. I would say probably the middle of my time there, it +was purchased, and it was a humongous project. +l. Please describe, if you could, just that particular project +of getting the island ready, what was involved in that and what +roles did you and Ghislaine perform? +MS. +: Objection. Foundation. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 48 of 246 +LCGCmaxZ +- direct +2343 +THE COURT: All right. You may inquire. Why don't +you start with the latter part of the question. +Q. Did you assist Ms. Maxwell in any way with the project. +Island? +Q. And what sort of things did you assist with? +A. There was new construction being done on the island, there +were, I think, new swimming pools. But the majority of what I +did was furnish the house, furnish the resort style. There +was, you know, every house good that you could think of - +silverware, glasses, towels, beach towels, linens. We had to +ship all of that over, all of the furniture, all of the +artwork. We even shipped in sand and palm trees and all kinds +of things to get the island to what he wanted it to be. +Q. To be clear, you shipped in sand to a tropical island, why +was that? +A. He wanted more sand on the beach. +l. Palm trees, too? +A. Uh-huh. +l. When you started when the island was acquired, was there +anything, to your knowledge, on the island or was there nothing +on the island? +A. I think there may have been one building or something. It +was a lot of construction going on. We even had a fire +department on the island, a firehouse with a proper firetruck + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 49 of 246 +- direct +2344 +and firemen and all of that. +Q. Was it part of your job to help Ghislaine do all this? +A. It was part of my job to, yes. Ghislaine would tell me who +she needed to talk to in a day, whether it be landscapers, +designers, interior decorators. +Q. So just focusing on that particular project with the +island, how big a job was that to get the island up and +running? +A. It was more than full-time, in my eyes. +l. And how long did that project last? +A. Months. I don't even know that it ever finished, to be +honest. +l. So just broadly speaking, how big a job, from your +observation, how big a job was it for Ghislaine to manage all +of these properties for Mr. Epstein? +A. It was a huge job. +l. Did she work hard? +2. And in connection with her responsibilities, did she ever +have to travel to the properties to manage them? +A. Sure. +l. And how often did she travel to do that? +A. Well, she traveled on a weekly basis for the most part. I +can't say, you know, when she went to each house for what +purpose. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +LCGCmax2 +- direct +2345 +Q. When she did travel, would she always travel with Jeffrey +Epstein or would she sometimes travel herself? +A. +She sometimes traveled herself. +Q. Did you ever travel with her? +A. No. +Q. If Mr. Epstein wanted to travel to one of his properties to +visit, what preparation would need to occur before he traveled? +A. Well, Jeffrey had -- we always had the houses prepared, all +of the houses prepared for wherever he decided he wanted to go. +So what needed to happen was there was bread flown in, his +favorite bread that he liked. I think we did butter, as well. +Make sure that the houses were stocked. There were certain +things from New York that he wanted specifically in all of the +residences, and it needed to be fresh for his arrival. So on +occasion, it wouldn't be odd to ship out this food to each of +the residences so that it would be there for whenever he +decided to show up or go. +Q. And whose job was it to supervise all of these logistics? +A. It would be Ghislaine's. +l. And did you assist her with those? +A. Absolutely. +"2. Do you recall someone named, I think you mentioned before, +e. Who was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 51 of 246 | +LCGCmaxZ +- direct +2346 +A. +was an assistant to Ghislaine. I kind of +looked at it more like a personal assistant as opposed to what +I did sitting in the office as an executive assistant. +Q. Can you describe a little bit about the difference between +your job versus what her job was. +A. Sure. +She would look after the dog, you know, take the +dogs for a walk, take it out if it needed, because Ghislaine +would bring the dog to the office. She would carry her handbag +and her coat and run out and get her coffee or pasta or +whatever. So that's what I saw in the office that she did for +Ghislaine. +e. Did +work in the office or did she work elsewhere? +A. She worked elsewhere. She was sometimes in the office, but +not too often. +l. Were you friendly with +e. +how did Mr. Epstein typically travel to his +different properties? +A. On one of his planes, private planes that he owned. +e. Do you know how many planes he owned around the time you +were working for him? +A. I think three, three or four maybe. +l. Did you ever fly on his private planes? +A. No. +2. Did you ever have any dealings with the pilots about + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 52 of 246 +LCGCmaxZ +- direct +2347 +flights that were going to take place on the private planes? +A. Sure. +On occasion I would have to tell them what time +wheels up was. Jeffrey might call in and I'd pick up the phone +and he'd say, tell Larry wheels up at 8 o'clock to wherever he +was going. +Q. And who was Larry? +A. Larry, one of Jeffrey's pilots. +Q. Did Ghislaine ever make a similar call when you were in the +office to let Larry know when wheels up was? +A. It was directed by Jeffrey Epstein, what time wheels were +up. And on occasion, I'm sure Ghislaine also told Larry what +time that would be. +l. Who in the office would most typically interact with the +pilots about wheels up times and make arrangements for flights? +A. It could be any of the assistants, me, Jeffrey's assistant, +or Ghislaine herself. +Q. And when you arranged the flights or when you had +conversations with the pilots, what information did you give +the pilots, typically? +A. That was it. The time - they always, you know, the planes +were at Teterboro airport, so there was never a question of +where they needed to be. It was just what time was wheels up +and where were they going. +l. Did you typically have information about the names of the +passengers that would be on the flights? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 53 of 246 +- direct +2348 +A. No. +l. Do you know if Mr. Epstein ever traveled with guests on his +plane? +A. Sure. Yes. +l. Did you typically know the names of the guests that were +flying? +A. No, not really. Sometimes some of his friends would call +and ask for a lift to Florida, something like that, but I don't +recall the names or I wouldn't really know what guests were +flying at any given time. +l. Did Epstein ever travel on commercial flights? +A. Not to my knowledge. +l. Would Ghislaine ever travel on commercial flights? +Q. And when would she do that? +A. There were times where she would either fly to see family +in London or she would fly to Miami a couple times. Couple +times she came out to California. Just different -- just when +she wasn't with Jeffrey, she would be somewhere else. +l. Did you help arrange those commercial flights? +l. Did you arrange commercial flights for anyone else in the +office? +A. No, not really that I can recall. Maybe, maybe I did, but +I don't remember exactly. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 54 of 246 +LCGCmax2 +- direct +2349 +Q. When you arranged these commercial flights, did you call +the airlines directly or did you use a travel service? +A. +We used a travel agency. +Q. And what was the name of that travel agency? +A. Shoppers Travel. +Q. Do you know +where that was located? +A. It was +in New York, but I don't know where. I never was +there in person, just on the phone. +l. As part of your responsibilities as Ghislaine's executive +assistant, did you ever book massages for Ms. Maxwell? +l. And where did you book those massages? +A. She had her places in SoHo. She liked Bliss Spa, she liked +the Red Door, Elizabeth Arden, places like that. +l. Were these professional massage places? +l. Did you ever schedule a massage for Jeffrey Epstein? +e. Do you remember how many times, roughly, you did that? +A. Maybe ten my entire time I was there. I don't - five to +ten. A handful of times. +l. Do you remember any of the masseuses he used? +A. I do remember a few names. +What comes to mind is there was +a Lydia, a Monica. I don't really remember. It's hard for me +to recall off the top of my head, but if I hear them that's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 55 of 246 +LCGCmaxZ +- direct +2350 +when I'm like, +I remember that name. +Q. Were these people professional masseuses? +A. Yeah. +Q. Did you ever get a massage yourself? +A. I did. +Q. Do you remember who gave you that massage? +A. Yes, that was +Q. Was that a masseuse that Mr. Epstein used? +l. Were you ever inside of Mr. Epstein's residence in New +York? +A. I did get a tour when I first started. I think I did meet +Ghislaine there on occasion once or twice to either drop off +something or retrieve something and take it back to the office. +Q. And where was the residence? +A. 9 East 71st Street. +l. Is that on the Upper East Side? +A. I don't know if that's considered the Upper East Side, but, +yes, it was right off the park, Central Park. +l. Were you ever in Ghislaine's residence? +l. Did she live in the same residence when you worked for her +or more than one residence? +A. She had more than one residence or she had moved. She was +first on the Upper East Side and then she moved to 65th Street. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 56 of 246 +LCGCmax2 +- direct +2351 +Q. Do you remember roughly where on the Upper East Side she +was living when you +started the job? +A. +I want to say it was 84th Street. I lived on 88th Street, +so I remember kind of feeling like we were in the same +neighborhood. +Q. And do you remember roughly when she moved to 65th Street? +A. I would say that would be during the middle of my time +there, maybe 2000, late '90s, early 2000. +l. And the 81st Street residence, what kind of residence was +that? +A. What kind of residence? +l. Was it a townhouse or an apartment? +A. It was a townhouse with many levels. +Q. Was that the 84th Street one or the 65th Street one? +A. No, I'm sorry. I was thinking that we were talking about +Jeffrey Epstein's on 71st Street. So now we went back to +Ghislaine? +Q. Yes. Let me be clear. I'm asking you about Ghislaine's +different residences, you mentioned two, one on 84th Street, +one on 64th Street? +A. Correct. +l. So let me first ask you about the 84th Street residence. +What kind of a residence was that? +A. That was a townhouse-type thing. Maybe it was an +apartment. It was so long ago, I can't really recall that, but + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 57 of 246 +LCGCmaxZ +- direct +2352 +I do recall her residence on 65th Street. +Q. Okay. +What do you recall about the residence on 65th +Street? +A. That was a townhouse with, I think, three levels. +l. And to your knowledge, did Ghislaine always retain her own +residence in New York while you were at your job? +Q. To your knowledge, did she ever reside with Jeffrey +Epstein? +A. No. +2. Whose residence was that? +A. Ghislaine's. +e. And what city was that in? +A. London. +MS. +l. Are you familiar with a residence at 44 Kinnerton Street? +: Objection. Foundation, your Honor. +THE COURT: Sustained. +Q. Have you ever been to that residence? +e. When were you in that residence? +A. Three years ago. +2. So do you know who owned that residence at the time you +were there? +MS. +: Objection. Foundation. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmax2 +Filed 08/10/22 Page 58 of 246 +- direct +THE COURT: I'll take yes or no to this question and +2353 +then sustain. +MS. +I should also just say hearsay, your +Honor. +THE COURT: I'll take yes or no to the question, do +you know who owned the residence at the time that you were +there. +A. I- +THE COURT: Just yes or no. +A. No. +Q. How was it that you were at that residence three years ago? +A. It was my first trip to Europe and I reached out to +Ghislaine to ask her if I could stay there. +l. And so you were inside while you were there? +l. Was there a massage room in that residence when you were +there? +A. No. +2. I want to jump back to your work in the office a bit. +From your work in the office, do you know whether +Epstein gave to charity? +A. He did give to charity. +MS. +: Objection, your Honor. +THE COURT: I'11 allow it. What's the next question? +MR. EVERDELL: What organizations did he give to. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 59 of 246 +LCGCmaxZ +- direct +2354 +THE COURT: I'll sustain with respect to that. +Q. Did he engage in any other types of giving? +2. What did you observe him -- what types of giving did you +observe him doing? +A. I know that he paid for some of the employees' kids' +education. +He was -- I believe that he also paid for other +people's educations. He was a giver. He was generous and I +always knew him to be donating to charities and just being a +kind person. +Q. Did Epstein ever give you any gifts? +A. He did give me the massage a couple times. And, also, he +had paid for a personal trainer for me to have. I guess that +was a gift. I kind of thought of it more as an employee perk. +I don't really think he gave me any gifts, other than when I +left. My departure, I was given a watch. +Q. Were there any special events he treated you to? +A. Yes. That was going to The Lion King. +Q. And was this the Broadway show or was this the movie? +A. The Broadway show. +Q. And about when did that happen? +A. I believe that's when the show first came out, it was a hot +ticket, and I recall him being friendly with the producer of +the show. And during a time of a month or two, he was sending +a lot of people to The Lion King. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +LCGCmaxZ +- direct +2355 +Q. And that included yourself? +A. Uh-huh. +Q. And about how soon after the show opened, in your +recollection, was he handing out these tickets? +A. That I can't say. I'm not sure. +Q. But you recall it being a hot ticket? +A. +yeah. It was new. +It was a new +show. +Q. Do you recall anybody else that he gave Lion King tickets +to? +A. I feel like he gave them to almost all of the employees if +they wanted. It was just something that he was giving out at +that time. I don't really recall who else. +l. I'm going to ask you a little bit more about the office. +Did Epstein ever receive visitors in the office? +l. Were any of these visitors female? +l. I want to show you on the screen, this is an exhibit that's +already admitted, Government Exhibit 12, but I believe it's +admitted under seal. So if we can just display it -- +MR. EVERDELL: May I confer, your Honor? +THE COURT: You may. +MR. EVERDELL: All right. So if we can just display +Government Exhibit 12 for the Court, the deputy, and the +witness only. This is already admitted under seal. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 61 of 246 +- direct +Q. Do you see that document in front of you? +A. Yes, I do. +2. Now, without saying the name of that person out loud, do +you recognize the name of the person on that document? +A. Yes, I do. +Q. I'm going to refer to that person as Jane and you should, +too. Okay? +A. Okay. +2356 +MR. EVERDELL: You can take that down now. +do you ever recall seeing Jane in the office? +e. +l. How old did she appear to you to be when you first saw her? +A. Probably 18. +l. And about when do you recall first seeing Jane in the +office? +A. I remember seeing Jane in the office with her mother. +l. And about when do you recall that happening for the first +time? +A. Probably the beginning to middle of my time there. +l. And about how many times did Jane visit the office, to your +recollection? +A. There was a few times. I can't really say how many times, +but I would say maybe five. +Q. And you mentioned Jane's mother. Do you recall how many +times Jane's mother came with her to the office? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 62 of 246 +LCGCmaxZ +- direct +2357 +A. I don't recall, but I know that Jane's mother called the +office a lot because I spoke to her a lot on the phone. +Q. About how often was Jane's mother calling the office? +A. Hard to say, but I want to say there was, you know, a +couple months where it was a lot. +Q. And who was she asking to speak to when Jane's mother +called the office? +A. Jeffrey Epstein. +2. What, generally, do you recall about Jane and Jane's mother +and their interactions with Mr. Epstein in the office? +A. Well, Jane's mother had mentioned that her daughter - +MS. +: Objection, your Honor. Hearsay. +MR. EVERDELL: It's not offered for the truth, your +Honor. +THE COURT: Just a moment. I'll need a proffer. + + +LCGCmaxZ +Filed 08/10/22 Page 63 of 246 +- direct +2358 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(At the sidebar) +MR. EVERDELL: Your Honor, I anticipate the witness is +going to say that Jane's mother referred to Jane as Epstein's +goddaughter and that that actually caused a reaction, that +people in the office treated her a certain way because that's +how she represented Jane to be. I'm not offering it for the +truth, it's simply the effect on this listener and how she +responded to Jane's mother when she was in the office. +MS. +: No objection. +THE COURT: Do you want a limiting? +MS. +: It's fine, your Honor. +THE COURT: Do you want a limiting? +MR. EVERDELL: I don't think so your Honor. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 64 of 246 +- direct +2359 +(In open court) +MS. +Objection withdrawn, your Honor. +BY MR. EVERDELL: +Q. Let me ask you this, [ +how did Jane's mother +refer to Jane among the people in the office? +A. Jane's mother said -- +THE COURT: Could you pull up to the mic, please. +A. Jane's mother said that Jane was Jeffrey's goddaughter. +l. And how did that, if at all, affect the interactions of the +people in the office with Jane and Jane's mother? +A. Well, I know from myself and the girls that worked in the +office, you know, she was treated with the utmost respect, kind +of considered her family of Jeffrey's. So, you know, we always +treated everyone that came in with courtesy and professionalism +and respect, but given that we thought Jane was the +goddaughter, she was just a little extra special. +Q. Did Jane have any siblings? +2. Were they brothers, sisters, do you remember? +A. Iwo brothers. +l. Again without saying their names, did they ever visit the +office? +A. I don't recall. +l. About how much contact would Jane's mother have with +Epstein during the time period when they were in contact? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 65 of 246 +LCGCmaxZ +- direct +MS. +: Objection, your Honor. Foundation. +THE COURT: Sustained. +Q. You said you received calls from Jane's mother; right? +A. Uh-huh. +l. And you said that she sometimes visited the office; is that +right? +A. Correct. +Q. Do you recall over what span of time this occurred? +A. No. +l. Do you know if Jane ever traveled on Mr. Epstein's planes? +A. I don't know. +l. What was your impression of the relationship between Jane +and Epstein? +MS. +: Objection. +THE COURT: One word, grounds. +MS. +: Foundation. +THE COURT: You can ask a foundation question. +l. Did you ever see Jane interact with Epstein in the office? +l. And how often did you see that interaction, how many times? +A. Maybe three or four. +l. Based on those three or four interactions, what was your +impression of the relationship between Jane and Epstein? +A. I felt it was a loving relationship. +Q. Did there come a time when Jane stopped visiting the +2360 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmaxZ +Filed 08/10/22 Page 66 of 246 +- direct +office? +2. Do you know why that was? +A. I think it was because she went to go work in California +for a soap opera. +Q. And how do you know that she ended up working for a soap +opera? +A. She told me and I also saw it myself, because it's one of +my soap operas I watched my entire life. +l. Are you a fan of this particular soap opera? +A. Big time. +l. And did you see Jane on the soap opera? +l. After she moved to LA and was on the soap opera, did you +have any continuing contact with Jane? +A. Only when she would call the office. +l. Any other type of contact with Jane after she stopped +coming to the office and was in LA? +A. Yes. She sent me a little envelope with headshots, signed +headshots of the cast from the soap opera, a few single +headshots and then the whole cast all signed. +Q. Is that something that you asked for or did she send that +to you as a gift? +A. I think it was a gift. +e. Do you remember roughly when she sent you those headshots? +2361 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 67 of 246 +LCGCmaxZ +- direct +2362 +A. I don't recall. I don't know. I've held onto them for +very many years. +MR. EVERDELL: One moment, your Honor. +Your Honor, I would like to approach the witness and +show her some exhibits marked for identification. I have a +copy for the Court, as well. +THE COURT: Okay. Marked for identification as? +MR. EVERDELL: Marked for identification as +defendant's CE3, CE4, CE5, CE6, CE7, and CE8. +May I approach, your Honor? +THE COURT: You may. +BY MR. EVERDELL: +2. +if you could take the documents I just handed +you and look at them, the documents that are marked for +identification as CE3 through CE8. +Have you had the chance to look at them? +2. Do you recognize what those are? +l. Sorry. I couldn't hear you. +Q. And what are they? +A. They are the headshots of three of the cast members and +then a group cast member shot. +Q. And is the envelope also there, too? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 68 of 246 +LCGCmax2 +- direct +A. The envelope is here, yes. +Q. Are they the headshots that were sent to you and is that +the envelope that they were sent in? +Q. And how do you recognize these? +A. They're mine. I've had them forever. +Q. Have you had them in your possession +since you received +them? +Q. And are they in the same or substantially the same +condition as when you first received them? +2363 +MR. EVERDELL: Your Honor, at this time, the defense +moves to admit CE3 through CE8, temporarily under seal so we +can apply appropriate redactions to protect the privacy +interests of witnesses. +MS. +: No objection, your Honor. +THE COURT: CE3 through 8 are admitted temporarily +under seal for the purpose of protecting the anonymity of a +witness who I've permitted to testify under pseudonym. +(Defendant's Exhibits CE3 through CE8 received in +evidence) +MR. EVERDELL: Correct, your Honor. Your Honor, at +this time, I do have copies for the jurors if the Court will +permit me to hand them out. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmax2 +Filed 08/10/22 Page 69 of 246 +- direct +2364 +THE COURT: Thank you. +e. +let's first take a look -- +THE COURT: I think they're waiting for me. Would you +like the jurors to look? +MR. EVERDELL: Yes. +May I publish this to the jurors, +your Honor? +THE COURT: So the jurors may look at the exhibits in +the folder. Go ahead. +BY MR. EVERDELL: +l. Look first at CE3. Do you see what that is? Actually, can +you hold that up? What is CE3? +A. CE3 is a manilla envelope addressed to Ms. Cimberly, care +of Epstein & Co., 457 Madison Avenue, from Jane. +l. Is there a date on the envelope? +A. You can't read what the postage machine -- you can't see +it. +THE COURT: Just my copy of the envelope doesn't have +a mark. +MR. EVERDELL: Understood. The physical copy of the +exhibit is what has the sticker on it. I don't know if we were +able to copy the entire thing because it's a large envelope. +THE COURT: Do you want to direct the jurors to look +at a photocopy of an envelope and that is what you're +indicating is CE3? +MR. EVERDELL: Well, your Honor, I'm actually having + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 70 of 246 +LCGCmaxZ +- direct +2365 +the witness hold up the envelope itself, which is CE3. The +photocopies are just copies of the envelope. +THE WITNESS: It says CE3. +THE COURT: Got it. +Q. Just hold up the envelope so the jurors can see it. Is +that the envelope that the headshots came in? +Q. And can you tell from the envelope what the postmark date +is or is it too hard to tell at this point? +A. Can't tell. +Q. You can set that down. +Let's 1ook at CE4, and I don't want you to hold that +up, but you have the original photograph there; correct? +l. And the jurors have photocopies. +First of all, who is in that photograph, using only +the names we've agreed upon? +A. Jane. +2. And is there an inscription on the front of that +photograph? +A. There is. +l. Without reading the name -- +MR. EVERDELL: One moment, your Honor. +l. Without reading the name on the inscription, can you just +read out the inscription on the front of the photograph? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmax2 +Filed 08/10/22 Page 71 of 246 +- direct +2366 +A. To Cimberly, with love, Jane. +l. Is there anything written on the back of the photograph +that is CE4? +e. Again, substituting the name we've agreed upon, can you +read out that +inscription? +A. Dearest Cimberly, thank you for always being so sweet and +such a great help. Take care. Jane. +l. And just looking quickly at the others in succession, which +is CE5, CEб, CE7, and CE8, what are those? +A. They are photos, a group shot of the cast of the soap opera +and three separate headshots of three of the actors. +l. And those actors are not Jane; right? +A. Correct. +Q. And just looking briefly at CE5, do you see Jane in that +group shot? +l. And where do you see her? +A. Middle row, all the way to the right. +l. So are these photographs in the envelope we just looked at +what Jane sent you after she started working at the soap opera? +2. Thank you. You can put those away now. +MR. EVERDELL: With the Court's permission, I'll have +the jurors put those down. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 72 of 246 +LCGCmax2 +- direct +2367 +THE COURT: Yes, please. You can put those under your +seats. +Thank you so much. +MR. EVERDELL: Your Honor, shall I continue? Okay. +BY MR. EVERDELL: +e. +are you familiar with the address 301 East +66th Street? +Q. And what is at that address? +A. That is an apartment building. +l. Did you have any job responsibilities with respect to that +apartment building? +l. Can you describe what those were? +A. Sure. First it was managing the scheduling of the +apartments, like a calendar, if you will. There was +approximately a dozen apartments that Jeffrey Epstein owned, +and there were employees that stayed there, family, friends, +guests. +2. And when you say you managed the calendar, what do you mean +by that? +A. Well, that we had a notebook that told us who was staying +in what apartment on any day, that way we would know what +apartment was available to give to someone else. +l. And was your responsibility to manage that calendar? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmax2 +Filed 08/10/22 Page 73 of 246 +- direct +Q. Do you remember any of the names of the people who had +regular apartments in that building, who regularly stayed +there? +Q. Who were some of those people? +A. Jeffrey Epstein's pilots had apartments there. Jane stayed +there, Jane's mother, +Jane's brothers. +We had -- let's see. +There were some other executives that Jeffrey knew. Can't +really recall other names. +had an apartment there +for a while. +e. Who was +2368 +was one of Jeffrey's friends, I guess. +2. Okay. Do you know if l +ever had an apartment +there? +A. +had an apartment there. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 74 of 246 +- direct +2369 +BY MR. EVERDELL: +Q. Now, you mentioned that Jane and Jane's mother and Jane's +brothers used the apartments; is that right? +Q. Were they regular users of the apartments or did they use +it every -- how many times did they use it? +A. They were regular for a duration of time, and then it was +come and go, specifically for the brothers and the mother. +l. About when do you recall Jane and Jane's mother and +brothers using the apartments in New York? +A. It was right around when I had met her. Again, I don't +recall the date, but I know that it was towards the beginning +of my - beginning to middle of my term there. +l. All right. So if the beginning of your term was the end of +1996 -- +A. Right. +l. - what, roughly, years are we talking about here, if you +can estimate? +A. Maybe late '90s, early 2000. +l. Okay. The best of your recollection? +A. Yeah. +l. All right. Let's discuss your observations of the +relationship between Epstein and Ghislaine. +As part of working in the office with Ghislaine, were +you able to observe Jeffrey Epstein and Ghislaine interacting + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 75 of 246 +- direct +2370 +with each other? +A. Sure. +Q. And when you first started in your job in 1996, what was +your impression of the relationship between Epstein and +Ghislaine? +A. I thought they were a couple. +Q. And what gave you that impression? +A. Just their interaction together. They were a little +flirty; and I just knew they were a couple, behaved like a +couple. +2. Did their romantic relationship change at all during the +time you worked for Epstein? +e. How so? +A. They just kind of went their separate ways. Seems like +Ghislaine moved on. I know that she started dating -- +MS. +: Objection. Foundation. +THE COURT: Sustained. +l. What, if anything, did you observe at the time that +indicated to you that the romantic relationship was changing? +A. Ghislaine started dating. +l. Dating other men? +A. Yes, other men. +l. Okay. Anything else? +A. Well, they would not show up at the office around the same + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 76 of 246 +- direct +2371 +time or leave together, things like that. +Q. Okay. And roughly when do you recall noticing that +Ghislaine was dating other men and not coming to the office as +much? +A. That would be probably the last two years of my employment. +Q. Now, you mentioned that Epstein had visitors come to his +office, right? +A. Mm-hmm. +l. And I think you said some of these were female. +A. Mm-hmm. +2. We've talked about Jane. But apart from Jane, how old were +these females who were visiting Jeffrey Epstein in the office +during your time there? +A. I don't know how old they were. +l. Roughly, how old do they appear to you to be? +A. Eighteen and over. Young women. +Q. And what contact did you see them -- withdrawn. +Do you remember some of the names of these women who +came and visited Epstein in the office? +e. Sorry? +A. I do remember. +Q. What names do you recall? +A. +¡ Jane, of course; + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 77 of 246 +- direct +Q. Well -- +A. There were others. +There were others, I just can't +remember. +Q. And what kind of contact did they have with Jeffrey Epstein +that you observed when they came into the office? +A. I didn't really observe the guests and him together too +often, because most of the time it was them being escorted to +his office. And the door would shut and they would visit in +his office, and I wouldn't see that. +e. Okay. Now, you mentioned +before. +l. Were you ever asked to do anything for +Q. What was that? +A. Send her flowers. +l. And what kind of flowers were these? +A. I recall an orchid at one time. There might have been +another bouquet another time. +2. Based on your -- the tasks you were given for her and your +observations of her, did you ever get the impression that there +was a romantic relationship? +MS. +: Objection, your Honor. +THE COURT: One-word grounds. +MS. +: Calls for speculation. +THE COURT: Overruled. +2372 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 78 of 246 +- direct +2373 +based on the tasks you were given for +and your observations of her with Epstein, what, +if any, sense did you have of their relationship with each +other, put it that way? +A. I felt like Jeffrey liked her very much; I felt like they +were a couple. They were -- yeah, they were together, a +couple. +Q. And did this happen either during or after the time when it +appeared to you that Ghislaine was in a romantic relationship +with Epstein? +A. I feel like it was at the very beginning of my employment, +so I - you know, being new, it could have been concurrent for +a little bit of time. +2. Do you know whether or not Ghislaine knew about, for +example, you buying the flowers for +A. No, she didn't know. +MS. +- Objection. +THE COURT: Just a moment. +I'll allow it. +l. Do you know whether or not Ghislaine Maxwell knew about you +buying flowers for +on behalf of Jeffrey +Epstein? +A. She did not know. +e. You also mentioned +before. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | + +- direct +2374 +l. Do you remember what nationality she was? +A. English. +Q. Did she speak in a British accent? +l. All right. I want to direct your attention now to the +final years of your employment, okay, so roughly 2000 to 2002, +all right? +Were Epstein and Ghislaine still involved in a +romantic relationship or was that over by this time? +A. I think it was over by that time. +Q. Was Ghislaine still working for Epstein at that time? +Q. Did her employment role for Epstein stay the same at this +time or did it change at this time? +A. Stayed the same. +l. Okay. Did she have as much involvement in his affairs or +were other people working for Epstein as well? +A. Well, there were other people working for Epstein. I don't +know. +Q. Let me ask this: How often was Ghislaine coming into the +office in the latter two years of your employment? +A. Not often. It started -- you know, at first it was almost +every day; then it became a few times a week; and then it +was -- towards the end it was full-time she wasn't coming into +the office. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 80 of 246 +- direct +Q. Okay. Was there anyone else who was in the office who, for +example, was sitting in the office where Ghislaine used to sit? +A. That would have been | +2375 +Okay. I want to show you what's already in evidence as +Government's Exhibit 327. +MR. EVERDELL: If we can put that on the screen. +THE COURT: You may. +MR. EVERDELL: Thank you, your Honor. +For the Court, deputy, the witness, and the jurors, +with the Court's permission. +THE COURT: It's a public document; correct? +MR. EVERDELL: It's not under seal, your Honor, as far +as I know. +THE COURT: Correct? +MS. I +|: I believe that's correct, your Honor. +MR. EVERDELL: We'll just confer with the government. +MS. +: Just take a quick look, your Honor. +It's fine, your Honor. Thank you. +THE COURT: Okay. So you can publish. +MR. EVERDELL: Thank you, your Honor. +So we'll also put it on the jurors' screens, if we +could. +BY MR. EVERDELL: + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 81 of 246 +- direct +2376 +do you see the person in that photograph, +Government's Exhibit 327? +2. Do you recognize who that is? +Q. Who is that? +A. That's +e. Do you remember -- +MR. EVERDELL: We can put that down now, with the +Court's permission. +THE COURT: Yes. +Thank you. +e. Do you remember when | +was hired, when she first +arrived? +A. I don't remember the date. +Q. Was it towards the beginning or towards the end of your +employment, if you know? +A. Towards the end. +l. Was it in the time period we're discussing now, 2000 to +2002? +Q. What was her job for Epstein? +A. I'm not sure what her job was, but she did accompany +Jeffrey around to the properties and was basically where he +was. I didn't really work with her much in the office, so I +don't know what her -- her job was. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 82 of 246 +- direct +Q. From your perspective, did she assist Epstein? +Q. Okay. Now, was she, in your mind, Epstein's assistant or +was she Ghislaine's assistant? +A. Epstein's assistant. +Q. Okay. +Who was Ghislaine's assistant? +A. I was still there. I was Ghislaine's assistant. +Q. Okay. Now, in the 2000s, did Ghislaine still travel with +Epstein to the properties? +A. I believe so. +l. Okay. Do you know, did she travel to Palm Beach +occasionally? +A. Sure. +Q. Did you help her arrange her travel when she traveled to +Florida? +A. Sometimes. +l. And when she traveled to Florida at this time, did she +always go to Palm Beach or did she go to other locations? +A. She visited other locations. +e. Where did she -- +A. Miami. +l. I'm sorry? +A. Miami, Florida. Miami. +Q. And how do you know that she was going to Miami? +A. Because she asked me to book a flight for her to Miami. +2377 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 83 of 246 +- direct +2378 +Q. Did you help her arrange where she stayed in Miami too? +A. I sort of recall, but I -- I -- it was a hotel. I don't +remember the name. +Q. Okay. But your recollection is you booked hotels for her +to stay in in Miami when she was traveling to Florida? +I also think she had a friend there that she may have +stayed in -- in the condo or whatever it was. +Q. +So when she was traveling to Florida around this time, was +she always staying at Epstein's residence or did she stay at +hotels? +MS. +: Objection. Foundation. +THE COURT: Sustained. +l. Fair to say you booked hotels in Miami for her travel to +Florida around this time, right? +A. Correct. +l. Now, you mentioned that Ghislaine was dating other men in +the 2000s, right? +A. Mm-hmm. +Q. Are you familiar with a man named Ted Waitt? +e. Who is Ted Waitt? +A. Ied Waitt is somebody that she dated and eventually became +a couple with. +l. All right. +And do you know who Ted Waitt was, what his job was? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 84 of 246 +- direct +A. I didn't know what his job was or who he was until I met +him personally after I had already left Epstein and Company. +Q. When did you meet Ted Waitt personally? +A. Boy. 2009, '8, something like that. I don't recall the +year. +Q. And was Ghislaine still with Ted Waitt as a couple at that +time? +A. +Yes. +Q. Okay. And that was how many years after you left your +employment with Epstein, roughly? +A. Maybe three years, something like that. +l. I think you said you left in 2002; is that right? +A. Correct. +Q. And when do you think you met Ted Waitt? +A. Before 2010. That's all I can really say. +Q. And why was it that you were meeting Ted Waitt at that +time? +A. For a job interview. +l. Okay. Did Ghislaine help to arrange that job interview? +l. Okay. And what was the job? +A. It was like an estate manager. +I. Did you end up getting the job? +A. No. +Q. Okay. Do you know if Ted Waitt had any children at the +2379 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 85 of 246 +- direct +2380 +time you met with him? +A. I don't -- +MS. +objection. +A. I don't know. +THE COURT: The response was "I don't know." +I'll allow that. +Move on. +l. And just jumping back, do you recall roughly when it was +that Ghislaine started seeing Ted Waitt as a couple? +A. Well, it was before I left in 2002. Maybe - +THE COURT: Could you speak into the mic? +A. It was before I left in 2002, so probably 2001 or so. +l. The best guess from your recollection? +A. Best guess. +THE COURT: Mr. Everdell, we'll break here for the +morning, unless - +MR. EVERDELL: Actually, if I could just have one +moment, your Honor. +THE COURT: Sure. +(Counsel conferred with defendant) +MR. EVERDELL: I think it's a good time to take a +break, your Honor, if we could. +THE COURT: How much longer do you anticipate? +MR. EVERDELL: I don't think I have very much, but I +just wanted the chance to confer. +THE COURT: All right. So we'll break for 15 minutes, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 86 of 246 +- direct +2381 +members of the jury. See you shortly. Thank you. +(Jury not present) +THE COURT: +step down and out +for the break. Thank you. +(Witness not present) +THE COURT: Counsel, matters to take up before the +break? +MS. +: Not from the government. +MR. EVERDELL: Nothing from the defense. +THE COURT: I'll see you in ten in case there's +anything to discuss before we resume. +(Recess) +THE COURT: Anything to take up? +MR. EVERDELL: Not from the defense, your Honor. +MS. +: Not from the government. Thank you. +THE COURT: All right. We can bring the witness back +and we can get the jury. +(Witness present) +(Jury present) +THE COURT: All right. +Thank you, members of the jury. +Mr. Everdell, you may continue with your direct +examination of +I remind you, you are under oath. +Go ahead, Mr. Everdell. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 87 of 246 +- direct +MR. EVERDELL: Thank you, your Honor. +2382 +BY MR. EVERDELL: +Q. +directing your attention again to the end of +your employment term, okay, in the 2000s, when -- the time +period when you said Ghislaine was moving on, right, did you +ever assist her during that time in hiring any other personnel +at the office? +A. I don't remember. +l. Who was taking care of the properties, Epstein's +properties, on a day-to-day basis at the properties? +A. +l. Did you ever assist in hiring any other people to help +assist with properties at that time? +A. Not that I recall. +l. Okay. But your recollection is that +managing the properties at that time? +was +A. Mm-hmm. +2. Speaking of +married? +do you know if she ever got +A. I heard that she got married. +MS. +|: Objection, your Honor. +THE COURT: Sustained. +The jury will disregard. +e. +this case, by the prosecutors? +were you ever contacted by the government in + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 88 of 246 +- direct +Q. And did you sit down for an interview with those +prosecutors in the case? +Q. Do you recall when that was? +A. I think it was during the summer of this year. +Q. Do you remember the first time you sat down with them? +Or +this may have been a videoconference? +A. It was a videoconference. +l. Do you remember when that videoconference occurred? +A. No. +Q. I want to show you something that may refresh your +recollection. Do you see the folder that's below you on the +floor next to the chair? +MR. EVERDELL: With the Court's permission, I'll have +her turn to 3501.063-002, which should be behind tab 2 of your +materials. +THE COURT: Ms. [ +, are you there? +MS. +: Yes, your Honor. +THE COURT: Okay. Go ahead. +l. Do you have that document in front of you? +Q. And if you could just 1o0k down at the bottom of the page +where there is some information on the left-hand side. Does +that refresh your recollection of when you had the +2383 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 89 of 246 +- direct +videoconference with the government? +A. Last year, I think. So repeat your question please. +Q. Does that refresh your recollection of when you had this +videoconference for the first time with the government? +A. Yes, well, there's a date on here. +Q. And does that generally refresh your recollection about +when this would have happened? +Q. Okay. And when did that happen? +A. November 2020. +l. Okay. All right. +Was that the only time you spoke to the government in +this case? +l. Okay. Question about Ghislaine. In the time that you +worked for Ghislaine Maxwell from 1996 to 2002, did you ever +see Ms. Maxwell pregnant? +A. No. +l. Ever were told that Ms. Maxwell was pregnant? +A. No. +2384 +MS. +: Objection, your Honor. +THE COURT: Overruled. +you said you left the job in roughly 2002; is +that right? +A. Correct. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 90 of 246 +- direct +Q. Why did you decide to leave at that time? +A. After 9/11, I had decided that it was time for me to move +back to my roots; wanted to be with my family. My brother had +his first child, and I just wanted to go back to where I came +from. +Q. And where was that? +A. California. +Q. Okay. When you left, did you continue to stay in touch +with Ghislaine after you left? +l. Looking back on your experience working with Ghislaine, +what are your impressions about the job and about Ghislaine? +A. I feel like Ghislaine was a very good resource for my own +career as far as experience and what I learned from her as far +as how to handle multiple projects at one time at a fast pace. +I think it helped me to get to where I am today in my job. +l. And what, if any, are your personal feelings and +reflections about your job? +MS. +: Objection, your Honor. +THE COURT: Sustained. +l. Besides your career path, are there any other reflections +you have on your experience with Ms. Maxwell? +MS. +: Objection. +THE COURT: Sustained. +Q. In the time -- +2385 +you are aware of the crimes + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 91 of 246 +- cross +that Ghislaine is accused of committing in this case? +Q. In the time that you worked for Ghislaine, did you ever see +her engage in any kind of inappropriate activity with underage +girls? +A. Never. +l. Did you ever see Jeffrey Epstein engage in inappropriate +activity with underage girls? +A. Never. +l. Did you ever see anything at all in the six years that you +worked for Ghislaine that gave you the impression that anything +like that was going on? +A. Never. No. +MR. EVERDELL: One moment, your Honor. +THE COURT: Okay. +(Counsel conferred) +MR. EVERDELL: I have no further questions, your +2386 +Honor. +THE COURT: All right. Ms. +MS. +: Yes. +THE COURT: Go ahead. +CROSS-EXAMINATION +BY MS. +l. Good afternoon, +A. Hi. +Briefly, your Honor. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 92 of 246 +- CrOsS +Q. You worked out of Jeffrey Epstein's Madison Avenue office +in Manhattan, right? +A. Correct. +Q. You did not work out of any of Jeffrey Epstein's homes, +right? +A. Correct. +l. You never went to Jeffrey Epstein's Palm Beach house, +right? +A. Correct. +MS. +: No further questions, your Honor. +THE COURT: Okay. Anything? +MR. EVERDELL: No redirect, your Honor. +THE COURT: All right. Thank you, +step down. You are excused. Thank you. +(Witness excused) +THE COURT: Mr. Everdell, the defense may call its +next witness. +MR. EVERDELL: Yes, your Honor. +The defense calls Mr. Raghu Sud. That's R-A-G-H-U, +2387 +S-U-D. +THE COURT: Okay. Mr. Sud may come forward. +RAGHU SUD, +called as a witness by the Defendant, +having been duly sworn, testified as follows: +THE COURT: Thank you. Mr. Everdell, you may inquire. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sud - direct +Filed 08/10/22 Page 93 of 246 +2388 +MR. EVERDELL: Thank you, your Honor. +DIRECT EXAMINATION +BY MR. EVERDELL: +Q. Good morning, Mr. Sud. +Just be sure to speak into the microphone so we can +hear your responses. +A. Good morning. +e. Thank you. +Where do you live, Mr. Sud? +A. East Windsor, New Jersey. +Q. How long have you lived there? +A. Since 2002. +2. Where do you work? +A. Shoppers Travel. +Q. What is Shoppers Travel? +A. It's a full-service travel agency providing airline +tickets, car rentals, hotels, and vacations to customers. +Q. How long has Shoppers Travel been a company? +A. Since 1988. +l. And when did you start working for Shoppers Travel? +A. Since 1988. +l. You were there when it started? +A. Yeah. +l. What is your current position at Shoppers Travel? +A. Vice president. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 94 of 246 +Sud - direct +2389 +Q. What are your duties and responsibilities in that position? +A. Overseeing day-to-day operation and interacting with +customers, +making travel bookings for them. +Whatever is +required to do. +l. Are you familiar with how Shoppers Travel bills or invoices +its customers? +Q. And how does that work? +A. When a customer calls, they ask for what they need. We +make up an itinerary or issue tickets according to their needs +and then charge their credit cards for that; or if they are +sending check, then take a check from them. +Q. And do you generate invoices as part of that process? +A. Yes, we do. +l. And what do you do with the invoices? +A. Invoices are sent to the customers. And we keep them and +put them -- enter in our accounting system, which is called +QuickBooks. +l. Is it QuickBooks? +A. Yeah. +l. Okay. And are you familiar with how Shoppers Travel uses +QuickBooks to keep its billing records? +A. Yes, I am. +l. Okay. And is that kept electronically? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sud - direct +Filed 08/10/22 Page 95 of 246 +2390 +Q. And do the QuickBooks records include information about the +invoices +that were sent +to the customers? +Q. How is the information from the invoices or any other +billing records input into the QuickBooks system? +A. According to each customer. It's different if it's repeat +customer. +We make up a profile for them and enter everything +under that name, even though they are different passengers, but +it's coming from one place. A request is made, then it's +entered accordingly, or it's individually entered with the +invoice numbers and the date. +l. Okay. And when is that information entered into the +QuickBooks system? +A. Either same day or next day. +Q. Same day or next day as what? +A. Of the transaction. +l. Okay. And are you able to search your QuickBooks database +for invoices and other billing records related to customers? +A. Yes, we can. +l. Okay. And how would you do that? +A. It all depends if we are doing it for a company which we +have made a profile, or a group we have made a profile for. +Then we put the profile name and run a report on it. +&. Okay. Great. +And does the QuickBooks system generate a report for + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +Sud - direct +2391 +that profile customer? +A. Yes, they do. +2. Okay. Do you ever have a profile for someone named Jeffrey +Epstein? +A. Yes, we do. +Q. Okay. +Was he a customer of Shoppers Travel? +A. His office was a customer, yes. +l. Okay. And did you have interactions with his office about +booking flights and other travel arrangements? +A. Yes, we did. +2. Did there come a time when you were asked to verify certain +records related to Epstein's office that you had at Shoppers +Travel? +A. Io verify, not as of yet. +Q. Okay. Did there come a time when you were asked to +generate a report from your QuickBooks system? +l. And when were you asked to do that? +A. In 2016. +l. Okay. And did there come a time when you were asked to +review that same report later on? +A. As of now, no. +l. How about this: I want to show you what's been marked for +identification as RS-1. And we'll put that on the screen for +the Court and the deputy and the witness for now. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Sud - direct +Filed 08/10/22 Page 97 of 246 +2392 +A. Yes, these are -- +Q. Before you say anything, let's make sure -- +MR. EVERDELL: Your Honor, may I inquire? +THE COURT: You may inquire. +e. Sorry to interrupt you, Mr. Sud. +Do you see what's marked in front of you as Defense +Exhibit RS-1? +A. Yes. It was a report run through us on -- like I said, in +2016. +l. Okay. So do you recognize that report? +Q. And what is that report? +A. It shows the invoice. It says the date of the invoice +issued, invoice number, name of the passenger, and the amount. +Q. And what customer is this report related to? +A. This was for file name Epstein. +l. And how do you recognize this document? +A. Because I was the one who ran it at that time. +2. And what years does this report cover? +A. Well, if you have all of it, this page which I'm looking at +it, has 2005, 2006. +l. Maybe if we could look now at the last page of the +document, which I believe is page 19. +Do you see page 19, Mr. Sud? +A. I do see. This is from '99. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 98 of 246 +Sud - direct +2393 +Q. Okay. So roughly the records between January 1999 and +December 2006? +A. Yes, sir. +Q. Okay. And are these -- is this a fair and accurate copy of +the report of invoice information that's related to Epstein +from -- during those dates that I mentioned? +A. Yes, sir. +Q. Now, was this report generated -- does this report contain +information that was added to the database at or near the time +that the invoices that are listed there? +A. I'm sorry, I didn't get the question. +l. Does the report -- does the information in the report about +the invoices, was it added to the database at or near the time +that the invoices reflect? +A. Like I said, it's always entered on the same day or the +next day. +l. Okay. And was the invoice information in this report added +to the database with someone who had knowledge of the +information on the invoices? +A. Yes, sir. +l. And was -- is it the regular practice of Shoppers Travel to +keep this information in its database? +A. Yes, sir. +l. And does this report summarize the invoice information +that's kept in the regular course of business at Shoppers + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +Sud - direct +2394 +Travel? +A. Yes, sir. +MR. EVERDELL: Your Honor, at this time the defense +offers what's been marked as RS-1 for identification. +MS. +Your Honor, no objection, provided it's +received under seal. +MR. EVERDELL: Yes, I should say that there are +personally identifying information of third parties, so we ask +for it to be received temporarily under seal so we can apply +appropriate redactions. +THE COURT: All right. RS-1 is admitted temporarily +under seal. And you can propose narrowed redactions as +necessary. +(Defendant's Exhibit RS-1 received in evidence) +MR. EVERDELL: Thank you, your Honor. +With the Court's permission, I will hand out copies to +the jury. +THE COURT: Okay. +MR. EVERDELL: Thank you. +With the Court's permission, I'll publish this to the +jury. +THE COURT: Ms.? +MS. +: No objection, your Honor. +THE COURT: Okay. The jury may open the folder and +take a look. It's RS-1, which has been admitted. + + +Document 761 Filed 08/10/22 Page 100 of 246 +Sud - direct +2395 +Q. All right. +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Mr. Sud, do you still have RS-1 in front of you? +Q. I'll just ask you a few questions about this document. +This is what comes from your QuickBooks system; +correct? +A. Yes, sir. +l. And you said this is for -- related to the customer Jeffrey +Epstein? +A. Yes, sir. +I. If we just look at the first page, you see the column that +says "type"? +A. Yeah. +2. What does that refer to? +A. It's an invoice. +l. Okay. And the date refers to what? +A. The date, when it was issued. +l. When the invoice was issued? +A. Yeah. +THE COURT: Mr. Sud, could I ask you to pull the +microphone a little closer to you. Thank you so much. +THE WITNESS: Okay. Sorry about that. +THE COURT: That's okay. +l. So the date is the date the invoice was issued? +A. Yeah. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 101 of 246 +Sud - direct +2396 +Q. And then number or num, what does that refer to? +A. The number of the invoice. +Q. And do you see where it says "name"? +A. That's the name of the passenger. +Q. Okay. I don't want you to say any of the names, but that +reflects the name of the passenger who the ticket was purchased +for? +Q. Okay. "Amount, " what does that refer to? +A. That was the amount of that particular invoice. +Q. Okay. And then balance, what does that refer to? +A. That's just a carry forward same number. If you keep +saying -- balance keeps adding up. +l. Okay. And again, these are records for Epstein from +January 1999 on the last page to December of 2006 on the first +page, right? +A. Yes, sir. +MR. EVERDELL: One moment, your Honor. +THE COURT: You may. +(Counsel conferred) +MR. EVERDELL: I have no further questions, your +Honor. +THE COURT: Ms. L +MS. L +: Very briefly, your Honor. +THE COURT: Go ahead. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 102 of 246 +Sud - cross +2397 +CROSS-EXAMINATION +BY MS. +Q. Good morning, Mr. Sud. +A. Good morning. +Q. Just to be clear, you began booking travel for +Mr. Epstein's office in 1999; is that right? +A. Yes, +Q. Okay. So you didn't book any travel for Mr. Epstein's +office before 1999? +A. +if we did, I do not have any records for that. +l. Okay. So the records that we're looking at in RS-1, those +begin in 1999 and run through 2006; is that correct? +A. Yes, +: Thank you very much. +Nothing further, your Honor. +MR. EVERDELL: No redirect, your Honor. +THE COURT: All right. Thank you. +Mr. Sud, you may step down. You are excused. +THE WITNESS: Thank you. +(Witness excused) +THE COURT: Mr. Everdell, the defense -- sorry, +jurors. Thank you. You may put your folders down. +Thank you so much. +And Mr. Everdell, the defense may call its next +witness. + + +Document 761 Filed 08/10/22 Page 103 of 246 +Loftus - direct +2398 +MR. EVERDELL: Turn it over to my colleague, your +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Honor. +THE COURT: Ms. Sternheim. +MS. STERNHEIM: Thank you, Judge. +The defense calls Elizabeth Loftus. +THE COURT: Okay. Elizabeth Loftus +. STERNHEIM: Judge, I have an exhibit. May I hand +it to the government and the Court and put it on the witness +stand? +THE COURT: Yes. +Good morning. +ELIZABETH LOFTUS, +called as a witness by the Defendant, +having been duly sworn, testified as follows: +THE COURT: Thank you. +MS. STERNHEIM: Judge, if I may. +THE COURT: Yes. Please just set that aside until +directed. Thank you. +1. STERNHEIM: Thank you very much. +DIRECT EXAMINATION +BY MS. STERNHEIM: +l. Good afternoon, Professor Loftus. +A. Good afternoon. +l. Please tell the jury why you are here today. +A. I am here as a professor and a scientist who studies human + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 104 of 246 +Loftus - direct +2399 +memory to talk about the nature of memory, the workings of +memory, how people can develop memories for things that didn't +happen or remember things differently from the way they +actually were, to talk about the work that I and other +scientists have done on false memories. +Q. Thank you, Professor Loftus. +Please tell the jury what your present occupation is. +A. I'm currently a professor at the University of +California-Irvine, the Irvine campus. My title is +distinguished professor. And I have appointments in a +department called psychological science, that's a psychology +department; I have an appointment in criminology, law, and +society, that's kind of a criminology department; and I'm also +a faculty member in the law school. +Q. How long have you been at UC-Irvine? +A. I joined the faculty in 2002, so it's coming on 20 years. +l. And prior to joining the faculty at Irvine, had you been on +the faculty of any other university? +A. Yes. Prior to UC-Irvine, I was a professor at the +University of Washington in Seattle for something like 29 +years. Prior to that, I spent a few years on the faculty at +the graduate faculty at the New School for Social Research here +in the city. And prior to that I was in graduate school. +l. Focusing on graduate school, please tell the members of the +jury what degrees you have academically. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 105 of 246 +Loftus - direct +A. Well, starting with college, I went to UCLA as an +undergraduate. +I majored in mathematics and psychology and +received my bachelor's degree in 1966. +After UCLA, I went to Stanford for graduate school and +received a +degree in psychology, followed by a Ph.D. +in psychology in 1970. +Q. Dr. Loftus, are you familiar with the term "curriculum +vitae"? +Q. And is the abbreviation for that a CV? +l. And please tell the members of the jury what a curriculum +vitae is. +A. Well, typically, it's a document that expresses your +educational background, career, publications, awards, honors, +your professional life. +l. And Dr. Loftus, do you, in fact, have a CV? +A. I do, yes. +2. And for what period of time does your CV cover? +A. Well, I think I have mentioned in there where I went to +college, so it goes back to the 1960s. And then just about +everything that's happened professionally since that time. +2. Professor Loftus, I'm going to ask you questions about your +background, research, education, etc. Would you benefit from +being able to look at your CV? +2400 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 106 of 246 +Loftus - direct +2401 +A. That would be helpful, yes. +MS. STERNHEIM: With the Court's permission, I would +ask that Dr. Loftus be permitted to look at her CV, which is +Defendant's Exhibit EL-1, a copy of which has been provided to +the government and the Court. +THE COURT: Marked for identification? +MS. STERNHEIM: Yes. +MS. +: No objection, your Honor. +THE COURT: She +. STERNHEIM: Thank you. +BY MS. STERNHEIM: +l. In addition to the degrees that you've just discussed, have +you ever received any honorary degrees? +A. I have received a number of honorary doctorates from +universities other than the ones I officially attended. +l. Of those universities, are they all in the United States or +elsewhere as well? +A. Some of them are in the United States, like John Jay +College of Criminal Justice, which is one of the honorary +doctorates. But I also have an honorary doctorate from a +British university, from -- actually, I think a couple of +British universities, from the University of Oslo, from Haifa +University in Israel. And I was supposed to be awarded an +honorary doctorate by an Australian university, Australian +National University, where I was supposed to go to the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 107 of 246 +Loftus - direct +2402 +commencement and receive it, but because of COVID, that hasn't +yet happened. +Q. Let's talk for a moment about any honors that you may have +received in connection with your professional capacities. +Could you please summarize them for the jury or +highlight those that you think are most significant. +A. Well, I don't know. That's kind of hard. It's like +which -- +l. Well -- +A. -- which baby is more important. +l. Let me stop you for a second. +A. Okay. +l. You are referring to your CV? +l. Approximately how many pages is your CV? +A. Well, the CV is 47 pages single-spaced. +l. Single-spaced. So it's rather dense; correct? +I. Well, I'm just going to ask you to highlight some of the +awards that you are most proud of for the jury. +A. Okay. Well, that would be page 2 or 3. Probably the most +prestigious of those awards is election to the National Academy +of Sciences. I was elected to the United States National +Academy of Sciences approximately 2004. And that is one of the +most prestigious things that can happen to an American + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 108 of 246 +Loftus - direct +scientist in a field that doesn't have a Nobel Prize. +Q. What are some of the other honors that you are especially +proud of? +A. I've received the two highest honors from the Association +for Psychological Science, an organization of primarily +academic scientific psychologists. I've received some lifetime +awards +even from the American Psychological Association, which +is an organization that has many clinical psychologists as +members. Those are some of them. +l. Is it fair to say you've received numerous awards, in +excess of dozens of awards? +l. And honors as well, correct? +A. I sort of lump them together, yes, sometimes. +l. Okay. With regard to your academic experience, do you +perform research? +l. And what kind of research do you perform? +A. Over the course of my career, I've done many hundreds of +experiments. And when I say "experiments, " these are +experiments that are conducted in my laboratory with my +graduate students or post-docs or sometimes undergraduate +research assistants, or they might be experiments that are done +outside in the field. And primarily these are studies of the +human memory; what happens after people have had some +2403 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 109 of 246 +Loftus - direct +2404 +experience, maybe recorded a little bit of information about +the experience into their memory, and are then exposed to some +new information that can potentially contaminate or distort +that memory. +l. In addition to the support that you received from the +universities of which you have been on the faculty and +supporting your research, have you received any fellowships or +grants that support your research? +A. Over the years, yes. My laboratory scientific experiments +have been supported by the National Science Foundation or the +National Institute of Mental Health or sometimes other +organizations or foundations that have provided the funds to, +excuse me, support that research. +l. In addition to research that you've conducted, have you had +occasion to consult with any government agencies? +A. I've consulted with many government agencies, yes. +e. Could you please share with the jury some of those agencies +that you've consulted with? +A. Well, I've consulted with the Department of Justice, the +Secret Service, the Central Intelligence Agency, the Federal +Bureau of Investigation, the Internal Revenue Service at +different points in my career. +l. With regard to the research that you conduct, are the +findings or your analysis of the experiments put into a report +generally? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 110 of 246 +Loftus - direct +A. +Generally, when we do an experiment or a set of +experiments, we will write up a scientific publication, submit +it hopefully to a peer-reviewed journal where it will undergo +peer review and then be published and be part of the scientific +literature so that it's available for other people to have +access +to. +l. Please, in a very simple fashion, describe to the jury what +the peer review process is. +A. Journals that are peer-reviewed journals generally have an +editorial board. Members of the scientific community that will +review a manuscript that has been submitted for publication, +will review that manuscript and will make recommendations to +the editor about whether this manuscript is worthy of being +published. Is it scientifically sound, is it sufficiently +interesting, is it appropriate for the journal, helping the +editor to make that - or should it be rejected, because it's +none of those things. +Q. In addition to your submission of your own reports to +peer-reviewed journals, have you had the occasion to serve on +the editorial boards of any peer-reviewed journals? +A. Well, over these years I've served on the editorial board +of many journals. And even today I am still on the editorial +board of a few journals. But over the years, many of the major +journals in the field of psychology. +Q. In the course of your career, have you been a member of any +2405 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 111 of 246 +Loftus - direct +2406 +professional organizations? +l. And give the jury just a sampling of what kind of +organizations those are. +A. Well, one of my primary organizations with which I +affiliate is the Association for Psychological Science. This +is an organization primarily of academic university research +psychologists, although there are many clinical researchers who +also belong to the organization. I was president of that +organization in 1998-ish. +I'm a member of the Western Psychological Association. +This is the organization in psychology that covers the western +region of the United States; so it's California, Oregon, +Washington, maybe Hawaii, and possibly some other states on the +west coast. And I was twice president of the Western +Psychological Association. +So those are just a couple of the organizations that I +affiliate with. +I've been president of a couple of the divisions of +the American Psychological Association in the past, like the +American Psychology Law Society, and have served in other roles +for other organizations, not president. +l. Moving on to publications. During the course of your +career, have you published articles and journals? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 112 of 246 2407 +Loftus - direct +Q. Can you approximate over the span of your career -- and let +me stop you for a minute. How many years would you say you +have been a psychologist in the field of memory science? +A. Well, at least since I got my Ph.D. in 1970. But I +actually published a few articles while I was still a graduate +student with my professors as coauthors. +Q. Well, let's begin at 1970. From 1970 to this year, 2021, +approximately how many articles, if you could estimate, have +you published? +A. Well, I've published over 20 books and probably over 600 +scientific articles and chapters. +l. And are all of them in your CV? +A. I believe just about everything I've published is listed in +the CV, and that's why it takes so many pages. +Q. In addition to the publications that you have discussed in +the books that you have written, have you also coauthored in +other people's books, such as chapters and textbooks and +otherwise? +A. Yes, I've coauthored a number of chapters, but that would +have been included in the 600 estimate that I've given you +already. +l. Okay. Now, I'd like to speak to you briefly about the +research that you've conducted. +Is it possible for you to approximate how many +research experiments you've conducted at least from 1970 to the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 113 of 246 +Loftus - direct +2408 +present? +A. I would just estimate hundreds of experiments involving +maybe 50,000 participants or more, but it's just a -- it's just +kind of an estimate. +l. Well, let's just focus on a few of those, if we might. +What stands out in your mind with regard to +experiments that you have done that have impacted the science +of memory? +A. I would say that one of the major contributions is the work +that I and my collaborators have done on the misinformation +effect on showing that after people see, say, a simulated crime +or a simulated accident, and they are exposed to some +misinformation about the accident or the crime that they saw, +that many people will incorporate that misinformation into +their memory and it causes an impairment in memory. False +swayed of the misinformation. It becomes their memory and +their memory becomes inaccurate. +One -- I guess you could call it a classic study, +because it's in many of the textbooks in psychology today is +one in which we show people a simulated accident, maybe a car +goes through a stop sign that's controlling the intersection. +And later on we expose our witnesses to misinformation that it +was a yield sign. Many people will now claim that they saw a +yield sign instead of a stop sign. So they have succumbed to +the misinformation in that new information that was presented + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 114 of 246 +Loftus - direct +2409 +to them and adopted it as their own memory. And that study was +published in 1978. +Q. Have you conducted any studies that have to do with +language and how language might affect memory? +An example of that would be -- again, this is also a +fairly widely cited study. +We showed people a simulated accident. Afterwards, we +asked people about the speed of the vehicles involved in the +accident. But different witnesses are questioned in different +ways. So some witnesses are asked a question like, How fast +were the cars going when they smashed into each other? And +others are asked, How fast were the cars going when they hit +each other? +And we found that people estimated the speed as +greater if you used the word "smashed" than if you used the +word "hit." Also we had found that if we use the smash word, +this leading kind of biased word, it affected what other things +that people remembered. Our witnesses were more likely to +that didn't exist if we had +remember, for example, broken +used that word smashed in questioning them. +So that's an example of what you're asking about, the +connection between language and memory. +2. In the course of your research and experience, are you +aware of any experiments that have actually measured emotion +and its impact on memory? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 115 of 246 +Loftus - direct +A. Yes, there is -- well, one study that's coming to mind +is - this is a study that we published somewhat later in the +2000s, maybe around 2008 or so, along with my former Ph.D. +student who is now professor of psychology, Dr. Laney. This +was a study where we -- we didn't just change memory for +turning a stop sign into a yield sign, but we planted entire +events into the minds of research witnesses, events that did +not happen. And then we measured people's emotional reactions +to these false memories. +So we planted false memories, for example, that you +witnessed your parents having a physically violent fight when +you were a kid or that you accidentally caught your parents, +you know, having sex when you were a kid. And once we +succeeded in planting these false memories and measured +people's emotional reactions, they were just as emotional about +these created memories as other individuals were who truly had +had those experiences. So the bottom line there was that +emotion is no guarantee that you're dealing with an authentic +memory. +l. Professor Loftus, in devising a research project, do you +need to gain approval from any organization or from your +university to permit you to engage in that experiment? +A. Yes, we do. Colleges and universities have human subjects, +review committees. And when we want to propose to do a study +with humans, there are separate groups that review studies with +2410 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +Loftus - direct +2411 +animals, but I am proposing studies with humans. It goes +through a process of review on the campus. And sometimes they +ask you to make modifications in your procedure; other times +they just outright give you the blessing to go ahead and do the +study. +Q. Is there a standard requirement that the experiment that +you're engaging in cause no harm to the participant? +A. Well, we certainly -- we certainly hope for -- yes, that +the -- when we're experimenting with human beings, that we are +not going to create any -- any harm in those participants. +Q. And does that requirement in and of itself limit the types +of experiments that you might otherwise choose to engage in? +A. Yes, it does. It does. So it might dictate what kind -- +in the case of my work on false memories, what kind of false +memory I would propose to plant in the minds of a research +participant. So I might want to plant a false memory that +something horrible happened that would have been traumatic if +it actually had happened, like you were, you know, attacked by +a vicious animal. And the human subjects review committee, +well, has been known to approve that kind of proposal. +But other kinds of studies that might be a little bit +more sensitive, the human subjects committee might feel a +little uncomfortable about approving, like a deliberate attempt +to - to plant a memory, for example, that your father, you +know, forced you to sacrifice animals or breed babies and kill + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 117 of 246 +Loftus - direct +those babies, something that you see in these claims of satanic +rituals, for example. +l. DI. Loftus, this is not your first time testifying, is it? +A. No, it's not. +l. Approximately how many times have you testified in a court +of law over the time that you have been a research scientist? +A. I've +testified in approximately 300 trials since June 3rd, +1975. +l. And in addition to giving testimony at trial, have you also +provided testimony at depositions? +l. Have you testified in civil cases? +l. Have you testified for both the plaintiff and the defense? +A. Many times, yes. +l. In connection with criminal cases, is it fair to say that +the majority, if not most, of your testimony is for the +defense; correct? +A. Well, I've only been asked to consult with the prosecution +maybe five or six times. But of those five or six times I've +consulted, only one time did the prosecution actually request +my testimony at trial; and I did testify for the prosecution in +that one case in Wisconsin. +l. I apologize. +Do you have any knowledge of why you have not +2412 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 118 of 246 +Loftus - direct +testified more often for the prosecution? +A. The prosecution is frequently the one that has -- is +putting on memory testimony and maybe wants to bolster that +testimony. And the testimony about memory distortion or the +potential for false memories is not something that typically +fits in their agenda. +2. With regard to the many hundreds of times that you've +testified, have you been declared as an expert in the science +of memory? +A. The vast majority of those 300 cases are testimony about +memory. Every now and then I have testified as an expert +witness on a slightly different issue, usually having to do +with human comprehension, but not necessarily memory, like how +people would understand warning labels, for example. +2. And is part of your expertise related to the impact of +memory on the brain? +A. I talk about memory and the processes of memory. It's the +neuroscientist who might be the ones who want to tell you about +the hippocampus and the amygdala and how it connects to the +parts of the brain. I know a little bit about that and I've +included material in some of my introductory psychology +textbooks about that; but I would defer to a different expert, +if you're talking about matters of neuroscience. +l. Well, with regard to memory though, have you testified +about these stages of memory as known in your field? +2413 + + +Document 761 Filed 08/10/22 Page 119 of 246 +Loftus - direct +2414 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +A. +yes. +Yes. +Q. Have +you testified with regard to the impact of post-event +information on memory? +A. Many times, yes. +(Continued on next +page) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 120 of 246 +Loftus - direct +2415 +BY MS. STERNHEIM: +l. And have you testified with regard to the construction or +reconstruction of memory? +MS. STERNHEIM: Judge, at this time, I would proffer +Professor Elizabeth Loftus as an expert in the field of memory +science, the nature of memory reconstruction, and the impact of +events upon memory. +MS. +: Subject to our earlier objections, +your Honor. +THE COURT: Consistent with my prior ruling, I +indicate Professor Loftus as an expert in the +you've +indicated. Go ahead. +MS. STERNHEIM: Thank you very much. +BY MS. STERNHEIM: +l. Professor Loftus, I just mentioned stages of memory. Can +you please explain to the jury what those stages are in the +study of memory science. +A. Yes. One of the things we know about memory is it doesn't +work like a recording device. You don't just record the event +and play it back later. The process is much more complex. And +we study the processes of memory, tend to divide that process +into three major stages. +THE WITNESS: And, your Honor, I don't know if it's +possible in this enclosure for me to illustrate this for the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 121 of 246 +Loftus - direct +jury, but it might help if I could use the equipment to +identify the three stages and -- +MS. STERNHEIM: Judge, the monitors have the capacity +to be used as a whiteboard and I would request that, for +demonstrative purposes, Professor Loftus be permitted to +demonstrate what she is discussing concerning the stages of +memory. +2416 +THE COURT: Ms. L +1. +MS. +: No objection, your Honor. +THE COURT: All right. If you can do it +technologically, go ahead. +I just go over and show professor +Loftus what we need to do to turn it on. I think we have our +able tech person to help us. Thank you. +Your Honor, I would ask the screen be visible for the +jury, the parties, and the public. +THE COURT: You +• STERNHEIM: +l. Professor Loftus, you may use the screen if it aids in your +testimony concerning the stages of memory. +A. So, typically, we start with the first stage, which is +called the acquisition stage. This is kind of -- and this is a +period where some event or events occur. That's the first +stage of the process. +But after that event or those events are over, now + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 122 of 246 +Loftus - direct +time is passing and we enter the second stage, and this is +called the retention stage. +After some time has passed, a +person might be asked to remember the event or the events, to +answer questions, to subject himself to an interview, to +testify. These are acts of retrieval where somebody is trying +to retrieve information about the event. +And so now we enter that third stage, which is the +retrieval stage. So our job as researches in this field is to +identify the psychological factors that come into play at each +of these three stages that can affect the accuracy of what +somebody is telling you. +Q. Let me stop you for a second. When you were referring to +the acquisition stage, you mentioned an event. In the category +of event, is it just something that one sees or can it be that +something that one actually personally experiences or hears? +A. Well, first of all, it could be just -- it could be what +somebody sees and hears. It can be a robbery, for example, +which somebody is seeing something and maybe hearing some +conversation, but it might just be memory from a conversation +or memory for some other experience that ends up being critical +where you would like to know what happened. +l. So one could actually be an observer or an actual +participant or a hearer, someone who hears something in that +acquisition stage? +A. Yes. Sometimes people, for example, are crime victims and +2417 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 123 of 246 +Loftus - direct +sometimes they're witnesses, and they're not the victim +themselves, but -- +Q. Now, after the acquisition stage, is anything that happens +after the event, whichever constitutes the event occurs, +considered retention stage? +A. Typically, yes. It's after the event is over, so we say, +well, that's the retention stage. I don't mean to complicate +things too much, but I think you can appreciate that actually +there can be many acts of retrieval. So there can be a long +retention interval peppered with different acts of retrieval. +But I used a simple diagram here to illustrate the three major +stages. +l. Can you simply identify what separate acts of retrieval +would be. +A. So after some event, say, you know, a robbery, sometimes +people might have a conversation with each other about what +they saw and then sometimes the police might come to the scene +and start asking questions about what did you see or what did +you hear, and then the person might go to a police station and +maybe try to make an identification of somebody who might have +been seen at the event, and then somebody may be interviewed +many more times, may then testify at trial. That would be a +standard situation in a legally relevant event. +2. Now, in each of those retrieval examples you just gave, +that is coming from an external source; correct? +2418 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 124 of 246 +Loftus - direct +2419 +Q. Is there the possibility of retrieval from an internal +source, meaning within the individual who is trying to recreate +the memory? +A. Well, in the example that I gave earlier with the stop sign +and the yield sign, we do suggest the misinformation +externally, we supply them with the misinformation. But +sometimes what happens with individuals is they draw inferences +about what might have happened or what could have happened or +what possibly happened and they can suggest things to +themselves. That's called autosuggestion where there is not +somebody deliberately suggesting something to you, not +deliberately trying to tell you, you know, I saw the thief and +he was wearing a +jacket instead of a +jacket, but +you, the witness, are drawing inferences that then start to +feel as if they're memories. +l. Going back to the acquisition stage, what would affect the +quality of one's acquisition of an event? +A. At the time of acquisition, the event itself, well, some +obvious thing, how good is the lighting, how far away are you, +how distracted are you, are you preoccupied thinking about +something else. Sometimes, if you're under the influence of +certain drugs. Marijuana is one that has been studied a lot, +for example, and we've studied it in a recent paper. That +could affect the formation of the memory in the first place. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 125 of 246 +Loftus - direct +2420 +Q. So in connection with the acquisition stage, there could be +external factors that can affect acquisition? +Q. And there could also be personal or internal factors that +could affect one's acquisition of information? +Q. Now, going to the retrieval stage -- +A. +Retention. +l. Well, retention would be -- +A. What would be next. +Q. What you hold from the experience; correct? +A. Well -- so, time is passing. I mean, the event is getting +older and older, and some other things are important in this +retention stage, and one of those things is whether or not a +person is exposed to post-event suggestion. If there is +post-event suggestion, maybe a little misinformation, it can +enter a witness's memory and cause a contamination, an +alteration, a distortion, or even a supplementation of memory, +and the longer that retention interval, the older -- the older +the event is, the more susceptible people are to having +post-event suggestion potentially contaminate their memory. +Q. It's fair to say that one does not need any degree +whatsoever to know that memory can fade over time; correct? +A. Correct - I think, yeah, that's kind of a matter of common +sense. But what's less a matter of common sense is that, as + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 126 of 246 +Loftus - direct +it's +faded and weakened, it becomes more vulnerable to +contamination. +2. Now, you spoke about post-event suggestion. Stepping back +for a moment and just using the term post-event information, +please tell the jury what that would be and what could +constitute such information. +A. Post-event information can happen when two people are +having a conversation with each other about the past and they +can influence each other. Post-event information can be +supplied when somebody is being interrogated, particularly, if +they're being interrogated with somebody who's got an agenda or +a hypothesis about what might have happened and communicates +that to the person they're interviewing, even inadvertently. +The media is a source of post-event suggestion that +we've actually studied where people are sometimes interviewed +on the media or media personalities will supply some suggestive +information that can contaminate memory. +Those are just examples of out there in the real +world, what are the opportunities for post-event suggestion to +become available to a person and potentially contaminate a +memory. +l. Have you conducted any studies or given any workshops with +regards to interviewing techniques and the effect on memory? +A. Well, that is typically what -- when I would be consulting, +for example, with the FBI or the Secret Service or even the +2421 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 127 of 246 +2422 +Loftus - direct +CIA, I would be talking about interviewing techniques and other +sources of potential post-event information that can +contaminate memory. That's part of what those lectures and +consulting is about. +Q. And in connection with an interviewing process, would there +be a difference between +asking what would be an open-ended +question +where the person being questioned provides the +information as opposed to, as we all know, what a leading +question is where the information may be provided and the +recipient of the question just answers yes or no? +A. Well, it's certainly open-ended questions give you, in some +sense, more accurate information. It might not be fully +complete, so you might need to follow it up with some specific, +more specific information or the closed-ended questions, and +you would like to have them be as neutral as possible so that +you don't contaminate the witness. But to get a little bit +more complete a version of what you're looking for -- but when +you ask leading questions like how fast were the cars going +when they smashed into each other, that's probably not a good +way to follow up an open-ended question. +2. Now, with regard to the process of questioning someone, +have you conducted any studies that show the impact of stress +in the interviewing environment? +A. I have -- no. Usually, when you talk about stress, it's +usually at the time of the event itself. It can be a very -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 128 of 246 +Loftus - direct +2423 +you've +seen a horrible traffic accident or something +particularly stressful happens to you. In terms of the stress +at the time of retrieval when you're answering questions, I'm +not sure, you know, to what extent that has been manipulated. +I'd have to think about that a little to see if I can think of +a study that might help you out there, but - +Q. Well, in addition to questioning someone, are there other +situations in which there can be the exchange of information +that can be suggestive to an individual? +l. Can you please give us some examples of that. +A. Sometimes when people are trying to retrieve information, +there is pressure to provide more, more details, more details +about some particular subject. I've seen that not only in law +enforcement interviews, but more often even in certain kinds of +psychotherapy. +l. Now, talking about psychotherapy for a moment, you told the +jury that you have a doctorate in psychology, but are you a +practicing therapist? +A. No. No. +l. Do you consult with patients in a therapeutic environment? +A. I don't do therapy, but I sometimes study patients. I +don't do therapy, though. +e. So you're not a psychologist who has a therapeutic +practice? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 129 of 246 +Loftus - direct +2424 +A. Correct. +Q. You just mentioned the suggestiveness at times of +psychotherapy. Could you please explain to the jury what you +mean with regard to that. +A. +Well, there are certain -- of course therapy can be +wonderful for many people, but there are some practices in some +psychotherapy where the therapist tells the patient that the +current problems are due to some buried memories of childhood +trauma and that they need to be recovered or retrieved in order +to heal the patient. Some of these patients -- some of these +psychotherapists have engaged in practices that have led their +patients to have false memories. +Q. But that certainly is not in every therapeutic environment? +A. No, absolutely not. +Q. Now, with regard to suggestiveness, are you familiar with a +concept called labeling? +l. Could you please explain to the jury what that means with +regard to memory. +A. There is a lot of classic work on labeling, which is if +you -- if a person sees something ambiguous and, later on, it +gets labeled with a particular label, that the individuals will +start to remember this ambiguous stimulus as something a little +closer to that label. +In one of the old classic studies, people saw a -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 130 of 246 +Loftus - direct +2425 +something that could vaguely look like it might be eyeglasses +or whatever, very ambiguous. If it got labeled as eyeglasses, +people remembered it as more like eyeglasses. If it got +labeled as dumbbells, people later remembered it as looking +more like dumbbells. That's just an example of how you can +label something ambiguous and it will affect people's memory +for what they saw. +Q. So if two people, let's say, are having a conversation +concerning an event, and one of the individuals characterizes +it in some colorful fashion that the other one may not have +considered, would that be a situation where the memory might +become labeled? +A. Yes, absolutely. In one of our older studies, we found +that labeling something as an +incident, which is really fairly +neutral, has a different affect than when you label the thing +that happened as a fight. People are more likely to construct +an image of a fight, probably because of that label. +Q. Are you familiar with the term memory traces? +A. Memory traces? +l. Yes. Or memory fragments? +A. Well, I suppose that every now and then somebody might talk +about memory fragments. Just, you would have a bit or a piece +of information in your memory. +l. And are you familiar with situations where someone might +take that bit of a memory and enhance it in some way? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 131 of 246 +Loftus - direct +2426 +MS. +objection, your Honor. +THE COURT: Grounds. +MS. +: Leading. +THE COURT: Sustained. +MS. STERNHEIM: Okay. I'll move on. +BY MS. STERNHEIM: +l. Are you familiar with the term forgetting curve? +l. Could you please explain to the jury what that means. +A. Yes. I hope in talking about the forgetting curve I'm not +violating any judge's order, but I will - +THE COURT: Jury will disregard the witness's last +comment. The witness will just direct her answers to the +questions posed. Thank you. +THE WITNESS: Okay. Sorry, your Honor. +e. So the forgetting -- +A. So the forgetting curve. If I were to plot how good is +memory as a function of how much time has passed -- +MS. +: Objection, your Honor. +THE COURT: Sustained. +MS. STERNHEIM: We'll move on. +l. Going back again to the concept of post-event information, +you spoke before about post-event suggestion. What would that +be? +A. Well, post-event information is sort of an umbrella term. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 132 of 246 +2427 +Loftus - direct +Post-event -- somebody could supply post-event information that +is accurate and that might cause somebody to supplement their +memory with accurate information. Post-event suggestion +typically refers to a situation where you're supplying people +with new information that is not particularly accurate. +Q. Memory has been +termed a constructive process; correct? +Q. Could you explain what that means to the jury. +A. What we mean by that is, as I testified earlier, we don't +just record events and play it back later like a recording +device would work, like a video machine, but rather, we are +actually constructing our memories when we retrieve memories. +We often take bits and pieces of experience sometimes that +occurred at different times and places, bring it together, and +construct what feels like a recollection. +2. With regard to the experiments that you have conducted, by +virtue of the experiment itself, you have proof of what would +form the basis of a memory; correct? +MS. +: Objection. +THE COURT: Just a moment. +Grounds. +MS. +_: Leading. +THE COURT: Sustained. +BY MS. STERNHEIM: +2. When you do memory research, is there a process in your +experiment that sets up a basis for a memory? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 133 of 246 +2428 +Loftus - direct +A. In some of the experiments, yes. So, for example, in the +study that I've testified about already, we show people a +simulated accident, so we know exactly what the event was, we +know what they saw and that way we can see how the post-event +information changes what they remember. +Q. And in contrasting that, which you just said you could see, +that would be different than somebody who just reports a memory +with no visual proof or documentation of it; correct? +A. Yes, then you don't have a record of what actually +happened. +Q. And somebody who might report a memory may give very vivid +detail; correct? +Q. And does the fact that someone reports a memory with vivid +detail mean that the memory is accurate? +A. No, because of false memories. Once they're constructed in +somebody's mind, either by external suggestion or by +autosuggestion, could be very vivid, detailed. People can be +confident about them, people can be emotional about them, even +though they're false. +2. So if somebody believes that they had an experience and +describes that experience, there is no way of proving that that +actually occurred? +MS. +: Objection. +THE COURT: Sustained. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 134 of 246 +Loftus - direct +2429 +l. Outside of the laboratory, is there any way of proving that +someone has an actual memory? +MS. +: Objection. +THE COURT: Sustained. +l. Does an experience that may contain some trauma make a +memory more reliable than one that does not? +A. Traumatic experiences compared to maybe more neutral ones +might be associated with certainly remembering, you know, the +core of what happened. You know that what you saw was a plane +crash and not a warehouse fire and maybe some core details, but +even traumatic experiences can be subjected to post-event +suggestion that can exaggerate or distort or change the memory. +Q. In the course of your research and experience, have you +done any experiments that have studied the confidence of +memory? +l. Can you please explain that to the jury. +A. Oftentimes, at retrieval, when somebody is answering a +question or reporting on what they remember from an event, they +might be asked to express the level of confidence, you know, +I'm pretty sure it happened, I'm very sure or what have you. +And one of the things we know is if the conditions are very +pristine, not a lot of -- not a lot of suggestion, not a long +period of time, they're a fair test, people are more accurate +when they're confident than when they're not confident. But + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 135 of 246 +Loftus - direct +2430 +the problem is when you have post-event suggestion or +intervention, people get very confident about their wrong +answers, and you can see that even wrong answers or false +information, false memories can be expressed with a high degree +of confidence. +Q. In connection with your experience and research, have you +ever come across the term, rich false memories? +l. Could you please explain to the jury what that means. +A. So going back, actually, to the typical eyewitness study, +witnesses see an accident, they really saw the car go through a +stop sign. Later on, you suggest it was a yield sign and many +people will succumb to the suggestion. You have changed a +detail in memory for an event that actually happened. +But somewhere around the 1990s, researchers from +around the world started to look at, could you plant an entire +event into the minds of people for something that didn't +happen, could you use enough suggestion that you would get +people to construct whole events, and we and others have +accomplished that, meaning other scientific laboratories, +planting false memories that -- well, as I mentioned, you +witnessed your parents have a physically violent fight or you +were attacked by a vicious animal, or you had a serious indoor +or outdoor accident, or you nearly drowned and had to be +rescued by a lifeguard, or you committed a crime as a teenager + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 136 of 246 +2431 +Loftus - direct +and it was serious enough that the police came to investigate — +all of these rich false memories have been planted in the minds +of otherwise healthy individuals. +THE COURT: Ms. Sternheim, we're going to break for +the lunch hour. +MS. STERNHEIM: That's great. Thank you. +THE COURT: Members of the jury, you'll have about an +hour for lunch. Thank you so much. Enjoy your lunch. + + +Document 761 Filed 08/10/22 Page 137 of 246 +Loftus - direct +2432 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Jury not present) +THE COURT: The witness may step down and out for the +break. Thank you. +Everyone may be seated. Are there matters to take up +before the break or just after the break? +MS. +: Not from the government. +MS. STERNHEIM: Not at this time, Judge. +THE COURT: Okay. You could step out, thank you. +THE WITNESS: Okay. +(Witness excused) +THE COURT: I just want to make sure we have clarity +on what needs to be resolved following the break. +On the prior inconsistent statements, I'm going to +spend my lunch looking through them, but I'm hoping there will +be consultation and stipulation in narrowing so that we can +really get down to where there is genuine disagreement after +you've had some discussion. +Is that everybody's understanding? +MR. +: That's fine with the government, your +Honor. +MR. EVERDELL: We will try to confer, see if we can +narrow the issues. +THE COURT: Okay. I don't know when you need +resolution of the un-narrowed issue, but my understanding is we +might hit that point today. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 138 of 246 +Loftus - direct +2433 +MR. EVERDELL: Your Honor, yes. This does create a +bit of a timing problem because it's possible we would get to +the witnesses where these issues would come up, so -- +THE COURT: All the more reason to work it out. +MR. EVERDELL: Very true. And if -- well, I guess +we'll address if we can't work it out with the Court when we +come back. +THE COURT: Okay. Were you going to offer something +there, Ms. +? +MS. +: No, your Honor. I saw something pop +up on the screen. +THE COURT: All right. We'll come back. We're going +to need to come back early I think to get to some resolution if +we need to. +And Mr. +, you're going to confer on that so +that we can have that testimony ready when it's time? +MR. +: We'll confer on the details about how +to make that testimony happen. My understanding is the Court +hasn't resolved the pending motion to preclude the testimony in +full. +THE COURT: Right. I wanted to know what timing we +were talking about for that so that I can look at the papers. +MR. +: We'll confer with defense counsel about +that. +THE COURT: My quick skim of the papers this morning + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 139 of 246 +2434 +Loftus - direct +was that there had been some narrowing there, as well; right? +MR. +That's the government's understanding +of the defense response, yes, is that it's narrowed to a few +paragraphs of the affidavit. +THE COURT: A few paragraphs of the affidavit. Okay. +So I will focus my attention on those few paragraphs of the +affidavit and try to come back with resolution after lunch if I +can. If not, end of the day -- is it fair to assume we're not +going to get to that today? +MS. STERNHEIM: That is correct, Judge. If we were to +get there, we would have to do all the logistics about the +Webex and I also would need to see if Mr. +is up to it, +physically. +THE COURT: Well, you should make that call -- +MS. STERNHEIM: I am doing that -- +THE COURT: Because it will either be today or +tomorrow; right? +MS. STERNHEIM: Yes. +THE COURT: Okay. And then what else do I need to +consider? Anything else? +MS. +: Not from the government. +THE COURT: About how much longer on Professor Loftus? +MS. STERNHEIM: With the lunch break, much shorter. I +don't expect to be very long and I would like to trim it so +that we can move on. + + +Document 761 Filed 08/10/22 Page 140 of 246 +Loftus - direct +2435 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: And then who's next? +MS. STERNHEIM: I think we need to have a conferral +about that. +MR. EVERDELL: It will either be Richard Barnett or +Michael Aznaran from Customs and Border Protection. +THE COURT: Okay. It's 1:03, we'll meet in 45 +minutes, so that's 1:50. +See you then. +(Recess) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 141 of 246 +Loftus - direct +2436 +AFTERNOON SESSION +2:05 p.m. +THE COURT: Okay, where are we? +MS. MENNINGER: Your Honor, the government and I spoke +over the break. We appreciate how lengthy two of the witness's +prior inconsistent statement contentions are. +We were unable, +in this amount of time, to try to reach agreement on all of +them. The witnesses that pertain to those two would be +testifying tomorrow. The one that pertains to Carolyn is here +from out of state and would be testifying this afternoon. So +our joint proposal, I think, would be to address right now the +Carolyn prior inconsistent statement so that witness could +testify or be released this afternoon and then, at the close of +court this afternoon, for us to sit down with the testimony and +try to reach agreement on the two related to Jane and Annie. +MS. +: That's correct, your Honor. I believe +there are only three statements at this point in dispute +regarding Carolyn, so I think we can resolve that pretty +quickly. Mr. Pagliuca, I believe, has the list of the three +that I believe are in dispute. +MR. PAGLIUCA: Yes, your Honor. The two that are +agreed to are at transcript 3610, 9 through 15 -- I'm sorry. +Not 36. I have 35 numbers in my head. 1610, lines 9 through +15; 1611, lines 1 through 5. Those correspond to the following +statements in the 302. + + +Document 761 Filed 08/10/22 Page 142 of 246 +Loftus - direct +THE COURT: I have them. And have you agreed on how +2437 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +they come in? +MS. +Your Honor, we've offered to stipulate to +what the 302 says. My understanding is that the defense +prefers a live witness, but we have offered to stipulate to +exactly what the witness would testify to if they wish. +MR. PAGLIUCA: The witness is here, your Honor. It +will be quicker just to put on the testimony than to draft up a +stipulation and read it into the record. So I think that's +what makes sense to me. +THE COURT: I mean, I can't force a stip. I can +strongly encourage when it makes sense. All right. +And then what's next? +MR. PAGLIUCA: The ones that are in contention, your +Honor, are transcript trial testimony 1564, lines 4 through 7, +and page 1565, 18 through 23. +THE COURT: Let me just get my eyes on it. Okay. Go +ahead. +MR. PAGLIUCA: That corresponds to 3505, 005, page 1, +second paragraph, the inconsistent statement is, +approached Carolyn at a party and asked her if she would like +to make $300." +THE COURT: So what's in dispute is whether it was at +a party or at the +house? +MR. PAGLIUCA: Correct. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 761 Filed 08/10/22 Page 143 of 246 | +2438 +Loftus - direct +MS. +Your Honor, we believe that's collateral, +and extrinsic evidence isn't appropriate on a collateral +matter. +THE COURT: And also, the quote was read in court, +wasn't it? +MS. +Yes, your Honor. +THE COURT: I'll sustain the objection to that one. +MR. PAGLIUCA: The next is 1567, lines 7 through 19. +THE COURT: Okay. Just give me one moment. +MR. PAGLIUCA: Sure. +THE COURT: Okay. +MR. PAGLIUCA: And the prior inconsistent statement is +at 3505, 005, page 1, second paragraph. +explained +Carolyn could make $300 by providing a man in Palm Beach with a +massage. +MS. +: Your Honor, our view is that the relevant +portion was read into the record and then, at lines 23 of 1567 +through 2 of 1568, she was asked specifically whether she made +that statement to the FBI and she responded, yes, she told me +that. So I don't see how extrinsic evidence would be +appropriate. +MR. PAGLIUCA: I think it's inconsistent, your Honor. +There is a denial and then there is a yes, she told me that, +and I think with that inconsistency, we should be allowed to +impeach it. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 144 of 246 2439 +Loftus - direct +THE COURT: Yes, she told me that, and that's what you +told the FBI, yes, I told you that. Sustained. +MR. PAGLIUCA: The next one that's on the chart, your +Honor, is not at issue. +THE COURT: Okay. +MR. PAGLIUCA: So I think that resolves it with the +Court's rulings. We're down to the two that have been agreed +to. +THE COURT: Okay. So that gets us what we need for +now and you'll keep working with respect to the other two +witnesses; correct? +MS. +: Yes, your Honor. +THE COURT: Great. What else? +MR. PAGLIUCA: I don't know if the Court -- well, the +Court does not need to address this, but I conferred briefly +with the government about the government's proposed rebuttal +expert. I'm prepared to file something related to that, but +they may not be calling the rebuttal expert, so we'll deal with +that later. +THE COURT: Let's do what we need to do in the +immediate and then it sounds like we could do that by written +submission if we need to. +So the +• issue, I'm trying to get my head +around. So let me just ask, make sure I understand. I'm +looking at the affidavit of Mr. +This is you, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 145 of 246 +Loftus - direct +2440 +Mr. Everdell? +MR. EVERDELL: I have an update on his availability. +I think the substance is Ms. Sternheim. +THE COURT: Okay. +MR. EVERDELL: But as to his availability, we were +able to make contact with him and he can do a Webex today or +tomorrow, we just have to let him know when. I don't think +we'll be able to get the technology set up today, but he is +available tomorrow. +MS. STERNHEIM: Judge, I would just say that because +of his condition, I have not been able to speak with him and I +would like an opportunity to at least talk to him before we put +him on. So my preference would be to make him the first +witness tomorrow morning because of the time difference. +THE COURT: Okay. I think that's fine. Now let's +figure out if we're going to hear from him. +So I'm looking at the declaration. And you've +narrowed to paragraphs — tell me, Ms. Sternheim. I think it's +17. +MS. STERNHEIM: Let me just confirm with my +colleagues. +Judge, I need to access the letter that was filed +earlier this morning. +THE COURT: I guess since perhaps we take this at the +end of the day. I don't want to have the jury -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 146 of 246 +Loftus - direct +2441 +MS. STERNHEIM: I'd appreciate that so that I can have +all of the documents in front of me. +THE COURT: Okay. +MS. STERNHEIM: Thank you very much. +THE COURT: Just so I can marinate on it. So the +basic idea is that you want this witness to testify about one +or two conversations that he had with this witness, who we're +calling +, the one or two conversations that he had with +in which -- and his proffered testimony is that, at one +point, +said, regarding the subject of Jeffrey Epstein, +that it, quote, fell right into my lap. +MS. STERNHEIM: That's correct. +THE COURT: Let's start with that one. What is the +purpose for which it is being offered? +MS. STERNHEIM: It certainly shows motive and bias on +the part of +There is a monetary issue here. That is not +the statement of someone who feels that they are a victim as +much as they feel -- it suggests that it's an opportunity that +is anything but placing her in the category of victim. It +sounds more like someone who is interested in a windfall. +THE COURT: So broadly stated, the purpose for which +it's being offered? +MS. STERNHEIM: Is her bias and motive. +THE COURT: And the government's objection? +MR. +: The government's objection is that this + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 147 of 246 +Loftus - direct +is a collateral matter. It doesn't go to bias or impeachment. +That -- +2442 +THE COURT: Is that a 401 objection? +MR. +: Well, it's not a form of impeachment of +testimony. So I guess it's 401 or it's not within the +common law motion to show bias or motive. It is not probative +on the question of any monetary incentive by +whatsoever. +There is no mention of money, no suggestion of her motive for +doing anything in that sentence. It's very difficult to parse, +without the witness's speculation, about what he thought | +might be referring to, which is it's certainly objectionable +and irrelevant testimony. +THE COURT: I wouldn't permit that. I guess the +question is just the recounting of what he said, she said, it +fell into my lap. +MR. +: Right. +THE COURT: So I think you mean that's -- I think it's +a 401 objection. +MR. +|: It's a 401 objection, your Honor, and +we think it's extrinsic evidence on a collateral matter because +it's not impeachment about any of the core subjects. She was +asked about that on cross, she denied the statement. Her +denial can't be impeached with extrinsic evidence. +MS. STERNHEIM: Judge, it's my understanding that +motive and bias can be attacked in this manner. The witness + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 148 of 246 +Loftus - direct +said no and we have a witness who says otherwise. To let it +just stand is only her statement, which we have the ability to +contest. +2443 +MR. +: That would only be true if it went to +bias and motive, which it doesn't for the reasons I've +explained. As the Court is aware, I think we had this +conversation at a sidebar during +testimony when +Ms. Sternheim had this declaration and we all agreed this is a +collateral matter at that time. +MS. STERNHEIM: Judge, collateral during the testimony +of that witness. Having another witness to counter what that +witness says elevates it to another category. +MR. +: It's impeachment with extrinsic +evidence, whether that extrinsic evidence is a declaration or +live testimony by a witness. +THE COURT: It's not just the impeachment, it's not +just the question of did she say it or not. Although, there is +that impeachment embedded in it. But there is just the +testimony itself and the question is whether that's relevant +evidence of bias or motive; right? Isn't that the analysis? +MR. +: I didn't understand the defense to be +offering this as affirmative evidence of bias or motive, just +as impeachment for those reasons. The defense has never turned +this over in Rule 16 discovery, for example, which they would +do if it was part of their case in chief because they were + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 149 of 246 +Loftus - direct +making an argument about witness bias, which is just, you know, +we're not raising a Rule 16 objection, it's just to show the +purpose for which this testimony is being used is extrinsic +evidence to impeach +testimony. +MS. STERNHEIM: The papers that we filed last night +specifically state the basis upon which we are seeking to +introduce this. I made this available at the time of the +testimony. It is dated at a time that occurred during the +course of the trial related to the testimony of their witness. +I don't see why it is a Rule 16 violation -- +THE COURT: Well, I think they're not actually arguing +2444 +that. +So, Mr. +,, for the proposition that the denial +can't be impeached by extrinsic evidence, cited Second Circuit +case, United States v. Harvey, 547 F.2d 720, "...that a cross +examiner is not required to, quote, take the answer, end quote, +of a witness concerning possible bias, but may proffer +extrinsic evidence, including the testimony of other witnesses +to prove the facts showing a bias in favor of or against a +party. +You agree that's the law, you're just saying that +there is not an available inference to the jury of bias from +the "it fell into my lap." +MR. +: That's right, your Honor. That +inference only becomes available when that statement is + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 150 of 246 +Loftus - direct +2445 +surrounded by the speculative mental impressions of the +witness, which are not admissible evidence. And the statement +on its own says almost nothing is an out of context statement +from which, on its face, doesn't say anything about | +motives or financial interests in anything. +MS. STERNHEIM: Judge, can the government really, with +a straight face, say that a victim would say, "It fell into my +lap." I think it goes to the weight that the jury wants to +give to it and I think that it is appropriate affirmative +testimony to be put on in a defense case. They can make +whatever arguments they want, they can cross examine +Mr. +,, but to exclude it on that basis I think is just +wrong. +THE COURT: I mean, I think we've settled on the +analytical framework, which is we agree, following Harvey, if +it is extrinsic evidence, to show bias in favor of or against a +party, it's permissible; right? +MR. +: Yes, we agree. +THE COURT: So it's really a 401 question. Is there +an available inference to the jury, if they believe +Mr. +1, that the witness said that +said, "It fell +into my lap, " if that goes to bias. I think there is an +available inference to the jury. I won't let Mr. +go +beyond and speculate as to meaning. +MS. STERNHEIM: Understood. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 151 of 246 +2446 +Loftus - direct +THE COURT: So what else beyond that? +MS. STERNHEIM: There is the statement that l +told +him that the case against Ms. Maxwell was getting stronger +because the women were strengthening their stories. +THE COURT: Okay. Mr. +MR. +So a few concerns about this one, your +Honor. +This one sort of doesn't attempt to be a quotation from +so we don't know the sense in which it's going to be +viewed with mental impressions from. Mr. +is not a +statement that +was asked about on cross examination. +THE COURT: Pause on that point. Tell me the legal +basis for the pertinence of that. +MR. +: Well, to the extent that they are -- I +guess if they're offering it solely to show bias or motive, +then that wouldn't be necessary. If they're offering it as an +inconsistent statement with her other statements that she did +give on direct, that would not be available since they didn't +challenge her with a statement. +THE COURT: This is why I keep asking what's the +framework, because -- +MR. +: If this is the bias framework again, it +wouldn't matter -- +THE COURT: Is that the same contention? +MS. STERNHEIM: Yes, Judge. +THE COURT: So then we have the 401 question. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 152 of 246 +Loftus - direct +MR. +: It's the same 401 question, although +this one is even more attenuated from any notion of bias or +motive since it says nothing about her incentives or why she is +testifying. She could be testifying for literally or +cooperating with the government for literally any reason and +make the same statement. It sheds no light on her motives or +biases. +2447 +MS. STERNHEIM: It sheds light on her knowledge that +she knows what the other accusers are doing. +MR. +: That is not a motive or bias objection. +THE COURT: I think that's right. I'm inclined to +sustain on that one on the 401 ground. Okay. +So I think we're limited to the first question. So +you'll work out -- +MR. +: We've been conferring and will work out +a way for Mr. +to testify on that point. +THE COURT: All right. We can bring in the jury? +MR. +: Nothing else from the government. +THE COURT: Ms. Sternheim. +MS. STERNHEIM: Ready to proceed. +THE COURT: We'll get the witness and +will get the jury. +(Witness present) +You may take off your mask. Thank you. +(Jury present) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 153 of 246 +Loftus - direct +THE COURT: Thank you, everyone. I hope you had a +pleasant lunch. We're going to continue with the direct +examination of professor Loftus. +Professor Loftus, I remind you, you are under oath. +2448 +•. STERNHEIM: Thank you. +BY MS. STERNHEIM: +l. Professor Loftus, before we broke for lunch, I was asking +you, had you been involved in any research that dealt with the +correlation between the certainty of confidence that one has +and whether the memory itself is accurate. Do you recall that? +A. Yes, I believe I answered the question. Yes. +l. And are you familiar with the concept that confidence is +malleable? +l. Can you please explain what that means to the jury. +A. People can express a level of confidence and if they then +get some new information, for example, confirming information, +something that confirms their recollection, it can increase -- +sort of artificially increase their confidence in what they're +saying. +So, for example, in some research, primarily research +done by one of the most prominent people in this field, +Professor Wells from Iowa State, individuals would make an +identification at a lineup and then be told -- and express some + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 154 of 246 +Loftus - direct +confidence like, I am pretty sure that's the guy. They get +some new +information, that's our suspect, or some other +confirming information and it increases their confidence in +their recollection. And that's confidence malleability. +Q. Are you familiar with the concept of prestige enhancing +memory distortion? +A. Yes, I am. +l. Could you please explain to the jury what that means. +A. So one of the things that memory scientists have discovered +about memory distortion is that we humans frequently remember +ourselves in a better light than perhaps is accurate. So there +are studies showing that people remember their grades were +better than they really were, that they voted in elections they +didn't vote in, that they gave more to cater than they really +gave, that their kids walked and talked at an earlier age than +they really did. These are prestige enhancing memory +distortions that people routinely make when they're not +deliberately lying, but maybe it makes them feel a little +better about themselves. +2449 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 155 of 246 +Loftus - direct +BY MS. STERNHEIM: +l. Earlier today I asked you various questions concerning the +context of your curriculum vitae, you remember that? +l. Fair to say that we didn't go into great detail about it; +correct? +A. Well, no, not great detail. +Q. And there was much more that you could have told the jury +about it, but it would be time-consuming, wouldn't it? +A. It would, yes. +MS. STERNHEIM: Judge, at this time I would move into +evidence Judge Loftus's CV, which is EF-1. +MS. +: Objection, your Honor. +THE COURT: I'm sorry? +MS. +: The government objects. +THE COURT: Overruled. EF-1 is admitted. +MS. STERNHEIM: Thank you. +(Defendant's Exhibit EF-1 received in evidence) +BY MS. STERNHEIM: +l. Professor Loftus, just to be clear, you are being +compensated for your time; correct? +A. I am, or I hope so, yes. +2. I hope so, too. +You don't have any stake in the outcome of this trial, +2450 +do you? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 156 of 246 +Loftus - direct +2451 +A. No, I don't. +l. The testimony that you give on memory science would be the +same regardless of what party called you; correct? +A. That's correct. It would depend on the facts of the case +and where it was appropriate; but whatever party wouldn't +matter. +l. And what is the hourly rate that you're charging for your +time? +A. Well, I'm currently charging in this case $600 an hour for +my time, which was the rate that I quoted when I was retained +back in January. +l. Thank you. Just a few more questions. +You testified earlier this afternoon about media being +a post-event information source; correct? +l. Now, media isn't just limited to the printed page; correct? +A. No. It's television, social media, newspapers, podcasts. +l. And dramatic portrayals would be a source of post-event +information, would it not? +A. Books and movies, yes. +e. Okay. Thank you. +Now, we've talked earlier about suggestion. And +you've talked about studies in which memories have been +implanted in your subjects. The implanting of information +either in your laboratory or outside of your laboratory in the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 157 of 246 +Loftus - direct +form of post-event information can be intentional or +inadvertent; correct? +A. Correct. Of course, in my studies or the studies of other +scientists, we do it deliberately in order to study what +happens, what changes it leads to. But out there in the real +world, it doesn't necessarily happen deliberately that people +are deliberately trying to mislead other people. It can happen +inadvertently. +l. Have you conducted any research or are you aware of any +research that has indicated that secondary gain or motive may +impact the retelling of an event? +A. Well, there is some work on motivated false memories. +People do seem to be more willing to accept suggestions when +it's going to fit with their -- with their prior beliefs or fit +with some motives. I'm not sure I know any specific study that +sort of shows if people are offered money for a particular +memory, that they are more likely to give it to you, but it +certainly seems plausible. +l. In any of the studies that you've conducted, has there been +an analysis of who provides the post-event information, meaning +someone who you trust as opposed to someone you don't trust? +A. Yes. There are several studies that are in the literature +on the source of the post-event information. And just in +brief, what people find is -- what researchers find is that +people are more likely to accept suggestive post-event +2452 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 158 of 246 +2453 +Loftus - direct +information if it comes from somebody they trust or if it comes +from somebody who seems knowledgeable rather than somebody who +seems like they're trying to bias you for nefarious reasons. +So the source of the post-event information does matter. +There's even one study with children that shows that +young children are more likely to accept suggestions from +adults than from other children. +Q. And in looking at memory, is there any way for you to tell, +based upon your training, experience, and research, whether a +memory is real or the product of post-event information? +MS. +: Objection. +THE COURT: Sustained. +l. Just going back for a moment, you spoke about post-event +information and post-event suggestion. What is post-event +contamination? +A. Post-event contamination would be a situation where there +was suggestive information that maybe led to a contamination. +You could have post-event suggestion and have people resist the +suggestion. But I think if I were going to use the term +"post-event contamination," it would mean that somebody was +exposed to the suggestive information and it actually +contaminated them. +I have a moment, Judge? +THE COURT: You may. +(Counsel conferred) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 761 Filed 08/10/22 Page 159 of 246 +Loftus - cross +2454 +MS. STERNHEIM: Thank you, Professor Loftus. +THE COURT: All right. Thank you, Ms. Sternheim. +MS. +MS. +Thank you, your Honor. +CROSS-EXAMINATION +BY MS. +e. Good afternoon. +A. Good afternoon. +l. I believe you testified that in addition to being a +researcher, you often serve as a consultant, right? +l. And that entails consulting with lawyers about cases, +right? +2. And sometimes it involves testifying at trials? +A. Correct. +Q. So let's first talk about consulting. +You consult with attorneys in criminal cases, right? +l. And you've consulted with attorneys hundreds and hundreds +of times, right? +2. You've consulted with defense attorneys in criminal cases +hundreds of times, right? +A. Probably, yes. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 160 of 246 +Loftus - cross +2455 +Q. About 1,000 times? +A. Well, I don't know about 1,000, but hundreds of times. +Q. Okay. And of those hundreds of times, you've consulted +with the prosecution about five or six times, right? +A. That's approximately the number of times I've been called +by prosecutors to consult, yes. +Q. I want to talk about your trial testimony. +You testified earlier that you have testified in about +300 trials, right? +A. Approximately, yes. +l. About half of those trials are criminal trials, right? +A. It's an estimate, but let's say roughly half, yes. +l. Okay. So you've testified in about 150 criminal trials, +right? +A. Approximately, yes. +l. And of the 150 times that you've testified at trial, you've +testified for the defense every single time but once, right? +A. Correct. +2. And that one time that you didn't testify for the defense +was in the 1990s, right? +A. It was a case in Wisconsin is what I remember. I think it +might have been the '90s, yes. +l. So it's fair to say that you've made a career out of being +a witness for the defense, right? +A. In criminal cases it's predominantly been testimony for the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 161 of 246 +Loftus - cross +2456 +defense, yes. +l. You wrote a book about some of your experiences testifying +at trial, right? +A. Yes, I did, 1991. +l. You wrote a book called Witness for the Defense, right? +A. Correct. +l. You haven't written a book called Impartial Witness, right? +MS. STERNHEIM: Objection. +THE COURT: Overruled. +A. I don't have a book by that title, no. +l. I'm holding up what's been marked for identification, +Professor Loftus. Can you see that? +A. I had eye surgery about six weeks ago and I can sort of see +it. +Ms. +THE COURT: You l +: Thank you, your Honor. +THE COURT: After showing it to the defense. +MS. STERNHEIM: No need to see it. +THE COURT: When you return to the podium, +you'll give an identification mark please. +| Yes, your Honor. +It's been marked for identification as Government +MS. + +THE COURT: Okay. +Q. That is your book, Witness for the Defense, right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 162 of 246 +Loftus - cross +2457 +Q. That's a photo of you on the cover, right? +A. Very old photo, yes. +Q. Okay. And in your book, Witness for the Defense, isn't it +true that you wrote: Should psychologists in a court of law +act as an advocate for the defense or an impartial educator? +My answer to that question, if I am completely honest, is both. +A. Could you refer me to the page number? +l. Sure. It's on page 238, I believe it's Government Exhibit +1518. +MS. +: Your Honor, I have a binder with +materials that I'm happy to provide at this time if that would +be helpful. +THE COURT: Okay. +A. I've turned to page 238. +THE COURT: Do you have for the defense? +MS. +: Yes. +THE COURT: Okay. +l. Dr. Loftus, I believe there is a binder now that you have. +The book works as well, but it is marked as Government Exhibit +1518. And the question I had asked was in your book Witness +for the Defense, isn't it true that you wrote: Should +psychologists in a court of law act as an advocate for the +defense or an impartial educator? My answer to that question, +if I'm completely honest, is both. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 163 of 246 +Loftus - cross +It's just a yes or no, is that what you wrote? +A. That is a quote, but it leaves out the context of -- in +which that quote is quoted. +Q. Professor Loftus, when you testify at a trial, you don't +sit in the courtroom when you're not testifying, right? +A. I don't usually. +Occasionally I do. +l. You were not present for any of the testimony in this case, +right? +A. Well, I was not in the courtroom. +l. Right. You were not present in the courtroom for any of +the testimony in this case, right? +A. I was not present in the courtroom; correct. +Q. Okay. I want to talk about your compensation. +You are being paid or you will be paid for your work +in this case, right? +A. I'm being compensated for my time, yes. +l. And as you sit here, you're billing for your services, +right? +A. I'm sorry, could you repeat that? +l. Sure. As you sit here, you're billing for your services, +right? +Q. And you're charging the defendant $600 an hour, right? +A. Correct. +Q. And you said earlier that you've testified at over 300 +2458 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 164 of 246 +Loftus - cross +2459 +trials, right? +A. In 50 years, yes. +Q. The first one was in about 1975, I believe you said? +A. June 3rd, yes. +e. And you've also consulted on hundreds and hundreds of +cases, right? +A. I have, yes. +Q. And in most of those cases or many of those cases, you were +compensated for your work, right? +A. In many of them, yes. +Q. You've served as a paid expert for the defense many times, +right? +A. I have, yes. +l. You served as a paid expert for some high-profile or famous +defendants, right? +A. I have. +l. It's fair to say that over the years, criminal defendants +have paid you millions of dollars for your services, right? +A. I don't know if it's millions of dollars, no. +l. When you started testifying as an expert witness back in +1975, you didn't charge $600 an hour, right? +A. I started by charging nothing because I wanted to learn. +l. Right. You charged much less than that, if anything at +all? +A. Correct. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 165 of 246 +Loftus - cross +2460 +l. Right. And over time, your hourly rate has increased, +right? +A. Correct. +Q. And in the years since 1975, you've testified in some +high-profile trials, right? +A. Correct. +l. In some instances your testimony has drawn media attention, +right? +A. Sometimes, yes. +l. There's been news articles about you and the testimony that +you've given, right? +A. Sometimes, yes. +l. And that's helped raise your public profile, right? +MS. STERNHEIM: I would object, your Honor. +THE COURT: Just a moment. +The pending question is has this helped raise your +public profile. +Overruled. You may answer. +A. Overruled. Open my mouth and speak. Okay. +I wouldn't put it that way. I think my profile is -- +I'm not sure what it means, my public profile. What do you +mean by that? +l. Well, your testimony has helped you get hired by other +defense attorneys, right? +A. It's certainly possible that somebody has heard of my + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 166 of 246 +Loftus - cross +2461 +testimony in one case and thought that maybe they would hire me +in their case, yes. +I would think that might be true. +Q. Your testimony -- you've used your testimony from +high-profile cases to market yourself, right? +MS. STERNHEIM: Objection. +THE COURT: One-word grounds. +MS. STERNHEIM: Relevance. +THE COURT: Overruled. +A. I don't market myself at all. +l. Well, you've used your testimony from high-profile cases to +attempt to earn more money, isn't that right? +A. That's false. +Q. Okay. So you have provided defense attorneys with the +names of cases at which you've testified, right? +A. Well, I have provided the names of cases when -- to show +that the testimony has been admitted in those cases. +Q. But you've provided the list of the names of cases at which +you've testified for defense attorneys, right? +A. When asked to do that, I've done that, yes. Only when +asked. +l. You've testified on behalf of many famous and high-profile +defendants, right? +A. A few, yes. +l. People who can afford to pay your hourly rate, right? +A. And many who -- who -- in the past who couldn't. + + +Document 761 Filed 08/10/22 Page 167 of 246 +Loftus - cross +2462 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Q. You testified for Harvey Weinstein in his criminal trial, +right? +MS. STERNHEIM: Objection. +A. I testified -- +THE COURT: Just a +moment. +I'll hear from you. +(Continued on next +page) + + +Document 761 Filed 08/10/22 Page 168 of 246 +Loftus - cross +2463 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(At sidebar) +THE COURT: +Is her testimony on her CV? +MS. STERNHEIM: Judge -- +THE COURT: Is her testimony on her CV? +MS. STERNHEIM: No. +THE COURT: I just wanted to know that. +MS. STERNHEIM: I don't believe it has testimony. +It's a CV of her academic pursuits, her awards, her +publications. +THE COURT: Not the cases she's testified. +MS. STERNHEIM: No. +THE COURT: Okay. Go ahead. +MS. STERNHEIM: Your Honor, I certainly understand the +desire on the part of the government to do some character +assassination. But the fact of the matter, testifying in a +high-profile case is being used in a way that is very insidious +here. I don't understand what the purpose is. Are they +getting into her testimony in that case? +MS. +: Your Honor, I'm happy to respond. +So the witness has financial incentive to testify on +behalf of the defense. It's not a question of just getting +paid by the defendant in this case. Over her career she has +used her testimony as a defense -- as an expert for the defense +to testify at trials. +In her book she has a chapter, the book that she has + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 169 of 246 +Loftus - cross +right up there, there's a chapter in that book -- multiple +chapters dedicated to high-profile cases in which she's +testified. +2464 +THE COURT: Wait. So I allowed it because it goes to +motive, an ironic objection, but it goes -- if she has a motive +to testify in high-profile cases, that's monetary. I suppose +the inference is available as to her motive and credibility, so +that's why I allowed it. +Why are we going into specific cases in which she +testified? +MS. +: Your Honor, it's not an accident. +She's testifying here on the heels of her testimony at the +Harvey Weinstein trial. I would note that in multiple +instances, for instance, when Jane was testifying, the defense +insisted on a need to name a particular name of a pageant. It +wasn't enough to just say national pageant. Here we are, it's +the same issue that's coming up, your Honor, is that the +relevance of this detail. It is relevant, your Honor, that +this is after she did that. She testified in the Harvey +Weinstein trial. There is a New Yorker Magazine article that's +published on her in which she participates in the interview and +she -- +THE COURI: You're just trying to associate her with +other people who have bad reputations. And frankly, +Ms. +1, to suggest otherwise is to show a lack of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 170 of 246 2465 +Loftus - cross +respect for the Court. You could, Ask after a trial, did you +have a profile done about you? It's obvious what you're trying +to do. It's impermissible on 403 grounds, 401/403 grounds. +There's lots of ways of asking it without trying to just draw +associations in the jurors' minds with other defendants for +whom she's testified. +So you won't do that. Sustained. +You can ask general questions that go to incentive to +testify in high-profile, I'll allow it. +But don't do what +you're doing. +MS. +: Yes, your Honor. + + +Document 761 Filed 08/10/22 Page 171 of 246 +Loftus - cross +2466 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(In open court) +BY MS. +l. After your testimony at certain high-profile trials, you've +had articles written about you; isn't that right? +A. I've had articles written about me or my work for decades. +Q. The question was +-- and let me ask it a little differently. +After your testimony at certain trials, you've +participated in interviews with the press about your testimony +as a defense witness; isn't that right? +A. I have. If somebody asks me questions about it, yes. +THE COURT: Could you pull up a little closer to the +microphone, please. Thank you. +THE WITNESS: Sorry, your Honor. +THE COURT: That's okay. Thank you. +Q. And in your book, Witness for the Defense, you have -- you +devote multiple chapters to different individuals on whose +behalf you testified as a defense witness; isn't that right? +e. And each time you've done -- you've testified on behalf of +famous high-profile defendants, it's brought you more business, +right? +A. I don't know if -- maybe. +Q. Your work focuses on research and experiments, right? +A. The scientific work, yes, primarily. +2. You're not a clinician, right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 172 of 246 +Loftus - cross +2467 +A. Correct. +Q. You're not licensed as a psychologist, right? +A. No, we don't get licensed as experimental psychologists. +Q. You don't see patients, right? +A. Correct. +Q. You've never treated a single patient, right? +A. Correct. +Q. You've never seen +a patient or client for therapy, right? +A. No, not for therapy, no. +l. You do not treat victims of traumatic events, right? +A. I don't officially treat anyone. +l. Now, the opinions that you've given today about memory are +based in significant part on your research and experiments, +right? +A. Not only my work, the work of many other scientists who +work in this field. +Q. They are based in part on your -- based in significant part +on your research and experiments, right? +A. Well, many of the experiments on -- particularly on +misinformation are my experiments, yes. +2. You've conducted many experiments over the years, right? +2. I want to talk about some of those experiments now. +One of your experiments involves Bugs Bunny, right? +A. A bunny. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 173 of 246 +Loftus - cross +2468 +Q. Bugs Bunny? +A. Bugs +Bunny, yes. +Q. And in that experiment, you tried to get people to think +that they met Bugs Bunny at Disneyland, right? +A. Correct. +Q. That experiment involved an advertisement for Disneyland +that includes a picture of Bugs Bunny, right? +A. That was involved in that study, yes. +l. And that would be impossible because Bugs Bunny is Warner +Brothers, right? +A. That's exactly why we did the study, yes. +l. Okay. So that experiment involved the use of fake +photographs, right? +A. Fake drawings, yes. +Q. And then you ask people in this experiment whether they had +met Bugs Bunny at Disney, right? +A. On a childhood trip to Disney, yes. +Q. And in that experiment, about 16 percent of people went +along with the suggestion, right? +A. Well, I don't -- it's been a while since I've looked at the +actual data. I don't remember the exact number, but some +percentage claim that they met Bugs Bunny at a Disney resort. +Q. We can pull up that study if that would be helpful for you +to see the percentage. It's Government Exhibit 1511. +MS. STERNHEIM: Judge, I'm going to object. And I + + +Document 761 Filed 08/10/22 Page 174 of 246 +Loftus - cross +2469 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +will give my reasons at sidebar, if you like. +THE COURT: Let me look at 1511. +Can we get the background erased, +You can come up. Thank you. + + +Document 761 Filed 08/10/22 Page 175 of 246 +Loftus - cross +2470 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(At sidebar) +MR. PAGLIUCA: Your Honor, the objection is that this +is far afield from her expert testimony. We're picking one +study out of hundreds and then going into it. +When I attempted to cross-examine Dr. Rocchio on a +study that she relied on, I was precluded from doing that and I +think the objection was similar. And the Court sustained the +objection saying, you know, we're not going to go into all of +the studies that she may or may not have relied on in support +of her testimony. +This is similar to that. Dr. Loftus is testifying +about a broad range of studies; and to single one out is, you +know, overly prejudicial, not very helpful to the jury, doesn't +go to any of the opinions that she's offered in this case. +THE COURT: I'm sorry, can you remind me of the +parallel objection. +MR. PAGLIUCA: Yes. There was a study that was given +to the prosecution by Dr. Rocchio on hindsight bias and -- +basically hindsight bias and what went into hindsight bias. +THE COURT: You were trying to introduce affirmative +evidence through that study and not using it to impeach her +reliance on it; correct? +MR. PAGLIUCA: I disagree. I was trying to impeach +her and using some of the words from that study to impeach her +on what her opinions were during trial. That was the purpose + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 176 of 246 +Loftus - cross +2471 +of doing it. And I think this is analogous to that, if not +exactly the same. +MS. +: Your Honor, this witness has testified +about her extensive findings on memory that are based on +multiple experiments. This is one of the experiments, so they +asked her about certain experiments on direct examination. +This is one of the studies that she herself conducted, and so I +don't see how this is a parallel question. It's presented for +the Court. This is part of the experiments that she used and +that she conducted that forms the basis of her opinions. +MR. PAGLIUCA: I think part of the analysis -- I'm +sorry, I didn't mean to cut you off, if you were finished. +MS. +: It's quite distinct from Dr. Rocchio, +who wasn't testifying. That was something, as your Honor +pointed out, that the defense is trying to introduce for +cross-examination, and it wasn't an article that she had +written. It's quite distinct. +THE COURT: Overruled. + + +Document 761 Filed 08/10/22 Page 177 of 246 +Loftus - cross +2472 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(In open court) +BY MS. +l. I'm going to direct you on Government Exhibit 1511 to page +17. +MS. +A. How do you pull it up? +MS. +: If we can pull that up. +Is that not on the witness's screen? +A. +: Okay. Great. The lines are now +removed. Thank you very much. +Q. And I want to just direct your attention to the first +paragraph under "Discussion." You see it says: For example, +16 percent of people claim that they shook hands with Bugs +after receiving the false Bugs ad. Do you see that? +MS. +Okay. We can pull that down. +l. So in this experiment, about 16 percent of people went +along with the suggestion that they had met Bugs Bunny at +Disney, right? +A. You'll have to put that back up because - +MS. +1: We can pull that back up. +study, Ms. +THE COURT: Is it in her binder as well, the full +P Is it in the binder? +MS. +: Yes. +Your Honor, I'm happy to move on from this. + + +Document 761 Filed 08/10/22 Page 178 of 246 +Loftus - cross +2473 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: Okay. +l. The thing that the subjects got wrong was that they saw +Bugs Bunny at Disneyland, right? +THE COURT: You said you were going to move on. But I +just want to direct her. She wants to look at the study to +refresh, if you're going to ask her questions about it, if it's +in the binder. +MS. +: Your Honor, I meant, sorry, I was +going to move on from the percentage. +THE COURT: +okay. Let me look at the question. +All right. Go ahead. You +l. The thing that the subjects got wrong was that they saw +Bugs Bunny at Disneyland, right? +A. The study is 20 years old. But according to what you just +showed me, 16 percent claim that they shook his hand. Others +claim they touched his tail or touched his ear or heard him say +What's up, Doc? And Bugs Bunny would not be at a Disney resort +because it's a Warner Brothers character. And that was the +whole point of this study. +l. All right. I'm going to turn to a different experiment. +You testified on direct about an experiment involving +a simulated car accident, right? +Q. And the misinformation was that the car accident involved a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 179 of 246 +Loftus - cross +2474 +yield sign, not a stop sign, right? +A. It was the critical item, yes. +Q. Okay. But to be clear, the research subjects still +remembered the simulated accident, right? +A. Presumably, yes. +Q. Okay. +In that experiment, did any of the experiment +subjects +face the possibility of getting charged with a crime +if they lied to you? +A. No. +l. Now, in that experiment, you changed one fact, that's the +yield sign stop sign, right? +A. Or vice-versa. +2. You've done other experiments where you've changed more +than one fact, right? +l. There is, I think, a science museum experiment? +Q. And in that study you tried to change two facts, right? +A. Correct. +l. People went to a museum and they watched a short video, +right? +l. And in that video, a blue car rushed towards a person for +eight seconds, right? +A. I don't - the car was blue, the offending car, yes. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 180 of 246 +Loftus - cross +2475 +Q. Okay. And then folks, after watching the video, they +walked through the museum and then they are asked some +questions, +right? +A. Correct. +l. And during that questioning, certain details were +distorted, right? +A. I believe that we had deliberately tried to change the +color of the car in their memory. +l. The color of the car was changed in the questions from blue +to +right? +A. Something like that, yes. +l. And there was a color of a jacket that was changed in +questions from, I believe, blue to black, right? +A. Well, I mostly remember the blue car, so -- +Q. And in that study, some of the research subjects were +fooled by one changed fact about the color of the car, right? +Q. But the research subjects were not fooled by the attempt to +change the second fact, right? +A. I believe that's what happened in that study, yes. +2. Okay. You've also conducted an experiment about planting a +false memory of someone being lost in a mall, right? +A. That's a study that we did in the mid '90s, yes. +l. And that study involved about 24 participants, right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 181 of 246 +Loftus - cross +2476 +Q. And the participants were between the ages of 18 to 53, +right? +l. And you tried to implant a false memory, right? +A. We tried to suggest to them that they, as a child, have +been lost in a shopping mall for an extended period of time and +then rescued by an elderly person and reunited with their +family. +l. So research subjects were -- they were shown one-paragraph +stories describing four events, right? +A. Well, again, that was a 1995 paper; but the fine details of +the method, that sounds close, yes, but - +l. So but there were three true stories and one false one, +right? +l. Okay. And you told the subjects that you talked to their +parents, right? +A. Yeah, or an older sibling. +l. So a parent or older sibling, right? +l. And you found out from the parents experiences that had +happened to the subjects when they were children, right? +A. Yes, some true experiences. +l. Right. For the three true ones, right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 182 of 246 +Loftus - cross +2477 +Q. Okay. And then you presented the subjects with the three +true memories that their parents had told you about, right? +Q. And then you presented the subjects with the false memory +that the +subject was lost in the mall when the subject was five +or six years old, right? +A. With more specifics, yes, but that's basically correct. +Q. And the subject was told that the false memory of being +lost in the mall was something that their family members said +had happened, right? +A. That was strongly suggested in the study, yes. +l. And sometime later, you conducted an interview of the 24 +participants in that study, right? +A. Yeah, we tested them, I guess, a few times. +Q. And 25 percent -- about 25 percent remembered some of the +false event, which means 75 percent did not, right? +A. Correct. +Q. Okay. Isn't it true that studies have shown that in the +extreme case where participants are given blatantly +contradictory suggestions, they are sometimes not susceptible +to suggestion or misinformation at all? +A. We did a study where we tried to give a blatantly false +suggestion and people resisted it, yes. +l. You, yourself, you published a paper called Reactions to +Blatantly Contradictory Information, right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 183 of 246 +Loftus - cross +A. Correct. +Q. In other words, if something contradicts the true events so +blatantly, the memory is not as susceptible to suggestion, +right? +A. In that particular study, yes, that was -- that was a +wallet-snatching crime. And we were not able to mislead people +about the color of the wallet, which was a very obvious, +obvious, strong detail. +l. You're familiar with a study conducted by Kathy Pezdek in +which Pezdek presented 20 subjects with one true memory and two +false memories, right? +A. Well, I know about that study, yes. +l. And one of the false memories was being lost in the mall, +right? +l. And the other false memory was receiving something called a +rectal enema, right? +A. Correct. +2. And I'm not going to ask you to describe a rectal enema, +but it's fair to say that that's an intrusive bodily procedure, +right? +2. Three of the 20 subjects remembered having been lost in the +mall, right? +A. Something like that in her study, yes. +2478 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 184 of 246 +Loftus - cross +2479 +Q. And none of the 20 subjects remembered the rectal enema, +right? +A. None of the 20 remembered the scenario that they were +presented with involving a rectal enema. But they weren't told +they even saw it. +Q. Pezdek tried to instill a false memory of subjects of +having a rectal enema, but she did not succeed in doing that, +right? +A. She did not; correct. +l. You testified on direct examination about post-event +contamination, right? +Q. Young children are more susceptible to post-event +contamination than adults, right? +A. Typically, very young children, yes. +l. And we're talking about children under the age of six, +right? +A. Correct. +Q. Not all memory is retained equally, right? +A. Right. +l. Not all memory is retrieved equally, right? +A. Correct. +l. If there was an event like the birth of your first child, +it would be very rare to forget that over time, right? +A. I would think that would be hard to forget. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 185 of 246 +Loftus - cross +Q. I want to talk about memories of trauma. +The core memory of trauma is stronger than other types +of memory, right? +A. There are studies that show typically people can remember a +core event and some core details, support for that proposition, +yes. +Q. People tend to remember the core or essence of trauma +events, right? +A. They can, yes. +l. People may forget some of the peripheral details of a +trauma event, right? +A. That can happen, yes. +l. But the core memories of a trauma event remain stronger, +right? +A. I probably agree with that. +l. And people who are involved in the trauma event tend to +remember the core or gist of the event better than those who +are nonparticipants, right? +A. There are at least one or two studies that show that if you +participate, your memory is somewhat better than if you're just +observing. +l. And if a person is involved in repetitive traumatic +experiences, they are more likely to remember it, right? +A. Generally, the more times something happens to you, the +better your memory; or the more times you're exposed to +2480 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 186 of 246 +Loftus - cross +something, the better your memory. +Q. That's a fundamental principle of human memory, right? +A. Yes, frequency, yes. +Q. Now, we've talked today about some of the experiments you +have done. And you talked about experiments you've done that +involved videos of car crashes, people being lost in the malls, +things like that, right? +A. Among other things, yes. +l. Now, obviously you've never done a study where you arranged +for teenage girls to be sexually abused, right? +A. Correct. +l. You've never done a study of how well those girls remember +that sexual abuse years later, right? +A. Well, I've done studies where we interview people who were +sexually abused about what they remember. +l. The question I'm asking you is have you conducted a study +where you arranged for girls to be sexually abused? +A. No, absolutely not. +2. You haven't conducted a study where you saw girls being +sexually abused, right? +A. Correct. +l. You've never conducted a study in which you attempted to +implant a false memory of childhood sexual abuse? +A. We have not. +2481 +I have one moment, your Honor? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 187 of 246 +Loftus - redirect +2482 +THE COURT: Okay. +(Counsel conferred) +MS. +: Nothing further, your Honor. +THE COURT: All right. +MS. STERNHEIM: Briefly. +THE COURT: Yes. +REDIRECT EXAMINATION +BY MS. STERNHEIM: +l. Professor Loftus, you've been conducting experimental +psychology research for over 50 years; correct? +A. Correct. +l. You have received numerous awards for lifetime achievement +for the work that you have done? +MS. +: Objection. +THE COURT: Sustained. +l. You were asked a number of questions about studies here; +correct? +A. Correct. +2. Some that you actually conducted and some that were +conducted by others; correct? +l. You were asked questions about studies that would involve +sexual abuse; correct? +Q. And earlier I had asked you whether there were certain + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +Loftus - redirect +2483 +restrictions placed upon the type of experiments that a +psychologist +is allowed to perform? +MS. +Objection. +THE COURT: Overruled. +A. Yes, you did. +Q. And please explain to the jury why that is. +MS. +: Objection. +Asked and answered, your Honor. +THE COURT: I'll allow it. +A. The human subjects review committees at universities and +colleges are in place to try to protect human beings from being +involved in experiments that might be harmful to them. And so +that is why these committees will review your proposal for a +piece of research and either allow you to go forward with your +proposal or not allow you to go forward or suggest +modifications that would allow you to go forward. +But their interest is in making sure -- or trying to +ensure that you're not doing something to harm the research -- +that might harm the research participants. That's why we +would, as I thought I indicated earlier in my testimony, would +not be probably, you know, allowed to deliberately plant +memories of sexual abuse. +Q. On cross-examination, the government had suggested that you +are a profiteer when you testify for the defense. Do you +remember that? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 189 of 246 +Loftus - redirect +Objection. +2484 +MS. +A. Yes, I do. +THE COURT: I'm going to sustain. +2. They took issue with the fact that you have testified in +criminal cases predominantly for the defense? +MS. +: Objection. +THE COURT: Grounds. +MS. +: Mischaracterization, your Honor. +THE COURT: Overruled. +l. You have worked as a consultant for the federal government, +have you not? +l. For the Secret Service; correct? +l. For the Department of Justice; correct? +l. For the FBI; correct? +l. For the Internal Revenue Service; correct? +l. And those entities were aware that you have provided +testimony for defendants in criminal matters; correct? +MS. +: Objection. +THE COURT: Grounds. +MS. +: Foundation. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 190 of 246 +Loftus - redirect +2485 +THE COURT: Sustained. +l. The testimony that you gave here today, would it have been +any different if you had been called to the stand by the +government? +A. I don't think -- I don't see how it would have been any +different. I think in the case where I did testify for the +prosecution, it was similar testimony. +Q. And if the prosecution had called you, you would have been +available to be a witness for them, wouldn't you? +A. I might have been. +MS. STERNHEIM: No further questions. Thank you. +THE COURT: Ms. L +MS. +: No, nothing further from the +government. Thank you, your Honor. +THE COURT: Thank you. All right. +Professor Loftus, you may step down. You are excused. +(Witness excused) +THE COURT: Defense may call their next witness. +MS. STERNHEIM: I'm just going to move please. +THE COURT: Sure. +Mr. Everdell? +MR. EVERDELL: Yes, your Honor. +The defense calls Michael Aznaran. +THE COURT: Okay. +He may come forward. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 191 of 246 +Aznaran - direct +MICHAEL WILLIAM AZNARAN, +called as a witness by the Defendant, +having been duly sworn, testified as follows: +THE COURT: You may inquire, Mr. Everdell. +MR. EVERDELL: Yes, your Honor. I believe the +government may have an objection to the exhibit we plan to +admit through this witness, so we may need to be heard at +sidebar before we begin the examination. +THE COURT: Can we start and then we can take it at +the break? +MR. EVERDELL: There's some questioning before we get +to the exhibit, your Honor, so yes. +THE COURT: Okay. +MR. EVERDELL: Thank you. +THE COURT: Is that okay, Ms. +? +MS. +: Yes. Thank you, your Honor. +THE COURT: All right. Thank you. +You may inquire. +MR. EVERDELL: Thank you, your Honor. +DIRECT EXAMINATION +BY MR. EVERDELL: +l. Good afternoon, Mr. Aznaran. +A. Good afternoon. +Q. How old are you, sir? +A. Thirty-seven. +2486 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 192 of 246 +Aznaran - direct +2487 +Q. Where do you work? +A. I currently work for U.S. Customs and Border Protection +here in Manhattan at the New York/New Jersey HIDTA task force. +Q. What is Customs and Border Protection? +A. It's a federal law enforcement agency that mainly works out +of the land border seaports and airports around the United +States. +Q. And generally, what functions do they serve at the borders? +A. Basically, checking incoming either passengers or land +border travelers entering the United States. +l. Did Customs and Border Protection used to be known as +something else in the past? +A. It did, yes. +Q. What was that? +A. It's actually made up of two legacy agencies. One was the +INS, Immigration and Naturalization Service; the other one was +USCS, U.S. Customs service. +Q. Okay. And those are both now combined in CBP or Customs +and Border Protection? +Protection? +l. Okay. How long have you worked at Customs and Border +A. Since July of 2008. +l. And can you just describe the different positions you've +held at CBP and your duties and responsibilities in those + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 193 of 246 +Aznaran - direct +2488 +positions. +A. +Sure. July of 2008, I entered the service. I went to the +academy for about four months. +When I got back from the +academy, I was assigned to John F. Kennedy International +Airport, passenger operations. +Q. Can you explain what passenger operations is? +It's considered what we call the core process. +So +any travelers that are coning into the United States at JFK, +when they get off the plane from a foreign country, they have +to go down to what's called an FIS, a federal inspection site. +At that site, we have officers, uniformed officers, in +booths that basically check the -- check each and every +traveler, swipe their passports, and either admit them or deny +them entry into the United States. +Q. So are those the folks that are in the booths or the kiosks +you show your passport to when you're traveling internationally +when you arrive? +2. Okay. So how long did you do that job for? +A. I did that for approximately three and a half years. +l. Okay. And did you say which airport you were in? +A. JFK, John F. Kennedy. +2. What did you do after that? +A. At that point I was selected to go up to what's -- what +used to be called PAU, passenger analysis unit. And more + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 194 of 246 +Aznaran - direct +2489 +specifically, I was assigned to what's called RCLG, regional +carrier liaison group. +Q. Can you explain for the jury what the passenger analysis +unit is and what the RCLG is? +A. Sure. PAU used to be mainly an intel center made up of +several different +functions such as narcotics, terrorism, and +RCLG. RCLG, we were more or less liaisons that would +communicate with airline and airport employees in foreign +countries. And we would make recommendations to those airline +employees if we basically found or noticed a particular +passenger that would be on one of their flights coming into the +United States that might have some kind of an issue being +admitted into the United States. +We would then, if we did find a passenger such as +this, we would recommend to that airline to do what we call an +offload. So it's just a recommendation to that airline saying, +If this passenger does travel on your airline into the United +States, there is either a high probability or a certainty that +they will not be admitted, be able to be admitted into the +United States. We recommend they go to the closest embassy and +get their issue figured out there. +Q. How long did you do that work for at CBP? +A. Roughly four and a half years. +l. And did you have a position after that? +A. I did. In 2015, I was promoted to first line supervisor, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 195 of 246 +Aznaran - direct +2490 +at which point I was then placed back into passenger +operations. +Q. And that's what we discussed before? +l. This time you were a supervisor? +Q. I see. +And what airport were you working there? +A. Same airport, John F. Kennedy International. +l. And is that your current position? +A. It is not. +l. What position did you hold after that? +A. So in April of 2018, still as a supervisor, I was selected +to be a task force officer with the New York/New Jersey HIDTA +task force. +l. What's HIDTA? +A. HIDTA is H-I-D-T-A, high intensity drug trafficking area. +2. What does that mean? What did you do for HIDTA? What's +the mission? +A. So I'm still currently assigned to HIDTA. +My function is basically to act as a liaison between +my agency, Customs and Border Protection, and the roughly 30 to +35 other law enforcement agencies that also have +representatives at HIDTA. +e. And how long have you held that post? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 196 of 246 +Aznaran - direct +2491 +A. Since April of 2018, so almost four years now. +Q. And that's your current position? +A. Correct. +Q. All right. Mr. Aznaran, does Customs and Border Protection +keep records on people that are entering or exiting the United +States? +Q. And where is that information stored? +A. It's stored in the system that we call TECS, I-E-C-S, +Treasury Enforcement Communication System. +Q. Okay. And are you familiar with the TECS system? +l. Can you just describe what the TECS system is. +A. It's a -- it's a law enforcement system which acts as a +platform. It collects data from several other systems and kind +of compiles it into one system that CBP -- we own and control +TECS. So we are able to utilize all that information to see +who's coming into or possibly departing the United States. +We also have access to NCIC, National Crime +Intelligence Center. So we can see if people have warrants for +their arrest, missing persons, things of that nature. +l. So you mentioned that TECS pulls information from lots of +different sources; is that right? +l. What sorts of information does the TECS system store from + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 197 of 246 +2492 +Aznaran - direct +these sources? +A. You have -- you have travel -- I'm sorry, international +travel records, you have passengers' travel documents, such as +passports and visas. We are able to do queries of addresses, +vehicles, license plates. NCIC, as I mentioned, already +warrants +missing +persons, stolen vehicles. +And does the information you just mentioned include also +border-crossing information? +l. Now, with respect to border-crossing information, what +kinds of information are stored in the TECS system? +A. As far as border crossing? +l. Yes, specifically border crossing. +A. So within the aviation and vessel or, more commonly known +as cruise line information, you would normally have somebody's +full name, their passport number that they are using to travel, +what location they are traveling from, what location they are +traveling to, if they are traveling into an airport, which +airport they are traveling, the site code. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 198 of 246 +LCGCmax6 +Aznaran - direct +2493 +BY MR. EVERDELL: +Q. And just to be clear, when I refer to border crossing, what +does that mean to you? +A. That, it could mean either any international traveler +coming into the United States at any international airport, +seaport, or land border along the Mexican or northern border of +Canada. +Q. And the information you just listed is stored in the TECS +system for those passengers that are entering through ports of +entry; is that right? +l. How far back do the border crossing records go in the TECS +system? +A. It's hard to say. In my experience, I have not seen any +border crossings any earlier than roughly the early '90s, mid +'90s. +l. And how does the border crossing information that is stored +in the TECS system get input into that database? +A. So, there is another system, it's called APIS, Advanced +Passenger Information System, and essentially what happens is +international airlines or any airline that has international +flights coming into or departing the United States, they're +required to submit their manifest to us. The manifest gets +loaded into APIS, which is then linked to text, and that's how +we're able to see that information. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 199 of 246 +LCGCmax6 +Aznaran - direct +2494 +Q. What sort of information is contained in the manifest from +the airlines? +A. +Generally, the name of the passenger, their date of birth, +the document that they're using, whether it's a passport or a +card, the flight information, the carrier code, the +flight number, where they're traveling from and where they're +traveling to. +Q. Is there any information in the TECS system about a border +crossing that gets supplied by those immigration officials we +talked about at the primary immigration line as opposed to the +airlines? +A. No. +l. So the people who check you in through the kiosks, is there +any information that gets input from there? +A. Not by the officers themselves. Once a passenger is +processed, there are certain +that will be automatically +updated. +Q. But those +immigration line; right? +l. That doesn't come from the airlines? +get updated once they go through the +A. NO. +l. For the information that comes from the airlines, the +information you mentioned, how soon after the flight takes off +does that information get input into the TECS system? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 200 of 246 +LCGCmax6 +Aznaran - direct +A. It's supposed to be what's called the securing of flight +doors. +So once the door to the aircraft is shut, the +information or the manifest is supposed to be sent to APIS. +Q. So the manifest information is supposed to reflect the +people who are on board at the time the doors are shut at the +gate? +Q. Before wheels up, I guess? +l. All right. And how soon after the traveler passes through +the immigration line at the kiosk is that information populated +into the TECS system? +A. I'm sorry. Could you repeat the question. +l. You mentioned that certain information gets populated after +the traveler goes through the immigration line at, say, the +airport they're coming into; right? +l. How soon after the passenger travels through that +immigration line does that information hit the system, hit the +TECS system? +A. It should be at that same time. +l. And is it the regular practice of customs and border +protection to keep this type of border crossing information in +its records in the TECS system? +2495 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 201 of 246 +LCGCmax6 +Aznaran - direct +2496 +Q. Is the text database searchable? +Q. And what +can you search with? +A. You could search by name, last name, first name. You could +search by a combination of last name, first name, and date of +birth. You could search by a passport number. +You could +search by a visa number. +Q. And those names you mentioned, those are the names of the +travelers; right? +l. So can you search by a particular traveler? +l. Can you limit the search to a particular timeframe? +Q. Now, if you search the TECS system for the border crossing +records for a particular traveler, what does the database +generate? +A. It would generate basically any border crossings of +encounters for that particular person within that timeframe. +It would basically be like rows of information for each +encounter or border crossing. +l. And it would be for whatever time period you put in for; +right? +e. And then that report contains the information that you had + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 202 of 246 +LCGCmax6 +Aznaran - direct +2497 +been discussing? +Q. Are those reports generated in the normal course of CBP's +regularly conducted activity? +Q. Mr. Aznaran, did there come a time when you were asked to +search the TECS system for certain border crossing records +related to this case? +Q. And were you asked to search for certain travelers? +l. How many travelers were you asked to search for? +A. Three. +l. And do you know the names of those travelers without +telling me the name? +A. I do. +l. So I want to show you first what is admitted under seal as +Government Exhibit 12. +MR. EVERDELL: With the Court's permission, I'll show +it just to the Court and the deputy and the witness. GX12, +please, under seal. +l. Mr. Aznaran, do you see that on your screen, that document? +Q. That's a document that's already in evidence under seal as +Government Exhibit 12. Do you see the name on that document? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | +Document 761 Filed 08/10/22 Page 203 of 246 +LCGCmax6 +Aznaran - direct +2498 +Just a yes or no. +l. I'm going to refer to that person as Jane and you should, +as well. All right? +Q. Was Jane one of the people whose border crossing records +you were asked to search for? +MR. EVERDELL: We can remove that. +Now I want to bring up what's also in evidence already +under seal as Defendant's Exhibit LV4. With the Court's +permission, just show it to the Court, the deputy, and the +witness. +THE COURT: Okay. +l. Mr. Aznaran, do you see that document? +l. You're looking at a document already in evidence under seal +as LV4. Do you see the name on that document? Yes or no. +l. I'm going to refer to that person as +as well. All right? +and you should, +Q. Was ( +you were asked to search for? +one of the people whose border crossing records + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 204 of 246 +LCGCmax6 +Aznaran - direct +MR. EVERDELL: All right. We can bring that down. +Q. Are you also familiar with the name, +Q. Was +one of the people whose border crossing +records you were asked to search for? +Q. So were Jane, +and +the records you were +asked to search for in the TECS system? +l. Were you asked to search for the records in a particular +date range? +2. What was that date range? +A. It was from January Ist, 1994, to December 31st, 2010. +l. Did you perform those searches? +l. And when did you conduct that search? +A. A few days ago. +2. Did the TECS system generate the three reports from those +searches? +2499 +MR. EVERDELL: Your Honor, at this time, I think we +may need to have our sidebar. +THE COURT: I'll give the jurors their mid afternoon +break. We'll resume in about 15 minutes. Thank you. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 205 of 246 +LCGCmax6 +Aznaran - direct +(Jury not present) +THE COURT: Okay. +Mr. Everdell. +MR. EVERDELL: Your Honor, the exhibit is marked for +identification as MAI, and I'll hand up a paper copy to the +Court, and I believe the government has a copy, but I have +another one for them, as well. +THE COURT: Okay. I'll hear the objection. +MS. +: Thank you, your Honor. Just briefly, +the question posed to the defense is what is the relevance of +these records, and in particular, we're talking about victim +travel records that go over 15 years of victim travel records +that extend well beyond the period charged in the indictment. +And so, we would ask for a proffer of relevance for the +admissibility of such extensive travel information, private +information of the victims. +THE COURT: So no objection within the charged +timeframe? +MS. +: No objection. +MR. EVERDELL: Your Honor, for example, these records +go up to 2010, which was the cutoff point for the request when +we issued the subpoena, we, in fact, negotiated with the +government over how broad the subpoena would be and we agreed +that it would go to 2010. +Now, as to the relevance -- and that's why the records +go that far. +2500 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 206 of 246 +LCGCmax6 +Aznaran - direct +2501 +As to the relevance, I mean, for example, we see +Jane's travel records going all the way up to 2010. Jane +testified in this case already that she continued to travel +after she had left New York and continued to travel, and I +think this is, if it's already in the record, that she +continued to travel. I don't think this is in any way +prejudicial -- +THE COURT: I just would like to know what the +relevance is. +MR. EVERDELL: Your Honor, she also testified - Jane, +I'm referring to - that she came from a family that did not +have much means when she first - when she was younger. She +testified extensively about the fact that she didn't have much +money, and these records show extensive foreign travel, going +on well into the 2010s. So it tends to counter that. +Same thing with [ +She said she came from +a family with a single mother, didn't have much money, and +these travel records show travel to Mexico and places like +that. +For +there was a discussion about she traveled +after the incidents that she talked about in the United Kingdom +and she was open-ended about how often she traveled and how +long she traveled. And there was also testimony that she was +still in contact with Jeffrey Epstein well into the 2000s. +I +think some of the emails are in the 2010s, 2015. So these + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 207 of 246 +LCGCmax6 +Aznaran - direct +travel records show her whereabouts and show her traveling +around the same time when she's still in contact with Jeffrey +Epstein. +2502 +THE COURT: What's the relevance of that? +MR. EVERDELL: Your Honor, I don't plan to make much +of an argument about those records that are happening after the +charged time period -- +THE COURT: You haven't asserted any relevance with +respect to after the -- where is the government with respect to +the time cutoff request? +MS. +: Your Honor, our proposal would be that +it would be redacting anything that postdates the charged +conspiracy. +MR. EVERDELL: Your Honor, there is probably a +practical solution that we could come to with this, because I +don't think that we -- you want to give me a moment, your +Honor. I'll just confer with my colleagues. +THE COURT: Okay. +MR. EVERDELL: Your Honor, one other point about +in particular, I believe her testimony was that she was on +public assistance at some point in her life that correspond to +when she's flying all over the world. So I think that those +records - +THE COURT: Is that during the time of the charged +conspiracy? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 208 of 246 +2503 +LCGCmax6 +Aznaran - direct +MR. EVERDELL: I don't know if she put a timeframe on +exactly when that was. I'm told it was not -- she testified it +was not during the period of the charged conspiracy when she +was on public assistance, but she did testify to it and that's +now on the record, and if these records tend to counter that +point, that she had made that point to the jury, I think we +could use these records to show that. +With the other travelers, your Honor, I think we can +come to a practical solution. +THE COURT: See if you can come to a solution and you +can tell me where we are. We'll break for 10 minutes. +(Recess) +THE COURT: All right. Where are we? +MR. EVERDELL: Your Honor, we conferred with the +government. We reached agreement as to redactions and other +omissions from this exhibit and we're just now printing new +copies of the revised exhibit. We have about half of those +copies. It's coming up right now and we'll have the other half +shortly in just a couple minutes. +THE COURT: Okay. +MR. EVERDELL: Your Honor, I have your copy I'll hand +up, and one to the government, and we'll put one, with the +Court's permission, facedown in the witness box. +THE COURT: Okay. Ms. +acceptable? +MS. +: Yes, your Honor. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 209 of 246 +LCGCmax6 +Aznaran - direct +THE COURT: Okay. We can bring in the witness. +MS. MENNINGER: Your Honor, may I raise one issue? +Your Honor gave us a 5 o'clock extension of filing of a brief +today. Can I ask for one hour so that we could -- until 6:00 +p.m. for that filing so we can confer with our office? +THE COURT: Okay. +MS. MENNINGER: Thank you. +THE COURT: I don't even know what it is. I'll still +be here at 6:00. That will be fine. +MS. +: Your Honor, just one thing to alert the +Court. I believe the parties have reached, in principle, +agreement on a stipulation regarding Mr. Glassman. So that +will obviate the need to deal with the service issue for his +live testimony. +THE COURT: Sounds like a good idea. +MR. PAGLIUCA: It could have been fun, your Honor. +THE COURT: If only someone had thought of that +2504 +sooner. +The witness is coming back and we can bring in the +jury. Thank you for working out agreement on the timeframe +issue. +MR. EVERDELL: Yes, your Honor. +(Witness present) +THE COURT: You may take a seat and you can remove +your mask. Just waiting for the jury. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGCmax6 +Document 761 Filed 08/10/22 Page 210 of 246 +Aznaran - direct +2505 +(Jury present) +THE COURT: Thank you for your patience, members of +the jury. We will continue with the direct examination of +Mr. Aznaran. +Mr. Aznaran, I remind you are you under oath. +Mr. Everdell you may inquire. +MR. EVERDELL: Thank you, your Honor. +BY MR. EVERDELL: +l. Welcome back, Mr. Aznaran. +A. Thank you. +l. If you recall when we left off, I was asking you about some +reports that you ran in the TECS system; is that right? +l. Can you remind us how many different travelers' reports did +you run in the TECS system? +A. Three. +l. I believe you said those were for Jane, +and +¡ is that right? +MR. EVERDELL: With the Court's permission I want to +show him what's been marked for identification as MAl. +Q. Mr. Aznaran, there is a document on the floor next to you, +you can pick that up, and a copy has been provided to the +government and the Court. Can you look at that document marked +as MAl for identification. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 211 of 246 +LCGCmax6 +Aznaran - direct +2506 +A. Okay. Yes. +Q. Do you recognize what MAl is? +Q. What is MA1? +THE COURT: Just without saying any of the names. +Q. Without saying the names of the travelers, please. +A. It is a person encounter list from TECS. +Q. Are these the person encounter list from the three +travelers you were asked to look at? +Q. And how do you recognize them? +A. I ran them on December 14th of 2021. +l. And are they fair and accurate copies of the three TECS +reports that you searched for and pulled off the system for the +border crossing records of Jane, +and +MR. EVERDELL: Your Honor, defense offers MA1 under +temporary seal to allow for redactions to protect privacy of +witnesses in this case. +MS. +: No objection. +THE COURT: All right. MAl is admitted under seal to +redact the identifying information of witnesses who I have +allowed to testify under pseudonyms. Thank you. +(Defendant's Exhibits MA1 received in evidence) +MR. EVERDELL: With the Court's permission, I'll hand + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 212 of 246 +LCGCmax6 +Aznaran - direct +2507 +out copies to the jury. +THE COURT: Okay. +Q. Mr. Aznaran, do you have the document in front of you? +I. First I'd like you to walk us through the various columns +that are in this report. +But just for clarity sake, do domestic flights appear +on these reports or just international flights? +A. Just international. +l. And if you could explain please then the different columns +as you read across the first page, what those mean. +A. The first column is last name, last name of the passenger. +Q. Again, please don't read the name. +A. Last name of the passenger or the person that's been +queried. The next column is the first name, which is the first +name of the person. DOB is for date of birth. DOC type is the +document type that's on record, such as, in this case, the +first page, the letter P is for passport. Document number is +the number of the documents, on this case, the passport number. +Date and time, eastern. So the date is the date of the border +crossing. The time is the time that they were processed when +they came through port of entry. Carrier code is two letters, +that's the airline code. So towards the bottom of the first +page, AA is American Airlines, for an example. Carrier number +is the number of the flight. I/O is indicating whether that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 213 of 246 +LCGCmax6 +Aznaran - direct +2508 +particular record was for an inbound or an outbound travel. +Site is the particular federal inspection site that the person +was encountered at. +Q. Could you explain that a little more. What do you mean by +the federal inspection site? +A. So on this first page, you have the very first site at the +top is Alpha 271. That is the specific terminal at whatever +airport that that traveler was encountered. So if I flip to -- +it's been redacted, but -- for example, JFK airport has five +international terminals. Terminal 4 is Alpha 471. Delta used +to be Alpha 473. +l. When we're referring to the sites, are those the sites +where the booths or the kiosks are where the immigration +officials stamp your passports? +l. Going to the right, what else do you see on these columns? +A. Then you have type. So that is the type of or more like +the way that this information was obtained for each border +crossing. +l. And on that, if you look at the first entry -- +THE COURT: Can't quite hear you there, Mr. Everdell. +MR. EVERDELL: Sorry. +l. On the column marked type, you see the first entry on the +top, it says airline, not API? +A. Right. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 214 of 246 +LCGCmax6 +Aznaran - direct +2509 +Q. And the one below that says APIS? +l. Can you explain the difference between the two. +A. +So the first one, airline, not API. An airline employee at +some point manually entered that person's information into +their manifest system as opposed to APIS, which is Advanced +Passenger Information System. That means that that airline +submitted their manifest electronically to the APIS system and +it was electronically and automatically uploaded into TECS. +l. Okay. And what's next? +A. The next column is status. +l. What does that indicate. Actually, if I can have you 100k +maybe at page 3 of the document, and you look at top of the +page, the third entry down in the column status, it says the +word passenger; is that right? +Q. So what does that indicate? +A. That indicates that that person was, at one point or +another, added to that manifest of that airline for that +particular flight. +2. Going to the next column, updated status. +A. Updated status, I have, in all of my experience querying +travel records, I have never seen anything in that column, and +I honestly don't know what it means or what it's supposed to. +2. Understood. What about the columns to the right of that? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 215 of 246 2510 +LCGCmax6 +Aznaran - direct +A. So ARRLOC, arrival location. That is the location, on the +first page anyway, all the airports that the flight is going to +be arriving or landing at. And to the right of that, DEPLOC is +departure location. That is the airport where the flight is +departing from. +Q. So let's just take one example, the first example on +page 1. That reflects a flight that Jane took from CDG to LAX; +right? +l. Do you know what CDG is? +A. Is Paris, Charles de Gaulle. +Q. And LAX is what? +A. Los Angeles International. +Q. And was that an incoming or outgoing flight? +A. That would be incoming. +It departed from Paris and it +landed at LAX, or Los Angeles. +Q. And you know the incoming from the I in the I/O category? +A. Yes, also Paris to Los Angeles. So that would be an +incoming. +l. And the date and time reflected there is 7/25/2004; right? +l. So what does that date reflect? +A. That is the date that that passenger arrived into the +United States and was processed. +Q. And the time? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 216 of 246 +LCGCmax6 +Aznaran - direct +A. The time is the updated time that the passenger was +actually processed by a CBP officer in the passenger operations +environment. +Q. All right. So looking at the information in this chart, +what of this information comes from the airlines and what of +this information comes from the kiosks when they're stamped +into the country? +A. So the airline manifest is going to provide the last name, +first name, the date of birth, document type, document number, +the carrier code, the carrier number, inbound or outbound, the +type, the arrival location, and the departure location. +Q. That all comes from the airline? +l. And the rest of the information that's not that is, I +think, the date and time and the site; is that right? +A. The date and the time is when the manifest is first loaded. +The date and the time will reflect the date of the flight and +it will reflect the time of the flight, the time of arrival. +Once the passenger is processed and that information is +captured by their border crossing into TECS, that time is +supposed to be updated to the time when they were processed. +l. Processed at the immigration kiosk? +A. At the kiosk, correct. +l. At the site location listed there? +2511 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 217 of 246 +2512 +LCGCmax6 +Aznaran - direct +Q. Okay. It looks like outbound flights, O's in that column +don't have any site +information typically. Why is that? +A. +Because CBP, we don't have a 100 percent outbound mandate, +if you will. +l. So you need to track incoming flights, people coming into +the United States, but not necessarily people leaving the +United States? +A. I wouldn't say track. I would say when you come into the +United States, you are required to be processed or admitted +into the country. When you depart the country, there is no -- +for example, at JFK, there is no FIS, or federal inspection +site with actual CBP officers that are processing you when you +go to get on board your outbound flight. +l. Understood. So I just want to take a look at the years +that's reflected in this report. If you look at the first +page, which are the records of Jane's travel; right? +l. You see the earliest one there is January 6th, 1996; right? +l. And the latest one there is July 25th, 2004; right? +A. Correct. Yes. +Q. Now, when you originally did this search, I think you said +you searched all the way up to 2010; correct? +Q. And were there records going that late, do you recall? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 218 of 246 +LCGCmax6 +Aznaran - direct +2513 +A. I believe so, yes. +Q. So we're just looking at a subset; right? +Q. And same thing with +records. If you go to page 3 of +that exhibit, you see on that page, there is some records of +transits, earliest one there is February 29th of 2004; is that +right? +A. My pages are -- +2. I think you have to count manually, one, two, three, third +page? +THE COURT: The page number is at the bottom right. +MR. EVERDELL: We can try that. +2. That page is 5. Do you see that? +A. 5. +e. For +the earliest one on that page is February 29th, +2004? +l. And the latest one is April 3rd of 2006; right? +l. Going to what's page 7, there is some redacted entries, but +those are also +records; is that right? +A. I'm sorry? +l. Those are also +| records on page 7? +Q. And the earliest one there is November Ist, 1997; correct? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 219 of 246 +LCGCmax6 +Aznaran - direct +2514 +A. Correct. +l. And that one is October 14th, 2006? +l. And then finally, looking at +earliest record there is July 20th, 1997? +on page 9, +l. And the latest one there is April 11th, 2006; right? +l. Now, just to be clear, we talked about how late you +searched, 2010, but how early did you search the records? +A. 1994. January Ist, 1994. +l. And these are the first records that come up in that +system, going back to '94? +Q. Let's actually flip back to page 1, or I guess it's page 2 +of the exhibit, even though it's the first page, you'll see +that's a record for Jane. If you look down at the last one on +the page, the flight on January 6th, 1996 -- do you see that? +l. That is the earliest border entry in the TECS system for +Jane; correct? +Q. And you see the date of birth for Jane there. I don't want +you to say what it is, but do you see it? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 220 of 246 +LCGCmax6 +Aznaran - direct +2515 +Q. And if you can do the math, based on her date of birth, how +old was she when this flight -- when she made this border +crossing back in the United States? +A. 16. +e. Actually. You want to do the math again? It's date of +birth -- +MR. EVERDELL: I can say the year, can I not? +Q. Is it accurate to say that she would have been 15 when that +flight took place? +2. Then you look at the entry above that, that's the flight on +April 15th of 1996; right? +Q. And where did that flight arrive into? +A. Arrived into JFK. +l. Where did it depart from? +A. MXP, which is Milan, Italy. +l. Based on the date of birth, fair to say that Jane would +have been 15 when that flight took place? +l. And if you look at the flight above that, that's the flight +on June 21st, 1997; right? +l. And, again, based on the date of birth for Jane, she would +have been 16 when that flight took place; right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 221 of 246 +LCGCmax6 +Aznaran - direct +2516 +Q. Let's take a look at a few of +entries. +So flip to +page 7 of what's marked on the bottom right as page 7. +l. You see the entry there is November Ist of 1997; is that +right? +Q. Is that the earliest border entry in the TECS system for +? +l. And you see her date of birth over to the left? +2. Based on her date of birth, she would have been 20 years +old when that flight took place; is that right? +l. So does this report reflect that +had any border +crossings in 1994? +A. No. +l. Does it reflect any border crossings for | +in 1995? +A. No. +l. Does it reflect any border crossing records for l +in +1996? +A. No. +l. First one was that one in November Ist, 1997, when she's +20? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 222 of 246 +LCGCmax6 +Aznaran - cross +2517 +Q. Now I want you to flip to the last page. Those are the +records for +e. Why don't you look at +that last entry. That's a flight on +July 20th, 1997; correct? +Q. What city did this flight depart from? +A. DUS, which is Düsseldorf, Germany. +l. Where did it arrive? +A. EWR, which is Newark Airport, New Jersey. +l. Is this the earliest border entry in the TECS system for +in 1996? +A. No. +l. Does this report show any border crossings for +MR. EVERDELL: One moment, your Honor. +THE COURT: Okay. +MR. EVERDELL: No further questions, your Honor. +THE COURT: Ms. L +MS. +: Thank you, your Honor. +CROSS-EXAMINATION +BY MS. +2. Good afternoon. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 223 of 246 +LCGCmax6 +Aznaran - cross +2518 +A. Good afternoon. +Q. You've been testifying about CBP records of international +flights from the 1990s and 2000s; right? +l. In your work as a CBP officer, do you have experience +reviewing flight records from before September 11th, 2001? +Q. In your work as a CBP officer, do you have experience +reviewing flight records from after 9/11? +Q. Based on your review of CBP records in your experience as a +CBP officer, have you noticed a difference between CBP records +from before 9/11 and after 9/11? +l. What difference have you noticed? +A. Well, so if you - if you look at the records, not +necessarily these, but just in general, from my experience, +what I have noticed is the farther back you go from the present +time, the more likelihood that you are not going to get an +on-board or not-on-board status for those records. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 224 of 246 +LCGVMAX7 +Aznaran - cross +2519 +BY MS. +Q. As a CBP officer, is it important to your job to understand +whether the CBP records you are reviewing are thorough and +accurate? +Q. And in your day-to-day work as a CBP officer, do you rely +on CBP records from before 9/11 to be complete? +A. We'd like to rely on or hope that the records are complete, +but not necessarily all the time, no. +Q. And why is that the case that records before 9/11 are not +necessarily complete? +A. Prior to 9/11, there was a little bit of a difference +between how the records were submitted to CBP systems and the +reliability of the airlines was not as good as it is now or +after 9/11. +l. And when did that start to change in terms of when did the +records start to be more complete and thorough? +A. After 9/11, there were several acts put into place by the +U.S. Government. The Department of Homeland Security was +created. And basically, the airline industry was at one point +mandated now to submit more complete records to CBP. I feel +comfortable saying -- as far as the status indicators, I feel +comfortable saying roughly 2009, 2010, based on the records +that I have ran in my experience, you would see more onboard or +not onboard status. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 225 of 246 +LCGVMAX7 +Aznaran - cross +Q. I want to talk about people traveling into the United +States. In your work you refer to that as inbound travel, +right? +Q. Based on your review of CBP records and your experience as +a CBP officer, if someone was traveling into the United States +before September 11th, 2001, would CBP records necessarily +reflect that person's travel into the United States? +A. Not necessarily. +l. Can you explain why? +A. Once again, the recordkeeping and the way that the airlines +used to basically operate, I'1l go back to APIS, Advance +Passenger Information System. Prior to 9/11, it was voluntary +for airlines to submit their manifests to APIS. After 9/11 +and, more specifically, the +most recent update that I'm aware +of in, I believe it's 2005, mandated airlines to submit full +and complete manifests to CBP using the APIS system. +Q. I want to talk about when someone leaves the United States +and travels internationally. In your work, you refer to that +as outbound travel, right? +l. Based on your review of CBP records and your experience as +a CBP officer, if someone was traveling out of the United +States before September I1th, would CBP records necessarily +reflect that person's travel out of the United States? +2520 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 226 of 246 +LCGVMAX7 +Aznaran - cross +2521 +A. Not necessarily, no. +Q. And can you briefly explain why? +A. Once again, the airlines, it was a little bit of a +different -- different world before 9/11 happened. +Q. I want to turn to the records that defense counsel asked +you about during direct examination. +Can you be certain that all outbound travel before +9/11 for the listed individuals is reflected in those records? +A. No. +l. And again, briefly, why not? +A. I can't really say whether these records truly reflect +exactly any passenger's complete travel history. +l. Can you be certain that all inbound travel before 9/11 for +those individuals is reflected in these records? +A. No. +l. So it is possible that the people named in these records, +in fact, took international trips in the 1990s that are not +reflected in these records, right? +A. Possible. +l. I think defense counsel had pointed you to -- if we could +turn to page 9. We're in Defendant's Exhibit -1. +THE COURT: I can't quite hear you, Ms. +MS. +: I'm sorry. Defense Exhibit -1. +l. We're on page 9. And on the last line there is a flight on +July 20th, 1997. Do you see that? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 227 of 246 +LCGVMAX7 +Aznaran - redirect +2522 +l. And I believe that you testified that that was a flight +from Düsseldorf to Newark; is that right? +l. But there is no flight reflected here of Annie's trip to +Düsseldorf, right? +A. No. +Q. +So to be clear, these records are not necessarily an +exhaustive list of every time Jane, +, and Annie traveled +internationally before September I1th, 2001, are they? +A. Not necessarily, no. +MS. +: No further questions. +THE COURT: Mr. Everdell. +MR. EVERDELL: Redirect. +THE COURT: Okay. +REDIRECT EXAMINATION +BY MR. EVERDELL: +Q. Mr. Aznaran, you were asked some questions on +cross-examination about the completeness of the records, right? +2. And I think you mentioned that before 9/11, the airlines +weren't always as complete with providing manifests as they +were after 9/11; is that right? +l. But as we discussed, not all the information on this TECS + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 228 of 246 +LCGVMAX7 +Aznaran - redirect +report comes from the airlines, isn't that right? +A. Correct. +Q. You mentioned certain columns that came from the kiosks and +the people who actually swiped the passports in at the +immigration sites; is that right? +l. And so, in fact, the site that you discussed was the site +where people passed through? +Q. And that would get populated when that traveler went +through that site, right? +l. And the date and time you said should get updated with that +information of when that passenger goes through the site in the +TECS report if they go through that immigration site, right? +MS. +: Objection, your Honor. +If we can just place this in time. +Q. I'm talking about prior to 9/11. +A. I'm sorry, say the question again. +I. We're talking about records prior to 9/11. You said that +for any of these records, before 9/11 or not, the date and time +reflects the date and time -- first it reflects the date and +time of the flight. But if the person goes through an +immigration site, it then gets updated to reflect the time that +they went through the kiosk and got their passport stamped; +2523 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 229 of 246 +LCGVMAX7 +Aznaran - redirect +2524 +correct? +A. Correct. +Yes. +Q. And that is information that comes from the people on the +ground at the immigration sites, not from the airlines, right? +A. Not from the people, but from the actual kiosk, yeah, or +the -- the booth. +l. From the computer systems that they are working on, right? +A. Correct. +l. Okay. And so that's not dependent on whether the airlines +has given their manifests or not, right? +A. Correct. +l. Okay. So if we look at that last page again of the +-1, and let's just take an example. You see the +exhibit, +2000, for +second entry from the bottom, that's a flight on May 27th, +A. Correct. +l. And you see that there is a site listed there, right? +Q. That's Alpha 263, right? +l. And there is a date and time listed for that -- for that +border crossing, right? +l. Okay. And it's that site and that date and time would +reflect when they actually passed through immigration, right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 230 of 246 +2525 +LCGVMAX7 +Aznaran - recross +Q. That is not dependent on the airline information; correct? +A. Correct. +Q. All right. And if we look just down below at the entry for +the Düsseldorf flight that you were just asked about, right? +l. That also reflects a site, does it not? +l. And it reflects a date at least of that entry, right? +l. So that record reflects an actual border crossing at a site +in an immigration line at an airport for +doesn't +it? +l. Okay. And that is not dependent on the airlines, right? +A. No. Correct. +l. Okay. One moment, please. +THE COURT: Okay. +MR. EVERDELL: No further questions, your Honor. +THE COURT: Okay. +RECROSS EXAMINATION +BY MS. +l. In the 1990s, there were no digital kiosk stands, right? +A. There were no digital kiosk stamps? +e. Stands. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGVMAX7 +Document 761 Filed 08/10/22 Page 231 of 246 +Aznaran - recross +2526 +A. +stands? I -- I don't know. +Q. Well, it was paper records; correct? +MR. EVERDELL: Objection. Foundation. +THE COURT: Sustained. +Q. Officer Aznaran, based on your experience as a CBP officer +and your review of CBP records, the CBP records from the 1990s +were paper +records; correct? +MR. EVERDELL: Objection. Foundation. +THE COURT: Sustained. +MS. +: Your Honor, may I have just one moment +please? +THE COURT: Okay. +(Counsel conferred) +l. Officer Aznaran, do you know whether they were paper +records in the 1990s? +MR. EVERDELL: Objection. +Asked and answered. +THE COURT: Overruled. +A. I'm sorry, say the question again. +l. Do you know whether they were paper records in the 1990s? +l. And were they paper records? +l. And before 9/11, were paper records always logged in the +system? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 232 of 246 +LCGVMAX7 +Aznaran - recross +2527 +MR. EVERDELL: Objection. Foundation. +THE COURT: Sustained. +(Counsel conferred) +2. Do you know if in the 1990s, before 9/11, if paper records +were logged into CBP's system? +A. I would think that they were, but I'm not sure. +MR. EVERDELL: Objection. He's speculating. +THE COURT: Well, the answer is "I'm not sure," so -- +MS. +: Your Honor, may I have just one +moment? +THE COURT: Okay. +(Counsel conferred) +MS. +: Nothing further, your Honor. +THE COURT: Okay. +MR. EVERDELL: Nothing further, your Honor. +THE COURT: All right. Thank you, Mr. Aznaran. +You may step down. You are excused. +(Witness excused) +THE COURT: Defense may call its next witness. +MS. MENNINGER: Your Honor, at this time we call +Dominique Hyppolite. +DOMINIQUE HYPPOLITE, +called as a witness by the Defendant, +having been duly sworn, testified as follows: +THE COURT: Thank you. You may inquire, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 233 of 246 +LCGVMAX7 +Hyppolite - direct +2528 +Ms. Menninger. +MS. MENNINGER: Thank you, your Honor. +DIRECT EXAMINATION +BY MS. MENNINGER: +Q. Good afternoon, Mr. Hyppolite. +A. Good afternoon. +e. Where do you live? +A. In West Palm Beach, Florida. +l. In Florida? +A. Yes, +Q. And how long have you lived there? +A. Thirty-five years. +e. Where do you work? +A. With Palm Beach School District. +Q. And where is the Palm Beach School District located? +A. In Florida, 3300 Forest +Florida, 33406. +e. Thank you. +Boulevard, West Palm Beach, +And what is your title at the Palm Beach School +District? +A. As a specialist. +l. What are your job responsibilities? +A. I coordinate the processing of subpoenas and represent the +district as a record custodian for trial and depositions. +l. So you do subpoena responses for trials and depositions of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 234 of 246 +LCGVMAX7 +Hyppolite - direct +2529 +records from the Palm Beach County School District? +A. Students records. +Q. Student records? +l. Okay. Are you familiar with the way that school records +are kept for the Palm Beach County School District? +A. Yes, +l. And can you describe for the jury a little bit about how +student records are kept. +A. Each school has a data processor and record custodian +depend on the level. Elementary, they have data processor. +And middle school, they have - each grade has a -- someone +that takes care of records. And high school, they have record +custodian. +Q. And are the student's records entered into the system at +the time the student is there at the school? +A. Yes, +And the records follow the student. If the +student - when the student is in elementary school. And once +they pull more to middle, and then everything follow the +student. And there is no information on the student in the +elementary school. Middle, and then it's transferred to high +school. And then after three years, then the student leave the +school system, and then the records and -- are -- they send the +records to the district to be purged and kept at the district +level. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 235 of 246 +LCGVMAX7 +Hyppolite - direct +Q. Does the Palm Beach County School District keep some +electronic records of all students that have gone to school in +the district? +A. Yes. After three years, when the student withdraw from +Palm Beach -- from the schools, and then if the student is -- +exceptional student education, the schools keeps the record for +five years. If the student is a regular student, after three +years the records are purged and processed and kept at the +district. +l. And are they kept electronically? +A. Yes, +l. Are you able to go and search for a particular student's +name in the system? +A. Definitely, yes. I have access to that. +Q. And when you enter a student's name in the system, are you +able to pull up certain of their education records? +Q. Is that true even if the student went to school in the '90s +or the early 2000s? +A. Yes, +2. So does the Palm Beach County School keep records for +decades, for example, on students? +I. Are there certain records that they get rid of? I think +you said some were purged. +2530 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 236 of 246 +LCGVMAX7 +Hyppolite - direct +A. Yes, they keep the most significant information on the +student, and then they do that according to the procedures of +the school board of Palm Beach County. +Q. Great. And were you asked to search for certain student +files related to our case here? +A. Yes, +l. Did you put those students' name into the system and pull +up the records that the district still keeps for those +students? +A. Yes, +2531 +I. MENNINGER: Your Honor, may I approach with some +records? +THE COURT: Yes. Although it's 4:59, so are we +wrapping up? +MS. MENNINGER: I probably have 10 to 15 more minutes, +your Honor. +THE COURT: We'll have to break. +MS. MENNINGER: All right. +THE COURI: We'11 break here, members of the jury, for +the evening. Same schedule for tomorrow. Thank you so much. +See you then. +(Jury not present) +THE COURT: Mr. Hyppolite, the witness may step down +and out for the evening. Thank you. +(Witness not present) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 237 of 246 +LCGVMAX7 +Hyppolite - direct +THE COURT: Everyone may be seated. +All right. Matters to take up. +MS. +Your Honor, I would just note that we +previously offered to stipulate to this witness's testimony. +We're happy to stipulate to the remainder of it if he can be +released. I don't know whether the defense would like that. +They did us that courtesy with another witness from Florida who +had to stay overnight, so I wanted to offer it. +THE COURT: Thank you. +MS. MENNINGER: Thank you, your Honor. +I'll speak with the government afterwards about a +potential stipulation. +THE COURT: Okay. Thank you. +Other matters? +MS. +: Nothing from the government, your Honor. +MS. MENNINGER: No, your Honor. Just that we have +conferrals on the inconsistent statements we are planning to do +after we finish. +THE COURT: What I'd like is for you to identify what +remains in dispute. What time can I hear from you on that? +MS. MENNINGER: 7:30? +MS. +: That sounds reasonable to us, your Honor. +THE COURT: Okay. If there are issues that remain in +dispute, I guess I could ask for anything, just like a joint +chart that -- +2532 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 238 of 246 +LCGVMAX7 +Hyppolite - direct +2533 +MS. MENNINGER: Yes, your Honor. I think we can take +the same +chart we have both been working off of and just +eliminate the ones that are no longer -- or somehow with color +indicate the ones that are still in dispute. +THE COURT: Yes. Or give me a new chart with the ones +that are in dispute and each just very briefly state each +side's position. +MS. MENNINGER: Yes, your Honor. +MS. +| Yes, your Honor. +THE COURT: Okay. The only other thing - l right. +So I gave you till 6 o'clock on what I didn't recall +at the time. It was your response on the remaining witness. I +sort of staggered the response time on the motion to preclude +based on when we thought we would have witnesses. +So who remains in dispute who will be called tomorrow? +MS. MENNINGER: I think there were Eva, +and +Kelly. I think Mr. +• I believe, we're not calling. +MR. EVERDELL: That's right, your Honor. +MS. MENNINGER: So that one is no longer in dispute. +THE COURT: Okay. So you said Eva, +1. MENNINGER: Yes, your Honor. +THE COURT: So they will be called tomorrow if they +are not precluded. +MS. MENNINGER: Yes, your Honor. I believe so. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 239 of 246 +LCGVMAX7 +Hyppolite - direct +2534 +THE COURT: All right. +So I'll get the defense's response to the motion to +preclude on that this evening. +And so what is tomorrow looking like? +MS. MENNINGER: I think we will be done, your Honor. +I am looking at my co-counsel. We've had to -- we have to make +a couple of inquiries because your Honor ruled this morning on +anonymity, and there may be some other issues that we have to +figure out whether that will carry forward to Monday or not. +MR. EVERDELL: Your Honor, sorry to interrupt. +There may be one witness that does carry over to +Monday. We have to figure that out. But our goal, I think, is +to try to wrap up, with the exception of this one potential +witness, by tomorrow. +I have a moment? +THE COURT: Yes. +(Counsel conferred) +MR. EVERDELL: I think if we went over in the morning, +even if we had this one witness, it would be very brief, so we +could have almost a full day on Monday. +THE COURT: Okay. +So finishing tomorrow or a very short witness on +Monday means closings on Monday and then charge and to the +jury. Okay. I'll permit that so long as it does not interfere +with that schedule. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCGVMAX7 +Document 761 Filed 08/10/22 Page 240 of 246 +Hyppolite - direct +2535 +MS. STERNHEIM: It will not interfere, Judge. +THE COURT: Okay. +MR. PAGLIUCA: Your Honor, just -- +THE COURT: It's like I'm getting triple-teamed here. +I can barely keep up. +MR. PAGLIUCA: Sometimes five heads, six heads may be +better than one, sometimes maybe not. +But there is an issue about a government rebuttal +witness that I don't know if that's been resolved yet. And I +just wanted to lay that out there for the Court. +MS. +: Yes, your Honor. We are leaning against +calling that witness. We need to circle up as a team and we'll +have a final decision tomorrow morning for your Honor. I doubt +we will be calling any rebuttal witnesses. +THE COURT: Okay. I guess the only thing I would ask +you to consider is if we have time left over tomorrow, if there +is a very short witness on Monday, if perhaps the government +does intend to call a rebuttal, if you would consider using the +time tomorrow for the rebuttal, if that's acceptable to the +defense. +MR. PAGLIUCA: If there is going to be a rebuttal +witness, your Honor, there's going to be briefing on it +tonight. +THE COURT: I'm here all day. +When will you come to a decision? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 241 of 246 +2536 +LCGVMAX7 +Hyppolite - direct +MS. +Your Honor, I think we can come to a +decision tonight by 8 o'clock. I'll be with Ms. Menninger +until 7:30. At 8 o'clock. +THE COURT: All right. So by 8 o'clock. So if there +is, and that requires briefing, when will I get your brief, +Mr. Pagliuca? +MR. PAGLIUCA: 8:05, your Honor. +THE COURT: It's in the can. Glad to hear it. +I don't know if you are joking, actually. +MR. PAGLIUCA: No, I'm not joking, your Honor. 8:05 +is when you will get it. +THE COURT: Good deal. I like it. +Okay. A couple other odds and ends. +I got a letter yesterday from counsel for a potential +defense witness. As far as I could tell, there was no +application in the letter. I don't know if anyone has an +application. +MS. +: I don't believe there's any application +from that witness or from the government with respect to that +witness, your Honor. +MS. MENNINGER: We don't have it, your Honor. I don't +know what you're talking about. +THE COURT: One of you was co'd on it. +MS. +: I believe Ms. Menninger was cc'd on it. +May I confer? + + +Document 761 Filed 08/10/22 Page 242 of 246 +LCGVMAX7 +Hyppolite - direct +2537 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: You | +. MENNINGER: Your Honor, if we could consider +whether what we need to do as far as docketing that or making a +record about it, we could do it tomorrow morning at the 8:45 +mark. It may be important for a foundational -- an exhibit +that may be predicated on an unavailable witness, and that's +the only reason I am considering whether anything else needs to +happen. +THE COURT: Okay. You'll confer. +MS. MENNINGER: Yes. +MS. +Yes, your Honor. +THE COURT: Okay. But, as I said, I didn't understand +an application in that letter, so I'm not doing anything with +it. +MS. MENNINGER: Your Honor, we just needed a record of +that officially in case we needed it for a foundational +purpose, and so that was the reason that I had said if -- +THE COURT: Okay. If that becomes a judicial +document, if I use it in some way, it will be docketed. +MS. MENNINGER: Right. I understand. +MS. +: Yes, your Honor. +THE COURT: Okay. And then the only other thing I +want to ask about is defense counsel as to timing. It's +usually around here where I allocute the defendant as to their + + +Filed 08/10/22 Page 243 of 246 +LCGVMAX7 +Hyppolite - direct +rights. +2538 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MS. STERNHEIM: Judge, I would ask that we wait until +tomorrow please. +THE COURT: Okay. +MS. STERNHEIM: Thank you. +THE COURT: We will do that. +MS. +Just one quick question, your Honor. +THE COURT: Yes. +MS. +: Is there any sense of when we might expect +a draft of the jury charge? +THE COURT: It will be tomorrow. +MS. I +: Thank you, your Honor. +THE COURT: That's tonight's project for the 9 a.m. +conference. +I don't suppose anyone has a time estimate of +closings? +MS. STERNHEIM: What's a closing, Judge? +I don't think we have an idea yet. As soon as we +do -- +THE COURT: Do you prefer "summations"? +MS. STERNHEIM: I prefer that, too. I prefer actually +getting two cracks at it, like the government, but we'll be +sparse. I don't think we're in a position to inform the Court +yet. +THE COURT: Okay. But presumably we're looking at + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 244 of 246 +LCGVMAX7 +Hyppolite - direct +2539 +completing closings and the charge on Monday. +MS. STERNHEIM: Yes. +THE COURT: Okay. +I inquire, your Honor? In some +courtrooms I've been in there is a rule, perhaps not strongly +enforced, but strongly suggested, that the government only +reserve a certain portion of their summation for the rebuttal +piece because otherwise it ends up being a bit of a more in +rebuttal than in the actual substance. I don't know if your +Honor has that practice, but I would request that some +reasonable percentage be allocated to the first versus the +rebuttal portion. +MS. +: Your Honor, I expect the rebuttal will be +significantly shorter than the closing. I don't think that's +going to be an issue. +THE COURT: Well, it certainly should be. It should +be rebuttal and not -- +MS. +That's exactly right, your Honor. And +I'll be doing the rebuttal. I fully intend it to be much +shorter than the closing and to the point, as is consistent +with our office practice before your Honor and in this +district. +THE COURT: Okay. Anything else on that? +Let me just check my various inputs to see if I'm +missing -- check with my law clerk. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 761 Filed 08/10/22 Page 245 of 246 +LCGVMAX7 +Hyppolite - direct +All right. I don't have anything else. +So I will hear +from you this evening. You'll get the +charge tomorrow. And I'll see you at 8:45. Thank you. +(Adjourned to December 17, 2021 at 8:45 a.m.) +2540 + + + +2541 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +INDEX OF EXAMINATION +Examination of: +Page +Direct By Mr. Everdell . . +Cross By Ms. +RAGHU SUD +..........2327 +... ... +• .2386 +Direct By Mr. Everdell +. 2388 +Cross By Ms. +ELIZABETH LOFTUS +• • +..........2397 +Direct By Ms. Sternheim +Cross By Ms. +• • +Redirect By Ms. Sternheim +MICHAEL WILLIAM AZNARAN +Direct By Mr. Everdell . . +Cross By Ms. +Redirect By Mr. Everdell . +Recross By Ms. +DOMINIQUE HYPPOLITE +Direct By Ms. Menninger • +.2398 +.... +.2454 +.. .2482 +... . .....2486 +•2517 +.2522 +• .2525 +•2528 +DEFENDANT EXHIBITS + +CE3 through CE8 +RS-1 +• * +EF-1 +MA1 +Received +• 2363 +•2394 +• 2450 +• 2506 \ No newline at end of file diff --git a/vision-fixhub/court-05/5ca7b47be67005b89b78f43fa9ac497f6e1e01a082d7e77bc8e1d1a6471cda44.receipt.json b/vision-fixhub/court-05/5ca7b47be67005b89b78f43fa9ac497f6e1e01a082d7e77bc8e1d1a6471cda44.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f98cbdb9d1363aa6b462f17279a8e1f528d6de20 --- /dev/null +++ b/vision-fixhub/court-05/5ca7b47be67005b89b78f43fa9ac497f6e1e01a082d7e77bc8e1d1a6471cda44.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -25813, + "dataset": "marble-joined", + "doc_id": "5ca7b47be67005b89b78f43fa9ac497f6e1e01a082d7e77bc8e1d1a6471cda44", + "engine": "marble-apple-vision", + "event_count": 266, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "1cf481c52422f02658b16964240f6859dfb077dbdbab031d55f9177c393acb1e", + "output_sha256": "b90322360a903243b75d0c62c9d39929415de5b410f44ef7f4c40f7313a5181b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5cf5a99298d58a006de24340f0525cabf379a84b04ecfc9f15b0744773afb16b.md b/vision-fixhub/court-05/5cf5a99298d58a006de24340f0525cabf379a84b04ecfc9f15b0744773afb16b.md new file mode 100644 index 0000000000000000000000000000000000000000..1530262425fd0c79e6d2924d0b78366b7b512a31 --- /dev/null +++ b/vision-fixhub/court-05/5cf5a99298d58a006de24340f0525cabf379a84b04ecfc9f15b0744773afb16b.md @@ -0,0 +1,102 @@ +Case 1:22-cV-10904-JSR Document 268-57 Filed 08/07/23 Page 1 of 4 + + + +Case 1:22-cV-10904-JSR Document 268-57 Filed 08/07/23 Page 2 of 4 +From: +Sent: +To: +Subject: +Cecile de Jongh [ +@yahoo.com] +4/10/20126:21:34 PM +Jeffrey Epstein [jeevacation@gmail.com] +Re: Important - Private and Confidential +Importance: High +That's what John went with. +With warm regards, +Cecile +DISCLAIMER: The information contained in this e-mail may be privileged, confidential, and protected from +disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, +distribution or duplication of this communication is strictly prohibited. If you have received this +communication in error, please notify the sender immediately and delete all copies. +"Nearly all men can stand adversity, but if you want to test a man's character, give him power." - +Please consider the environment before printing this e-mail. +Lincoln +From: Jeffrey Epstein +To: Cecile de Jongh < +@yahoo.com> +Sent: Tuesday, April 10, 2012 2:20 PM +Subject: Re: Important - Private and Confidential +i would simply state that you are an office manager. +On Tue, Apr 10, 2012 at 2:04 PM, Cecile de Jongh < +Jeffrey, +@yahoo.com> wrote: +Please see below. Please see my answers in BOLD to the questions pertaining to FTC and me. +Forwarded message +From: Matthew Boyle < +@dailycaller.com> +Date: Tue, Apr 10, 2012 at 11:24 AM +Subject: URGENT REQUEST FOR COMMENT ON EDC BENEFITS/ICC VITELCO/OTHER +COMPANIES +To: "Jean P. Greaux, Jr." +@gmail.com> +Jean, +I've learned that ICCITELCO is in the process of applying for new EDC tax benefits - a 100 +percent exemption of all taxes, including income taxes. Attomey Marjorie Rawls +them with the application, and according to one of my sources, former Sen. Roosevel: Dashelping +helping as well. + +ESTATE_JPMO15014 + + +Case 1:22-cV-10904-JSR Document 268-57 Filed 08/07/23 Page 3 of 4 +My source adds that Gov. deJongh, who will ultimately approve the application or not approve it, is +pushing this application through the EDC, is using Mr. David to push the application through the +process. +In addition, it is estimated that those benefits - if Gov. deJongh ends up approving the application - +would amount to about $3 million per year that ICC/VITELCO would not have to pay in taxes. +Do you have any comment/response? +Also, at least as of September 13, 2011, Gov. deJongh's wife is listed in official EDC records as +being employed by convicted sex offender Jeffrey Epstein's Financial Trust Company, Inc. Her title, +according to the documents, is "manager." +Does Cecile deJongh still work for Mr. Epstein's company? If so, what is her role with the company +and did she have anything to do with Mr. Epstein's company getting EDC tax benefits? CECILE DE +JONGH CURRENTLY WORKS FOR FINANCIAL TRUST COMPANY IN THE CAPACITY +OF OFFICE MANAGER. SHE HAD NOTHING TO DO WITH FINANCIAL TRUST COMPANY +RECEIVING EDC TAX BENEFITS. +If not, when did she leave Mr. Epstein's company, what was her role when she was there and, once +again, did she have anything to do with Mr. Epstein's company getting EDC tax benefits? +My deadline is 5 p.m. today. +With warm regards, +Cecile +DISCLAIMER: The information contained in this e-mail may be privileged, confidential, and protected from +disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, +distribution or duplication of this communication is strictly prohibited. If you have received this +communication in error, please notify the sender immediately and delete all copies. +"Nearly all men can stand adversity, but if you want to test a man's character, give him power." - +Lincoln +* Please consider the environment before printing this e-mail. +***** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, +and +..... + +ESTATE_JPM015015 + + +Case 1:22-cv-10904-JSR Document 268-57 Filed 08/07/23 Page 4 of 4 +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved + +ESTATE_JPMO15016 diff --git a/vision-fixhub/court-05/5cf5a99298d58a006de24340f0525cabf379a84b04ecfc9f15b0744773afb16b.receipt.json b/vision-fixhub/court-05/5cf5a99298d58a006de24340f0525cabf379a84b04ecfc9f15b0744773afb16b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b5d65ee2092f4f8e8daece2b3046dc44c2020e32 --- /dev/null +++ b/vision-fixhub/court-05/5cf5a99298d58a006de24340f0525cabf379a84b04ecfc9f15b0744773afb16b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -95, + "dataset": "marble-joined", + "doc_id": "5cf5a99298d58a006de24340f0525cabf379a84b04ecfc9f15b0744773afb16b", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "5cf64e2264617c066068f739f0d4186cf8c2ee7a2f94ada208f665db28454ffa", + "output_sha256": "7bdf4fc648863b4a2976997649a75f9632e9d595662a1373d81d5b7dc4e9cd89", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5d009e832fa5df59c27de11b48a590f16bcf4e76004a347fce0477073ccb1de8.md b/vision-fixhub/court-05/5d009e832fa5df59c27de11b48a590f16bcf4e76004a347fce0477073ccb1de8.md new file mode 100644 index 0000000000000000000000000000000000000000..3c6233b59319e09fb2d2fbbea16b0ecf3438f844 --- /dev/null +++ b/vision-fixhub/court-05/5d009e832fa5df59c27de11b48a590f16bcf4e76004a347fce0477073ccb1de8.md @@ -0,0 +1,1511 @@ +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 1 of 27 +1 +N960gov0 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-X +GOVERNMENT OF THE UNITES +STATES VIRGIN ISLANDS +Plaintiff +JP +al. +v. +CHASE BANK N.A. et +Defendants +22 Civ. 10904 (JSR) +Oral Argument +-X +New York, N.Y. +September 6, 2023 +10:15 a.m. +Before: +HON. JED S. RAKOFF +District Judge +APPEARANCES +MOTLEY RICE +Attorneys for Plaintiffs +DAVID I. ACKERMAN +LINDA | +ELIZABETH BOGGS +WILLIAM H. NARWOLD +WILMER HALE +Attorneys for Defendants +FELICIA H. ELLSWORTH +ERIC HAWKINS + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 2 of 27 +N960govo +2 +(In open court; case called) +THE COURT: Counsel, please state your appearances. +Linda +• for the United States Virgin +Islands. +Virgin Islands. +MS. BOGGS: Elizabeth Boggs for the United States +MR. ACKERMAN: David Ackerman for United States Virgin +Islands. +MR. NARWOLD: Bill Narwold, Motley Rice for USVI. +MS. ELLSWORTH: Felicia Ellsworth for JP +Chase, +joined by my colleague Eric Hawkins, both from Wilmer Hale. +THE COURT: My courtroom deputy is absent today and my +law clerks are even apparently more technologically challenged +than I am, which is saying a good deal, but we need to move +this along. +So this is argument on the challenges under Daubert. +So my preliminary view is that none of these witnesses should +be admitted in any respect. It looks to me like they are +mostly either irrelevant, or testifying about matters that are +exclusively for the Court, or testifying about matters that are +solely within the prerogative of the jury. So I am inclined to +strike them all. But I will give you each an opportunity to +talk me out of it. +I will ask each side to pick which of their experts +they think is most clearly admissible, and tell me why. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 3 of 27 +N96Qgovo +3 +So starting with the government of the Virgin Islands. +MS. BOGGS: Good morning, your Honor. Professor Carr +is our human trafficking expert and all -- +THE COURT: So why is trafficking an issue in this +case? It's not in the statute, is it? +MS. BOGGS: Yes, your Honor. Sex trafficking, we need +to establish that there was a sex trafficking -- +THE COURT: Wait a minute. Let's take a look, what is +it, it's 18 U.S.C. -- give me the section again. +LAW CLERK: 1591. +THE COURT: I'm sorry? +LAW CLERK: 1591. +THE COURT: 1591. Thank you. +So I don't see anywhere in the actual language of the +statute the word "trafficking." It is in the title. Of +course, the law of the United States has been clear for a +hundred years that the titles are irrelevant. So I don't see +anywhere in the statute any reference to the term +"trafficking." Moreover, if it were in the statute, it would +be a legal term whose definition would be left to the exclusive +province of the Court. +MS. BOGGS: Your Honor, there are factual +determinations that need to be made about whether the +commercial sex was engaged in through force, fraud or coercion +for adults or whether there was just commercial sex with minors + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 4 of 27 +4 +N96Qgov0 +under the statute. +THE COURT: Those are everyday terms that a jury can +determine when properly instructed by the Court. I don't know +why we need an expert. +MS. BOGGS: Your Honor, in other cases they have used +experts to educate the jury about what human trafficking -- +THE COURT: Well, those are other cases not binding on +me. +MS. BOGGS: So in sex trafficking cases, there are a +lot of misconceptions about sex trafficking and what it lo0ks +like. For example, there are a lot of misconceptions that +human trafficking victims are going to not have freedom of +movement; that they're going to be locked in a room; that -- +THE COURT: So that is a question of law. If you +wanted - I, frankly, am not sure you're right in your +assumption, but assuming you were, you would be entitled to an +instruction to the jury that force, fraud, coercion or whatever +doesn't mean that they didn't have freedom of movement or +something like that. That's a question of law. I don't see +it's a question for an expert at all. +MS. BOGGS: I appreciate that — +THE COURT: If 500 experts testified that in their +opinion that was or was not an element of force, fraud or +coercion, I would have to strike all 500. They were invading +my province to tell the jury what the law is. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 5 of 27 +N96Qgov0 +5 +MS. BOGGS: Well, I think there's the law force, +fraud, and coercion, but what does that look like. In the +example I gave you -- +THE COURT: What do you mean what does that look like? +That's for factual evidence. These are not terms that are +exactly unknown to everyday citizens. Force, fraud, coercion +are terms that every member of the jury, every jury I've ever +had, understands from their everyday experience. But if they +need a more specific definition like fraud involves +misrepresentations or something like that, that's a legal +question, not an expert question. +MS. BOGGS: So, your Honor, I appreciate that, but in +other cases there has been a view that it's been helpful to the +jury to hear, for example, the bonds that can form and the +relationships or that victims may not act or look how you would +expect a victim to act. Having that on-the-ground information +about what human trafficking looks like, for example, having a +victim who may think she is -- +THE COURT: Let me make sure I understand the +argument. The argument is the functional equivalent if someone +was on trial for murder, you think an expert could be admitted: +Ladies and gentlemen, although I'm not speaking to the facts of +this case per se, because I have no personal knowledge of the +facts of this case, as an expert on murder, I want to tell you +how murders are often carried out. I can't believe any court + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 6 of 27 +6 +N96Qgov0 +in the United States would admit that, and certainly it doesn't +meet Daubert. +MS. BOGGS: Your Honor, I think that's a distinct +scenario. Here, sex trafficking is not very well understood so +the examples I have given you, there are a lot of popular +misconceptions, and that's something that both of the proffered +experts in this case agree -- +THE COURT: I don't agree. I don't know what their +basis is for saying that. But, in any event, as I say, if a +jury is under what you believe is a misconception, then you're +entitled to instruction to clean up or counteract those +misconceptions. Those are misconceptions about the meaning of +the statutory terms, which is a question of law. +MS. BOGGS: Well, Professor Carr will also talk about +red flags that are used in the field to see whether there's +human trafficking and to identify potential human trafficking, +and that's an industry standard that is also helpful to have an +expert's testimony so that we can identify particular red flags +in JP +documents. +THE COURT: Wait a minute this goes now to what JP +should have doped out? +MS. BOGGS: Well, it goes to that there were -- in the +field of human trafficking, there are certain red flags that +are indicative of human trafficking and whether or not -- first +establishing what those red flags. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 7 of 27 +N96Qgov0 +7 +THE COURT: Red flags indicative of human trafficking. +Remember, trafficking is not in the statute. So you think you +need an expert to tell what there -- there are red flags of +force, fraud, coercion, threats? Why isn't that just everyday +evidence about what happened in this case? +MS. BOGGS: Your Honor, for example, one of the things +that Professor Carr opines about is that JP +role in +setting up an account for young models at a private bank on +behalf of Jeffrey Epstein or at his request was indicative of +sex trafficking because the modeling industry is one way that +girls are sometimes recruited into sex trafficking and how that +should be a red flag for sex trafficking at a financial +institution. +THE COURT: So what element of your causes of action +is that related to? +MS. BOGGS: It relates both to the existence of a sex +trafficking venture that there was commercial sex engaged in +with force, fraud, or coercion or minors -- +THE COURT: So with respect to that, Mr. Epstein's +activity, the evidence is Mr. Epstein's activity, not whether +it suggested something in the abstract that was a red flag of +improper sex activity. Either he did it or didn't, which, to +be +I don't think should be very difficult for you to +prove in this case. But in any event, the relevant thing is +what he did. Okay. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 8 of 27 +N96Qgovo +8 +So then we turn to your second element, which is what +you think the bank should have figured out, right? +MS. BOGGS: That's correct. And so having an expert +talk through the role of how sex trafficking -- the red flags +and how it would present in these documents. +THE COURT: Red flags to whom? To bankers? +MS. BOGGS: Correct, within JP| +THE COURT: And which expert has the expertise in what +a banker should have perceived? +MS. BOGGS: Well, Professor Carr can opine about red +flags in human trafficking and -- +THE COURT: Yeah, well, I -- yes, and then I -- again, +it seems to me you're making -- and both sides are making much +more complicated what is a straightforward issue. Depending -- +and it's still part of the summary judgment motions that I have +to decide, but either you're going to have to show the bank +knew or recklessly disregarded evidence that their money was +being used to promote sex trafficking or you're going to have +to show that they knew or should have known that it was being +done. Under any of those standards, familiar standard +standards that have been part of the legal system for about a +thousand years, the question is what should a reasonable banker +in this position should have known, if it's the negligence +standard, or what should -- or what did in fact the banker know +or willfully disregard information actually given to him. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 9 of 27 +N96Qgov0 +9 +On the latter, I don't see the relevance of the expert +at all. On the former; that is to say the negligence standard, +I think the -- I don't see any of the experts really speaking +to that as opposed to just what they think in the abstract are +red flags of sex trafficking. +MS. BOGGS: Your Honor, the role of Professor Carr +would be to explain to the jury what are the red flags of sex +trafficking and also look through JP +documents. For +example, some of JP +own compliance policies talked +about sex trafficking and red flags for sex trafficking. And +so that would be the role here is to offer that expertise and +explain what they should have been looking for when they're +reviewing documents and how those red flags appear in this +case. +THE COURT: Do you agree that if I adopt on summary +judgment the argument made by your adversary, that the standard +is either that they knew or willfully -- recklessly disregarded +knowledge that their money was being used to promote sexual +misconduct, that what you just proffered would be irrelevant? +MS. BOGGS: No, your Honor. I think it would still be +helpful for the jury to be educated about the red flags of sex +trafficking so that they can identify along the documents of JP +-- +THE COURT: I think it's a complete diversion from the +facts of the case. But, all right, I hear your arguments. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 10 of 27 +N96Qgov0 +10 +Let me hear from defense counsel and their best shot. +MS. ELLSWORTH: Thank you, your Honor. We disclosed +four experts. Only three have been challenged by the +government of the U.S. Virgin Islands -- +THE COURT: As you may know, under Daubert, the Court +has an independent duty to conduct a rigorous analysis, so it +doesn't matter whether it's been challenged or not. +MS. ELLSWORTH: An expert they didn't challenge would +only be responsive to two of the experts that we challenged, +your Honor, and not Ms. Carr-- +THE COURT: So assuming I knock them out, two of yours +go. +MS. ELLSWORTH: It would be one I think, your Honor. +In any event, the expert that has been challenged by +the U.S. Virgin Islands that you heard briefing on that I would +submit doesn't fall prey to the any of the problems that you +correctly identified I think with Ms. Carr's report would be +Fonseca. He is a retired FBI agent who spent 20 plus +years conducting sex trafficking investigations. +THE COURT: Hang on one second. Let me look at my +notes on him. +MS. ELLSWORTH: Your Honor, in particular, if the +Court does not grant our summary judgment motion on the +obstruction count, Mr. Fonseca's testimony would be +particularly relevant. If the obstruction count is removed + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 11 of 27 +11 +N96Qgov0 +from the case, then I think we have to assess whether it would +be still be youthful to the jury to still hear from +Mr. Fonseca. +THE COURT: I'm sorry. I don't know why I'm having +trouble finding my notes on him but hang on. There it is. +So as I understand it, he is going to say that based +on his prior experience as a special agent, that filing +additional SARs by JP +would not have caused earlier +federal charges against Epstein to be filed. Putting aside +completely the hearing that occurred in my court yesterday in +which representatives of several government prosecution +agencies; namely, the New York City Police Department, the +Alcohol Tobacco and Firearms Agency, and the U.S. Attorney's +Office, said that the reason they had investigated Mr. X, the +defendant in another case before me, was because of the SARs +filed by a little-known bank called JP +Chase. Putting +that all aside, as I understand it, he has no prior experience +with SARs. +MS. ELLSWORTH: That's exactly the point, your Honor. +He has experience with sex trafficking investigations on behalf +of the Federal Bureau of Investigation. I expect his +testimony, if allowed to be presented, would cover the types of +material and information that he found useful as a special +agent who conducted actual sex trafficking investigations, +including the type of financial information that they might go + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cV-10904-JSR Document 329 Filed 09/15/23 Page 12 of 27 +12 +N960govo +out and seek in the course of an investigation, which would be +sought by subpoena and not by looking at regulatory filings +that might be might with another department. +THE COURT: I'm not sure what the relevance of this +is. The question if I -- if Mr. +in my hypothetical +purposely fails to bring to the attention of a government +agency as required, suspicious or even criminal activity, and +does so for the purpose of making sure that the government writ +large never finds out about this activity, what more is needed +for obstruction? +MS. ELLSWORTH: Well, I agree that that type of +purposeful conduct is what the U.S. Virgin Islands will have to +attempt to prove to make out their obstruction claim. What +Mr. Fonseca would testify to would be whether additional -- the +theory, as I understand it, that the plaintiff will seek to +establish at trial is that had JP +made additional +reports to the federal government, that somehow would have +spurred more investigation of Mr. Epstein or perhaps a sooner +investigation of Mr. Epstein. So in response to that theory, +Mr. Fonseca' testimony -- +THE COURT: But if they are charging obstruction even +from a civil standpoint, they still have to show intent. +MS. ELLSWORTH: Correct. +THE COURT: So they have to show that the reason these +SARs were not filed was because it was believed it would -- it + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 13 of 27 +13 +N960govo +might lead to government action, government criminal action. +MS. ELLSWORTH: I think that's right, your Honor. And +I won't re-argue the motion, but I don't see a world in which +they could possibly prove that. Putting that to the side -- +THE COURT: So assuming that's what they have to show, +what does it matter what a guy in the FBI years ago would have +done or would not have done? +MS. ELLSWORTH: Well, then I suppose if the +government -- if the plaintiff is held to not being allowed to +suggest to the fact-finder that filing additional reports would +have spurred some action, if they're not allowed to make that +argument, then maybe Mr. Fonseca's testimony which rebuts the +theory that additional federal reports would have somehow +spurred some different action, potentially then that testimony +would be -- +THE COURT: Well, yeah, I'm not going to deal today +with something that is implicit in any pretrial ruling that the +Court makes regarding evidence, which is if the door is opened +somehow by the other side, then stuff that is otherwise +irrelevant may become relevant. That's true of motions in +limine, and it's true of a Daubert motion as well. +But at least operate assumption which I think I will +hear from the defense, but I think is very likely where I am +not going to come out, which is they've got to show obstruction +intent to carry their burden on the -- to some -- you know, it + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 14 of 27 | +14 +N96Qgov0 +may be -- intent may include reckless disregard, but I'm not +sure it would be in the obstruction area. It probably would +just be intent straightforward, I don't see the relevance. +MS. ELLSWORTH: Well, I think, again, most of our +experts are responsive to the testimony that the Virgin Islands +would put on. +THE COURT: And I agree with you if I am persuaded +contrary to where I am leaning at moment to allow in some of +their experts, then to the extent your experts respond to what +I allow in, likely that your experts could be admitted too. +But at least at the moment I'm leaning the other way. +MS. ELLSWORTH: And the last point I would make about +Mr. Fonseca, your Honor, is the testimony that he would provide +would - putting aside the obstruction count, which may or may +not even be proceeding, to the extent the U.s. Virgin Islands +is arguing, as they have throughout this case, that the failure +by JP +to file enough reports or to include certain +information in those reports somehow creates either +participation in or knowledge of a sex trafficking venture as +they have to prove under the participant beneficiary liability +count, then Mr. Fonseca's testimony about the fact that that +was not information he ever used in his 23 years in the FBI and +not information that would have been relevant to the actual +federal criminal investigation of the sex trafficking, I think +could have -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 15 of 27 +N96Qgov0 +15 +THE COURT: Just out of curiosity, what is his -- what +does it matter whether he personally would have used this stuff +or not? He may have been a lousy investigator for all we know. +But his personal experience is not, I think, admissible under +Daubert. Under Daubert he has to identify a methodology that +would be used by law enforcement generally or something like +that, and I am not hearing where he says that. +MS. ELLSWORTH: Well, he's saying the FBI in his +division of the FBI this is what they did. So there's not +testimony from the U.S. Virgin Islands that says here's what +the FBI, you know, have a current - +THE COURT: Is that why they got so many cases wrong, +in all the instances of the Innocence Project has now shown +that they got wrong? That's an unfair comment, but I couldn't +resist. +But so how does he say -- when he's saying in his +experience the FBI doesn't look at this stuff -- +MS. ELLSWORTH: He's saying that — +THE COURT: -- and shame on the FBI if that's correct. +But anyway, if that's what he's saying, how does he know that? +Is that a policy of the FBI do not look at SARs? +MS. ELLSWORTH: What he's saying is that the FBI has +at its disposal lots of resources to obtain information, +including financial information when it's conducting an +investigation, and that it does not use these types of treasury + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 16 of 27| +16 +N960govo +reports for a sex trafficking investigation. Whatever the case +is that your Honor had yesterday doesn't sound like it was a +sex trafficking case. +THE COURT: No, it was an identity theft case, so +the -- and I am, you know, that was a separate case, but I +don't quite understand if -- supposing the SAR in my +hypothetical had said: We are very suspicious for the +following reasons that Mr. Epstein is using our money to engage +in sexual coercion of minors on a massive scale, and you're +saying that he will testify, "l +, we couldn't care less. We +don't want to know that. We would totally ignore that. We +wouldn't expect anyone to bring that -- in treasury to bring +that to our attention. We don't do that kind of inquiry." Is +that what he's going to say? +MS. ELLSWORTH: No, your Honor. I think what he would +testify to is that the way that a sex trafficking investigation +is conducted does not start nor finish nor is it particularly +aided by these reports to a completely different branch of +government that relate to financial regulations and not to sex +trafficking. What a sex trafficking investigation looks like +is interviews with victims and subpoenaing potential third +parties that might have information. JP +received-- +never +THE COURT: We all know what a great job they did with +Mr. Epstein. How many decades did they take to finally + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 17 of 27| +17 +N96Qgov0 +identify his misconduct? +All right. Thank you very much. Let me hear from +plaintiff's counsel on the point just raised. +MS. ELLSWORTH: Your Honor, do you want me to respond +to the argument about Ms. Carr or do you have on what you need +on Ms. Carr? +THE COURT: Let me hear from the other side on the +point you've just raised. +MR. ACKERMAN: David Ackerman. Good morning, Judge. +On the point just raised, I think you did hit the nail +on the head when you mentioned that he's testifying about his +own experience because that is all that Mr. Fonseca is doing. +He admitted in his deposition he didn't know what other FBI +agents were doing in other FBI field offices. I would also +note that although JP +briefing describes what they +claim is a truism, which is more information is better for law +enforcement, Mr. Fonseca for some reason is standing up and +saying the opposite, which is, well, we wouldn't want that +information. So those are the responses that I have. +THE COURT: Okay. All right. Yes? +: Your Honor, if I may speak to another of +the U.S. Virgin Islands' proposed experts Mr. Amador. +Linda +1, by the way. +So Mr. Amador serves I think a particularly important +function in this case. He is the certified forensic accountant + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 18 of 27| +18 +N960govo +presented by the U.S. Virgin Islands. This case, as your Honor +is well aware, involves financial records spanning from 2002 +through 2013 and then beyond. Financial information is +contained in monthly financial statements for more than 130 +different Epstein accounts. As JP +has acknowledged, +more a billion dollars of transactions flowed through those +accounts. Mr. Amador is the expert who uses his professional +experience to frame those financial transactions which are +really at the heart of the U.S. Virgin Islands' case. Those +are the kinds of voluminous records that particularly lend +themselves to an expert's presentation to the jury which would +otherwise have to sort through a dizzying array of financial +information. Mr. Amador has presented those financial +transactions, including extensive cash payments, payments to +women, other forms of payment in charts that we think will be +particularly helpful to the jury. +THE COURT: So a couple of questions about Mr. Amador +first. If I conclude as part of the rulings on summary +judgment that the standard is actual knowledge or reckless +disregard as opposed to negligence, what's the relevance of his +testimony? +: I think what Mr. Amador does is present +to the jury exactly the information that was available and +actually presented by JP | +including in its 2019 filing, +which we talked about with the Court last week. So I think he + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 19 of 27| +N960govo +is directly relevant to the reckless disregard standard. +THE COURT: Well, also, I mean, for example, as part +of his testimony, as I understand it, is that Mr. Epstein's +payments to lawyers were suspicious because they seemed like a +large amount of legal fees. +What possible relevance is that +and how is he arriving at that opinion? I would have thought +that counsel in this case are being paid such a huge amount +that we also should be very suspicious of all the lawyers in +this case. +19 +: If only, your Honor. We do not have that +problem, unfortunately. +So Mr. Amador serves two functions: One is the basic +presentation organization of the financial information. The +second is based on his experience as a certified forensic +accountant, he does identify unusual or exceptional +transactions. He presents a range of them that in particular +would have been available to the financial professionals and +compliance officials at JP +• The first is cash, of +obvious significance in Mr. Epstein's case, given his known +history of paying for victims and recruiters with cash. The +payments to women, which he observes, based again on his +experience as a certified forensic accountant, were +inconsistent with Epstein's business activities. And then he +also does talk about attorneys in a particular regard in light +of the other transactional information that was present in this + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 20 of 27 +20 +N960govo +case, but also the trend of it. And that's what Mr. Amador +talks about. +So one of the questions obviously at play in the +obstruction count is whether there was an ongoing +investigation. I would point out, by the way, that Exhibit 4 +to Ms. Ellsworth's declaration in this case also includes +information that that was an ongoing investigation because it +notes that victims were being interviewed, or at least one +victim in 2011. But put that aside, Mr. Amador is able to +observe based on his analysis of the financial records that if +he wasn't engaged -- if Epstein was not engaged in ongoing +traffic, then you would expect his legal expenses to decline +over time, but they didn't. And that itself was a red flag to +JP +that he continued to engage in conduct and was the +subject of ongoing investigation. +And Mr. Amador explained that that is the kind of +trend information both that he as a forensic accountant, and he +cites to standards that he applies, the American Association -- +I'm sorry - AICPA standards for forensic services. He also +cites to the FFIEC manual which points to the red flags that +banks should observe in monitoring or conducting due diligence +of financial accounts. And, again, excuse me, I lost my train +of thought. But, again, that goes directly to the reckless +disregard standard in this case, although we stand by our +argument that while we meet reckless disregard that the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 21 of 27 +21 +N96Qgov0 +standard here ought to be negligence for the -- +THE COURT: I haven't resolved that yet. I will +though as part of the summary judgment motion. +Okay. Let me hear from defense counsel. +MS. ELLSWORTH: So as to Mr. Amador, your Honor, as +just indicated, he purports to conduct a comparative +analysis of things that should have been suspicious or highly +unusual is another opinion he purports to offer, payments out +of the Epstein accounts without actually comparing them to +anything. He didn't compare Mr. Epstein's account activity to +any other account activity at the bank or to any other account +activity that he was familiar with in the course of his work. +He's a CPA. He's not a banker. The idea that somehow this +flow of funds, the trend, whatever it is that he purports to +identify, is suspicious or unusual, he doesn't have a basis to +make those sort of judgments or to offer that type of opinion +experience-wise. He also provides no comparator. So he +provides no suggestion that here's an account of similar +magnitude of funds, but we see fewer payments to lawyers, or +the payments to names that sound female are less than names +that sound male. He didn't even look at whether there were +male-sounding names that received payments out of the Epstein +account, and of course there were. So the whole sort of +comparative analysis that he purports to offer is both not +grounded in any reliable methodology but also not something on + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 329 Filed 09/15/23 Page 22 of 27 | +22 +N96Qgov0 +which he has any basis -- +THE COURT: It's a very funny argument that I +understand plaintiffs are saying, well, it's just one aspect of +his opinion, and I will look at all aspects, but to say that a +lot of payments to lawyers is somehow proof of anything, you +know, so it's clear that Donald Trump hasn't committed any +crime because he never pays his lawyers, +so -- but we will +regard that comment as facetious. +So, anyway, the -- but I understand your point. Okay. +Is there anything further that any one wanted to say +before we conclude this hearing? Yes? +: Your Honor, if I may just briefly respond +to counsel's points on that. +THE COURT: Yes. +cites no authority for the +proposition that a forensic analysis has to be comparative, and +I think there is none. In fact, the fact that everybody is +doing something, as I frequently told my children, is not proof +that it is an appropriate thing to do. You 100k at - +THE COURT: Are you offering yourself as an expert? +: No. My children would certainly come in +as adverse witnesses on that point. +You can certainly have conduct that is suspicious, +unusual, or exceptional in light of the prior history of that +customer in terms of their business purpose and in terms of the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 23 of 27 +23 +N96Qgov0 +bank's own knowledge. So I think the idea that this needed to +be comparative is simply unfounded. +I want to respond to the point on men because I know +JP +extends -- takes issue with that in their briefing. +Mr. Amador does testify that there was no trend with regard to +men that he observed in his analysis of data, and that in fact +the payments to men were smaller, they weren't round dollar and +repetitive, or of that kind of significant in volume, which I +think again goes to the point of why Mr. Amador's detailed +knowledge and expertise is useful to the jury to address those +kinds of misassertions. +In terms of other experts to present to your Honor, +taking your invitation very briefly, I do want to address the +U.S. Virgin Islands banking expert Professor Rush. And I +would, by the way, point your Honor to - with hesitancy point +your Honor to any legal cases, as I know you are so familiar +with them, but Sharkey v. JP +case is another case +against this defendant makes just this point; that there the +expert testified as to what conduct included "red flags of +possible fraud and/or money laundering in the financial +industry including incomplete due diligence, suspicious fund +transfer activity" -- +THE COURT: If I understand Mr. Rush's proposed +testimony, he is going to say that he looked at all of your +evidence, and that he concluded that it showed that Mr. -- I'm + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 24 of 27 +N960govo +sorry -- that the defendants had committed one violation or +another, and, I mean, that's the ultimate question for the +jury, is it not? +24 +: I don't believe so, your Honor. I think +what Professor Rush does importantly is explain, based on +regulatory guidance, prudent banking practice, and JP +own policies and procedures, first, again, what the red flags +of suspicious financial activity are that regulators advise +banks to monitor. These are reflected in complicated guidance +from regulators like the federal financial institutions +examination council which is not going to be familiar to +members of the jury. He explains what a financial institution +is expected to do when it observes those red flags. He +explains why SARs were untimely and inadequate in this case, +the importance of SARs to financial regulators. All of those +things are the kinds of evidence or expertise -- +THE COURT: Let me make sure I understand. Is he +saying that a banking employee would have seen these red flags +or is he saying that if they had had a better are detection +program in place, then they would have seen these red flags? +: He is saying that they would have seen +these red flags. +THE COURT: So what's his basis for saying all of +that? +He summarizes and explains —— + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cV-10904-JSR Document 329 Filed 09/15/23 Page 25 of 27 +25 +N96Qgovo +THE COURT: Is he a former banking employee? +: Not of JP +• your Honor. He was a +former compliance official at Wells Fargo, and he was the chair +of the interagency task force responsible for financial +enforcement in the federal government, so he understands these +issues as a regulator, as a prosecutor -- +THE COURT: Well, no, no. But I don't think a +regulator or prosecutor is relevant to what you just told me. +If his testimony is to say that a reasonable bank employee +would have seen these suspicious activities, which, by the way, +that would only be relevant if the standard was negligence, but +assuming for the moment the standard was negligence, then that +has to be based on his knowledge and experience of what a bank +employee would be called upon to see, do, whatever; not upon +what a law professor what see, do, or whatever or what someone +handling some commission would see, do, or whatever. +: Except, your Honor, to the extent that as +a regulator and prosecutor, and he was also head of corruption +and bribery at Wells Fargo, so did work in the private sector +in compliance, and as an academic understands what an effective +BSA-AML compliance program identifies to a bank, and that is +confirmed by the evidence that he will point to that shows that +it was observed. So it is framing the red flags that would +have been evident to JP +and then organizing the facts +that provide the basis for that opinion. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 26 of 27 +N960govo +26 +THE COURT: All right. Let me hear briefly from +defense counsel, and then I have another matter, telephone +conference at 11:00, so we need to bring this to a close. +MS. ELLSWORTH: Thank you, your Honor. I'll be brief. +Professor Rush is, like several of the other disclosed +experts of the U.S. Virgin Islands, serving merely as a +mouthpiece for counsel. He goes through emails and documents +and tells a narrative that is the U.S. Virgin Islands' theory +of the case. That is not the province of an expert. It is the +province of a fact-finder to look at those materials. +He also does not have experience in evaluating the +effectiveness or adequacy of BSA or AML compliance programs. +He was a federal prosecutor in fraud. He didn't do BSA-AML +compliance reviews. If he did, he did maybe one or two. Then +spent three years at Wells Fargo relatively recently, so not +during the time period in question when allegedly these +so-called red flags would have been apparent to JP +• So +I think the testimony is improper for a variety of reasons. +The first is it does not provide any expertise or +helpfulness to the jury. It is simply a recitation of evidence +that the jury can weigh itself. +Secondly, he doesn't actually have the relevant +expertise to provide the opinions he purports to offer. +And the third is to the extent he offers an opinion +that is within the province of expert testimony, it would be + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 329 Filed 09/15/23 Page 27 of 27 +27 +N96Qgov0 +simply that the BSA-AML program at JP +prior to 2013 was +not as good as it could have been, which would simply be a +negligence-type opinion which has no relevant to the claims in +this case which require, as your Honor questioning has +demonstrated, a knowing and intentional obstruction of some +sort of investigation, or a knowing and intentional violation +of the BSA as opposed to here we're talking about the IVPA. +The last point I would note is he also has this +impermissible attempt to calculate what the criminal sentence +would be under the United States Sentencing Guidelines. The +Court doesn't really need any help with that at all, but at a +minimum, that should certainly not be presented to the jury. +THE COURT: Yes, and I will put out of my mind when +addressing that particular question the fact that, as I have +stated at least 200 times now on the record, I regard the +Sentencing Guidelines as totally irrational. But that's a +separate issue. +Very good. Thanks so much. +(Adjourned) \ No newline at end of file diff --git a/vision-fixhub/court-05/5d009e832fa5df59c27de11b48a590f16bcf4e76004a347fce0477073ccb1de8.receipt.json b/vision-fixhub/court-05/5d009e832fa5df59c27de11b48a590f16bcf4e76004a347fce0477073ccb1de8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dec36ff6c12ba1b133b1ce34e2a5b1c724338d5d --- /dev/null +++ b/vision-fixhub/court-05/5d009e832fa5df59c27de11b48a590f16bcf4e76004a347fce0477073ccb1de8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1648, + "dataset": "marble-joined", + "doc_id": "5d009e832fa5df59c27de11b48a590f16bcf4e76004a347fce0477073ccb1de8", + "engine": "marble-apple-vision", + "event_count": 28, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "d381940acf88b8f641943b97825a46f00136d2a09fbf23290a663e5f8c938319", + "output_sha256": "a9e48f2e5dd692f3390cd61ea54a057ee849876af4b2b542500537f8e01d22f1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5d270401ad1f99b9bb11c27acd4298c64cc6892ab2d6a65753d29bc6a6d4f00c.md b/vision-fixhub/court-05/5d270401ad1f99b9bb11c27acd4298c64cc6892ab2d6a65753d29bc6a6d4f00c.md new file mode 100644 index 0000000000000000000000000000000000000000..2435a81f3eb518e62363e8fb386d5a25a85d7255 --- /dev/null +++ b/vision-fixhub/court-05/5d270401ad1f99b9bb11c27acd4298c64cc6892ab2d6a65753d29bc6a6d4f00c.md @@ -0,0 +1,33 @@ +Case 1:22-cv-10904-JSR Document 284-32 Filed 08/14/23 + + +FILED UNDER SEAL + + +Case 1:22-cv-10904-JSR Document 284-32 Filed 08/14/23 Page 2 of 2 +Date : 12/20/2019 4:00:21 PM +From: "Celina D. Morris" +To: "Cecile +Subject: Introduction to the VIEDA Business Ambassador +Attachment : Business Ambassador Introduction_Southern Trust. polf;image001.peg;insige002.png;insge003.png;image004.png; +Good day: +Season's Greetings from the U.5. Virgin Islands Economic Development Authority ("VIEDA")! +Attached is a letter from VIEDA CEO, Kamal +requesting your company's assistance with promoting the VIEDC tax incentive program, as +well as introducing you to our Business Ambassador, Yolanda Bryan. Ms. Bryan is available to assist you with any challenges you may +encounter as you do business in the U.S. Virgin Islands. She will be contacting you to schedule a meeting in the new year. Ms. Bryan can be +reached via email at ybryan@usvieda.org or by telephone at 340-773-6499 (office) or +Thank you for your time and consideration, and all the best for the coming year. +Regards, +Celina D. Morris +Executive Assistant to the CEO +Email: cmorris@uvieda.org +Phone: 340-714-1700 Ext 1113 +Fax: 340-774-0990 +www.usvieda.org +come belopment tolt, +BOOD Nisky Shopping Center, Suite 620 +St. +US. Virgin Islands 00802 + +ESTATE_JPM061123 diff --git a/vision-fixhub/court-05/5d270401ad1f99b9bb11c27acd4298c64cc6892ab2d6a65753d29bc6a6d4f00c.receipt.json b/vision-fixhub/court-05/5d270401ad1f99b9bb11c27acd4298c64cc6892ab2d6a65753d29bc6a6d4f00c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a0064ed3d2e6914812850d3dfbd268cde0a1c53a --- /dev/null +++ b/vision-fixhub/court-05/5d270401ad1f99b9bb11c27acd4298c64cc6892ab2d6a65753d29bc6a6d4f00c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -58, + "dataset": "marble-joined", + "doc_id": "5d270401ad1f99b9bb11c27acd4298c64cc6892ab2d6a65753d29bc6a6d4f00c", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "8688bedc23fb02337c0b98647cd740cee1efebc456a0f9d247f2528472b257d4", + "output_sha256": "53b2c652ccc38a03cb1b7700811ce081a4b84f25e0f2dd4a62735c60e1d42bd9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5d4383fbef86a250552b0556cc9cad3f9cc1ae9a357e6b24ad92a564e36cebbb.md b/vision-fixhub/court-05/5d4383fbef86a250552b0556cc9cad3f9cc1ae9a357e6b24ad92a564e36cebbb.md new file mode 100644 index 0000000000000000000000000000000000000000..aa44cdff26fa8b725adbff93c827e765f86a1715 --- /dev/null +++ b/vision-fixhub/court-05/5d4383fbef86a250552b0556cc9cad3f9cc1ae9a357e6b24ad92a564e36cebbb.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 265-46 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/5d4383fbef86a250552b0556cc9cad3f9cc1ae9a357e6b24ad92a564e36cebbb.receipt.json b/vision-fixhub/court-05/5d4383fbef86a250552b0556cc9cad3f9cc1ae9a357e6b24ad92a564e36cebbb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b7a97c78cb6434bf358ca25304fbe2716dd99b24 --- /dev/null +++ b/vision-fixhub/court-05/5d4383fbef86a250552b0556cc9cad3f9cc1ae9a357e6b24ad92a564e36cebbb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "5d4383fbef86a250552b0556cc9cad3f9cc1ae9a357e6b24ad92a564e36cebbb", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "d3274e1b3538c5ffdafbc960f0b74d25a4e2e242f7f8c6fb292e153e9fbfcff4", + "output_sha256": "7fefdbb9193e68aa1c3596250a49a61139584022b529888f1322350caeeeae81", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5d70300122fdad87aaa12e398d436e284d35c0d525757b841fb7a9bc4fa7fab4.md b/vision-fixhub/court-05/5d70300122fdad87aaa12e398d436e284d35c0d525757b841fb7a9bc4fa7fab4.md new file mode 100644 index 0000000000000000000000000000000000000000..d2596a6ff1a702c5487058c056ce3a437dae0b66 --- /dev/null +++ b/vision-fixhub/court-05/5d70300122fdad87aaa12e398d436e284d35c0d525757b841fb7a9bc4fa7fab4.md @@ -0,0 +1,1618 @@ +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 1 of 34 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +Case Number: 1:22-cv-10904-JSR +JAMES EDWARD STALEY +Third-Party Defendant. +DECLARATION OF MIMI LIU IN SUPPORT OF +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +MOTION FOR PARTIAL SUMMARY JUDGMENT +Pursuant to 28 U.S.C. § 1746, I, Mimi Liu, declare under penalty of perjury as follows: +1. +I am a member in good standing of the bars of the State of New York and the +District of Columbia. I am one of the attorneys representing the Government of the United States +Virgin Islands in the above-captioned action and have been admitted to this Court pro hac vice. I +am a Member of the law firm of Motley Rice LLC, 401 9th Street NW, Suite 630, Washington, +DC 20004. I am familiar with the facts set forth herein and if called as a witness, I could and would +competently testify thereto. I submit this declaration and the attached Exhibits in support of the +United States Virgin Islands' Motion for Partial Summary Judgment. + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 2 of 34 + +Number + + + + + + + + + +Attached hereto are true and correct copies of the following: +Description +Article by Kevin Breuninger, et al., JPMorgan Prepared to Pay $290 Million in +Settlement with Jeffrey Epstein Victims, CNBC (June 12, 2023), +https://www.cnbc.com/2023/06/12/jpmorgan-reaches-settlement-with-epsteinvictim-in-lawsuit.html. +JPM-SDNYLIT-W-00018180-00018196 produced by +JPMorgan in this Action and marked as Cutler Exhibit 38 at deposition. +Designated Confidential by JPMorgan pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +JPM-SDNYLIT-W-00002185-00002196 produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +JPM-SDNYLIT-00184442-00184461, JPM-SDNYLIT- +00184460-00184461 (excerpts) produced by JPMorgan in this Action, +designated Confidential by JPMorgan pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +August 10, 2019, email, | +JPM-SDNYLIT-00154364 produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Article by William K. Rashbaum, +Weiser, & Michael Gold, Jeffrey +Epstein Dead in Suicide at Jail, Spurring Inquiries, N.Y. Times (Aug. 10, 2019) +https://www.nytimes.com/2019/08/10/nyregion/jeffrey-epstein-suicide.html. +Document, "Risk Level & Designation Determination," New York State +Division of Criminal Justice Services, +https://www.criminaljustice.ny.gov/nsot/risk_levels.htm#f:~:text=Level7o20372 +0(high%20risk%20of,threat%20to%20public%20safety%2Oexists). +EVCP00000006 produced by nonparty Epstein Victims +Domestion Program (EVCO) i this Action, dosignate Confidential by +the EVCP pursuant to the Protective Order in this matter and filed under seal. +(Sealed] +Excerpt of Expert Report of Bridgette Carr, June 16, 2023. Designated +Confidential pursuant to the Protective Order in this matter and filed under seal. +2 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 3 of 34 + + + + + + + + + + + + + +LN_000001-000024 produced by a nonparty in this Action, +designated Confidential pursuant to the Protective Order in this matter and filed +under seal. [Sealed] +Document at JDoe_DBAG_010034-010044 produced by a nonparty in this +Action, designated Confidential pursuant to the Protective Order in this matter +and filed under seal. [Sealed] +Document at JDoe_DBAG_010023-010032 produced by a nonparty in this +Action, designated Confidential pursuant to the Protective Order in this matter +and filed under seal. [Sealed] +Document at JDoe_JPMC_007438-007448 produced by Plaintif Doe in +this Action, designated Confidential pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +JDoe_JPMC_007449-007464 produced by Plaintiff Doe in +this Action, designated Confidential pursuant to the Protective Order in this +matter and filed under seal. (Sealed] +Document at! +1 LC 000456-000476 produced by a nonparty in this Action, +designated Confidential pursuant to the Protective Order in this matter and filed +under seal. [Sealed] +Creditor's Claim on behalf of Jane Doe 981: In the Matter of the Estate of +Jeffrey Epstein, Superior Court of the Virgin Islands, March 12, 2020. +Creditor's Claim on behalf of 1 +In the Matter of the Estate of Jeffrey +Epstein, Superior Court of the Virgin Islands, November 26, 2019. +Complaint, Jane Doe No. 2 v. Epstein, No. 08-cv-80119 (S.D. Fla. Feb. 6, +2008). +Excerpt of Complaint, +y. Epstein, No. 10-cv-81111 (S.D. F1. Sept. 17, +2010). +Complaint and Demand for Jury Trial, Jane Doe No. 102 v. Epstein, No. 09-Cv- +80656 (S.D. Fla. May 4, 2009). +First Amended Complaint, Jane Doe 43 v. Epstein, No. 17-cv-616 (S.D.N.Y. +June 5, 2017). +ESTATE_000454, ESTATE 000464, +ESTATE 000466, ESTATE_000474, ESTATE_000500, ESTATE_000536 +produced by nonparty The Estate of Jeffrey E. Epstein in this Action, designated +Confidential pursuant to the Protective Order in this matter and filed under seal. +(Sealed] +3 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 4 of 34 + + + + + + + + + +Estate of efiey E. Epstein in this Action, designated Conte yount to +the Protective Order in this matter and filed under seal. (Sealed] +800256500257 prodied by nonparty yary visk in this Action, designated. +Confidential pursuant to the Protective Order in this matter and filed under seal. +[Sealed] +LV_000339-000340, LV_000362-00363, +LV_000381-000382, LV_000391-000392, LV_000401-000402 produced by +nonparty Larry Visoski in this Action, designated Confidential pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Flight manifests at?? +LV_000423-000424, LV_000429-000430, +LV_000473-000474, LV_000491-000492 produced by nonparty Larry vIsol +in this Action, designated Confidential pursuant to the Protective Order in thi +natter and filed under seal. [Sealed +Document at | JPM-SDNYLIT-W-00038289, JPM-SDNYLIT-W- +00038401-00038408 produced by JPMorgan in this Action, designated +confidential by JPMorgan pursuant to the Protective Order in this matter and +filed under seal. [Sealed] +Excerpts of JPMorgan Chase Bank, N.A.'s Responses and Objections to Third- +Party Defendant's (Staley) First Request for Admissions, No. 22-cv-10019-JSR, +dated May 22, 2023. +Document at JPM-SDNYLIT-00128026-00128033 produced by +JPMorgan in this Action, and previously marked as Pearn Exhibit 2 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +|JPM-SDNYLIT-00131915-00131916 produced by +Poorian indis Action, designated Confidential boy SMor +designated Confidential by JPMorgan pursuant to th +Due Diligence Report approved on April 14, 2011, | JPM-SDNYLIT- +4 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 5 of 34 + + + + + + + + +Transcript excerpts of the Deposition of Mary | taken April 7, 2023, in +this Action. JPMorgan has withdrawn its initial designation of Confidential for +the testimony contained in these excerpts. +Transcript excerpts of the 30(b)(6) Deposition of Senior Advisor, Risk and +Compliance, Francis Pearn, taken on March 29, 2023, in this Action. +JPMorgan has withdrawn its initial designation of Confidential for the +testimony contained in these excerpts. +Transcript excerpts of the Deposition of Vice Chairman and Banker, Private +Bank, William Marcus Sheridan, taken on July 12, 2023, in this Action. +Designated Confidential by JPMorgan pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +Transcript excerpts of Deposition of Private Bank Risk Manager, Kevin +McCleerey, taken on April 28, 2023, in this Action. JPMorgan has withdrawn +its designation of Confidential for the testimony contained in these excerpts. +Transcript excerpts of Deposition of former AML Compliance Manager, +Maryanne Ryan, taken May 24, 2023, in this Action, designated Contidential +in part by JPMorgan pursuant to the Protective Order in this matter and filed +under seal in part. [Sealed in part] +Due Diligence Report from Aug.-Sept. 2006, +JPM-SDNYLIT- +00037183-00037205, produced by JPMorgan in this Action, and previously +marked as +| Exhibit 17 at deposition. JPMorgan initially designated this +document Confidential pursuant to the Protective Order in this matter but has +withdrawn the designation in part and the document is filed under seal in part. +[Sealed in part] +Excerpt of Due Diligence Report requested February 22, 2011, L +JPM- +SDNYLIT-00013546, JPM-SDNYLIT-00013551, produced by JPMorgan in +this Action, and previously marked as Langford Exhibit 49 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +Excerpts of JPMorgan Chase Bank, N.A.'s Responses and Objections to +Plaintiff Government of the United States Virgin Island's First Request for +Admissions, No. 1:22-cv-10904 (JSR) (S.D.N.Y.), dated May 17, 2023. +JPMorgan initially designated this document as Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +5 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 6 of 34 + + + + + + +Article, After long probe, billionaire faces solicitation charge, The Palm Beach +Post (July 26, 2006), previously marked as Erdoes Exhibit 9 at deposition in this +Action. +Probable Cause Affidavit, Palm Beach Police Department, dated May 1, 2006, +and previously marked as Langford Exhibit 15 at deposition in this Action. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +July 28, 2006, article from ABC News: The Blotter, Warrants Were Prepared to +Arrest Others in Millionaire Sex Scandal, JPM-SDNYLIT-00269657- +00269658, produced by JPMorgan in the Action, designated Confidential by +JPMorgan pursuant the Protective Order in this matter and filed under seal. +[Sealed] +August 14, 2006, email, +JPM-SDNYLIT-00105859, produced by +JPMorgan in this Action, and a New York Post article by Dan Mangan, Mystery +Mogul's Teen-Sex Secret Bared in Probe, dated August 14, 2006, +http://www.nypost.com/news/regionalnews/mystery_moguls_teen_sex_secret_b +ared_in probe_regionalnews_dan mangan.htm, accessed April 4. 2023, +together previously marked as +[Exhibit 11 at deposition. JPMorgan +initially designated this document Confidential pursuant to the Protective Order +in this matter but has withdrawn the designation in part and the document 1s +filed under seal in part. [Sealed in part] +AML Operations Human Trafficking Overview, _ +|| JPM-SDNYLIT- +00174047-00174061, dated August 5, 2008, produced by JPMorgan in this +Action, and is an excerpt of a document previously marked as Langford Exhibit +14 at deposition. JPMorgan initially designated this document Confidential +pursuant to the Protective Order in this matter but has withdrawn the +designation for this portion of Langford Exhibit 14. +September 22, 2006, email and attachment, +JPM-SDNYLIT-00269393- +00269403, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant the Protective Order in this matter and filed under seal. +[Sealed] + + +July 26, 2006, email, | JPM-SDNYLIT-00099334, produced by JPMorgan +in this Action, and previously marked as Erdoes Exhibit 8 at deposition. +6 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 7 of 34 + + +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +Excerpts of Third-Party Defendant James E. Staley's Reponses and Objections +to United States Virgin Islands' First Set of Request for Admissions, dated May +22,2023. +May 21,2003, email, JPM-SDNYLIT-00137281, produced by +JPMorgan in this Action, and an article by Vickyl +1L, The Talented Mr. +Epstein, Vanity Fair (March 1, 2003), https://www.vanity +fair.com/news/2003/03/jeffrey-epstein-200303 (accessed March 31, 2023), +Exhibit 4 at deposition. JPM-SDNYLIT- + + + + +I JPM-SDNYLIT-W-00025790 - 00025790_003, produced +by JPMorgan in this Action, and previously marked as Dimon Exhibit 125 at +deposition. Designated Confidential by JPMorgan pursuant the Protective Order +JPM-SDNYLIT-W-00025792 - 00025792_003, produced +by JPMorgan in this Action, and previously marked as Dimon Exhibit 126 at +deposition. Designated Confidential by JPMorgan pursuant the Protective Order +Document at JPM-SDNYLIT-W-00025791 - 00025791 +_003, produced by +JPMorgan in this Action, and previously marked as Dimon Exhibit 127 a +deposition. Designated Confidential by JPMorgan pursuant the Protective Order +in this matter and filed under seal. Sealed] +Presentation, "Human Trafficking,"|||| JPM-SDNYLIT-00151917- + + +the designation. +Document at | JPM-SDNYLIT-00174386-00174391, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-W-00037475-00037476, produced by +IPMorgan in this Action, designated Confidential by JPMorgan pursuant th +rotective Order in this matter and filed under seal. [Sealed +7 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 8 of 34 + + + + + + +Expert Report of Jorge Amador, June 16, 2023. Designated Confidential +pursuant to the Protective Order in this matter and filed under seal. +Index of account statements for Epstein's JPMorgan account ending in 0438, +produced by JPMorgan in this Action." +Index of account statements for Epstein's JPMorgan account ending in 1001, +produced by JPMorgan in this Action." +Index of account statements for Financial Trust's JPMorgan account ending in +0001, produced by JPMorgan in this Action." +Index of account statements for Financial Trust's JPMorgan account ending in +5001, produced by JPMorgan in this Action." +1 JPM-SDNYLIT-00449033, produced by + + + + +Excerpts of JPMorgan Chase Bank, N.A.'s Responses and Objections to +Plaintiff Doe's First Request for Admissions, Case No. 1:22-cv-10019, dated +March 23, 2023. +Oct. 19-23, 2007, email thread with multiple attachments, +| JPM- +SDNYLIT-00269651-00269660, produced by JPMorgan in this Action, and +previously marked as Cutler Exhibit 8 at deposition. JPMorgan initially +esignated this document Confidential pursuant to the Protective Order in thi +natter but has withdrawn the designation in part and the document is filed unde +seal in part. [Sealed in part] +Account summary for account ending in 2810, +00091213, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +(Sealed] +Document at | JPM-SDNYLIT-00104316-00104317, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +"For all account statements, the Government is producing an index rather than attaching these +ocuments because they are voluminous (thousands of pages). The Government's SUF include +ables summarizing relevant information from the account statements. The Government wi +provide these documents to the Court at its request. +8 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 9 of 34 + + + + + + + + +January 14, 2011, email and attachment, | JPM-SDNYLIT-00152804- +00152806, produced by JPMorgan, and previously marked as Ryan Exhibit 34 +at deposition. JPMorgan initially designated this document Confidential +desigant to the Protective Order in this matter but has withdrawn the +JPM-SDNYLIT-00149696-00149700, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +February 9, 2004, Due Diligence Report, | JPM-SDNYLIT-00036564- +0036569, produced by JPMorgan in this Action, and previously marked a +Erdoes Exhibit 6 at deposition. JPMorgan initially designated this documen +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation in part and the document is filed under seal in part. [Sealed in +Document at | SDNYLIT-W-00041545-00041550, produced by JPMorgan +in this Action, designated Confidential by JPMorgan pursuant to the Protective +Order in this matter and filed under seal. [Sealed] +January 10, 2011, email, 1 +JPM-SDNYLIT-00152748_R, produced by +PMorgan in this Action, and previously marked as Cutler Exhibit 28 a +leposition. JPMorgan initially designated this document Confidential pursuan +to the Protective Order in this matter but has withdrawn the designation. +Document entitled, "Human Trafficking Finance: Nature, Scope and Control +Project, " November 2010. _ +JPM-SDNYLIT-00173973-00173992, +roduced by JPMorgan in this Action, and previously marked + +8 at deposition. JPMorgan initially designated this document Confidenti +pursuant to the Protective Order in this matter but has withdrawn th +lesienation in part and the document is filed under seal in part. [Sealed in +John Carney; Meet. +• Star Girl of the Raunchiest Part of +Epstein Scandal, Dealbreaker (July 28, 2006), +https://dealbreaker.com/2006/07/meet-| +-star-girl-of-theraunchiest-part-of-epstein-scandal, accessed July 1, 2023. +March 8, 2007, email and attachment, | JPM-SDNYL.IT-00001494- +00001496, produced by JPMorgan in this Action and previously marked as +Exhibit 15. JPMorgan initially designated this document Confidential +ursuant to the Protective Order in this matter but has withdrawn tr +esignation in part and the document is filed under seal in part. [Sealed i +9 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 10 of 34 + + + + + + + + + +JPM-SDNYLIT-00008237-00008240, produced by +Morgan in this action, and previously marked as (|| Exhibit 35 a +leposition. JPMorgan initially designated this document Confidential pursuan +to the Protective Order in this matter but has withdrawn the designation while +retaining its original redactions to the document. +Document at 1| JPM-SDNYLIT-00026318, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Oct. 17, 2006 Rapid Response Team memorandum, - +JPM-SDNYLIT- +00127953, produced by JPMorgan in this Action, and previously marked as +Erdoes Exhibit 3 at deposition. JPMorgan initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation. +Transcript excerpts of the Deposition of Risk Manager, Bonnie +I taken +May 10, 2023, in this Action, designated Confidential in part by JPMorgan +pursuant to the Protective Order in this matter and filed under seal in part. +JPM-SDNYLIT-W-00021995-00021996, produced by +JPMorgan in this Action, and previously marked as DeLuca Exhibit 29 at +deposition. Designated Confidential pursuant to the Protective Order in this +Currency Transaction Reports, produced by third-party the Financial Crimes +Enforcement Network ("FinCEN) in this Action. +July 16, 2008, email and attachment, JPM-SDNYLIT-00269718- +00269719, produced by JPMorgan in this Action, designated Confidential +pursuant to the Protective Order in this matter and filed under seal. [Sealed] +Document at || JPM-SDNYLIT-W-00021932-00021937, produced by +JPMorgan in this Action, and previously marked as McClecrey Exhibit 13 at +deposition. Designated Confidential pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-W-00021965-0021966, produced by +JPMorgan in this Action, and previously marked as Ryan Exhibit 23 at +Deposition. JPMorgan initially designated this document Confidential pursuant +**The Government is producing an index rather than attaching the currency transaction reports +because they are voluminous (nearly 700 pages). The Government's SUF includes tables +summarizing relevant information from the currency transaction reports. The Government will +provide these documents to the Court at its request. +10 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 11 of 34 + + + + + + + + +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +July 19,2013, email, +JPM-SDNYLIT-00100966, produced by JPMorgan +in this Action, and previously marked as Erdoes Exhibit 30 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +January 7, 2011, Rapid Response Team memo, | | JPM-SDNYLIT- +00127930-00127932, produced by JPMorgan in this Action, and previously +marked as Erdoes Exhibit 24 at deposition. JPMorgan initially designated this +document Confidential pursuant to the Protective Order in this matter but has +withdrawn the designation. +Document at | JPM-SDNYLIT-00230825-00230830, produced by +JPMorgan in this Action, designated Confidential pursuant to the Protective +Order in this matter and filed under seal. [Sealed] +Docunient at || JPM-SDNYLIT-00036884-00036890, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +JPM-SDNYLIT-W-00019086-00019096, produced by +spotion Detention petity rude cite Bai. 3 at +Order in this matter and filed under seal. [Sealed] +Transcript excerpts of Deposition of former CEO of Private Bank John +Jufly, taken July 13, 2023, in this Action. Designated Confidential b +PMorgan pursuant to the Protective Order in this matter and filed under sea +[Sealed] +Document at JPM-SDNYLIT-00006049-00006050, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +November 9, 2010, email, | JPM-SDNYLIT-00010814-0001080815, +produced by JPMorgan in this Action, and previously marked as I +[Exhibit +7 at deposition. JPMorgan initially designated this document Confidentia +ursuant to the Protective Order in this matter but has withdrawn th +designation in part and the document is filed under seal in part. [Sealed in +11 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 12 of 34 + + + + + +July 26,2006, email, +JPM-SDNYLIT-00099335, produced by JPMorgan +in this Action, and Palm Beach Post article by Larry | +After long probe, +Palm Beach billionaire faces solicitation charge, published July 26, 2006, at +http://www.palmbeachpost.com/pbccentral/content/local_new/epaper/2006/07/2 +6/slb_EPSTEIN_0726.html, accessed March 15, 2023 through +https://web.archive.org/web/20060929041447, together previously marked as +1! Exhibit 5 at deposition. JPMorgan initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation in part and the document is filed under seal in part. [Sealed in +September 20, 2007, emails, +JPM-SDNYLIT-000099500, JPM- +SDNYLIT-000099501, JPM-SDNYLIT-00390951, JPM-SDNYLIT- +00390952, produced by JPMorgan in this Action, and previously marked as +Staley Exhibit 14. JPMorgan initially designated these documents Confidential +designation in part ed to orients ate bur her sitart seated in +June 17, 2013, email and attachment, +JPM-SDNYLIT-00194342- +00194344, produced by JPMorgan in this Action, and previously marked as +DeLuca Exhibit 23 at deposition. JPMorgan initially designated this document +the didiptial pu in part and the docine t is rin hider seat bup at Vitate in +Jeffrey Epstein's 2007 Non-Prosecution Agreement, +JDoe_JPMC_003010-003023, produced by Plaintiff Jane Doe in this Action, +and previously marked as Erdoes Exhibit 39 in deposition. +JPM-SDNYLIT-00099526- +00099528, produced by JPMorgan in this Action, and previously marked as + + +July 1, 2008, email and attachment,|| JPM-SDNYLIT-00002952- +00002955, produced by JPMorgan in this Action, and previously marked as +Erdoes Exhibit 17 at deposition. JPMorgan initially designated this document +C'onfidential pursuant to the Protective Order in this matter but has withdrawr +the designation. +July 15, 2008, email and multiple attachments, JPM-SDNYLIT- +00003026-00003035, produced by JPMorgan in this Action, and previously +12 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 13 of 34 + + + + + + + + + +marked as +Exhibit 27 at deposition. JPMorgan initially designated this +document Confidential pursuant to the Protective Order in this matter but has +withdrawn the designation in part and the document is filed under seal in part. +[Sealed in part] +Sept. 9, 2010, email, +| JPM-SDNYLIT-00229703, produced by JPMorgan +in this Action, and previously marked as Cutler Exhibit 9 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +Transcript excerpts of the Deposition of former General Counsel Stephen +Cutler, taken May 24, 2023, in this Action. Designated Confidential in part by +JPMorgan pursuant to the Protective Order in this matter and filed under seal in +part. (Sealed in part] +March 16, 2011, email, | JPM-SDNYLIT-00274527-00274531, produced +by JPMorgan in this Action, and previously marked as Cutler Exhibit 29 at +deposition. JPMorgan initially designated this document Contidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +Oct. 6,2007, article, L +JPM-SDNYLIT-00036593, produced by JPMorgan +in this Action, and previously marked as +Exhibit 24 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +Oct. 26, 2007, email, +JPM-SDNYLIT-00001962-00001965, produced by +JPMorgan in this Action, and previously marked as + +leposition. JPMorgan initially designated this document Confidential pursuan +to the Protective Order in this matter but has withdrawn the designation. +Document at JPM-SDNYLIT-00002155, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant the Protective Order i +his matter and filed under seal. Sealed +July 31, 2010, email, L +JPM-SDNYLIT-00100251, produced by JPMorgan +in this Action, and previously marked as Erdoes Exhibit 23 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +Document at JPM-SDNYLIT-00011902, produced by JPMorgan in this +Action, designated confidential by JPMorgan pursuant to the Protective Order in +this matter and filed under seal. [Sealed] +August 4, 2010, article, [ +JPM-SDNYLIT-00036596-00036598, produced +by JPMorgan in this Action, and previously marked as + +deposition. JPMorgan initially designated this document Confidential pursuant +13 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 14 of 34 + + + + + + + + + +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. (Sealed in part] +March 7, 2011, email and attachment, JPM-SDNYLIT-00013499- +00013500, produced by JPMorgan in this Action, and previously marked as +Erdoes Exhibit 26 at deposition. JPMorgan initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation. +Document at JPM-SDNYLIT-00751685, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at ] +JPM-SDNYLIT-00751686, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Article by Dareh Gregorian, Second Girl Sues Mogul, New York Post (February +7,2008), https://nypost.com/2008/02/07/second -girl-sues-mogul/ (accessed +July 11, 2023). +Intentionally left blank. +Due Diligence Report, I +JPM-SDNYLIT-00036258-00036263, produced +by JPMorgan in this Action, and previously marked as Pearn Exhibit 17 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +October 22 - December 21, 2010, email thread, | JPM-SDNYLIT- +00194018-00194021, produced by JPMorgan in this Action, and previously +marked as DeLuca Exhibit 7 at deposition. JPMorgan initially designated this +locument Confidential pursuant to the Protective Order in this matter but has +withdrawn the designation +December 22, 2010, email, +| JPM-SDNYLIT-00152738-00152742, +produced by JPMorgan, and previously marked as DeLuca Exhibit 8 at +deposition. JPMorgan initially designated this document Contidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +December 23, 2010, email, L +JPM-SDNYLIT-00204777, produced by +JPMorgan in this Action, and previously marked as DeLuca Exhibit 10 at +deposition. JPMorgan initially designated this document Contidential pursuant +to the Protective Order in this matter but has withdrawn the designation while +retaining its original redactions to the document. +14 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 15 of 34 + + + + + + + +January 4, 2011, email, +JPM-SDNYLIT-00011967-00011968, produced +by JPMorgan in this Action, and previously marked as Exhibit 40 ar +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +January 6, 2011, email, JPM-SDNYLIT-00194062-00194063, produced by +JPMorgan in this Action, and previously marked as Ryan Exhibit 6 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +January 10, 2011, email and attachments, JPM-SDNYLIT-00157065_R- +00157082, produced by JPMorgan in this Action, and previously marked as +Ryan Exhibit 8 at deposition. JPMorgan initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation in part and the document is filed under seal in part. [Sealed in +Transcript excerpts of the Deposition of former head of Compliance at +JPMorgan, William Langford, taken on May 3, 2023, in this Action. J +JPMorgan has withdrawn its designation of Confidential for the testimony +contained in these excerpts. +Transcript excerpts of the Deposition of the Former Managing Director, +Global FIU Investigations, Phillip DeLuca, taken on April 19, 2023, in this +Action. JPMorgan has withdrawn its designation of Confidential for the +testimony contained in these excerpts. +March 12, 2013, email, || JPM-SDLIT-00194272-00194273, produced by +JPMorgan in this Action, and previously marked as DeLuca Exhibit 22 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in par +and the document is filed under seal in part. [Sealed in part] +"Bear Stearns Collapses, Sold to J.P. +Chase," available: +chase, accessed June 23, 2023. + + +Due Diligence Report, JPM-SDNYLIT-00037171-00037177, produced +by JPMorgan in this Action, and previously marked as | Exhibit 34 at +leposition. JPMorgan initially designated this document Confidential pursuant +15 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 16 of 34 + + + + + + + +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. (Sealed in part] +1L JPM-SDNYLIT-00373074-00373076, produced by +Protective Order in this dece and con under seal. eMergen pursuant to the +Arthur Middlemiss LinkedIn Profile, https://www.linkedin.com/in/arthurmiddlemiss-341aбb11/. +January 10, 2011, email, JPM-SDNYLIT-00157192-00157193, produced by +JPMorgan in this Action, and previously marked as Langtord Exhibit 3/ at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation while +retaining its original redactions to the document. +Document at || JPM-SDNYLIT-00373247, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. Sealed] +LJPM-SDNYLIT-00373248-00373252, produced by +JPMorgan in this Action, designated confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +Aug. 27, 2006, email, +JPM-SDNYLIT-00099337, produced by +JPMorgan in this Action, and previously marked as Erdoes Exhibit 1.0 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +Document at JPM-SDNYLIT-00106627, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. (Sealed] + + + +May 28, 2008, email, +JPM-SDNYLIT-00134475, produced by +JPMorgan in this Action, and previously marked as Erdoes Exhibit 44 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +Article by John M. Cunningham, Miley Cyrus, +http://www.britanica.com/biography/Miley-Cyrus, accessed July 12, 2023. +16 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 17 of 34 + + + + + + + + +February 9, 2011, email, L +JPM-SDNYLIT-00453044, produced by +JPMorgan in this Action, and previously marked as Ryan Exhibit 13 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +Article, Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, +Gawker, https://www.gawker.com/5751094/law--order-commemorates-jeffreyepsteins-taste-for-teen-hookers, accessed June 30, 2023. +November 29, 2011, email, | JPM-SDNYLIT-00100689, produced by +JPMorgan in this Action, and previously marked as DeLuca Exhibit 20 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +JPM-SDNYLIT-00100935-00100936, produced +by JPMorgan in this Action, and previously marked as Erdoes Exhibit 29 at +deposition. JPMorgan initially designated this document Contidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00755203, produced by +PMorgan in this Action, and previously marked as Staley Exhibit 1y a +leposition. JPMorgan initially designated this document Confidential pursuan +to the Protective Order in this matter but has withdrawn the designation. +July 10, 2010, email, +JPM-SDNYLIT-00008669-00008670, produced by +JPMorgan in this Action, and marked as Staley Exhibit 35 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00006171, produced by +JPMorgan in this Action, and previously marked as Dimon Exhibit 11 at +eposition. JPMorgan initially designated this document Confidential pursuar +o the Protective Order in this matter but has withdrawn the designatior +September 1, 2009, email, +ESTATE_JPM002773, produced by nonparty + +December 20, 2009, email and attachment, +| JPM-SDNYLIT-00006791- +10006792, produced by JPMorgan in this Action, and previously markea a +Stalev Exhibit 37 at deposition. JPMorgan initially designated this documen +Confidential pursuant to the Protective Order in this matter but has withdrawn +17 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 18 of 34 + + + + + + +the designation in part and the document is filed under seal in part. [Sealed in +Morgan in this Action, and marked Staly 5 hibit 21 at position. IP Morgar +initially designated this document Confidential pursuant to the Protective Order +in this matter but has withdrawn the designation in part and the document Is +filed under seal in part. [Sealed in part] +December 5, 2009, email and attachment, +JPM-SDNYLIT-00006715- +00006716, produced by JPMorgan in this Action, and marked as Staley Exhibit +38 at deposition. JPMorgan initially designated this document Confidential +ursuant to the Protective Order in this matter but has withdrawn th +lesignation in part and the document is filed under seal in part. Sealed " +| JPM-SDNYLIT-00006718-00006719, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Department of Financial Services announcement: "Superintendent Lacewell +Announces DFS Imposes $150 Million Penalty on Deutsche Bank in +Connection with Bank's Relationship with Jeffrey Epstein and Correspondent +Relationships with Danke Estonia and FBME Bank." Previously marked as +Cutler Exhibit 39 at deposition. +Consent Order, In the Matter of Deutsche Bank AG, et al., New York State +Department of Financial Services, signed July 6, 2020. Previously marked as +Cutler Exhibit 40 at deposition. +JPM-SDNYLIT-00921097, produced in Excel + + +Bank statement for account ending in 6312, +I JPM-SDNYL.IT-00085024- +00085031, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +[Sealed] +Bank statement for account ending in 4324, |||| JPM-SDNYLIT-00076877- +00076880, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +18 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 19 of 34 + + + + + + + + +Index of account statements for Epstein's JPMorgan account ending in 0663, +produced by JPMorgan in this Action. +Index of account statements for The C.O.U.Q. Foundation's JPMorgan account +ending in 1565, produced by JPMorgan in this Action." +Compilation of wire instructions, | JPM-SDNYLIT-00095431-95432; +JPM-SDNYLIT-00095431-95432; JPM-SDNYLIT-00095471; JPM- +SDNYLIT-00095709; JPM-SDNYLIT-00096355; JPM-SDNYLIT- +00097240; JPM-SDNYLIT-00097437-97438; JPM-SDNYLIT-00097820- +97821, produced by JPMorgan in this Action. Designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +(Sealed] +Account statement summary for account ending in 4810, JPM- +SDNYLIT-00091214, produced by JPMorgan in this Action, designated +Confidential by JPMorgan pursuant to the Protective Order in this matter and +filed under seal. [Sealed] +Documents related to Epstein's 2012 gift tax return, +MP-00000778- +00000832832, produced by nonparty Marks Paneth in this Action, designated +Confidential pursuant to the Protective Order in this matter and filed under seal. +[Sealed] +November 20, 2012, Private Bank Client Cash Transaction Guidelines, +JPM-SDNYLIT-00130224-00130226, produced by JPMorgan in this Action, +and previously marked as +Exhibit 32 at deposition. JPMorgan initially +designated this document Confidential pursuant to the Protective Order in this +matter but has withdrawn the designation. +Excerpt of document, +| JPM-SDNYLIT-W-00017133 - W-00017134, +JPM-SDNYLIT-W-00017206 - W-00017210, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. [Scaled] +JPM-SDNYLIT-W-00000001-00000002, JPM-SDNYLIT +-W-00000175-00000182 (excerpts), produced by JPMorgan in this Action, +previously marked as Dimon Exhibit 132 at deposition. Designated Confidential +by JPMorgan pursuant to the Protective Order in this matter and filed under + +Transcript excerpts of the Deposition of former Private Banker Paul Morris +taken April 18, 2023, in this Action. Designated Confidential in part by +JPMorgan pursuant to the Protective Order in this matter and filed under seal in +19 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 20 of 34 + + + + +Document, +"Wealth Management Top 25 Investor Clients," JPM. +SDNYLIT-00133088, produced in Excel format by JPMorgan in this Action, +and previously marked as Staley Exhibit 3 at deposition. JPMorgan initiall +designated this document Confidential pursuant to the Protective Order in this +matter but has withdrawn the designation in part and the document is filed under +October 2, 2006, email, | JPM-SDNYLIT-00001091-00001099, produced +by JPMorgan in this Action, and previously marked as Erdoes Exhibit 5 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +JPM-SDNYLIT-00105030, produced by +JPMorgan in this Action, and previously marked as + +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00448615-00448616, + + + + +July 15, 2008, Rapid Response Team memorandum, +JPM-SDNYLIT- +0127944, produced by JPMorgan in this Action, and previously marked a +rdoes Exhibit 18 at deposition. JPMorgan initially designated this documen +Confidential pursuant to the Protective Order in this matter but has withdrawn +Document at JPM-SDNYLIT-00003755-00003758, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +JPM-SDNYLIT-00011654-00011655, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +Document at | JPM-SDNYLIT-00754975-00754979, produced by +JPMorgan in this Action, and previously marked Staley Exhibit 4 at deposition. +PMorgan initially designated this document Confidential pursuant to the +rotective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +20 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 21 of 34 + + + + + + + + + + +July 3, 2013, email, +JPM-SDNYLIT-00029230, produced by JPMorgan +in this Action, and previously marked as Nelson Exhibit 7 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +Document at JPM-SDNYLIT-00394015-00394017, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Transcript excerpts of the Deposition of Justin Nelson, taken April 21, 2023, in +this Action. JPMorgan has withdrawn its designation of Confidential for the +testimony contained in these excerpts. +Third-Party Defendant James E. Staley's Responses and Objections to the +Government of the United States Virgin Islands' First Set of Interrogatories, +dated April 20, 2023. +January 23, 2008, email, |JPM-SDNYLIT-00002152, produced by +PMorgan in this Action, and previously marked as Dimon Exhibit 113 a +deposition. JPMorgan initially designated this document as Confidentia +pursuant to the Protective Order in this matter but has withdrawn the +designation in part and the document is filed under seal in part. [Sealed in +June 5, 2009, email, +JPM-SDNYLIT-00005959, produced by JPMorgan +in this Action. Designated Confidential by JPMorgan pursuant to the Protective +Order in this matter and filed under seal. (Sealed] +Excerpt of document at +JPM-SDNYLIT-00907707, produced in Excel +format produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this Matter and filed under seal. +(Sealed] +JPM-SDNYLIT-00006005, produced by +JPMorgan in this Action, and previously marked as Dimon Exhibit 101 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00004763, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00007534-00007535, produced by +IPMorgan in this Action, designated Confidential by JPMorgan pursuant to th +Protective Order in this matter and filed under seal. (Sealed] +21 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 22 of 34 + + + + + + + + + + +Document at || JPM-SDNYLIT-00007970, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at ||| JPM-SDNYLIT-00009703, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. (Sealed] +December 2, 2010, email, | ESTATE_006071, produced by nonparty The +Estate of Jeffrey E. Epstein. The Estate initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation in part and the document is filed under seal in part. [Sealed in +Document at |||| JPM-SDNYLIT-00011808, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +November: 23, 2013, email, +JPM-SDNYLIT-00153462-00153463, +produced by JPMorgan in this Action, and previously marked as Staley Exhibit +13 at deposition. JPMorgan initially designated this document Confidential +pursuant to the Protective Order in this matter but has withdrawn the +Document at | JPM-SDNYLIT-00102986, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. Sealed] +JPM-SDNYLIT-00102892-00102893, produced by +JPMorgan in this Action, and previously marked ||||| Exhibit 10 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +JPM-SDNYL.IT-00000184_R-00000186_R, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYL.IT-00099558-00099560, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Documents at SB-0001-0006, produced by nonparty Sergey Brin in this +Action, designated Confidential pursuant to the Protective Order in this matter +and filed under seal. [Sealed] + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 23 of 34 + + + + + + + + + + + +Documents at AUBURN-001-AUBURN-024, produced by nonparty +Larry Page in this Action, designated Confidential pursuant to the Protective +Order in this matter and filed under seal. [Sealed]. +JPM-SDNYLIT-00902708-00902714, +produced by JPMorgan in this Action, and previously marked as Staley Exhibit +10 at deposition. JPMorgan initially designated this document Confidential +pursuant to the Protective Order in this matter but has withdrawn the +designation in part and the document is filed under seal in part. [Sealed in +Document at JPM-SDNYLIT-00449185, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Orde +in this matter and filed under seal. [Sealed +Document at JPM-SDNYLIT-00390515, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00390516, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +1JPM-SDNYLIT-00390517, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +I JPM-SDNYL.IT-00390519, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +October 26, 2006, email, | +JPM-SDNYLIT-00099356, produced by +JPMorgan in this Action, and previously marked as Staley Exhibit 9 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +Document at | JPM-SDNYLIT-00390520-00390521, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00390522-00390523, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed +Document at | JPM-SDNYLIT-00390590-00390591, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +23 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 24 of 34 + + + + + + + + + + + +IJPM-SDNYLIT-00099423, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at | JPM-SDNYLIT-00134152, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +| JPM-SDNYLIT-00449668, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00449669-00449672, produced by +Do organ in this Action, designated Confidential by IPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +JPM-SDNYLIT-00390671, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +January 31, 2007, email, +JPM-SDNYL.IT-00390720, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00449037-00449038, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Mahmoud Difrawy LinkedIn Profile, available at: +https://www.linkedin.com/in/mahmoud-difrawy- +41889529/?originalSubdomain=uk. +JPM-SDNYLIT-00006724-00006725, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +December 8, 2009, email, +[ESTATE_JPM002897, produced by nonparty +The Estate of Jeffrey E. Epstein in this Action. The Estate initially designated +this document Confidential pursuant to the Protective Order in this matter but +has withdrawn the designation. +I JPM-SDNYLIT-00006727, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +24 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 25 of 34 + + + + + + + + + + +Document at JPM-SDNYLIT-00006729, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00101010-00101011, produced +by JPMorgan in this Action, and previously marked as Erdoes Exhibit 49 at +deposition. JPMorgan initially designated this document Confidential pursuan! +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. (Sealed in part] +July 10, 2012, email, LIII +JPM-SDNYLIT-00022569, produced by JPMorgan +in this Action, and previously marked as Erdoes Exhibit 31 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +JPM-SDNYLIT-00393112, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +| JPM-SDNYLIT-00028892-00028893, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00029911-00029913, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +Document at Apollo_VI_00000423, produced by nonparty Apollo Global +Management, Inc. in this Action, designated Confidential pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +Apollo_VI_00000646, produced by nonparty Apollo Global +Management, Inc. in this Action, designated Confidential pursuant to the +Protective Order in this matter and filed under seal. Sealed] +March 23, 2011, email, |||| JPM-SDNYLIT-00013841, produced by +JPMorgan in this Action, and previously marked as Staley Exhibit 12 at +leposition. JPMorgan initially designated this document Confidential pursuan +o the Protective Order in this matter but has withdrawn the designation in pat +and the document is filed under seal in part. [Sealed in part] +Document at JPM-SDNYLIT-00014260, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +25 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 26 of 34 + + + + + + + + + + +Document at JPM-SDNYLIT-00017368, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. [Sealed) +Excerpt of JPMorgan Chase Bank, N.A.'s Responses and Objections to Third- +'arty Defendant's First Set of Interrogatories, dated May 18, 2023. Designate +Confidential by JPMorgan pursuant to the Protective Order in this Matter anc +filed under seal. [Sealed] +JPM-SDNYLIT-00032344-00032346, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +JPM-SDNYLIT-00032434-00032435, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +September 30, 2014, email, +| JPM-SDNYLIT-00032511-00032516, +produced by JPMorgan in this Action, and previously marked as Nelson Exhibit +6 at deposition. JPMorgan initially designated this document Confidential, +pursuant to the Protective Order in this matter but has withdrawn the +designation. +April 21, 2023, email, L +| JPM-SDNYLIT-00032218-0003220, produced by +JPMorgan in this Action, and previously marked as Nelson Exhibit 5 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +Excerpt of JPMorgan Chase Bank, N.A.'s First Supplemental Responses and +Objections to Interrogatories in Lieu of Rule 30(b)(6) Deposition Testimony, +dated April 14, 2023. JPMorgan has designated portions of the document +Confidential pursuant to the Protective Order in this matter and the document is +filed under seal in part. +JPM-SDNYLIT-00030644-00030645, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +JPM-SDNYLIT-00031300, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00394592-00394593, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +26 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 27 of 34 + + + + + + + + + +Document at JPM-SDNYLIT-00032975-00032976, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +JPM-SDNYLIT-00033177-00033179, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +I JPM-SDNYLIT-00034618, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Urder +JPMorgan Chase Bank, N.A.'s Supplemental Responses and Objections to Doe +Plaintiff's First Set of Interrogatories, dated April 11, 2023. +Document at | JPM-SDNYLIT-00233394, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +| JPM-SDNYLIT-00233392, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00791467, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. (Sealed] +Document at L +JPM-SDNYLIT-00448060-00448065, produced by +JPMorgan in this Action, and previously marked as Dimon Exhibit 107 at +leposition. Designated Confidential by JPMorgan pursuant to the Protective +Order in this matter and filed under seal. [Sealed] +ESTATE_JPM010125-010128, produced by +nonparty The Estate of Jeffrey E. Epstein in this Action. The Estate initially +desienated this document Confidential pursuant to the Protective Order in this +matter but has withdrawn the designation in part and the document is filed under + + +JPM-SDNYLIT-00154163-00165164, produced by +JPMorgan in this Action, designated Contidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +February 15, 2005, email, | +JPM-SDNYLIT-00448590-00448591, +roduced by JPMorgan in this Action, and previously marked as Staley Exhib +at deposition. JPMorgan initially designated this document Confidentia +pursuant to the Protective Order in this matter but has withdrawn the +27 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 28 of 34 +designation in part and the document is filed under seal in part. [Sealed in + + + + + + + + + +June 16, 2004, email and attachments, | JPM-SDNYLIT-00448149- +00448196, produced by JPMorgan in this Action, and previously marked as +taley Exhibit 2 at deposition. JPMorgan initially designated this documer +onfidential pursuant to the Protective Order in this matter but has withdraw +Article by Andrew ||||| Sorkin and Landon ||| Jr., J.P.| Chase to +Acquire Bank One in S58 Billion Deal, New York Times (January 0 4,q004), +-to acquirebank-one-in-58-billion-deal.html. +Document at JPM-SDNYLIT-00724984-00725000, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +I JPM-SDNYLIT-00448780, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at JPM-SDNYLIT-00016246-00016256, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to tne +Protective Order in this matter and filed under seal. [Sealed] +Article by Reuters, J.P.L +to Buy Control of Hedge Fund, The New York +imes (Sept. 28, 2004), https: www.nytimes.com/2004/09/28/business/i1 +|||1-to-buy-control-of-hedge-fund.html, accessed July 20, 202 +Article, Purchase of Highbridge Capital Management, J.P, LI +/ (June 11, +2009), +https://web.archive.org/web/20120426055706/https://careers.jpmorganchase.co +m/cm. Previously marked as Staley Exhibit 17 at deposition. +JPM-SDNYLIT-00004787-00004789, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +August 8, 2006, email, L +JPM-SDNYLIT-00000254-00000255, produced +by JPMorgan in this Action, and previously marked as +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +28 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 29 of 34 + + + + + +Document at JPM-SDNYLIT-00026223, produced by JPMorgan in this +ction, and previously marked as Third-Party Exhibit 109 at the deposition o +ohn Duffy. Designated Confidential by JPMorgan pursuant to the Protectiv +Order in this matter and filed under seal. [Sealed] +Excerpt of "JPMC- Cumulative Privilege Log" (May 9, 2023), produced in +Excel format by JPMorgan in this Action, designated Confidential by JP Morgan +pursuant to the Protect Order in this matter and filed under seal. (Sealed] +Verified Complaint, Financial Trust Company, Inc. v. The Bear Stearns +Companies Inc.., 3:09-cv-00106-CVG-GWB (D.V.I. Div. St. I| +& St. +John, Aug. 5, 2009) +July 20, 2011, email, +JPM-SDNYLIT-00274561, produced by JPMorgan +in this Action, and previously marked as Cutler Exhibit 21 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation while +retaining its original redactions to the document +July 22, 2011, email, +JPM-SDNYLIT-00135958_R-00135958_R, + + + +|| JPM-SDNYLIT-00269848, produced in Excel format by +PMorgan in this Action, and previously marked as Langford Exhibit 45 a +leposition, JPMorgan initially designated this document Contidential pursuan +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +JPM-SDNYLIT-00230025- +00230028, produced by JPMorgan in this Action, and previously marked as +McCleerey Exhibit 25 at deposition. JPMorgan initially designated this +document Confidential pursuant to the Protective Order in this matter but has +withdrawn the designation in part and the document is filed under seal in part. +[Sealed in part] +July 22, 2011, email, L +TJPM-SDNYLIT-00754982-0075984, produced by +and the document is filed under seal in part. [Sealed in part] +29 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 30 of 34 + + + + + + + + + + +7/26/2011, email, | JPM-SDNYLIT-00136106, produced by JPMorgan in +this Action, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +[Sealed] +March 29, 2011, email, || JPM-SDNYLIT-00731610, produced by. +JPMorgan in this Action, and previously marked as Cutler Exhibit 30 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00790948_R-00790950 +_R, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00892560-00892561, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +August 16, 2010, email, +JPM-SDNYLIT-00752910-000752912, +produced by JPMorgan in this Action, and previously marked as Cutler Exhibit +20 at deposition. JPMorgan initially designated this document Confidential +pursuant to the Protective Order in this matter but has withdrawn the +designation while retaining its original redactions to the document. +February 6, 2011, email, +ESTATE_JPM-001591, produced by nonparty +The Estate of Jeffrey E. Epstein in this Action. The Estate initially designated +this document Confidential pursuant to the Protective Order in this matter but +has withdrawn the designation. +Document at JPM-SDNYLIT-00016652-00016654, produced by +JPMorgan in this Action. Designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at A JPM-SDNYLIT-00016924, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at GF000664-000670, produced by nonparty Bill & Melinda +Gates Foundation in this Action, designated Confidential pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at || GV000028, produced by nonparty Gates Ventures in this +Action, designated Confidential pursuant to the Protective Order in this matter +and filed under seal. [Sealed] +30 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 31 of 34 + + + + + + + + + + +Document at JPM-SDNYLIT-00133931-00133932, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00005844, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at 1 JPM-SDNYLIT-00010121-00010122, produced by +JPMorgan in this Action, designated confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +December 12, 2008, email, L JPM-SDNYLIT-00099627, produced by +JPMorgan in this Action, and previously marked as Erdoes Exhibit 41 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +Full Transcript: CNN Anchor Poppy Harlow's exclusive interview with +JPMorgan Chase Chairman and CEO Jamie Dimon, CNN (April 7, 2023), +cnnpressroom.blogs.cnn.com/2023/04/07/full-transcript-cnn-anchor-poppyharlows-exclusive-interview-with-jpmorgan-chase-chairman-and-ceo-jamiedimon. Previously marked as Cutler Exhibit 3 at deposition. +Excerpt of Expert Report of Shaun O'Neill, CPA, CFF, CFE, dated May 16, +2023. Designated Confidential pursuant to the Protective Order in this matter +and filed under seal. +Due Diligence Report, l +JPM-SDNYLIT-00149678-00149683, produced +by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to +the Protective Order in this matter and filed under seal. [Sealed] +March 1, 2011, email, L +JPM-SDNYLIT-00100422-00100423, produced +by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to +the Protective Order in this matter and filed under seal. (Sealed] +Article by Constant Méheut, Epstein Associate Is Charged with Rape of Minors +in France, New York Times (December 19, 2020), +https://www.nytimes.com/2020/12/19/world/europe/france-epstein-brunel.html +(accessed July 20, 2023). +Transcript excerpts of the Deposition of former U.S. Virgin Islands Attorney +General Vincent Frazer, taken on July 13, 2023, in this Action. +31 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 32 of 34 + + + + + + + + +2012 correspondence between Hodge & Francois and the Office of the Attorney +General of the Virgin Islands at || VI-JPM-000012484 - 0000125491. This +is an excerpt of | VI-JPM-000012328-000012522, produced by Plaintifi +Government of the United States Virgin Islands in this Action, and previously +marked as Frazer Exhibit 18 at deposition. +Transcript excerpts of the 30(b)(6) Deposition of U.S. Virgin Islands +Department of Justice Sexual Offender Registry Coordinator Shani Pinney, +taken on July 18, 2023, in this Action. +2012 correspondence between Hodge & Francois or Darren Indyke and the +Office of the Attorney General of the Virgin Islands at || VI-JPM- +000012246-000012250, VI-JPM-000012263-000012265, and VI-JPM- +000012268-000012272. These are excerpts of VI-JPM-000012328- +000012522, produced by Plaintiff Government of the United States Virgin +Islands in this Action, and previously marked as Frazer Exhibit 4 at deposition. +Transcript excerpts of the Deposition of former U.S. Virgin Islands Attorney +General Denise +, taken on July 17, 2023, in this Action. +Transcript excerpts of the Deposition of U.S. Virgin Islands Board of +Education Interim Executive Director and former Economic Development +Authority Compliance Officer U.S. Sandra Bess, taken on May 17, 2023, in +this Action. +Industrial Development Certificate for Financial Trust Company, Inc., March +22, 1999, LI +VI-JPM-000017992-000018004, produced by Plaintiff +Government of the United States Virgin Islands in this Action, and previously +marked as Bess Exhibit 1 at deposition. +Industrial Development Certificate (Extension) for Financial Trust Company, +Inc., effective January 1, 2012, I| +I VI-JPM-000017983-000017991, +broduced by Plaintiff Government of the United States Virgin Islands in this +Action, and previously marked as Bess Exhibit 2 at deposition. +Industrial Development Certificate for Financial Trust Company, Inc., October +25, 2012, || +TVI-JPM-000018005-000018014, produced by Plaintiff +Government of the United States Virgin Islands in this Action, and previously +marked as Bess Exhibit 3 at deposition. + +32 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 33 of 34 + + +Outline, "Jeffrey Epstein's EDC Companies," with handwritten notes, Hill +VI-JPM-000019063-000019067, produced by Plaintiff Government of the +United States Virgin Islands in this Action, and previously marked as +Exhibit 1 at deposition. +Outline, "Jeffrey Epstein's EDC Companies," VI-JPM-000019063 - +000019067, produced by Plaintiff Government of the United States Virgin +Islands in this Action, and previously marked as +n Exhibit 12 at +deposition. + + + + + + + +:VI-JPM-000016206-000016247, produced by +Plaintiff Government of the United States Virgin Islands in this Action, and +previously marked as +Exhibit 19 at deposition. +Transcript excerpts of the Deposition of U.S. Virgin Islands Governor Albert +Bryan, taken on June 6, 2023, in this Action. +Excerpt of transcript of Public Hearing of the Economic Development +Commission held February 12, 2009, +• VI-JPM-000016200-000016205, +produced by Plaintiff Government of the United States Virgin Islands in this +Action, and previously marked as Bryan Exhibit 1 at deposition. +Letter dated January 7, 2015, from Stephanie Berry to Jeffrey Epstein regarding +Southern Trust Company, +Estate_JPM018432, produced by nonparty +The Estate of Jeffrey E. Epstein in this Action, and previously marked as +Exhibit 32 at deposition. Designated Confidential pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Letter dated January 8, 2014, from Erika Kellerhals to Stephanie Berry +regarding Southern Trust Company, Inc., +VI-JPM-000040186, produced +by Plaintiff Government of the United States Virgin Islands in this Action. +Transcript excerpts of Deposition of U.S. Virgin Islands Congresswoman and +former Economic Development Authority Counsel Stacey Plaskett, taken on +May 9, 2023, in this Action. Designated confidential in part by Representative +Plasket pursuant to the Protective Order in this matter and filed under seal in +part. +Excerpt of transcript of Public Hearing of the Economic Development +Commission held February 12, 2009, L +| VI-JPM-000016200-000016205, +produced by Plaintiff Government of the United States Virgin Islands in this +Action, and previously marked as Plaskett Exhibit 2 at deposition. +33 + + +Case 1:22-cv-10904-JSR Document 245 Filed 07/25/23 Page 34 of 34 + + + + + + + +Transcript excerpts of Deposition of former Financial Trust Company and +Southern Trust Company Office Manager Cecile de Jongh, taken on May +29,2023, in this Action. +Transcript excerpts of the 30(b)(6) Deposition of U.S. Virgin Islands +Economic Development Authority Managing Director Margarita +, taken on July 14, 2023, in this Action. +Transcript excerpts of Deposition of U.S. Virgin Islands Superior Court +Judge and former Acting Attorney General Caroli +i, taken on +July 13, 2023, in this Action. +May 13-15, 2013, email thread regarding Quick response re: TOEFL, HI +ESTATE_JPM024114-024118, produced by nonparty The Estate of Jeffrey E. +Epstein in this Action, and previously marked as C. de Jongh Exhibit 25 at +deposition Designated Confidential pursuant to the Protective Order in this +matter and filed under seal. Sealed +August 28, 2008, email, +JPM-SDNYLIT-00003706_R, produced by +JPMorgan in this Action, and previously marked as +• Exhibit 29 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +July 10-11, 2011, emails and attachment, +JPM-SDNYLIT-00110055- +00110056 and JPM-SDNYLIT-00100548-00100549, produced by JPMorgan +in this Action, and previously marked as Third-Party Exhibit 85 at the July 12, +2023, deposition of Mary Erdoes. Designated Confidential by JPMorgan +pursuant to the Protective Order in this matter and filed under seal. (Sealed] +Photograph, previously marked as Third-Party Exhibit 85B at the July 12, 2023, +deposition of Mary Erdoes. Designated Confidential pursuant to the Protective +Order in this matter and filed under seal. [Sealed] +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true +and correct. +Dated: July 24, 2023 +Mimi Liu \ No newline at end of file diff --git a/vision-fixhub/court-05/5d70300122fdad87aaa12e398d436e284d35c0d525757b841fb7a9bc4fa7fab4.receipt.json b/vision-fixhub/court-05/5d70300122fdad87aaa12e398d436e284d35c0d525757b841fb7a9bc4fa7fab4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e5542b3d523eb9d9fb2a3a0645e5fbbab4b0c9b7 --- /dev/null +++ b/vision-fixhub/court-05/5d70300122fdad87aaa12e398d436e284d35c0d525757b841fb7a9bc4fa7fab4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -5412, + "dataset": "marble-joined", + "doc_id": "5d70300122fdad87aaa12e398d436e284d35c0d525757b841fb7a9bc4fa7fab4", + "engine": "marble-apple-vision", + "event_count": 350, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "23e0c84d0180b10bd3585d0c1983c96e4ec90861cb353e583b18afda139b5ddf", + "output_sha256": "76e02e47735fe90d08b9701001ee3271e0233f96158a48592671728afe251139", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5d9059f54b296a9b86d4d91f87cb3924708f2240ec257467bf90c7e7ff77e495.md b/vision-fixhub/court-05/5d9059f54b296a9b86d4d91f87cb3924708f2240ec257467bf90c7e7ff77e495.md new file mode 100644 index 0000000000000000000000000000000000000000..1a0a59147772617161d40c05062cd19ff780db85 --- /dev/null +++ b/vision-fixhub/court-05/5d9059f54b296a9b86d4d91f87cb3924708f2240ec257467bf90c7e7ff77e495.md @@ -0,0 +1,602 @@ +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 1 of 14 + + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 2 of 14 +UNITED +SIATES VIRGIN 174ARDY +Economic Development Authority +WWW.USVIEDA.ORG 1877432-8784 +January 31, 2014 +Mrs. Cecile deJongh +Office Manager +6100 Red Hook Quarter B3 +St. +VI 00802 +Re: Financial Trust Company, Inc. +Dear Mrs. deJongh, +A compliance review has been completed on Financial Trust Company, Inc. Enclosed for your +review and commentary is the compliance report which covers the period January 1, 2007 to +December 31, 2008. The company was found out of compliance with the procurement requirements. +Please provide a response to this compliance report within thirty (30) working days of receipt of this +correspondence. You may request an extension of time to file your response by submitting a formal +notice. If we do not receive a response from you by this date, we will conclude that you are in +agreement with the findings of this report. +Should you have additional questions concerning this matter, please do not hesitate to contact +Stephanie Berry, Director of Compliance at 340-773-6499. +Sincerely, +Cc: +Clouden, Chief Executive Officer +Tracy +Bhola, Legal Counsel +Stephanie J. Berry, Director of Compliance +Sandra Bess, CCP Compliance Officer +Erika Kellerhals, Legal Counsel for FTC +Ecanomic Develapment Commission +Enterprise lane Commission +Street, Frederiksted, USVI 00840 (340) 775-6499 FAX (340) 773-7701 ST. +Goversment Development Bank +Industrial Park Development Corporation +8000 Nisky Shopping Center Suite 620, St. +Small Business Developm +USMI 0080Z (340) 714-1700 FAX +VI-JPM-000023078 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 3 of 14 +STATES VIRGIN IS1 +Economic Development Authority +WWW.USVIEDA.DRG : 877 432-8784 +CONFIDENTIAL COMPLIANCE REPORT +FINANCIAL TRUST COMPANY, INC. (INACTIVE) +As of December 31, 2008 +SUMMARY HIGHLIGHT: +• Financial Trust Company, Inc. received nine (9) years of tax benefits. +• A compliance review was completed on April 17, 2008, covering the period of April 1, +1999 through December 31, 2006. This review covers the period January 1, 2007 to +December 31, 2008. +• The Beneficiary met the capital investment of $300,000 as of December 31, 1999. +• Capital Expenditures from 2007 to 2008 were $76,806 of which 42% ($39,634) was +procured locally. +• Goods and Services from 2007 to 2008 were $1,404,02l of which 69% ($965,657) was +procured locally. +• The Beneficiary met its employment requirement of 11 full-time employees. +• The Beneficiary met its residency requirement. +• The Beneficiary met the 20% management, supervisory and/or technical requirement. +• The Beneficiary met the requirements of Special Conditions one through five. +• The Beneficiary did not comply with the requirements of the procurement process. +• The Beneficiary met the reporting requirements. +Economit Development Commission +Esterprise Zone Commission +ST. CROIX 116 +Street, Frederiksted, USVI 00840 (340) 773-6499 FAX (340) 773-7701 ST. +Government Development Bank +Industrial Park Develapment Corperation Small Business evelopment Agency +_8000 Nisky Shopping Center Suite 620, St. Themas, USVI 00802 (340) 714-1700 FAX (340) 715-2753 +VI-JPM-000023079 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 4 of 14 +As of December 31, 2008 +Title 29, Chapter 12 VIC, Section 715(a) states in part "upon proper application or reapplication, +public hearing and in compliance with all other relevant provisions of this chapter pertaining to +the grant of initial benefits, as determined and required by the Commission, any recipient of +industrial development benefits (sic), may be granted an extension, modification, or renewal of +benefits..." +HISTORY: +On November 6, 1998, Financial Trust Company, Inc. filed Articles of Incorporation with the +Office of the Lieutenant Governor. Then on November 30, 1998 Financial Trust Company, Inc. +obtained a Certificate of Incorporation authorizing them to conduct business in the Virgin +Islands. On February 22, 1999, Financial Trust Company, Inc. completed an application to the +Economic Development Commission "EDC", and was approved for tax benefits by the Governor +of the Virgin Islands on November 26, 1999. +The Chairman of the EDC Board of +Commissioners executed a certificate of benefits on March 21, 2000. +Financial Trust Company, Inc. was granted tax exemption benefits "to conduct the business of +financial and economic consulting, money management, investment advisory and fiduciary +services for its clients. +Such clients include individuals, trusts, foundations and business +entities," excluding residents of the United States Virgin Islands. Benefits were granted for a +period of ten (10) years commencing and terminating as follows: +Income Taxes +Gross Receipt Taxes +Excise Taxes (Raw Materials) +Excise Taxes (Equip., Mach.) +Dividend Withholdings +Interest Withholdings +Real Property Tax +COMMENCEMENT +April 1, 1999 +April 1, 1999 +January 1, 2000 +January 1, 2000 +April 1, 1999 +April 1, 1999 +January 1, 2000 +TERMINATION +March 31, 2009 +March 31, 2009 +December 31, 2009 +December 31, 2009 +March 31, 2009 +March 31, 2009 +December 31, 2009 +The Beneficiary, Financial Trust Company, Inc. received nine (9) years of benefits. +INVESTMENT: +"The Beneficiary shall invest in this business in the Virgin Islands of the United States not less +than the amount of U.S. $300,000 excluding inventory, no later than one year from April 1, +1999." + +2| Page +VI-JPM-000023080 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 5 of 14 +As of December 31, 2008 +FINDINGS: +The investment requirement of $300,000 was met as of December 31, 1999, which was reported +by the previous compliance review. For the period covered in this review, the Beneficiary made +additional capital investments totaling $76,806. +CAPITAL EXPENDITURES: +ELIGIBLE VI +YEAR +2007 +2008 +SUPPLIER +-0. +-0- +TOTALS +VI +SUPPLIER +$ 29,925 +9,709 +$ 39,634 +NON-VI +SUPPLIER +-0- +$ 37,172 +$ 37,172 +TOTAL +$ 29,925 +46,881 +$ 76,806 +FINDINGS: +From 2007 to 2008, a total of $76,806 was procured in capital expenditures. Of the total +CAPITAL EXPENDITURES +2007-2008 +48% +• VI Supplie +52% +• Non-Vi Suaplier + +3|Page +бр +VI-JPM-000023081 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 6 of 14 +As of December 31, 2008 +GOODS AND SERVICES: +YEAR +2007 +2008 +TOTAL +ELIGIBLE +VI +VI +SUPPLIER | SUPPLIER +$ 39,764 +$ 446,126 +57,252 +422,515 +$ 97,016 +$ 868,641 +NON-VI +SUPPLIER +$ 101,038 +337,326 +$ 438,364 +TOTAL +$ 586.928 +817,093 +$1,404,021 +FINDINGS: +From 2007 to 2008, the reported total procured for goods and services was $1,404,02l. +Purchases from Virgin Islands' suppliers totaled $868,641 (62%) of which the majority was +spent on rent, utilities, and supplies. Reported procurement from Non-Virgin Islands' suppliers +GOODS & SERVICES +2007-2008 +31% +7% +*Eligible VI Supplier +• VI Supplier +• Non-VI Supplier +62% + +4| Page +VI-JPM-000023082 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 7 of 14 +As of December 31, 2008 +LOCAL PROCUREMENT: +In accordance with Division 10 of the Economic Development Commission Rules and +Regulations, the Beneficiary must comply with procurement procedures (Section 708-701 to +708-713). +FINDINGS: +For the period 2007-2008, the Beneficiary reported expending a total of $1,480,827. There was +a reported 61% ($908,275) expended to Virgin Islands' Suppliers. Of these purchases, the +majority was spent on rent, utilities, supplies, insurance, machinery & equipment, and leasehold +improvements. +There was also a reported 32% ($475,536) made from Non-Virgin Islands +Suppliers, of which the majority was spent on legal and accounting, machinery & equipment, +7% ($97,016) of expenditures were purchased from +ani fure Wire i fisands, anderse mainajority was spent on legal and aeroping services. +In accordance with the EDC Rules and Regulations, Section 708-709 the Beneficiary was +required to provide proof of solicitation for quotes on a competitive basis. +For the period covered in this report, the Beneficiary failed to provide proof of solicitation quotes +for purchases of machinery and equipment. +TOTAL PROCUREMENT +2007 - 2008 +100% +90% +80% +70% +60% +50% +40% +30% +30% +0% +Non-local +VI +Engible Vi +Suppliers +Cap Exp +37,172 +39.634 +Goods & +Sves +438,364 +868.641 +97.016 + +5| Page +VI-JPM-000023083 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 8 of 14 +As of December 31, 2008 +EMPLOYMENT: +"The Beneficiary shall employ, no later than one year from September 7, 1999 no less than +eleven (11) persons on a full-time basis employees of which no less than 80% of all employees +shall be "Residents of the Virgin Islands" as defined in Title 29, V.I. Code Section 703(e) and +provided that not less than twenty percent (20%) shall be in the area of management, supervisory +and/or technical positions filled by residents of the Virgin Islands. Pursuant to Title 29, Chapter +12, Section 710(a)." +In accordance with Section 710(a) Title 29, Chapter 12, VIC (Amended 2006), "after the third +year of operation, a beneficiary shall be required to have at least 20% of its management, +supervisory, and/or technical positions filled by residents of the United States Virgin Islands +unless granted a waiver by the Commission." +EDC Rules and Regulations section 708-605 defines full-time employees or employment as +"employment, on a permanent and continuous basis, for thirty-two (32) hours or more per week". +FINDINGS: +YEAR +2007 +2008 +TOTAL += +11 +AVERAGE +FULL +AVERAGE +AVERAGE +AVERAGE +TIME +V.I. RES. +% V.I. Res. +11 +11 +96% +MGMT. +6 +11 +91% +5 +20% +V.I. +MGMT +92% +83% +For the period January 1, 2007 to December 31, 2008, the Beneficiary reported employing an +average of eleven (11) employees on a full-time basis, meeting the employment requirement of +the certificate. The Beneficiary also met the residency, management, supervisory, and technical +requirements for the period covered in this report. +SPECIAL CONDITIONS: +The following special conditions shall apply: +1. The Beneficiary shall provide all employees with health care insurance, funded by the +Beneficiary. +• For the years 2007 and 2008, the Beneficiary provided documentation for +employer funded health, life, and dental insurance provided to ten full-time + +6| Page +VI-JPM-000023084 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 9 of 14 +As of December 31, 2008 +employees through United HealthCare Insurance Company. Noted and +reviewed at site visit was one employee who opted out of this coverage as +they had alternate insurance coverage. +United HealthCare Insurance Company is registered with the Lieutenant Governor's +Office of Banking and Insurance. +The Beneficiary met the requirements of this special condition. +2. The Beneficiary shall provide all employees a qualified retirement plan funded by the +Beneficiary. +• The Beneficiary provided documentation for an established American Funds +Savings Incentive Match Plan for Employees ("SIMPLE") incorporated with an +Individual Retirement Agreement (IRA). The plan was offered to all employees +receiving at least $5,000 in compensation. +The Beneficiary made matching +contributions equal to 100% of elective deferrals up to a limit of 3% per calendar +year. For the period 2007 through 2008, nine employees participated in the Simple +IRA Plan. Mr. Epstein, +» and l +opted out of the retirement +plan. +The Beneficiary met the requirements of this special condition. +3. The Beneficiary shall provide employee training and tuition reimbursement program for +eligible employees. +• The Beneficiary provided documentation for training in 2007 offered to employees +for a two-day SkillPath Windows Server Workshop and Continuing Accounting +Education courses through the VI Society of CPAs. +• The Beneficiary provided documentation for training in 2008 offered to employees +for an Excel seminar and three (3) continuing education courses in accounting. +The Beneficiary met the requirements of this special condition. +4. The Beneficiary shall make annual contributions of $50,000 or one percent (1%) of gross +receipts tax exemption value, whichever is greater, to be distributed annually as follows: +(a) 50% to educational scholarships +(b) 25% for charity +(c) 25% for co-op marketing with EDC + +7| Page +VI-JPM-000023085 + + +YEAR +2007 +2008 +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 10 of 14 +As of December 31, 2008 +However, after issuance of its certificate, applicant shall prepay the first five (5) years of +contribution fixed at $50,000, or the sum of $250,000, to be distributed as follows: +(a) $187,500 to a tax-exempt entity from which annual distributions of not less +than $25,000 to educational scholarship and $12,500 to charity shall be made, +(b) $62,500 for co-op marketing with IDC. +CERTIFICATE REQUIREMENT: +GROSS +RECEIPT +GROSS +RECEIPT +EXEMPTION +1% GROSS +RECEIPT +EXEMPTION +VALUE +CONTRIBUTION +REQUIREMENT +PER +CERTIFICATE +50,000 +50,000 +50% +EDUCATIONAL +SCHOLARSHIPS +25,000 +25,000 +25% +CHARITY +12,500 +12,500 +TOTAL CONTRIBUTION PER EDC CERTIFICATE +100,000 +50,000 +25,000 +The Beneficiary provided documentation for contributions totaling $469,980 made from January +2007 to December 2008. Of the total contributions, $108,925 was made from Financial Trust +Co., Inc. and $361,055 from the J. Epstein Foundation. Contributions were made to charities, +educational scholarships, educational symposiums (other), and Co-op Marketing to the EDC. +ACTUAL CONTRIBUTIONS: FINANCIAL TRUST Co., INC. +YEAR +2007 +2008 +TOTAL +J. EPSTEIN +EDUCATIONAL +CONTRUBUTIONS +FOUNDATION +SCHOLARSHIPS +$ 18,565 +90,360 +$108,925 +- +37,500 +37,500 +300 +12,500 +12,800 +CHARITY +5,765 +27,860 +33,625 +CO-OP +MARKETING +WITH EDC +12,500 +12.500 +25,000 +25% CO. +OP +MARKETI +NG - EDC +12,500 +12,500 +25,000 + +8| Page +Jp. +VI-JPM-000023086 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 11 of 14 +As of December 31, 2008 +In 2007, the Beneficiary contributed a total of $18,565. These contributions were +made to Antilles School's scholarship fund and organizations such as Atlas Tours, +Inc. and Charlotte Kimmelman Cancer Institute. +In 2008, the Beneficiary contributed a total of $90,360. These contributions were +made to Antilles and Sts. Peter & Paul Catholic Schools, organizations and +schools such as Friends of the St. +Public Libraries, Ivanna Eudora Kean High School, VI Council on the Arts, +Community Foundation of the VI, Boys and Girls Club of the VI, Inc., and United +Way of St. +-St. John. +In 2007, the Beneficiary did not contribute in accordance with the certificate's requirement in the +YEAR +2007 +2008 +ACTUAL CONTRIBUTIONS: J. EPSTEIN FOUNDATION +TOTAL +CONTRIBUTIONS +EDUCATIONAL +SCHOLARSHIPS +CHARITY +EDUCATIONAL +SYMPOSIUMS +INELIGIBLE +CONTRIBUTIONS +$ 218,542 +142,505 +20,650 +20,000 +152,500 +90,164 +$ 361,047 +40,650 +242,664 +45,392 +32,341 +77,733 +The J. Epstein Foundation is a tax-exempt entity established by Financial Trust, Company Inc, +primarily for making charitable contributions to the Virgin Islands community. Mr. Jeffrey +Epstein, sole owner of Financial Trust Company Inc., personally funds the J. Epstein Foundation. +In 2007, the J. Epstein Foundation made contributions totaling $218,550. These +contributions were made to The Junior Statesmen Foundation, Miss Virgin +Islands Scholarship, and Antilles School. Charitable organizations such as the +V.I. Tennis Association, Inc., +Virgin Islands Missions, Inc., Friends of the St. +Caribbean PromoMart, Dakota Sports, the Close Up Foundation, United Way of +St. Croix, Schneider Regional Medical Center, and the Family Resource Center, +Inc. +In 2008, the J. Epstein Foundation made contributions totaling $142,505. These +ontributions were made to Miss Virgin Islands Scholarship and the Junio +'tatesman Foundation. Charitabl + +9| Page +ЭВ. +VI-JPM-000023087 + + +Case 1:22-cv-10904-JSR . Document 186-34 Filed 06/14/23 Page 12 of 14 +As of December 31, 2008 +organizations and schools such as Antilles School, U.S. Customs & Border +Protection Explorer, C.A.H.S. L +Club, the Community Foundation of the +Virgin Islands, Family Resource Center, and the V.I. Tennis Association. +During the period covered in this report, the J. Epstein Foundation made contributions totaling +$26,500 to the St L +7St. John Chamber of Commerce. This contribution was disqualified in +accordance with the Internal Revenue Service code. +For the period covered in this report, total contribution made by Financial Trust Company, Inc. +and the J. Epstein Foundation, exceeded the certificate's requirement. +The Beneficiary met the requirements of this special condition. +5. The Beneficiary shall utilize the services of resident licensed broker dealers whenever +possible, given market conditions. +• The Beneficiary provided documentation showing Seslia Securities, a FINRA +registered broker was utilized as a Broker of Record for their Savings +Incentive Match Plan. +The Beneficiary met the requirements of this special condition. +REPORTING REQUIREMENTS: +EDC Annual Report: +Income Tax Return / +Audited Financial Statements +Current +Current +Lt. Governor's Annual Report: +Current +VIESA Report: +Current +Affidavit of IDC Beneficiary: +Current +Publication Notices +Current +FINDING: +The Beneficiary filed all reports within the filing deadlines. + +10 | Page +VI-JPM-000023088 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 13 of 14 +As of December 31, 2008 +FINANCIAL ANALYSIS REVIEW: +Financial Trust Company, Inc reported operating with an average loss of +period 2007 to 2008. +for the +Years +2007 +2008 +Avg. +Ordinary +Income +Annual Net +Aggregate +% Change +S +(513.38%) +The Cost Benefit Analysis for 2007 to 2008 reflects a ratio of 1:66.75. For every $100,000 in tax +revenues forgone by the government during this time, the Virgin Islands of the United States +received approximately $6,680,000,000 in economic output across the local economy. +For every $100,000 in tax revenues foregone by the territory, $2,890,000 in total value added to +the Gross Territorial Product (GTP). The Virgin Islands Economic Development Commission +granted tax exemptions to the Beneficiary totaling +during 2007 to 2008. +This does not include the value of tax exemptions on personal income tax of Mr. Jeffrey Epstein. +OTHER FINDINGS: +At the time of application, Mr. Jeffrey Epstein was stated as the sole owner of Financial Trust +Company, Inc. +By letter dated November 26, 2007, the Beneficiary notified the Division of Corporations and +Trademarks that effective September 21, 2007 Mr. Darren Indyke assumed the position of +Director/President of Financial Trust Company, Inc. + +I| Page +VI-JPM-000023089 + + +Case 1:22-cv-10904-JSR Document 186-34 Filed 06/14/23 Page 14 of 14 +As of December 31, 2008 +CONCLUSION +1. Received nine years of benefits. +2. Met the investment requirement. +3. Met the full-time employment requirement. +4. Met the residency and management requirement. +5. Did not comply with the procurement requirements. +6. Complied with Special Condition one through five. +7. Complied with the reporting requirements of the EDC. +Prepared by: Sandra Bess, Compliance Officer +Reviewed by: Stephanie Bety, Compliance Director +January 31, 2014 +Jennifer Nugent- +SEO/Chief Operating Ofticer + +12| Page +VI-JPM-000023090 \ No newline at end of file diff --git a/vision-fixhub/court-05/5d9059f54b296a9b86d4d91f87cb3924708f2240ec257467bf90c7e7ff77e495.receipt.json b/vision-fixhub/court-05/5d9059f54b296a9b86d4d91f87cb3924708f2240ec257467bf90c7e7ff77e495.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f7a01e0ccddf1987a53f35d7de36fb03778d893c --- /dev/null +++ b/vision-fixhub/court-05/5d9059f54b296a9b86d4d91f87cb3924708f2240ec257467bf90c7e7ff77e495.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1402, + "dataset": "marble-joined", + "doc_id": "5d9059f54b296a9b86d4d91f87cb3924708f2240ec257467bf90c7e7ff77e495", + "engine": "marble-apple-vision", + "event_count": 27, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "a87a0eae1f404e785f2c2f7f0899f061df11756a953d7d4eeddfb854c9e0ea11", + "output_sha256": "ede5aa7b42f77902117f2180fa77ed998cd4e9d92b88e64840ad155f55d038e3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5db772312295364241fdc0aa7ac48ee653f3661d6905be0980325c439b97f43b.md b/vision-fixhub/court-05/5db772312295364241fdc0aa7ac48ee653f3661d6905be0980325c439b97f43b.md new file mode 100644 index 0000000000000000000000000000000000000000..20828d24ae57c56bf968a71ae31bfc80c4f7e0f1 --- /dev/null +++ b/vision-fixhub/court-05/5db772312295364241fdc0aa7ac48ee653f3661d6905be0980325c439b97f43b.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 263-14 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/5db772312295364241fdc0aa7ac48ee653f3661d6905be0980325c439b97f43b.receipt.json b/vision-fixhub/court-05/5db772312295364241fdc0aa7ac48ee653f3661d6905be0980325c439b97f43b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..40ed747e284a1fbfb9b3a89fde88e9f42f2e81b7 --- /dev/null +++ b/vision-fixhub/court-05/5db772312295364241fdc0aa7ac48ee653f3661d6905be0980325c439b97f43b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "5db772312295364241fdc0aa7ac48ee653f3661d6905be0980325c439b97f43b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "d21874649bf5400c6bd3cfb81bbf22eb8a56f2f667d6399e79c60da64643485b", + "output_sha256": "69a111979db663c8a53db88d667cc34f343d00c96cc2a2b3b895e68f3aba6941", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5e014c9d0208c8208f4a39238349415bed9aa8e49e089822ab14f061088b43c8.md b/vision-fixhub/court-05/5e014c9d0208c8208f4a39238349415bed9aa8e49e089822ab14f061088b43c8.md new file mode 100644 index 0000000000000000000000000000000000000000..9c3df246f7e0d766afa0c810d22595e1d3317a9d --- /dev/null +++ b/vision-fixhub/court-05/5e014c9d0208c8208f4a39238349415bed9aa8e49e089822ab14f061088b43c8.md @@ -0,0 +1,40 @@ +Case 1:22-cV-10904-JSR Document 238-13 Filed 07/25/23 Page 1 of 3 + + + +Case 1:22-cV-10904-JSR Document 238-13 Filed 07/25/23 Page 2 of 3 +Confidential Due Diligence Report +Due Diligence Report +Jeffrey Epstein +JP +Chase +Confidential - This report is not to be disseminated or photocopied to any third party without the +express consent of Global Security & Investigations. +FILENAME + +Langtord 42 +Date: _ +513/23 +MLG, CSR, RPR, CRR +1 + +JPM-SDNYLIT-00013546 + + +Case 1:22-cV-10904-JSR Document 238-13 Filed 07/25/23 Page 3 of 3 +Confidential Due Diligence Report +TABLE OF CONTENTS +COMPANY INFORMATION +OTHER DATABASE SEARCHES - (SEX OFFENDER) +PUBLICATIONS +OFAC/CONTROL LIST SEARCH +7 +11 +13 +23 +Confidential - This report is not to be disseminated or photocopied to any third party without the +express consent of Global Security & Investigations. +FILENAME +6 + +JPM-SDNYLIT-00013551 diff --git a/vision-fixhub/court-05/5e014c9d0208c8208f4a39238349415bed9aa8e49e089822ab14f061088b43c8.receipt.json b/vision-fixhub/court-05/5e014c9d0208c8208f4a39238349415bed9aa8e49e089822ab14f061088b43c8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c599ef46297d7f23764bc08b2222c54e22e80812 --- /dev/null +++ b/vision-fixhub/court-05/5e014c9d0208c8208f4a39238349415bed9aa8e49e089822ab14f061088b43c8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -77, + "dataset": "marble-joined", + "doc_id": "5e014c9d0208c8208f4a39238349415bed9aa8e49e089822ab14f061088b43c8", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "a8eec995de948fa7b207af972dc5b24196bac9a1afd4fb15479c63769000cb85", + "output_sha256": "b2d198ca88ac9f287ad1fd818b7345bbf1d8e7cb17073ea27ef69534593b0669", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5e049593eb0f984cbf9cc08cfbfbf34dd872c79e0e3931cddf84a527f009616d.md b/vision-fixhub/court-05/5e049593eb0f984cbf9cc08cfbfbf34dd872c79e0e3931cddf84a527f009616d.md new file mode 100644 index 0000000000000000000000000000000000000000..52a7b45182c44cf2caa1fe6edcc2a55301145412 --- /dev/null +++ b/vision-fixhub/court-05/5e049593eb0f984cbf9cc08cfbfbf34dd872c79e0e3931cddf84a527f009616d.md @@ -0,0 +1,41 @@ +Case 1:22-cV-10904-JSR Document 326-85 Filed 09/08/23 Page 1 of 2 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-85 Filed 09/08/23 Page 2 of 2 +kjes.staley@jpmorgan.coms +1/11/2010 11:45:23 PM +FW: +From: Jeffrey Epstein +Date: Mon, I1 Jan 2010 18:36:09 -0500 +To: +Subject: Re: +krause said he told you to call him at anytime, do it +On Mon, Jan 11, 2010 at 6:06 PM, +Dear Jeffery, +wrote: +I just got back from California and I wanted to let you know that I had a fantastic time. It was a great experience +and it was amazing to meet such smart people. Lisa Randall is simply brilliant and truly a role model for women +in physics. ® 1 am very excited to do research and hope to go to more conferences in the future. Thank you so +much for inviting me to the conference - I can't even begin to state how much I appreciate it. +Best +#*** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. + +89882H +JPM-SDNYLIT-00006886 \ No newline at end of file diff --git a/vision-fixhub/court-05/5e049593eb0f984cbf9cc08cfbfbf34dd872c79e0e3931cddf84a527f009616d.receipt.json b/vision-fixhub/court-05/5e049593eb0f984cbf9cc08cfbfbf34dd872c79e0e3931cddf84a527f009616d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5de9f3541e4f07f530a593ede787ab1ea4916aee --- /dev/null +++ b/vision-fixhub/court-05/5e049593eb0f984cbf9cc08cfbfbf34dd872c79e0e3931cddf84a527f009616d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "5e049593eb0f984cbf9cc08cfbfbf34dd872c79e0e3931cddf84a527f009616d", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "37dc6b86c22e0e652170b7cb1266406940c160177bf25695a8e811702f322341", + "output_sha256": "a5b87fdb440f6135abc4db1e31a926602f228bd4591bb65e1535adba185c7c0c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5e19fe0e1c3c0e4c073ea677299ace0cc2e4329f78cf41452322424f2d0bf98d.md b/vision-fixhub/court-05/5e19fe0e1c3c0e4c073ea677299ace0cc2e4329f78cf41452322424f2d0bf98d.md new file mode 100644 index 0000000000000000000000000000000000000000..79b807955a2641935874997d3073173b281bcb8f --- /dev/null +++ b/vision-fixhub/court-05/5e19fe0e1c3c0e4c073ea677299ace0cc2e4329f78cf41452322424f2d0bf98d.md @@ -0,0 +1,23 @@ +Case 1:20-cr-00330-PAE +Document 799 +Filed 08/04/25 + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +- against - +GHISLAINE MAXWELL, +20 CR. 330 (PAE) +ORDER GRANTING MOTION TO +WITHDRAW +Defendant. +Upon consideration of the Motion to Withdraw, it is HEREBY ORDERED THAT +Christian R. Everdell and Mark S. +]of| +& Gresser LLP are granted leave to withdraw +as co-counsel for defendant Ghislaine Maxwell in the above-captioned matter. +Dated:_August 4 +, 2025 +and N. Engetnage +The Honorable Paul A. Engelmaye +United States District Judge diff --git a/vision-fixhub/court-05/5e19fe0e1c3c0e4c073ea677299ace0cc2e4329f78cf41452322424f2d0bf98d.receipt.json b/vision-fixhub/court-05/5e19fe0e1c3c0e4c073ea677299ace0cc2e4329f78cf41452322424f2d0bf98d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1395eacbd6e755e71282621f96f69340725ca3f2 --- /dev/null +++ b/vision-fixhub/court-05/5e19fe0e1c3c0e4c073ea677299ace0cc2e4329f78cf41452322424f2d0bf98d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "5e19fe0e1c3c0e4c073ea677299ace0cc2e4329f78cf41452322424f2d0bf98d", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "1e77a33225d4ccb600d4d5c03dc5f46231ce1d7b9e688f510322e8053026bd61", + "output_sha256": "08aae067e6c92b482df18fd6bb41cde8c90c3972668c30401036edb603484ae1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5e6ad8c1c6ff2d19188228e4eec4cd5d2f29a8e6f86d810f53445efa4170b8c3.md b/vision-fixhub/court-05/5e6ad8c1c6ff2d19188228e4eec4cd5d2f29a8e6f86d810f53445efa4170b8c3.md new file mode 100644 index 0000000000000000000000000000000000000000..e2edbc6b654262accf6fd983c1a2c363f4941c4f --- /dev/null +++ b/vision-fixhub/court-05/5e6ad8c1c6ff2d19188228e4eec4cd5d2f29a8e6f86d810f53445efa4170b8c3.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 311-10 Filed 08/25/23 + + +Filed Under Seal diff --git a/vision-fixhub/court-05/5e6ad8c1c6ff2d19188228e4eec4cd5d2f29a8e6f86d810f53445efa4170b8c3.receipt.json b/vision-fixhub/court-05/5e6ad8c1c6ff2d19188228e4eec4cd5d2f29a8e6f86d810f53445efa4170b8c3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5b01fd833908289305c825fe47fbeee0cef16c0f --- /dev/null +++ b/vision-fixhub/court-05/5e6ad8c1c6ff2d19188228e4eec4cd5d2f29a8e6f86d810f53445efa4170b8c3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "5e6ad8c1c6ff2d19188228e4eec4cd5d2f29a8e6f86d810f53445efa4170b8c3", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "ca83acb111ae24bc5e84031a78f0d6aea9ab1e92a9e9addc777d3d82acb2bbdc", + "output_sha256": "558eb9f73f7f9a00ee2d2aba3f432ff420dd829f4423e15997f3f2888739f63a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5e832f23bf43eca689e0ef27c6913c503d419faaff77fb880cd1c216b08d18c9.md b/vision-fixhub/court-05/5e832f23bf43eca689e0ef27c6913c503d419faaff77fb880cd1c216b08d18c9.md new file mode 100644 index 0000000000000000000000000000000000000000..6fb6aa45a050d83c93329912d8bc333fd6a744bd --- /dev/null +++ b/vision-fixhub/court-05/5e832f23bf43eca689e0ef27c6913c503d419faaff77fb880cd1c216b08d18c9.md @@ -0,0 +1,98 @@ +Case 1:22-cV-10904-JSR Document 268-10 Filed 08/07/23 Page 1 of 4 + + + +Case 1:22-CV-10904-JSR Document 268-10 Filed 08/07/23 Page 2 of 4 +July 14, 2023 call with Monica Carbon, Attorney to Lt. Governor +Monica +Carbon, Esq. +Chief of Staff +Office of the Lieutenant Governor +5049 Kongens Gade +St. +VI 00802 +Phone: (340) 774-2991, Extension 4113 +Email: monica.carbon@lgo.vi.gov +Worked for Attorney General mid-2007- ~March 2015 (until the beginning of the Mapp administration, +that's when she left) +Legal Counsel to AG. He assigned her to work with SOR Board. +Sex Offender Registry Board expressed concerns that the law didn't have much teeth and was weak on +guidance. Maybe around 2008 she researched and found a US DOJ model law. If adopted, then you +could receive funding to build a registry (they didn't have one at that time). And you would be part of +national registry with other US jurisdictions that signed on. Allowing to work with other registries in +unison to track offenders. +She brought this to AG Frazer and recommended they establish task force (which was done), included +Court and Human Services and others. They met and reviewed the sections of the model law and got +input from the community. +It took about 2 years to adopt - drafting legislation and going before legislature to get it passed. Then +they built a registry. She can't recall when it was passed (it was passed in 2012). +In order to get funding, Carbon had a liaison at US DOJ. She is no longer there. Laurie| +VI couldn't revise the law too much because if it differed too much from model law then the +Government would lose federal funding. +The +Carbon shared the VI language with the US DOJ and the USDOJ said the USVI changes were okay. Every +step they took was under the guidance and approval of US DOJ. +Why working with Maria Hodge on proposed legislation and changes? Carbon wasn't working "with +her" but Carbon thinks she made inquiries to legislature re the language. At the time, she wasn't +concerned about Maria Hodge's representation of a sex offender because Carbon knew that anything +submitted had to be approved by US DOJ. +In the early period was there only one investigator in St. Croix or St. | +? She thinks there were +funding issues, she believes there was only funding for 1 investigator and 2 registrars - and that's what +they had. The investigator was in St. Croix. +Epstein. +She can't recall when she got involved, Pinney would have been in direct contact with the registrants. +• Looked at 2010 file and she didn't recognize any of the handwriting. It's not hers. +1 + + +Case 1:22-cv-10904-JSR Document 268-10 Filed 08/07/23 Page 3 of 4 +• July 19, 2010 Email Indyke to Petty cc Carbon. Doesn't recall meeting with Indyke in 2010. +Merlyn Petty was probably just filling in until they got a registry person. She doesn't recall any +conversations about this, but most likely Carbon told Petty that Epstein had to notify of travel +changes in person (which would have been just the general instructions to all registrants). +• 2010 file - fax from Florida registration included "Blogs and Stories - Billionaire Pedophile Goes +Free" July 20, 2010. She doesn't remember seeing this. She doesn't remember if she knew it +was in the file. Their role is to monitor him - he served his time and their job is registration. They +did what they were supposed to do. +• The only thing she recalls about Epstein is that she met him. Epstein and Maria Hodge came in +and met with Pinney. Epstein asked to meet her too. So she went and met him. +• She did not know or have any knowledge that there was illicit things going on in the VI involving +Epstein. ( +• He seemed creepy and weird, nothing they could use to investigate. +• Met with Kellerhals, Hodge or Indyke? Just that one time (above) with Hodge and Pinney and +Epstein. +What would be required to launch an investigation? +• If she knew for sure that something is going on - something beyond rumors. +2011 file: New York document indicating "level 3" offender in NY but classified as Level 1 in USVI. +• She recalls wanting him to be classified higher but in the USVI statute but believed they weren't +able to put him as a level 3. +Memo from Indyke re classification as level 1 v. 3? Can't recall anything about the memorandum. +2012 file: Memo to Pinney from Indyke cc Carbon. 9/6/2012. +• She doesn't recall the memo. She doesn't recall the assessment. +Statute 2019 Sexual Offender Registration and Community Protection Sec. 1721B Tiered Offenses. +• Carbon can't recall whether she considered the 13month sentence when looking at the tier +assignment for Epstein. +• Solicitation of minor is also tier 2. She can't recall her analysis. +• She can't recall the process to which a tier was assigned. She can't recall who made the +determination but believed it was likely her. +2012 Epstein's counsel sought waiver of notification requirements - +• She recalls a 48 hour notice requirement for travel +1/13/2012 Letter from Frazier to Epstein - this looks familiar to her. +6/2012 - legislation amendments pass, then Hodge sends letter requesting waiver. 7/26/12 Frazier +responds; and follow up letters including 8/14/2012 Letter from Frazier. +• She doesn't recall doing any research or work on this request for a waiver. +• She probably would have been involved in the review of this statute. +2 + + +Case 1:22-cV-10904-JSR Document 268-10 Filed 08/07/23 Page 4 of 4 +Monitoring Visits to LSJ where JEE wasn't there. +• She doesn't recall much - she just recalls that Pinney mentioned a question as to whether they +had the authority to go past the dock. +• She recalls that the US Marshalls would go out and invite them - because they had the boat. +• She doesn't recall any discussion re getting a warrant. +• If there were concerns she would have passed it to the AAG but does not recall ever doing so. +She took the sex offender registry responsibility very seriously. If they had the authority, she would have +done more but under the statute, they were just monitoring his location. +3 diff --git a/vision-fixhub/court-05/5e832f23bf43eca689e0ef27c6913c503d419faaff77fb880cd1c216b08d18c9.receipt.json b/vision-fixhub/court-05/5e832f23bf43eca689e0ef27c6913c503d419faaff77fb880cd1c216b08d18c9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b5bf78e214ff009aa5140c82c77e5345590be782 --- /dev/null +++ b/vision-fixhub/court-05/5e832f23bf43eca689e0ef27c6913c503d419faaff77fb880cd1c216b08d18c9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -59, + "dataset": "marble-joined", + "doc_id": "5e832f23bf43eca689e0ef27c6913c503d419faaff77fb880cd1c216b08d18c9", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "a1d007631dcf2b9649aa07b88c28ceaddc83f2b8326f8ff928c94be5ca6d722f", + "output_sha256": "557a9249f69b16016a4cb4907b2d478ead3da7e16e2954f9d154eb8415afbe59", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5e92f5041017c1d918eb164e84a0ce8ea6d205cd42cf286dedb63586ffd8721b.md b/vision-fixhub/court-05/5e92f5041017c1d918eb164e84a0ce8ea6d205cd42cf286dedb63586ffd8721b.md new file mode 100644 index 0000000000000000000000000000000000000000..38d771362b99c6cc1155783e7ac8bb183c3bfe79 --- /dev/null +++ b/vision-fixhub/court-05/5e92f5041017c1d918eb164e84a0ce8ea6d205cd42cf286dedb63586ffd8721b.md @@ -0,0 +1,69 @@ +Case 1:22-cv-10904-JSR Document 284-50 Filed 08/14/23 + + +FILED UNDER SEAL + + +Case 1:22-cv-10904-JSR Document 284-50 Filed 08/14/23 Page 2 of 3 +From: +Sent: +To: +Subject: +Cecile de Jongh +7/30/201211:23:18 AM +Jeffrey Epstein [jeevacation@gmail.com] +Re: +Importance: +High +When I see you next 1 can give you my insight into what I think is going on with V. I do not want to do it via +email or phone. +With warm regards, +Cecile +Sent from my iPhone +On Jul 30, 2012, at 7:11 AM, Jeffrey Epstein wrote: +he went to the hearing, made a speech, without telling john, he didnt return maria phone calls.. his office +repeatedly did not give the letter we were told was coming, he agreed with maria and darren and then told +john then changed the letter. reverting back to the exact same spocch that he made at the legislature. +On Mon, Jul 30, 2012 at 7:01 AM, Cecile de Jongh +Will do. It's not his style to go and say anything to +wrote: +With warm regards, +Cecile +Sent from my iPhone +On Jul 29, 2012, at 9:26 PM, Jeffrey Epstein wrote: +I appreciate you keeping a close watch on the vincent, issue, +we will have to go for an amendment soon, i do +not want to alienate him so he whispers in russells car. +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressce. It is the property of +Jeffiey Epstein +Unauthorized usc, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by c-mail to jccvacation@gmail.com, and +destroy this communication and all copies thercof, +including all attachments. copyright -all rights reserved + +ESTATE_JPMO15021 + + +Case 1:22-cV-10904-JSR Document 284-50 Filed 08/14/23 Page 3 of 3 +*************************************** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved +****** + +ESTATE_JPMO15022 diff --git a/vision-fixhub/court-05/5e92f5041017c1d918eb164e84a0ce8ea6d205cd42cf286dedb63586ffd8721b.receipt.json b/vision-fixhub/court-05/5e92f5041017c1d918eb164e84a0ce8ea6d205cd42cf286dedb63586ffd8721b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..56d12dbfc9eb3c1e16f0782cf98a8b7476b60551 --- /dev/null +++ b/vision-fixhub/court-05/5e92f5041017c1d918eb164e84a0ce8ea6d205cd42cf286dedb63586ffd8721b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -82, + "dataset": "marble-joined", + "doc_id": "5e92f5041017c1d918eb164e84a0ce8ea6d205cd42cf286dedb63586ffd8721b", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "a3136b88580ddfbf4e380897ff43f1511a7324bb81aeb8484f2b24b730785d8a", + "output_sha256": "bef7ec7c72cef72aff49c5e94e11eac70ad3fbd647056b38d60711527e01c7b3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5ea4d26fe23e729be7ae3df9beed38ac3296e911f3fe1b0eb65c51e7066a242d.md b/vision-fixhub/court-05/5ea4d26fe23e729be7ae3df9beed38ac3296e911f3fe1b0eb65c51e7066a242d.md new file mode 100644 index 0000000000000000000000000000000000000000..29273f119c8055fda684d69b77c9024e3700b393 --- /dev/null +++ b/vision-fixhub/court-05/5ea4d26fe23e729be7ae3df9beed38ac3296e911f3fe1b0eb65c51e7066a242d.md @@ -0,0 +1,61 @@ +Case 1:22-cV-10904-JSR Document 326-96 Filed 09/08/23 Page 1 of 2 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-96 Filed 09/08/23 Page 2 of 2 +Jeffery + +7/17/2008 5:30:28 PM +Re: +Tell him a one million dollar increase to 25 mlllion.. The times are tougher +and the market would pay more for you to be a trouble shooter at one of the +messes.. Plus options you can point out that your options aren;t worth +much, and that for two years you were underpaid.. He cannot reduce your +salary.. It can't be stay with me and you'll be fine, and the future will +take care of itself, and when the future is tough ou get penalized.. DO Not +give in. I'll try to call later today +on 7/16/08 6:06 PM, "jes.staley@jpmorgan.com" +wrote: +> Jamie wants me to tell him how much I should make this year, given the +> expected bank results and my results. To put it in context, my business +> will be down around 158 this year. What do you think? +> I hope you're managing. I miss our calls. Its boring without you around? +> Do you have any books yet? +Jes +> Generally, this communication is for informational purposes only +> and it is not intended as an offer or solicitation for the purchase +> or sale of any financial instrument or as an official confirmation +> of any transaction. In the event you are receiving the offering +> materials attached below related to your interest in hedge funds or +> private equity, this communication may be intended as an offer or +> solicitation for the purchase or sale of such fund(s). All market +> prices, data and other information are not warranted as to +> completeness or accuracy and +are subject to change without notice. +> Any comments or statements made herein do not necessarily reflect +> those of JPMorgan Chase & Co., its subsidiaries and affiliates. +> This transmission may contain information that is privileged, +> confidential, legally privileged, and/or exempt from disclosure +> under applicable law. If you are not the intended recipient, you +> are hereby notified that any disclosure, copying, distribution, or +› use of the information contained herein (including any reliance +> thereon) is STRICTLY PROHIBITED. Although this transmission and any +> attachments are believed to be free of any virus or other defect +> that might affect any computer system into which it is received and +> opened, it is the responsibility of the recipient to ensure that it +the recipient to enauce a n +> is virus free and no responsibility is accepted by JPMorgan Chase & +> Co., its subsidiaries and affiliates, as applicable, for any loss +> or damage arising in any way from its use. If you received this +> transmission in error, please immediately contact the sender and +> destroy the material in its entirety, whether in electronic or hard +> copy format. Thank you. +> Please refer to http://www.jpmorgan.com/pages/disclosures for +> disclosures relating to UK legal entities. + +JPM-SDNYLIT-00003060 diff --git a/vision-fixhub/court-05/5ea4d26fe23e729be7ae3df9beed38ac3296e911f3fe1b0eb65c51e7066a242d.receipt.json b/vision-fixhub/court-05/5ea4d26fe23e729be7ae3df9beed38ac3296e911f3fe1b0eb65c51e7066a242d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dff54329de797ec60e6542b388e3098634a618ea --- /dev/null +++ b/vision-fixhub/court-05/5ea4d26fe23e729be7ae3df9beed38ac3296e911f3fe1b0eb65c51e7066a242d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -46, + "dataset": "marble-joined", + "doc_id": "5ea4d26fe23e729be7ae3df9beed38ac3296e911f3fe1b0eb65c51e7066a242d", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "485b41cb1f823d46bd30a192e7c2e8b80cf6d7a5a5c64a12cc2ca4271a42be0d", + "output_sha256": "5a90455192c5e0346af18e03200d27ab5f6804017fda957f6f0f57c5570b3a38", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5eb4cc2f585ad312530df7c1f33faa88c4a6f04ead78fbc6cb4d7d626456dc23.md b/vision-fixhub/court-05/5eb4cc2f585ad312530df7c1f33faa88c4a6f04ead78fbc6cb4d7d626456dc23.md new file mode 100644 index 0000000000000000000000000000000000000000..dc517c7ca897cae7767ab098e1c0817fc36ba481 --- /dev/null +++ b/vision-fixhub/court-05/5eb4cc2f585ad312530df7c1f33faa88c4a6f04ead78fbc6cb4d7d626456dc23.md @@ -0,0 +1,262 @@ +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 1 of 12 +IN THE UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +JANE DOE, individually and on behalf of +all others similarly situated, +Plaintiff, +V. +Case Number: 1:22-cv-10019-JSR +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff, +V. +JAMES EDWARD STALEY +Third-Party Defendant. +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +v. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff, +Case Number: 1:22-cv-10904-JSR +v. +JAMES EDWARD STALEY +Third-Party Defendant. +DECLARATION OF STEPHEN L. WOHLGEMUTH IN SUPPORT OF +THIRD-PARTY DEFENDANT JAMES STALEY'S +MOTION FOR SUMMARY JUDGMENT +Pursuant to 28 U.S.C. § 1746, 1, Stephen L. Wohlgemuth, declare under penalty of +perjury as follows: +1 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 2 of 12 +1. I am a member in good standing of the bar of the State of New York and the District of +Columbia. I am one of the attorneys representing Third-Party Defendant James Staley in +the above-captioned actions and have been admitted to this Court pro hac vice. I am a +Partner with the law firm of +and Connolly LLP, 680 Maine Ave SW, +Washington, DC 20024. I am familiar with the facts set forth herein, and if called as a +witness, I could and would competently testify thereto. +2. Attached as Exhibit 1 is a true and correct copy of excerpts of the transcript from the July +13, 2023 Deposition of JPMorgan's 30(b)(6) witness, Francis Pearn, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +3. Attached as Exhibit 2 is a true and correct copy of excerpts of the transcript from the June +10, 2023 Deposition of James Staley, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +4. Attached as Exhibit 3 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00935658, designated confidential pursuant to +5. Attached as Exhibit 4 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00901998, designated confidential pursuant to +6. Attached as Exhibit 5 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-W-00029751, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +2 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 3 of 12 +7. Attached as Exhibit 6 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00130162, designated confidential pursuant to +8. Attached as Exhibit 7 is a true and correct copy of excerpts of the transcript from the July +12, 2023 Deposition of Mary Erdoes, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +9. Attached as Exhibit 8 is a true and correct copy of excerpts of the transcript from the +April 28, 2023 Deposition of Kevin McCleery, designated confidential pursuant to the +Protective Order in this matter and filed under seal. +10. Attached as Exhibit 9 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00129133, designated confidential pursuant to +11. Attached as Exhibit 10 is a true and correct copy of excerpts of the transcript from the +May 3, 2023 Deposition of William Langford, designated confidential pursuant to the +Protective Order in this matter and filed under seal. +12. Attached as Exhibit 11 is a true and correct copy of a document produced by Defendant +JPMorgan, I +stamped JPM-SDNYLIT-00128563, designated confidential pursuant to +13. Attached as Exhibit 12 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00036570, designated confidential pursuant to +3 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 4 of 12 +14. Attached as Exhibit 13 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00129159, designated confidential pursuant to +15. Attached as Exhibit 14 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00128937, designated confidential pursuant to +16. Attached as Exhibit 15 is a true and correct copy of excerpts of the transcript from the +May 24, 2023 Deposition of Maryanne Ryan, designated confidential pursuant to the +Protective Order in this matter and filed under seal. +17. Attached as Exhibit 16 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00457617, designated confidential pursuant to +18. Attached as Exhibit 17 is a true and correct copy of excerpts of the transcript from the +June 11, 2023 Deposition of James Staley, designated confidential pursuant to the +Protective Order in this matter and filed under seal. +19. Attached as Exhibit 18 is a true and correct copy of a document produced by Defendant +JPMorgan, I +stamped JPM-SDNYLIT-00134722, designated confidential pursuant to +20. Attached as Exhibit 19 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00137008, designated confidential pursuant to +4 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 5 of 12 +21. Attached as Exhibit 20 is a true and correct copy of excerpts of the transcript from the +May 26, 2023 Deposition of Jamie Dimon, designated confidential pursuant to the +Protective Order in this matter and filed under seal. +22. Attached as Exhibit 21 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00029203, designated confidential pursuant to +23. Attached as Exhibit 22 is a true and correct copy of excerpts of the transcript from the +March 15, 2023 Deposition of Mary Erdoes, designated confidential pursuant to the +Protective Order in this matter and filed under seal. +24. Attached as Exhibit 23 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00032902, designated confidential pursuant to +25. Attached as Exhibit 24 is a true and correct copy of excerpts of the transcript from the +April 21, 2023 Deposition of Justin Nelson, designated confidential pursuant to the +Protective Order in this matter and filed under seal. +26. Attached as Exhibit 25 is a true and correct copy of excerpts of the transcript from the +April 18, 2023 Deposition of Paul Morris, designated confidential pursuant to the +Protective Order in this matter and filed under seal. +27. Attached as Exhibit 26 is a true and correct copy of excerpts of the transcript from the +April 7, 2023 Deposition of Mary L +designated confidential pursuant to the +Protective Order in this matter and filed under seal. +5 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 6 of 12 +28. Attached as Exhibit 27 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00230977, designated confidential pursuant to +29. Attached as Exhibit 28 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00231554, designated confidential pursuant to +30. Attached as Exhibit 29 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00450001, designated confidential pursuant to +31. Attached as Exhibit 30 is a true and correct copy of a document produced by Jane Doe 1, +stamped JDoe_JPMC_ +_ 004535, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +32. Attached as Exhibit 31 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00208285, designated confidential pursuant to +33. Attached as Exhibit 32 is a true and correct copy of a document produced by Defendant +JPMorgan, I +stamped JPM-SDNYLIT-00127953, designated confidential pursuant to +34. Attached as Exhibit 33 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00127944, designated confidential pursuant to +6 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 7 of 12 +35. Attached as Exhibit 34 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00149784, designated confidential pursuant to +36. Attached as Exhibit 35 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00229703, designated confidential pursuant to +37. Attached as Exhibit 36 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00353401, designated confidential pursuant to +38. Attached as Exhibit 37 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00148059, designated confidential pursuant to +39. Attached as Exhibit 38 is a true and correct copy of excerpts of the transcript from the +May 24, 2023 Deposition of Stephen Cutler, designated confidential pursuant to the +Protective Order in this matter and filed under seal. +40. Attached as Exhibit 39 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00100305, designated confidential pursuant to +41. Attached as Exhibit 40 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00152738, designated confidential pursuant to +7 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 8 of 12 +42. Attached as Exhibit 41 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00003036, designated confidential pursuant to +43. Attached as Exhibit 42 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00195660, designated confidential pursuant to +44. Attached as Exhibit 43 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00010816, designated confidential pursuant to +45. Attached as Exhibit 44 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00100199, designated confidential pursuant to +46. Attached as Exhibit 45 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00274272, designated confidential pursuant to +47. Attached as Exhibit 46 is a true and correct copy of a document produced by Defendant +JPMorgan, I +stamped JPM-SDNYLIT-00099530, designated confidential pursuant to +48. Attached as Exhibit 47 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00153179, designated confidential pursuant to +8 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 9 of 12 +49. Attached as Exhibit 48 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-W-00026305, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +50. Attached as Exhibit 49 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-W-00033761, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +51. Attached as Exhibit 50 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00136519, designated confidential pursuant to +52. Attached as Exhibit 51 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00015747, designated confidential pursuant to +53. Attached as Exhibit 52 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00269651, designated confidential pursuant to +54. Attached as Exhibit 53 is a true and correct copy of a document produced by Defendant +JPMorgan, J +stamped JPM-SDNYLIT-00194154, designated confidential pursuant to +55. Attached as Exhibit 54 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00025688, designated confidential pursuant to +9 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 10 of 12 +56. Attached as Exhibit 55 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00026223, designated confidential pursuant to +57. Attached as Exhibit 56 is a true and correct copy of the Department of Justice's +Investigation into the U.S. Attorney's Office for the Southern District of Florida's +Resolution of its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its +Interactions with Victims During the Investigation, dated November 2020. +58. Attached as Exhibit 57 is a true and correct copy of excerpts of the transcript from the +August 14, 2023 Deposition of JPMorgan's 30(b)(6) witness, Francis Pearn, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +59. Attached as Exhibit 58 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00901997, designated confidential pursuant to +60. Attached as Exhibit 59 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00449995, designated confidential pursuant to +61. Attached as Exhibit 60 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00449996, designated confidential pursuant to +62. Attached as Exhibit 61 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00920701, designated confidential pursuant to +10 + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 11 of 12 +63. Attached as Exhibit 62 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00011896, designated confidential pursuant to +64. Attached as Exhibit 63 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00013546, designated confidential pursuant to +65. Attached as Exhibit 64 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-W-00000211, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +66. Attached as Exhibit 65 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00919725, designated confidential pursuant to +67. Attached as Exhibit 66 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00919580, designated confidential pursuant to +68. Attached as Exhibit 67 is a true and correct copy of JPMorgan Chase Bank, N.A.'s Third- +Party Complaint Against James Edward Staley filed on March 8, 2023 in the matter of +Government of The United States Virgin Islands v. JPMorgan Chase Bank, N.A., 1:22-cv- +10904. +69. Attached as Exhibit 68 is a true and correct copy of JPMorgan Chase Bank, N.A.'s +Supplemental Responses and Objections to Interrogatories in Lieu of Rule 30(b)(6) +Deposition Testimony, dated August, 11, 2023. + + +Case 1:22-cv-10904-JSR Document 311 Filed 08/25/23 Page 12 of 12 +70. Attached as Exhibit 69 is a true and correct copy of JPMorgan Chase Bank, N.A.'s +Responses and Objections to Interrogatories in Lieu of Rule 30(b)(6) Deposition +Testimony, dated July 12, 2023, designated confidential pursuant to the Protective Order +in this matter and filed under seal. +71. Attached as Exhibit 70 is a true and correct copy of JPMorgan Chase Bank, N.A.'s +Fourth Supplemental Initial Disclosures in the matter of Government of The United States +Virgin Islands v. JPMorgan Chase Bank, N.A., 1:22-cv-10904, dated May 30, 2023. +72. Attached as Exhibit 71 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00136984, designated confidential pursuant to +73. Attached as Exhibit 72 is a true and correct copy of a document produced by Defendant +stamped JPM-SDNYLIT-00127930, designated confidential pursuant to +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true +and correct. +Dated: August 25, 2023 +Is/ Stephen L. Wohlgemuth +Stephen L. 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ALISON J. NATHAN, +Jury Trial +New York, N.Y. +December 18, 2021 +9:10 a.m. +District Judge +APPEARANCES +DAMIAN +United States Attorney for the +Southern District of New York +BY: MAURENE COMEY +LARA POMERANTZ +ANDREW ROHRBACH +Assistant United States Attorneys +HADDON | +AND +Attorneys for Defendant +BY: JEFFREY S. PAGLIUCA +LAURA A. MENNINGER +BOBBI C. STERNHEIM +-and- +& GRESSER +BY: +CHRISTIAN R. EVERDELL + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 2 of 95 +2740 +(In open court; jury not present) +THE COURT: Good morning, everyone. +ALL COUNSEL: Good morning. +THE COURT: Please be seated. +All right. Looks like we have everybody. Let me just +make sure we're set up. +okay. Thank you, everyone, for the Saturday charging +conference, a first for me, but it helps us use our time well, +I think, so thank you for that. +I circulated to the parties the draft charge, which we +docketed last night. In the draft verdict form, the way I do +this is to just ask, starting with the first page on which you +have a request that you want to make, and give me the page and +line number and we'll discuss it. If I accept the change, it +will be entered in redline by my law clerk. And then once +we're finished, I'll send to the parties the redline so you can +help me make sure that everything got entered properly. +All right. So Mr. Rohrbach, first page that you have. +MR. ROHRBACH: The government's first request is on +page 32. +THE COURT: Before that? Mr. Everdell? +MR. EVERDELL: Yes, your Honor. Defense's first +request - +THE COURT: It may be best to -- you're welcome to +remain seated -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 3 of 95 +2741 +MR. EVERDELL: I can pull this up a little bit? +THE COURT: -- if I'm going to hear from you a lot. +But yes, pull up the mic and -- yes. First page, Mr. Everdell. +MR. EVERDELL: Defense's first page is page 15. +THE COURT: Okay. Line? +MR. EVERDELL: Well, we'll start with line 8 and 9. +THE COURT: Okay. +MR. EVERDELL: So this was the summary of the +indictment charge, your Honor. +THE COURT: Yes. +MR. EVERDELL: And on 8 and 9, there's a reference to +travel to both interstate and foreign commerce. I think +throughout the charge there's a bit of an inconsistency. +Sometimes we're talking about just interstate, sometimes we're +talking about interstate and foreign. I actually don't think +that there's any evidence, especially with respect to Count One +or the +Act charges or any of them, we're talking about +"and foreign commerce." I think it's interstate commerce, +so I +don't think the "and foreign" is necessary. +THE COURT: I think we have -- Mr. Rohrbach? +MR. ROHRBACH: Your Honor, this actually relates to +the government's later request, but the government's view is +that there are flight records that show +traveling with the defendant and Jeffrey Epstein overseas while +she is 17, I believe, and so that would be sufficient, at least + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 4 of 95 +2742 +as to Counts Five and Six. +THE COURT: So the government's request is that I +include "foreign" in each instance and the defense's request +that I remove "foreign" in each instance. As we stand, there's +inconsistency. Do I have that right, Mr. Everdell? +MR. EVERDELL: I'm sorry, your Honor. +Can you say +that again? +THE COURT: Sure. Right now there's inconsistency as +to whether "foreign commerce" is included or not, and the +defense's request is that "foreign" be excluded in each +instance and the government's request is that "foreign" be +included in each instance. +MR. EVERDELL: That's correct, your Honor. +THE COURT: Okay. Mr. Everdell, do you want to +respond to the government's point about flight records. +MR. EVERDELL: Your Honor, the flight records, I +think -- I'm trying to think of the references to -- you said +it relates to which individual? I'm sorry, your Honor. +MR. ROHRBACH: It relates to +while +she was 17, and so that, at a minimum, in the government's +view, means "foreign commerce" should be included in Counts +Five and Six. +MR. EVERDELL: Your Honor, there's no testimony about +the purpose of those trips or any enticement with respect to +those trips. I think +the sum total of her + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 5 of 95 +2743 +testimony was that she recruited Carolyn, and she didn't +testify, and I don't think -- this is not the theory that the +government's been proceeding on on these counts. These counts +relate to the four accusers that testified. I think for the +jury to infer then that there's enticement with respect to +when there's no evidence in the record of +Ms. Maxwell or anybody enticing her, there's just testimony +that she enticed Carolyn, if anything, that's not an +appropriate theory for the jury to base their conviction on +foreign commerce, if she's the one who traveled. +MR. ROHRBACH: If I may, your Honor. I think for +counts -- +THE COURT: We're talking 18 U.S.C. 1591, correct? +MR. ROHRBACH: Yes. The government does not -- if the +Court and defense prefer to remove "foreign commerce" from One +through Four, +conduct doesn't show that. +While that's a legally proper instruction to leave "foreign +commerce, " it's at least available to the jury as to Counts +Five and Six because of 18 U.S.C. 1591). +THE COURT: But the text of 18 U.S.C. 1591 doesn't +include "in foreign commerce," does it? +MR. ROHRBACH: Yes. It says, "Whoever knowingly, in +or affecting interstate or foreign commerce, recruits, entices, +harbors, " etc. +• I see. It appears that —- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 6 of 95 +2744 +THE COURT: There is a -- +MR. ROHRBACH: +- there was a statutory change that +added "foreign commerce." +MR. EVERDELL: Yeah. +THE COURT: It depends on what the operative time +period for the inclusion of it is. +MR. ROHRBACH: In light of that, your Honor, I think +the government would withdraw its request as to Counts Five and +Six. +THE COURT: Okay. +MR. ROHRBACH: To avoid any ambiguity about that +point. +THE COURT: Okay. All right. So you'll help me, +Mr. Everdell, find each instance in which we need to remove +"and foreign"? +MR. EVERDELL: Yes, your Honor. +THE COURT: The first one you've identified -- +MR. EVERDELL: If you like, on this charge, I can go +through the ones I see on this page. +THE COURT: Let me just note the first one we've +discussed, because my clerk is going to wait for me to say the +change in order to make it. So let me just note on page 15, +lines 8 and 9 -- on line 8, deleting the word "and, " on line 9, +deleting the word "foreign." +Next one, Mr. Everdell? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 7 of 95 2745 +MR. EVERDELL: Line 12, your Honor. +THE COURT: Line 12, deleting the word "and," deleting +the words "and foreign"? Go ahead, Mr. Everdell. +MR. EVERDELL: Line 15, same change, your Honor. +THE COURT: Line 15, deleting "and foreign." +MR. EVERDELL: Yes, your Honor. +THE COURT: And line 19? +MR. EVERDELL: Correct, your Honor. +THE COURT: Deleting "and foreign." +That's it for that, for the summary, correct? +MR. EVERDELL: That's it for the "and foreign," yup. +THE COURT: Okay. +MR. EVERDELL: We have a few others. +THE COURT: All right. Well, let's be comprehensive +on this. Are there any other places in the charge where that +appears? +MR. EVERDELL: +•, the other places in the whole +charge. +THE COURT: Actually, we'll hit it when we get there. +So what else on 15? +MR. EVERDELL: Sure. So line 10, your Honor -- +THE COURT: Okay. Just one second. +MR. EVERDELL: Okay. +THE COURT: Go ahead. +MR. EVERDELL: Thank you, your Honor. On line 10, it + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 8 of 95 +now reads, "Count One relates to multiple alleged victims in +the time period 1994 into 2004." We believe it should read, +"Count One relates solely to Jane and the time period 1994 to +2004." And I can explain, if you like, your Honor. +THE COURT: Let me just get my eyes on it. +Okay. +MR. EVERDELL: So, your Honor, this is an issue I +think we've gone back and forth on quite a bit in the motions +in limine. But with respect to the government's theory of the +conspiracy and of the substantive counts, enticement and +transportation, so Counts One through Four, is that the +underlying object was a violation of New York law, right, +Section 130.55. So there has to be -- the object of this +conspiracy is a violation of New York law. With respect to +Kate, there was no violation of New York law. Your Honor +already instructed the jury that they can't consider that +evidence for purposes of conviction because she was above the +age of consent. There was no violation of New York law. Same +thing with -- +THE COURT: Well, just to be slightly more precise, +they can't convict on that count based solely on the evidence +of the conduct involving her. +MR. EVERDELL: Correct. And with respect to Annie, +the Court also instructed that this is -- whatever conduct they +may find that she talked about in New Mexico, was not illegal +2746 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 9 of 95 +2747 +sexual activity as charged in the indictment, which is a +reference to the violation of New York law, because that is the +theory we're proceeding under. +With respect to Carolyn, there was no limiting +instruction, but it's evident we were talking about Florida +conduct. +There is no violation of New York law there. So the +only evidence we have that goes to -- that actually establishes +a violation of New York law, which is the object of this +conspiracy, and the object of the transportation conspiracy, is +what Jane said. +Now the Court did instruct the jury that they can +consider the testimony of Kate and of Annie for whatever +relevant purpose they see fit, and I suppose that could be +evidence of a conspiracy, correct, but for them to actually +convict on this, they have to believe that somebody committed a +violation of New York law, and that relates solely to Jane, and +so we don't think -- there are no multiple alleged victims of +this conspiracy other than Jane that's been established by the +evidence at trial. So we believe while they may be able to +consider the testimony of Annie and Kate as evidence of some +sort of relevant evidence that speaks to this conspiracy, that +is not - they are not victims of this conspiracy, there was no +violation of New York law that they testified to, and that is +Jane alone. So this count relates solely to Jane, as does the +substantive count, your Honor. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2748 +THE COURT: Mr. Rohrbach? +MR. ROHRBACH: Your Honor, this is a place where the +defense confuses conspiracy violations and substantive +violations. There does not have to be a proven violation of +New York law as to any of the minor victims. It just has to be +an agreement to accomplish that purpose. +Carolyn, for +instance, was invited to travel by the defendant. The jury can +readily find that that invitation to travel included an +invitation to New York, where the abuse would continue, as it +did for Jane. Annie was in fact transported by the defendant +Epstein to New Mexico and New York. The jury could readily +find that that was a conspiracy that existed, and as part of +that grooming conduct, the plan would be to continue to abuse +her, including back in New York. These are available +inferences to the jury, and that's all that's required for the +conspiracy count. +THE COURT: That's precisely why there was a different +limiting instruction for Annie than there was for Kate. +MR. EVERDELL: Well, your Honor, I would dispute the +facts a little bit there, because they said that Carolyn's +testimony was that she was invited to travel to the island. +She was not invited to travel anywhere; she specifically +testified she was given an invitation to the island. That's +not travel to New York. And her mother said she couldn't be +able to go. So I don't think that is evidence -- if the object + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2749 +of the conspiracy is to violate New York law, then an +invitation to an island that's not New York doesn't count. +And also, an invitation to travel to New Mexico to do +whatever it is they were planning on doing in New Mexico is +also not a goal of violating New York law. I'm sorry, from +Arizona. So there's no connection to New York law with respect +to Annie's testimony either. +And so whatever purpose they want to glean from those +two witnesses' testimony, Kate and Annie, or even Carolyn, the +object of this conspiracy, for this to be a crime, it can only +be hung on the testimony, at least in the evidence in the +record, the testimony of Jane. And -- +THE COURT: You're doing precisely what Mr. Rohrbach +said, which is you're switching back and forth between the +conspiracy and the substantive count. So Annie, for example, +the evidence is the conduct occurred in New Mexico. That's why +I gave the limiting instruction. But that could be considered +with other evidence of the conspiracy with respect to New York, +the violation of New York law. You don't have to have the +violation of New York law to establish the elements of the +conspiracy count. +Next. +Honor, same page. +So the objection is overruled. +MR. EVERDELL: Al1 right. Next is line 13, your + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 12 of 95 2750 +THE COURT: Okay. +MR. EVERDELL: We would add, the last sentence, "Count +Two relates solely to Jane and the time period 1994 to 1997." +THE COURT: Okay. Mr. Rohrach? +MR. ROHRBACH: I think that's redundant, but the +government is fine with that. +THE COURT: Okay. Page 15, line 13, adding "solely" +between "Count Iwo" and "relates." No, I'm sorry. Between +"relates" and the word "to." So the sentence will read, "Count +Iwo relates solely to Jane." +Next. +MR. EVERDELL: Yes, your Honor. Same page, line 15. +This is on Count Three. +I'll just go back to line 14. Count "Three of the +indictment charges the defendant with conspiring with others to +transport an individual," and we would add "under the age of +18," "in interstate commerce," because we've eliminated "and +foreign." +THE COURT: Mr. Rohrbach. +MR. ROHRBACH: I believe that the elements that the +Court has set forth for that count is an individual under the +age of 17. +MR. EVERDELL: I'm sorry. +MR. ROHRBACH: Is that -- +THE COURT: We've adopted the Sand suggestion. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2751 +MR. EVERDELL: Right. +THE COURT: So just rather than give the jury two +elements with two different ages, which I think makes sense. +But so then the suggestion is "to transport an individual under +the age of 17." +MR. EVERDELL: Yes, your Honor. +THE COURT: Mr. Rohrbach? +MR. ROHRBACH: The government agrees that that's an +element of the offense. There is no reason to incorporate all +of the elements into the summary. +THE COURT: Well, he's not asking all. He's just +asking this one. So -- +MR. ROHRBACH: That's fine, your Honor, although the +government would note that that creates an asymmetry between +Counts One and Three, so we think it should be in both or +neither. +THE COURT: All right. +MR. EVERDELL: Well, it's not an element of the +offense in Count One. I add it there because it says "an +individual" and "an individual" seems sort of vague. I mean, +there's testimony about lots of individuals traveling, and +transporting here and there. We just wanted to make it clear +to the jury that we're talking about individuals under the age +of 17 rather than all these people on the flight logs that we +saw who we have no evidence of their ages. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-Cr-00330-PAE Document 765 Filed 08/10/22 Page 14 of 95 +LCIIMAXI +2752 +MR. ROHRBACH: If this is the defense's preference, +your Honor, the government is fine with it. +THE COURT: Okay. I'll accept that request. Page 15, +line 15, after the word "individual," adding "under the age of +17." +Next? +MR. EVERDELL: Yeah. And then similar request: line +18, after the word "individual," add "under the age of 17." +THE COURT: Mr. Rohrbach? +MR. ROHRBACH: No objection. +THE COURT: Okay. Making that same change, page 15, +line 18, after "individual," adding "under the age of 17." +Let me just give my law clerk a moment to get it +entered. +Okay. +MR. EVERDELL: And then line 20, it's a similar -- +THE COURT: Hang on. Hang on. Let me just read that +full sentence for clarity. +So page 15, line 18, first sentence of the paragraph, +"Count Four of the indictment charges the defendant with +transporting an individual under the age of 17 in interstate +commerce." +MR. EVERDELL: Yes, your Honor. +THE COURT: Go ahead. +MR. EVERDELL: Next line, line 20, similar to what we + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2753 +asked for before, last sentence, "Count Four relates solely to +Jane and the time period --" +THE COURT: Okay. I'll accept that. +Page 15, line 20, the sentence that begins, "Count +Four," adding "solely" after "relates," so the sentence would +read, "Count Four relates solely to Jane." +Okay. Next? +MR. EVERDELL: Page 16, line 2, similar request: +"Count Six relates solely to Carolyn." +THE COURT: Okay. I'll accept that. +Page 16, last line, adding "solely" after "relates" +and before "to Carolyn." +Okay. Next page. +MR. EVERDELL: Page 17, this is a small one, your +Honor. +THE COURT: Okay. +MR. EVERDELL: Lines 2 to 3, "Each count charges the +defendant," since we're using "Ms. Maxwell" in the other parts +of this charge, we'll just say, "Each count charges Ms. Maxwell +with a different crime." +THE COURT: All right. That's fine. +So instruction 11, page 17, line 3, changing +"defendant" to "Ms. Maxwell." So the sentence reads, "Each +count charges Ms. Maxwell with a different crime." +MR. EVERDELL: Your Honor, can I just have one moment. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCI 1MAXI +Document 765 Filed 08/10/22 Page 16 of 95 +2754 +THE COURT: Yes. +MR. EVERDELL: Your Honor, I'm sorry. Could we just +return to page 15. +THE COURT: Sure. +MR. EVERDELL: Line 23. +THE COURT: Okay. +MR. EVERDELL: There, it says -- and it's also on the +next page, but we'll get to that. It says, "Count Five of the +indictment charges the defendant with conspiring to engage in +sex trafficking of minors. And the word "minors" depends on +jurisdiction, and it creates a lot of ambiguity because we've +got allegations, especially because the time period of the +conspiracy, 2001 to 2004, you know, the word "minors" is going +to create an ambiguity, and it raises issues with the age of +consent, because you're not a minor unless, you know —- +THE COURT: You want to change it to an individual +under the age of 17? +MR. EVERDELL: Yeah, either under the age of 17 or +under the age of consent. +MR. ROHRBACH: Well, your Honor, first, for the sex +trafficking counts, the relevant age of consent is 18. +THE COURT: Right. +Sorry. Thank you. +MR. EVERDELL: Yeah, actually, that's right. That's +in the language of the statute itself. +MR. ROHRBACH: Yeah. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2755 +MR. EVERDELL: So why don't we say "under the age of +18, " if we could, your Honor. +THE COURT: Is that okay, Mr. Rohrbach? +MR. ROHRBACH: Since it relates to multiple +individuals here, it would have to be "individuals under the +age of 18, " but the government would be fine with that change +to avoid ambiguity. +THE COURT: Okay. So page 15, line 23, it will read +"to engage in sex trafficking of individuals under the age of +18. " Just one moment. +Okay. +MR. EVERDELL: And your Honor, next page, it's a +similar request. On line 1, we would say, "Count Six of the +indictment charges the defendant with sex trafficking of +individuals under the age of 18." +THE COURT: Okay. +MR. ROHRBACH: Well, your Honor, for this one, since +it just relates to Carolyn, it could just be an individual, but +otherwise that's fine. +MR. EVERDELL: An individual under the age of 18. +THE COURT: That's right. All right. So we'll change +page 16, line 1 to read, "Count Six of the indictment charges +the defendant with sex trafficking of an individual under the +age of 18." +MR. EVERDELL: Yes, your Honor. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2756 +THE COURT: Okay. Have we made it to 17? +MR. EVERDELL: We've made it to 19, in fact. +THE COURT: 19. Wow. Progress. +MR. EVERDELL: Page 19 is the next one, your Honor. +THE COURT: Okay. Go ahead. +MR. EVERDELL: First, on line 5, there's another "or +foreign," which we can omit. +THE COURT: Okay. Let me just 1ook. +Yeah. Okay. +MR. ROHRBACH: It would need to be ellipses since this +is the statutory text, but that's fine with the government. +THE COURT: So we'll do, page 19, line 5, it will +read, "Travel in interstate... commerce," cutting "or foreign" +and replacing with the ellipses. +Okay. Next page. +MR. EVERDELL: Same page, your Honor, line 4. +Don't worry. I tried to be efficient about this. +We'll go quickly. +THE COURT: That's fine. +MR. EVERDELL: Line 4. There is the inclusion of the +statutory text "or coerces, " and since we don't have any +evidence of coercion, our proposal would be to add -- have it +read "knowingly persuades, induces, or entices... any +individual." +THE COURT: Or in brackets. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCI 1MAXI + +2757 +MR. EVERDELL: Or in brackets because it's an addition +to the statutory text. +MR. ROHRBACH: Your Honor, the government does not +agree with this one. The jury could conclude that the minors +had been coerced for the enticement counts. There's expert +testimony from Dr. Rocchio about how these relationships sort +of evolved; there's testimony from Jane in the record about +how, toward the end of her relationship with Mr. Epstein, she +felt like she was compelled to continue answering the phone and +would drop everything because she had no other choice. I think +the jury could conclude that these victims were coerced. +"Coercion" in this context just bears its ordinary and natural +meaning, and there's no reason to delete it from the charge. +MR. EVERDELL: Well, your Honor, I agree I know we +give normal meanings to these words, and coercion in my normal +meaning implies some sort of force, or at least of violence or +something, and there's no evidence of that in the record. +MR. ROHRBACH: It's an argument that the defense is +free to make to the jury. +THE COURT: Well, what's the legal basis for the +notion that coercion as used here textually requires force? +MR. EVERDELL: Your Honor, as in Sand, they just say +"given the normal everyday meaning." It's not particularly +helpful, but I guess that can differ by person. My normal +everyday meaning of "coercion" means some sort of force being + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 20 of 95 +2758 +used, and if that's not the Court's opinion, then -- +THE COURT: I'm just asking if you have any legal +support for that principle. +MR. ROHRBACH: Your Honor, one good reason to think +that coercion does not involve force is that the sex +trafficking statute includes criminal activity by force, fraud, +or coercion, and in that statute, "force" and "coercion" carry +different meanings. +THE COURT: Okay. I'm going to overrule the +objection. So that will remain. +Next page, Mr. Everdell. +MR. EVERDELL: Yes, your Honor. Before I get to the +next page, just for purposes of clarity, if the Court overrules +a proposed edit, I would still note that I have that same +proposal going through my changes. I just won't reiterate it. +But I would like to just preserve those, preserve my +suggestions, similar ones in similar charges. +THE COURT: So you would repeat your request to remove +"coercion" from every instance, so that is preserved. +MR. EVERDELL: Correct, your Honor. +All right. So we can go to page 20 now, your Honor. +THE COURT: Okay. +MR. EVERDELL: All right. So on this one, your Honor, +I understand, we're talking about the substantive count, and I +do understand that because the way the charge is organized and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 21 of 95 +2759 +the conspiracy counts come later, I think there is an attempt +here to generalize the wording of the elements because it's +going to be applied later to the conspiracy counts, right? But +this is the substantive count, and if we look at the line 5, it +says first that the defendant knowingly persuaded or induced or +enticed or coerced an individual to travel in interstate +commerce. +The individual in the substantive count is Jane. +The defense request is for it to say not "an individual," +replace that with "Jane to travel in interstate commerce from +Florida to New York, as alleged in the indictment." +THE COURT: Mr. Rohrbach. +MR. ROHRBACH: So, your Honor, I don't think the jury +will be confused. Both in the summary and later on in this +section, it says this relates to Jane. If the defense would +like it to say it relates solely to Jane here as in the +summary, that would be fine, but the Court is just laying out +the elements of the offense and there's no need to put all of +the factual predicates of the offense into the statement of the +elements. I think here and elsewhere, the defense -- +Mr. Everdell can correct me, but an issue in the parties' +proposed requests to charge is whether things like the name +Jane, travel to New York, the name Jeffrey Epstein should all +be included in the recitation of the elements. I think the +defense is getting that because it's in the "to wit" clause of +the indictment, and the law is quite clear -- and I have + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2760 +authority if the Court would like -- that the fact that there +are proper nouns in the "to wit" clauses does not mean the +government is bound by them as elements of the offense, as long +as the government is proceeding on the essential elements of +the crime as charged by the grand jury. And I think there's no +suggestion -- it's quite clear that the government has been +trying to prove the offenses in the indictment and there's no +need to include words like "travel from Florida to New York," +or "Jane, " to avoid any suggestion of a variance. +THE COURT: Yes, I agree with that. Obviously this +dispute was in the parties' proposed charge, and I balanced I +think, as appropriate, including the name of the individual +where a particular count applies only to them, but not +otherwise restating factually in the explanation of the counts +and the elements each of the factual points to be proved. So I +think here, Mr. Rohrbach, you didn't disagree with substituting +Jane for an individual? +MR. ROHRBACH: Well, that just creates the -- the +government thinks the charge is fine as it is because, in +line 11, it says it relates to Jane, and the government would +be fine with adding "solely to Jane, " or "relates, " if that's +what the defense would like. I do think adding Jane in line 6 +would create a problem when it's later incorporated by the +conspiracy instruction. +THE COURT: Okay. I agree with that. And that's the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 23 of 95 +2761 +usefulness of line 11, which states expressly Count Iwo, and +I'll add, "Count Iwo relates solely to Jane during the time +period 1994 to 1997," for the reason indicated. Because the +conspiracy count requires looking back to the substantive count +for the object of the conspiracy. +I won't adopt the requested change within the +statement of the elements. +Anything else on page 20? +MR. EVERDELL: With the addition of solely, your +Honor, on line 11, there is just, on line 7, another "or +foreign" that we need to omit. +THE COURT: Okay. Thank you. So from the second +element, page 20, line 7, the sentence that begins with +"Second, " cutting "or foreign." Okay. +MR. EVERDELL: Page 21, your Honor. On line 4, I'1l +just reiterate, I understand this has been overruled by the +Court but we would propose replacing "an individual" with the +word "Jane." On line 5, there is "or foreign, " which should be +omitted. +THE COURT: Thank you. Page 21, line 5, "to travel in +interstate commerce, " cutting "or foreign." +Okay. +MR. EVERDELL: On line 6 we would just reiterate our +objection to the word "coerced." I understand that's been +overruled. But then, your Honor, generally I would say the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2762 +word "coerced" we would like to remove. We understand that's +been overruled by the Court. +Okay. But there is some additional language we would +propose at the end of line 6, and this is something that I +raised I think in a letter submission in -- or not in a +letter -- orally at the Rule 29 argument. It's based on U.S. +v. Broxmeyer, which, as I argued to the Court at the Rule 29 +argument, the words "persuade," "induce," and "entice" are +words of causation and they need to cause an effect, and so +what we would propose after the sentence, "The terms +'persuaded, ' 'induced,' 'enticed,' and 'coerced' have their +ordinary, everyday meanings," we would propose adding the +following language: "This element is satisfied only if the +'persuasion,' 'inducement,' or 'enticement' caused Jane to +travel in interstate commerce as alleged in the indictment." +We're basing that on U.S. V. Broxmeyer, interpreting those +words from a different but related statute. +THE COURT: Give me one moment. +MR. EVERDELL: I have a copy of Broxmeyer, your Honor, +if you'd like to see it. +THE COURT: Sure. I'll take it. +MR. EVERDELL: Your Honor, I believe it's on page 125 +of the opinion. +THE COURT: Okay. The relevant language. +MR. ROHRBACH: Your Honor, this is not just a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 765 +LCI 1MAXI + +2763 +different statute, it's quite a different statute. It's the +production of child pornography statute. +And also, the +question in Broxmeyer was somewhat different. It was a +sufficiency of the evidence question about whether the +government's evidence showed that the persuasion or inducement +occurred before the production of the child pornography, and so +that's -- I don't think that this case stands for a particular, +like, form of causal nexus that's required between +"persuasion, " "inducement," or "coercion" and the travel +itself. I think the jury will be confused by an instruction +along those lines because it suggests that some amount of +causation is required above the inherent causation in the +statutory terms of inducement or enticement. Those are words +of causation, but they are sort of words of causation in the +plain and ordinary sense and not in any greater or more +significant sense that I think a further instruction on that +point would suggest. +MR. EVERDELL: Your Honor, if I could just respond. I +don't think this is heightening the level of proof. I think +this is simply -- the opinion is simply explaining what is +required by those words, "persuasion, " "inducement, " +"enticement," and those words are the exact same words that are +used in the statute, so I don't think the context of the case +really matters in terms of what those words mean. There may be +some inherent causation built into these words, but this is + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2764 +explaining the fact that that causation needs to exist. In +case +there's any doubt in the minds of the jurors, there does +need to be causation. There has to be an effect from the +inducement, the persuasion, the enticement. +MR. ROHRBACH: First there has to be some sort of +causal relationship. +That's what the word "inducement" means, +for example, as a form of a causal relationship. I'm certainly +not aware of any case or treatise that provided this +instruction. Maybe perhaps defense counsel is. But, you know, +the fact that it is in Broxmeyer does not mean it's appropriate +to give a further and more specific instruction about causation +than is already inherent in the ordinary meaning of these +words. +THE COURT: Just so I have my head around it, the +specific suggestion was what, Mr. Everdell? +MR. EVERDELL: "This element is satisfied only if the +persuasion, inducement, or enticement caused Jane, " or we can +say "caused the individual," "to travel in interstate commerce +as alleged in the indictment." +MR. ROHRBACH: The problem, your Honor, is that to the +extent that those words already mean to cause, inducement has a +causal meaning, persuasion has a causal meaning. It's already +in the instruction. And to say, you can only satisfy those +words if she caused the travel suggests that there are two +requirements -- there's the requirement that the defendant + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2765 +induced the travel, and a separate requirement that she caused +the travel. And there's no causal obligation or causal +requirement in the statute above and beyond the persuasion, +inducement type causal requirement. +MR. EVERDELL: I mean, your Honor, if the objection is +to the preamble by saying, "This element is satisfied only if," +we could modify that a bit, if the government's saying that is +too strong, but the guts of the suggestion is that the +persuasion, inducement, or enticement must have caused the +individual to travel in interstate commerce, as alleged in the +indictment. +THE COURT: I mean, I've seen this charge in a variety +of cases. I've never seen that language. This decision is +2010. Have you ever seen it in a charge? +MR. EVERDELL: I can't say that I have, your Honor. +But it is interpreting the very words of the statute that are +at issue here, and I don't think this is the way that -- the +proposal I'm proposing is not trying to belabor the point, but +it is trying to raise the issue of causation. +THE COURT: I mean, the opinion includes further +definition of the words that are subject to the ordinary +meaning, the paragraph above that you point to. +MR. EVERDELL: Your Honor, I'll add that it is +possible to be persuaded, induced or enticed, and then not +actually travel. I mean, the persuasion does have to cause the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 28 of 95 2766 +travel, so that there has to be a causation, some effect of the +persuasion. +MR. ROHRBACH: Well, the instructions say that there +has to be persuasion and inducement or enticement to travel, +and the individual has to actually travel. Those concepts are +all already captured in the instruction. These instructions +for this element are just -- or this offense are quite standard +that are in the Court's jury charge. +THE COURT: Yeah, I think that's right. It seems to +me — well, one, it's a standard charge for this provision; +two, it's accurate; three, adding -- I mean, it seems to me +that the basic suggestion applies additional causation beyond +what's required by the ordinary meaning, and I don't see a +basis for that. So I will overrule the request. +What's next? +MR. EVERDELL: One moment, your Honor? +THE COURT: Yes. +MR. EVERDELL: Your Honor, next request is at page 23. +THE COURT: Okay. +MR. EVERDELL: This is at line 15 through 22, which is +the instruction on significant or motivating purpose -- +THE COURT: Yes. +MR. EVERDELL: -- which was a suggestion from the +defense, and we appreciate the Court's inclusion. +THE COURT: Well, I think you'd suggested significant + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +and, if I'm remembering correctly -- +MR. EVERDELL: Yes, your Honor. That may be true. +THE COURT: Yes. +Go ahead. +MR. EVERDELL: So we have found a different +instruction on this point which we would ask the Court to +consider, and it comes from United States v. +• and I can +hand that up to the Court and the government. +THE COURT: Just to be clear, I adopted your +suggestion and now you're asking me to do something different. +MR. EVERDELL: Well, it is true, your Honor, and I +will keep what I have, if this is objectionable to the Court. +But we only found this one as we were looking through with +respect to the charge. +THE COURT: It happens. Just give me a moment to get +to my notes on this one. +proposed instruction. +MR. EVERDELL: Your Honor, I can give a typewritten +Page 211 of the opinion is the instruction that was +given by Judge Rakoff. +THE COURT: And what's the charge in the +case? +MR. EVERDELL: Well, your Honor, +was found +guilty of 2422 and 2423, the same statutes we're talking about. +THE COURT: Okay. So the proposal is, in order to +establish the element, the government must prove that it was +part of Ms. Maxwell's conscious purpose in having Jane travel +2767 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2768 +across state lines to have her engage in criminal sexual +conduct, in violation of New York law. It need not have been +her only purpose or motivation, but it must have been more than +merely incidental. It must have been one of the dominant +purposes of the trip. +MR. ROHRBACH: Your Honor, all that the law requires +is that it be one of the dominant purposes of the trip, which +is the instruction that the defense originally sought and the +Court gave. It's the practice, as Sand endorses, to rephrase +"dominant" as "significant or motivating purpose" to avoid +confusion, because it doesn't have to be the sole dominant +purpose, it just has to be a dominant purpose, and so from +Sand, that creates ambiguity that it has to be a sufficient -- +such a big purpose that it's the dominant purpose, which is not +what is required by the statute. This instruction suggests +there's an additional requirement, which is that it be some +sort of conscious purpose to engage in the particular criminal +violation suggesting knowledge of the criminal statute and +criminal prohibition. All the +case does is affirm that +this instruction is not error. It does not say that that is +the required instruction by -- at least as I'm reading the -- +I'm reading the +case for the first time now, but it is +an appeal from a conviction on that instruction. It is not +suggesting that it's required by -- +THE COURT: Let me look. I've only read the -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2769 +MR. ROHRBACH: I've only read portions of it too, but +that's my quick read. +THE COURT: So the defendant's argument in +was +that the prostitution or other criminal sexual activity must be +the dominant purpose of the interstate travel rather than only +one of the dominant purposes as the judge charged. +MR. ROHRBACH: In fact, your Honor, I think in light +of that conclusion, the final sentence of the defense's +proposed instruction would be suggestive of error because the +point is that +-- or at least creates the very confusion that +arose in +about whether it has to be one of the dominant +purposes. The use of the word "dominant" is a source of +confusion, as Sand has explained. +MR. EVERDELL: Well, your Honor, on that point, the +language "significant or motivating purpose" is completely +invented by Sand, right, and now people have used it because +Sand is an authority in this area, but that does not -- that +did not come from case law. That is Sand's proposal to deal +with the issue of the dominant purpose versus one dominant +purpose. There is, however, case law in many circuits where +the instruction "one dominant purpose" is accepted instruction, +and the +case endorses that instruction because that was +the charge that was given by Judge Rakoff and they said it was +perfectly proper to give that charge. So I actually think +there is more support in the case law for the "one dominant + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2770 +purpose" language than language that happened to have been +invented by Sand. As smart as Judge Sand was, that did not +actually come from any circuit case law. So we propose going +with what the courts have actually said on this issue rather +than a proposal in Sand. +THE COURT: I'm just going to read for a moment. +I think I want to start by asking what's wrong with +the current instruction, the one that you proposed that I +adopted? That's the one that I've seen in -- +MR. EVERDELL: Well -- +THE COURT: -- in charges. +MR. EVERDELL: Your Honor, there's nothing wrong with +it per se. It is a charge that has been used in other cases, +and we proposed it, so we obviously think it's acceptable. But +I think the new proposed charge is a charge that is more +accurate and also tracks the case law development on this point +because the dominant purpose is actually something that was in +a Second Circuit opinion and it's, you know -- Judge Rakoff has +tried to craft an instruction in +to deal with the issue +of one dominant purpose versus the dominant purpose, but the +way that I think the case law has developed in the Second +Circuit, it started with "dominant purpose" was the language +used and then we had to deal with this issue of ambiguity +there, and this is how Judge Rakoff came out, but was still +keeping the "dominant purpose" language but clarifying it was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 33 of 95 +2771 +only one of the dominant purposes. +THE COURT: Let me just note my remarkably crack law +clerks have found the following case: United States v. An Soon +MR. EVERDELL: Yes. +THE COURT: You're aware of it. +MR. EVERDELL: Yes. But that case -- +THE COURT: Just let me give the cite. 471 F. App'x +82 (2d Cir. 2012). Summary order, obviously, but it says a +couple of things. One -- ooh, I lost what my crack law clerk +sent there. It endorses the Sand language over "dominant." +"These instructions are legally sound. Neither 'dominant' nor +'predominant' appear in the statutory language. Although we +have previously approved a jury charge that included the phrase +"one of the dominant purposes," (see, e.g., +) we've never +required such language to appear in a jury charge on 2421. +Indeed, Judge Sand recommends excluding the word 'dominant' +from the charge so as to avoid confusion." And then at the end +of the opinion, "The charge given by the district court, which +closely tracks the charge outlined by Judge Sand, accurately +and thoroughly conveyed the second element of the crime. +Accordingly, we find no error, much less plain error, in the +jury charge." +MR. EVERDELL: Yes. So the way I read that case, your +Honor, is that there are two variants on how this charge has + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2772 +been given in the Second Circuit, both of which have been +endorsed by the Second Circuit, neither of which is required +but both are permissible. +THE COURT: But I think what we have here is Second +Circuit agreeing with Sand that "dominant" can be confusing. +And so I will stick with your original proposal and not the +request to change that out now for the language adopted by +Judge Rakoff because it would include the -- although deemed +not error, it would include the "one dominant purpose" +language, which is potentially confusing and not moored to the +text of the statute. +What's next? +MR. EVERDELL: Understood, your Honor. +The next page, your Honor? +THE COURT: Yes, please. +MR. EVERDELL: Page 24. So this is the page where the +charge describes the violation of New York law. +THE COURT: Page? +, I'm sorry. I'm on my annotated +version. Just a second. +Yes. +MR. EVERDELL: Well, first, this one very small change +on line 19, if we could replace "the defendant" with +"Ms. Maxwell. " +THE COURT: Okay. +MR. EVERDELL: But there's a larger request. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 35 of 95 +2773 +THE COURT: All right. Page 24, line 19, I'll adopt +that change. So instead of "the defendant," "Ms. Maxwell." +Just one moment. +Okay. +MR. EVERDELL: Okay. So the additional request is -- +this is where the issue of the fact that Kate was above the age +of consent and about the fact that -- well, Annie's testimony +was not a violation of New York law. That's what the Court +gave the limiting instruction to the jury on. We think that it +is appropriate to incorporate those limiting instructions into +the jury charge and that this is the place where it should be +given. Because it's one thing to give the limiting instruction +at the time of the testimony -- that is what we asked for and +we appreciate the Court doing that -- but I think that they +need to be instructed again before they go into deliberations, +now having heard 12 plus days of testimony, that what those +considerations -- that testimony they are allowed to consider +for what purpose, because if they're given an instruction on +New York law, I think it's time to reiterate in the charge to +them that Kate was over the age of consent and was not +involved -- it cannot be considered illegal sexual activity, +because this is where the illegal sexual activity is defined. +And same with Annie. I have a proposed instruction to add +here, but it tracks the language of the limiting instruction +the Court gave, so I don't think it's adding any language. +I + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2774 +can hand it up. +THE COURT: Sure. +MR. EVERDELL: And your Honor, as you consider that, +there is one proposed addition I just want to request to what's +on that page, but I want to handle that slightly separately. +THE COURT: The representation is these are -- +MR. EVERDELL: Yeah. +THE COURT: —- my limiting instructions given before +Kate and +testified, and you're asking for +inclusion -- repetition of those limiting instructions where +the violation of New York criminal law is provided. +MR. EVERDELL: That's correct, your Honor. And we +would propose just putting it at the end after the discussion +that's already there. +THE COURT: Mr. Rohrbach. +MR. ROHRBACH: I think that among other things, your +Honor, I think that would be -- the instruction as you've +crafted it is a correct statement of New York law and the +relevant issues. Adding these instructions would be quite +confusing to the jury. The jury has already heard them. This +is the place where there's no reason to give the Kate +instruction because these jury instructions state specifically +that the jury may not convict based solely on overt acts that +relate to Kate, and so there is no risk, when these full set of +instructions is read to the jury, that they will think that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2775 +they can convict based on the illegal sexual activity as it +relates to Kate and as it relates to Annie. Annie only relates +to the conspiracy counts, at least as to these +Act +charges, and the jury is going to be instructed here that the +relevant illegal sexual activity has to be the violation of the +New York offense. +So again, there's no risk that the jury will +think that the sexual contact that happened in New Mexico is +something that on its own is sufficient to show the illegal +sexual activity required by the statute. So, here, in the full +set of instructions, there's no need for an additional +instruction, especially on top of the fact that the Court has +already given these limiting instructions to the jury. +THE COURT: All right. I agree with that. +MR. EVERDELL: Well, your Honor, there's one other +issue, which is the part that's not in the typewritten +instruction I handed you, which is the fact that Jane testified +about traveling to New Mexico at various times in her +testimony. And there was I think one trip she may have said +she was under the age of 16, which -- 15 or 16 I think is what +she said as to that trip, which we believe is the actual legal +age of consent in New Mexico; but she also testified about +other travel to New Mexico, where events took place, where +sexual contact took place, and so I think with respect to that, +we are going to need some kind of instruction to the jury that +if she's above the age of consent in New Mexico, that can't be + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 38 of 95 +considered illegal sexual activity for the purposes of their +deliberations. +It's not as charged in the indictment. We're +talking about New York law, so I don't know if that was made +clear to the jury. +MR. ROHRBACH: Your Honor, these instructions do not +put before the jury any violation of any New Mexico offense +whatsoever above or below the age of consent, so I think +there's no risk that the jury is going to convict the defendant +based on their concerns about a violation of a New York +offense. +2776 +MR. EVERDELL: That's not really the issue about what +instructions to put before the jury. The testimony put before +the jury, sexual contact between Jane and Epstein in New Mexico +after what we believe is the age of consent in New Mexico, and +so if -- +THE COURT: That's why, I think, it's the same reason +I gave limiting instructions as asked with respect to the +testimony of Kate and Annie. I think what I'm hearing you say +is, you meant to ask for a limiting instruction at that time? +MR. EVERDELL: Well, your Honor, we knew from the +proffered 3500s for the other witnesses what they were planning +on testifying to, so we were able to request those at the time +before the witnesses testified and brief those in limine. I +didn't think we -- what we knew about Jane ahead of time was +that she alleged that she traveled to New Mexico but that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2777 +nothing happened on the New Mexico trips, and then I think it +came out in the testimony -- unless the government wants to +correct me if we're wrong about that, but I think that our +status of our knowledge was that we weren't expecting to hear +about testimony about sexual contact in New Mexico. But they +can correct me if I'm wrong about that. +MR. ROHRBACH: I believe that Jane only testified as +to one sexual incident of sexual abuse in New Mexico and that +that was reflected in the 3500 material. I think Ms. Pomerantz +is looking for it, but it should not have been a surprise to +the defense. +THE COURT: Yeah. I mean, the problem - the +instructions are accurate. It's clear it's a violation of New +York law. This was the government's argument for not giving +the limiting instructions that I gave with respect to Annie and +Kate, but I did give those instructions. It sounds like maybe +there was an instance in which the defense might have requested +one following a particular piece of testimony. To add that +now, having not - well, let me put it this way. Having not +asked for a limiting instruction then I don't think provides a +basis for inclusion of limiting instructions, repetition of +limiting instructions in the charge, and even without it, which +was the government's original argument, it's clear that the +violation of law is as charged in New York. So I'm not +persuaded to include it. I'm not persuaded to include it. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2778 +MR. EVERDELL: Understood, your Honor. +Okay. Next page, your Honor? +THE COURT: Yes. +MR. EVERDELL: The next one we have is on page 26. +THE COURT: Okay. +MR. EVERDELL: We would reiterate, just for the +purposes of the record, of including "Jane" as opposed to "an +individual" or "the individual." That's been overruled, but we +will ask that the word "solely" be included on line 12, so, +"Count Four also relates solely to Jane." +MR. ROHRBACH: No objection. +THE COURT: Okay. We'll make that change. And my +clerk tells me we missed an "and foreign" on page 25. +MR. EVERDELL: Yes, yes. So we do have to go back to +page 25. So on line 5, there's an "or foreign." +THE COURT: So that will be with the ellipses. So +page 25, line 5, "interstate... commerce..." +MR. EVERDELL: Yes. And there's one other thing on +that page, your Honor, I forgot to mention. +THE COURT: Just a moment. +Okay. Go ahead. +MR. EVERDELL: Your Honor, on line 4 of that same +page, 25, I know it's a quote from the statute, which does say, +"knowingly transports any individual under the age of 18, " but +this is the issue with New York law being under the age of 17, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2779 +which is on the next page, page 26. The third element says +that the defendant knew that Jane was less than 17 years old. +THE COURT: Do you want to do bracket? +MR. EVERDELL: Yeah, I think we should do a bracket. +THE COURT: Mr. Rohrbach? +MR. ROHRBACH: That's fine. The government proposed +perhaps an awkward instruction I think to perhaps explain this +to the jury. This is an elegant solution. +THE COURT: I spent an inordinate amount of time +thinking through precisely this question, and I decided that +it's best just to do this because it would just be confusing. +I mean, it is a separate element, but it would just be +confusing. So I think this is a good suggestion. +Page 25. So we'll take out -- well, why don't we do +this. Why don't we do "under [the age of 17 years] in +interstate commerce." +MR. EVERDELL: That's fine, your Honor. +MR. ROHRBACH: That's fine with the government. +MR. EVERDELL: That's perfectly acceptable. +THE COURT: So page 25, line 4, "Any individual under +[the age of 17 years] in interstate commerce." +Okay. What's next? +MR. EVERDELL: We covered page 26 already, so -- and +on page 27, I believe there's an "or foreign" issue, so line 5. +THE COURT: Yes. Page 27, line 5, deleting "or + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +foreign." + +2780 +MR. EVERDELL: And then also on lines 7 to 8, it said, +"from one state to another or between the United States and a +foreign country, " so we should eliminate "or between the United +States and a foreign country." +MR. ROHRBACH: No objection. +THE COURT: okay. +Page 27, lines 7 through 8-L +and also the sentence above has "or foreign" in the quote, so +we'll ellipses I guess the phrase "transport an individual in +interstate," cutting "or foreign, " adding "... commerce." And +then the next line, ending the sentence after "another," so it +would read "from one state to another, " cutting "or between the +United States and a foreign country." +MR. EVERDELL: Yes, your Honor. +THE COURT: Hang on one second. +•. My clerk makes a good point. We should just cut +"or foreign" in that quote, not do ellipses, because I'm just +quoting myself. +MR. EVERDELL: That's right. +THE COURT: Okay. So line 6 is just "transporting an +individual in interstate commerce." +Okay. Next. +MR. EVERDELL: And your Honor, I did just notice +something, because I always forget to focus on the titles +sometimes, but for Count Four, they all refer to transportation + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2781 +of a minor to engage in, so I think we need to change the +titles +for Count Four, and I can get you the pages in a second, +but "transportation of an individual under 18 to engage in +illegal sexual activity." +MR. ROHRBACH: That's fine, your Honor, but this +actually raises a related question, which is just whether the +Court sends the indictment back with the jury, since I think +the indictment has the same issue. It describes some of the +offenses in their captions as "of a minor." +THE COURT: Well, what are the parties' positions on +that? +MR. ROHRBACH: The government is not seeking to send +the indictment back, your Honor. +MR. EVERDELL: One moment, your Honor. +THE COURT: Yes. +MR. EVERDELL: Your Honor, the defense would not like +that to happen. We think that the instructions advise the jury +about what they need to know about the law. +THE COURT: You're saying you don't want to send the +indictment back. +MR. EVERDELL: Right. +THE COURT: You're in vigorous agreement. +MR. EVERDELL: •. I thought we were disagreeing. +That's so rare. Yes, we're in agreement with that. +THE COURT: I don't send it back unless the parties + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2782 +agree. +MR. ROHRBACH: That's fine, your Honor. We're in +agreement. How about that? So then the edit to this title is +fine and there's no need to make it track the indictment. +THE COURT: And this one -- +MR. EVERDELL: So, your Honor, this would apply to +pages 25, 26, 27 -- +THE COURT: Can you give me the instruction numbers, +because my clerk's pages are off now that we made edits. +MR. EVERDELL: Yes, sure. It's Instruction No. -- let +me get the first one. 18, 19, 20, 21, 22, and I think that's +it. +THE COURT: Okay. And the request here is? +MR. EVERDELL: We would change the title to +"Transportation of an Individual Under 18 to Engage In --" +MR. ROHRBACH: It would be 17. +MR. EVERDELL: 17, yes. +THE COURT: Okay. So for all of the Count Four +titles, we'll change "a Minor" to "an Individual Under the Age +Of 17." +MR. ROHRBACH: And I'm sure the Court will likely make +this change automatically, but just to note that that change +would need to be reflected in the Table of Contents as well. +THE COURT: I believe that auto-populates it. I +wouldn't know how to do that, but I believe that's what + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +happens. But we will double-check it. Thank you. +Okay. What's next, Mr. Everdell? +MR. EVERDELL: Well, your Honor, just page 28, to +preserve our suggestion, we would request to substitute the +charge. We understand that's been overruled. Lines 11 +2783 +to 17. +THE COURT: Okay. +MR. EVERDELL: Then I think we can skip to page 32. +THE COURT: That was your first one, right, +Mr. Rohrbach? +MR. ROHRBACH: It was, although, your Honor, we have, +in the course of our conversations, resolved that, so the +government has no -- our next edit, our next request, is on +page 69, actually. +THE COURT: Okay. Page 32, Mr. Everdell. +MR. EVERDELL: Yes, still on 32 for the defense. We +request on line 10, "This count relates solely to Carolyn." +MR. ROHRBACH: No objection. +THE COURT: Okay. Thank you. We'll make that change. +Instruction No. 25, line 10, "This count relates, " adding the +word "solely," "to Carolyn." +All right. Mr. Everdell, next page. +MR. EVERDELL: One moment, your Honor. +THE COURT: My clerk notes that we have "Minor" in the +heading of all the Count Six -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 46 of 95 2784 +MR. EVERDELL: So this one, because the statute is 18, +it would have to be sex trafficking of an individual under the +age of 18. +THE COURT: I agree with that. +Mr. Rohrbach? +MR. ROHRBACH: No objection, your Honor. +THE COURT: Okay. +So go ahead. You want to call them +off, the instruction numbers for that, Mr. Everdell? +MR. EVERDELL: Sure, your Honor. That is Instruction +Nos. - just a minute -- 24, 25, 26, 27, 28, and 29. +THE COURT: Okay. So for all of those, we'll take out +"a Minor" and replace with "an Individual Under the Age of 18." +MR. EVERDELL: Right. +THE COURT: Next page. +MR. EVERDELL: Okay. So we just dealt with page 32, +which is the addition of the word "solely" on line 10? +THE COURT: Yes. +MR. EVERDELL: All right. Then on page 35, small +edit. At line 13, replace "the defendant" with "Ms. Maxwell." +THE COURT: Okay. Page 35, line 13, replacing "the +defendant" with "Ms. Maxwell." +MR. EVERDELL: Yeah. +THE COURT: Okay. +MR. EVERDELL: Okay. Yes. And just for clarity's +sake, your Honor, we're not replacing every instance of the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2785 +word "defendant" with "Ms. Maxwell." We tried to pick the ones +which made sense, and I understand the Court did the same. +THE COURT: I was trying to do that as well, as is +typical in my charges. +MR. EVERDELL: Yes, understood. +So I think our next one is not until -- I'm just +checking with my colleagues -- is not until page 49, but give +me one minute. +THE COURT: Okay. +MR. EVERDELL: Okay. Actually, your Honor, if we go +back to page 44. +THE COURT: 44? Okay. +MR. EVERDELL: So this is line 4. We have the word +"minors" again, right? This is a discussion of the elements of +the conspiracy, but, "Count One charges Ms. Maxwell with +participating in a conspiracy" etc., etc. "to entice minors to +travel and engage in sexual activity." And there are other +instances of "minors" in line 15. It's "to transport minors." +THE COURT: So for all of these, this would be "an +individual under the age of 17." +MR. EVERDELL: Well, yes. So it's going to be line 4, +line 6, line 15, and line 19. +THE COURT: Mr. Rohrbach? +MR. ROHRBACH: That's fine, your Honor. And I would +note in the next paragraph, there is a reference to "minor," + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 48 of 95 +2786 +and there the change should be "under the age of 18" rather +than 17, but the conforming changes make sense. +THE COURT: Okay. Let me just articulate these. +MR. EVERDELL: That's fine. +THE COURT: So Instruction No. 34 on lines 4, 6, 15, +and 19, we're going to replace "minors" with "individuals under +the age of 17." +MR. EVERDELL: And there's one on line 10 as well, +your Honor. +MR. ROHRBACH: As well as line 13, your Honor. +THE COURT: Come on. The clerks are good, but, you +know, it's Saturday, after all. +We'll do a search and replace also, but I think it is +worth doing, since some of them are under 17 and some are under +18. +MR. EVERDELL: That's right, your Honor. +THE COURT: Okay. So let me just repeat. +So Instruction 34, lines 4, 6, 10, 13, 15, and 19, we +will replace "minors" with "individuals under the age of 17." +MR. EVERDELL: Correct, your Honor. +THE COURT: And then moving to replacing the word +"minor" with "an individual under the age of 18, " Mr. Everdell, +that's line 24. +MR. EVERDELL: Yes, your Honor. +THE COURT: And what else? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 49 of 95 +2787 +MR. EVERDELL: And then the next page, page 45, +line 1, there's the word "minor," which would be "an individual +under the age of 18." +MR. ROHRBACH: Your Honor, in this paragraph, since +this is the conspiracy that applies to multiple minors, I think +it should be "individuals under the age of 18" rather than just +one. +MR. EVERDELL: That's fine. +THE COURT: For the second -- yeah. Right. So that +is important that we're doing these one at a time. So line 24, +it's "an individual under the age of 18." And then the next +page, page 45, line 1, it's - +MR. ROHRBACH: I think they both should be -- +THE COURT: They both should be "an individual under +the age of --" +MR. ROHRBACH: I think they both should be +"individuals under the age of 18." +THE COURT: I'm sorry. You're right. They're both +the conspiracy. +MR. EVERDELL: That's right, your Honor. +THE COURT: Okay. I apologize. Let me start again. +So Instruction No. 34, line 24, "individuals under the age of +18," on line 24; and then the following page, line 1, same +change, "individuals under the age of 18"; and then same change +on line 3. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCIIMAXI + +2788 +MR. EVERDELL: Slightly different. That would be "an +individual under the age of 18," because that's the substantive +count. +THE COURT: Yes. Line 3, replacing "minors" with +"an --" wait. Let me just read that sentence again. +MR. ROHRBACH: I think these are all references to the +conspiracy. +MR. EVERDELL: That's right. I'm sorry, your Honor. +This is still talking about the conspiracy. So that one on +line 3 would still be "sex trafficking of individuals under the +age of 18." +THE COURT: Yes. I agree with that. +Okay. So for all of Instruction 34, all of the +instances -- well, in the second paragraph -- no, I'm sorry. I +won't repeat it. We got it. Page 45, line 3, "individuals +under the age of 18." +Okey dokey. Next. +MR. EVERDELL: So, your Honor, now we have page 49, or +instruction No. 36. It's -- +THE COURT: I'm sorry. What page? 49? +MR. EVERDELL: Page 49, Instruction 36. +THE COURT: Okay. Actually, before you start, I'1l +just note, there's an extra word, "Iwo, " I-W-O, in the title. +So line 1, it's just Counts One, Three, and Five, deleting the +word "Iwo." + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2789 +MR. EVERDELL: +• yeah. Agreed, your Honor. +MR. ROHRBACH: Yes. +THE COURT: What do you have, Mr. Everdell? +MR. EVERDELL: So this is where it gets a little +complicated, your Honor. I mean, I know that in lines 11 +through 22, we're listing -- and in the next page as well, +we're listing out the overt acts in the indictment. We're +listing them verbatim, but they're talking about ages, under +the age of 18, under the age of 18, and we've already talked +about how the ages are sort of different depending on the +statutes. That's one issue. Right. So we might want to +replace the -- instead of the ages -- and I know -- it's less +of an issue because I think we've agreed that the indictment is +not going back to the jurors, so they're not going to be +reading the language, but maybe instead of "under the age of +18, " "when Jane was under the relevant age of consent in the +relevant jurisdiction," or something to that effect. +MR. ROHRBACH: Your Honor, if I may. I understand the +concern the defense is raising. I think for Counts One and +Three, since the relevant age of consent I think everyone +agrees is 17, the government would be fine with saying "under +the age of 17," and we'd have to say "the indictment alleges" +or something like that, because it would no longer be following +the text of the indictment. +THE COURT: Yes. I mean, we could do "alleges" or + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +brackets or something. +So are you okay with "alleges" there, Mr. Everdell? +MR. EVERDELL: Well, let me see about that. +Are we talking just about the overt acts with respect +to Jane or are we talking about with Annie as well? Because +the overt act with respect to Annie is, she's saying she's +under the age of 18, but the age of consent there is 16, so -- +and Kate -- there are a few issues here, so I'1l just lay them +out. +2790 +The instruction with Annie is, you know, there's the +age of consent issue with Annie. But skipping to Kate, which +is No. 4, on line 18, I don't think that should be in there at +all because that invites them to base an overt act and convict +the defendant based on Kate's testimony, which the Court has +already instructed that the jury can't. So, I mean, if they +found that this element was satisfied solely with Kate's +testimony, that would be an improper conviction. So that +shouldn't be included. +MR. ROHRBACH: Insofar as we're no longer following +the exact text of the indictment, the government would be fine +with deleting the overt act relevant to Kate for the reason +Mr. Everdell stated. +THE COURT: Okay. All right. +MR. EVERDELL: All right. So then I think we could +probably say with respect to 1 and 2, which we're talking about + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2791 +Jane, Jane was -- we would say the indictment alleges that Jane +was under the age of 17, in both 1 and 2. +THE COURT: All right. So let me just -- +MR. EVERDELL: Yeah. +THE COURT: Hang on. So this is Instruction 36, +line 11. +MR. EVERDELL: Correct. +THE COURT: Page 49. I'm going to change "reads" to +"alleges," and then line 12, we're going to say "when Jane was +under the age of 17, " correct? +MR. EVERDELL: That's correct. +THE COURT: So that's line 12, subbing 17 for 18. +And then the next instance of that is line 14. +MR. EVERDELL: Correct, your Honor. +THE COURT: "When Jane was under the age of 17." +MR. EVERDELL: Mm-hmm. +THE COURT: And then we get to line 16. +MR. EVERDELL: For this one, I would propose that we +simply, you know, eliminate the age, if they want to keep this +as an overt act and if we think it's proper for the jury to +consider Annie's testimony as a potential overt act in +furtherance of the conspiracy, even though the goal of the +conspiracy is a violation of New York law. So my first +objection is that I don't think you can actually consider +Annie's testimony as the overt act if what's described there is + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2792 +not the violation of New York law. So that is our objection to +that. +MR. ROHRBACH: Well, I think, understanding that +Mr. Everdell is I think preserving the earlier objection about +Annie's testimony, as far as the suggestion to resolve the +redacting issue is just to remove her age from this clause, I +think that would be fine and the jury can make its own +conclusions about, you know, Annie's age and how it relates to +the offense. +THE COURT: I understand the broader suggestion, but +in light of my earlier conclusion, this third overt act would +read, "In or about 1996, Maxwell provided Annie with an +unsolicited massage in New Mexico." +MR. ROHRBACH: That's my understanding of +Mr. Everdell's suggestion, and the government would be fine +with that. +MR. EVERDELL: And I guess to clarify, Judge, I'm +understanding the Court's logic to be that the testimony of +Annie about the topless massage can be considered by the jury +as evidence of the conspiracy to violate New York law. +THE COURT: That's right. +MR. EVERDELL: Okay. And understanding that's the +Court's logic and ruling, then we would -- but then we would +like the redaction. We preserve our objection from before, +but - yes. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2793 +THE COURT: And again, noting that that's why I gave +the limiting +instruction for Annie's testimony, that's why the +limiting instruction did differ from the limiting instruction +for Kate, because that is the Court's legal conclusion. +MR. EVERDELL: Understood, your Honor. +THE COURT: So let me just make sure my clerks -- +yeah. Right. My clerk has adopted the change on line 16, +cutting the comma, "when Annie was under the age of 18, " comma. +Next. +MR. EVERDELL: Your Honor, just to confirm, we are +also eliminating, with the government's consent, No. 4, which +refers to Kate, the overt act referring to Kate. +THE COURT: Yes. So eliminating entirely the overt +act on line 18 through 20. And then we'll have to change the +fifth one to 4 -- +MR. EVERDELL: Correct, your Honor. +THE COURT: -- on line 20. And that one looks like it +can stay as is with the age. +MR. EVERDELL: Yes, your Honor. +THE COURT: Okay. +MR. ROHRBACH: Your Honor, I think that that should +be - on line 21, it should still be changed to 17, even +though -- +THE COURT: Because of the —- +MR. ROHRBACH: Because of the legal count. It's the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2794 +conspiracy to violate the offense with the age of consent of +17, even though elsewhere Carolyn is charged with an age of +consent of 18. +THE COURT: I presume you have no objection? +MR. EVERDELL: No objection, your Honor. +THE COURT: Yes. Let me just think about that. +I see. Okay. All right. So Instruction 36, line 21, +changing "Carolyn was under the age of 18" to "the age of 17." +Yeah, that's right. +Okay. Next. +MR. EVERDELL: Next one, lines, on that page, 23 to +24, and on the following page, lines 1 through 10, it tracks +the same changes for the transportation charge. +MR. ROHRBACH: That makes sense, I think, your Honor. +THE COURT: Okay. Let me see if I can do these. +Line 24, changing "age of 18" to "age of 17," and then line 2, +changing "age of 18" to 17. Line 4, cutting the clause "when +Annie was under the age of 18, " and then cutting overt act +regarding Kate at No. 4. So that's lines 6 through 8. And +then line 19, changing 18 to 17. +MR. EVERDELL: Correct, your Honor. +MS. STERNHEIM: Judge, you would also want to change +the bracketed No. 5 to No. 4. +THE COURT: Thank you, Ms. Sternheim. Changing the +fifth listed overt act to the fourth listed overt act. Just + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 765 + +one moment. +2795 +, and we'll again change, on line 23, page 49, the +word "reads" to "alleges." +MR. EVERDELL: Yes, your Honor. +THE COURT: Okay. +Next. +MR. EVERDELL: Same page, page 50, your Honor, +line 18, just going back, these are overt acts with respect to +Count Five. +THE COURT: Mm-hmm. +MR. EVERDELL: The third one, which begins on line 17, +between -- +, yes. "Between in or about 2001 and in or about +2004, Epstein's employees, including at times Maxwell, sent +Carolyn gifts, including lingerie, etc." I don't think there's +any evidence in the record that Maxwell sent any gifts. In +fact, I think the FedEx records show that it wasn't Maxwell +sending anything. I don't think there's any testimony in the +record that Maxwell was sending the gifts, so I think that +should be excluded. +MR. ROHRBACH: That's fine, your Honor. This is what +the grand jury charged, but that is fine, given the state of +the record. +THE COURT: Okay. +MR. ROHRBACH: But to be clear, the government is fine +with including the clause -- cutting the clause "including at +times Maxwell." + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2796 +THE COURT: So I think that's the request. So line 18 +on my page 50, which is the second page of Instruction No. 36, +we will cut comma, "including at times Maxwell," comma. +MR. ROHRBACH: And in light of that change, your +Honor, on line 11 of that page, it should say, "The indictment +alleges as follows." +THE COURT: Right. On line 11, changing "reads" to +"alleges." +What's next, Mr. Everdell? +MR. EVERDELL: Yes, your Honor. It's on page 51, +line 15. I think we've been using "Ms. Maxwell" in this +charge, so we'll change on line 15 "the defendant" to +"Ms. Maxwell." +MR. ROHRBACH: That's fine, your Honor. +THE COURT: Okay. So we're on Instruction No. 36. +Close to the end of that, the second to last paragraph of that +instruction, line 15, changing "the defendant" to +"Ms. Maxwell." +So one question. We've taken Kate out of the overt +acts. Page 51, lines 13 through 16 are no longer seem to make +sense. +MR. EVERDELL: 51, your Honor? +THE COURT: Yeah. Right? +MR. EVERDELL: Well, I understand what you're saying +with respect to reference to overt acts because she's not in + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 59 of 95 +2797 +the overt acts, but I do think it's important to instruct the +jury here that they can't convict solely on the basis of Kate's +testimony. That I think is -- +THE COURT: Right, because it's not just about what's +in the indictment. +MR. EVERDELL: Right. +MR. ROHRBACH: That's right, your Honor. +THE COURT: Okay. +I just have one moment with +Mr. Everdell? +THE COURT: Yes, please. Actually, why don't we take +a 10-minute break. +MR. EVERDELL: Thank you, your Honor. +MR. ROHRBACH: Thank you, your Honor. +THE LAW CLERK: All rise. +(Recess) +(Continued on next page) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2798 +(Jury not present) +THE COURT: All right. Mr. Everdell. +MR. EVERDELL: Thank you, your Honor. The next page +we have is page 54, instruction 39, the conscious avoidance +instruction. Your Honor, on that, the defense objects to this +being included, this instruction being included in the charge. +I think, as the Court is aware, to include an +instruction on conscious avoidance, you have to establish two +prongs. First is that the defendant has to assert some lack of +specific aspect of knowledge required for conviction. I don't +think we're disputing that. But the second prong is that there +must be an appropriate factual predicate for the charge. And +here, your Honor, the government's theory of the case and the +proof that's been elicited through the testimony is that she +was an active participant in all aspects of the charges. There +has been testimony by all of the witnesses that she was not +only participating and facilitating the sexual encounters but +that she participated. So we have testimony from Jane that she +was involved, that Ms. Maxwell was involved in the group +sexualized massages. We had testimony from Annie that the +topless massage was done by Ms. Maxwell; she rubbed the top +part of her chest during the topless massage. We had testimony +from Carolyn that Ms. Maxwell groped her breasts and commented +upon her hips. These are all active-participant measures. +This is someone that's not consciously avoiding. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2799 +The theory they are proceeding on is that she is an +active participant. They can't have it both ways. The proof +at trial that they have elicited is that she was actively +involved. This seems to be here as some sort of backup option. +And that's not permissible, your Honor. +And I would add that, in a case like this in +particular, there is a real concern that the jurors are going +to 1o0k at this evidence and, given the subject matter of the +case, they're going to think, well, she must have known and +that's enough for me because this is conduct that really I +can't countenance because it involves children. And then the +conscious avoidance instruction will give them license to +convict the defendant on an improper basis simply because of +the nature of the subject matter. +So that's an overlay, your Honor. But at the basis, +it's that the proof and the theory of the charging in this case +and the proof that's gone with it is that she's an active +participant o, so we do not think that there is an appropriate +factual predicate for this charge. +MR. ROHRBACH: A few responses to that, your Honor. +First of all, the witnesses testified that she was an active +participant. The jury may reject their testimony that she +actively participated and can still convict based on her +facilitation of the various offenses, including through a +conscious avoidance theory. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +Second of all, there are particular factual knowledge +elements that the defense is contesting. One is her knowledge +of the age of the victim. +Another is her mens +with regard +to the purposes of travel. And so for those things the jury +could reasonably conclude that she had sufficient -- that she +was engaging in conscious avoidance as to those particular +tacts. +2800 +So, for example, to take the knowledge of age issue, +the defense has elicited testimony from several witnesses that +the defendant could not, was not aware that the various victims +were minors. The jury could conclude that she in fact did have +that knowledge. The jury could also conclude that she +consciously avoided having that knowledge. Those are both +reasonable theories available for the jury for which there is +an adequate factual predicate in the record, your Honor. +MR. EVERDELL: Your Honor, I think this is inviting +the jury, by considering the conscious avoidance charge, to +convict on an improper basis that she must have known. +THE COURT: Could you just respond to the specific +argument, because I think you started by saying there's been no +contention as to a lack of knowledge with respect to any aspect +of the crimes charged. So the specific contention and the +reason I had in my head to include it rather than not include +it - which, for reasons you've indicated, is a case-by-case +analysis depending on what factual issues are in play. But on + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 63 of 95 2801 +the question of knowledge as to age, what's your response? Why +isn't it applicable with respect to what the defense has put in +issue with regard to that? +MR. EVERDELL: Yes, your Honor. The witnesses +themselves -- sorry, your Honor. One moment. +THE COURT: Yes. +MR. PAGLIUCA: If you don't mind, your Honor, it's +easier for me -- +THE COURT: Since it's Saturday, I will break my +one-lawyer-per-issue rule. +MR. PAGLIUCA: I appreciate it. My recollection is +the testimony from each of the four witnesses, I will call +them, is that they said that they told Ms. Maxwell their age. +Carolyn said that she told Ms. Maxwell her age. Jane said she +told Ms. Maxwell her age. Similarly, Kate said she told +Ms. Maxwell her age. +So there is no "I'm not trying to find out what her +age is" evidence in this case. The evidence that was +elicited -- I think this is, you know, largely through +Mr. Alessi. Mr. Alessi said that he only saw two people at the +house that he thought were under the age of 18, and that was +and Jane. I'm trying to remember everybody's +names. +So that's that testimony. +I don't think there's any other testimony in the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2802 +record that relates to that topic. So I think that -- +THE COURT: So the defense has questioned multiple +witnesses on their perceptions of individual ages, of relevant +individuals' ages, so that puts into question the knowledge +element with respect to ages, and it's true there's testimony +from each of the alleged victims as to what they told +Ms. Maxwell, but of course I don't know whether the jury will +accept that testimony or not, or any of those individual pieces +of testimony. So it seems like having -- the question here is +whether there are specific elements, knowledge elements that +are in issue, either because it's what some of the evidence +goes to or because the defense has made cross-points or will +make arguments regarding that. I mean, I don't suppose it's +the case that the defense won't -- will it not argue during +closing anything with respect to whether Ms. Maxwell knew of +the relevant ages? +we have a moment, Judge? +THE COURT: Sure. +MR. PAGLIUCA: Here's the -- I'm going to try to +address -- there's a larger concern. I need to break this into +two pieces. +THE COURT: OK. +MR. PAGLIUCA: One that I view as an evidentiary issue +with the indictment and the evidence in the case is that there +was testimony about multiple females being at the Palm Beach + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2803 +residence. And I think the testimony that was elicited by the +defense went to what the ages of these multiple females looked +like, because the inference is that there are, you know, +literally hundreds of under-age women at Epstein's house. +And so the testimony from Mr. Alessi was, he only saw +two people that he thought looked under age, as opposed to the +rest of these people. +There was no testimony elicited that, you know, +Ms. Maxwell did or didn't know what -- I mean, the contention +is that these folks were older. Kate, for example, the +contention is she wasn't under age. +THE COURT: Yesterday, I think +was asked how +Jane appeared to her. +MR. PAGLIUCA: Correct, at the office. But I also +think that that's a tension here, is that Jane was older than +she is saying. You know, the actual factual dispute is, Jane +says she was 14, 15. We disagree. We believe it's later in +time. +So this is not an avoidance issue. This is a factual +dispute as to how old these people actually were. With the +exception of Carolyn, who says, you know, I was this age, and +we say, we never, you know, had anything to do with Carolyn. +That's the factual dispute. +And so I think there is a legitimate argument that +doesn't relate to conscious avoidance, which is, simply, there + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2804 +were lots of women there and, you know, there are many -- no +one -- no one observed women that they thought were under age. +But it's not -- I don't believe there is going to be +an argument, Ms. Maxwell is not guilty because she couldn't +have known that these four people were whatever age they are. +I think the argument is going to be, they weren't that age. +That's what I think the defense's position is here, your Honor, +not, you know, gee, Mr. Epstein slipped in a couple of +teenagers on me here. +MR. ROHRBACH: Your Honor, unless the defense is +stipulating that Ms. Maxwell knew the ages of these victims, +and it's an open issue. The defense has elicited from Larry +Visoski, Kimberly +, the appearance of the victims. +They elicited from Carolyn that she was told not to tell -- or +told to tell people at the house that she was 17 or 18, when +she was younger than that. So the evidence that's been +elicited certainly puts the defendant's knowledge of the +victims' age at issue. +THE COURT: Yes. There are two issues. There's the +first question, what age were they. And you contest that. But +then there's the second question of, let's assume the jury +concludes that they were under the age of 17, then there is the +question of Ms. Maxwell's knowledge, and that seems to me to +have been put in issue through argument and -- through openings +and questions asked on cross. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2805 +MR. PAGLIUCA: I think I disagree with that, your +Honor. +And let's take Carolyn as the example. Carolyn, the +government affirmatively elicited that she was told by Virginia +to say that she was, you know, whatever age she was told to +say. That's, I think, the government's testimony. +MR. ROHRBACH: I believe that came out on cross, your +Honor. +It's on page 1569. +MR. PAGLIUCA: If it came out on cross, it was her +volunteering that information, I think. +But anyway, that doesn't have anything to do with +Ms. Maxwell. I mean, that's simply "Virginia told me whatever +my name -- whatever the age I'm supposed to say." It's not +Ms. Maxwell saying to Virginia, "Say this age." +So I just disagree as a factual matter that this has +anything to do with conscious avoidance. +MR. ROHRBACH: The defense also elicited testimony +that the defendant was from -- through Mr. Alessi -- that the +defendant was going to legitimate hotels to identify massage +therapists. I assume that that's in service of an argument +that she didn't know the ages of people coming to the house as +massage therapists, and so she could have confused some of them +who were under the age of consent with ones who were older than +the age of consent. I'm not sure what other evidence that +would be in service of. +MR. PAGLIUCA: Well, that's in service of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2806 +being -- that's a factual dispute as well: when did we -- you +know, when did +appear? How old was +when +she appeared and then allegedly recruited other people? +That's in service of that argument. It's not in service of +some other argument. And that's what that testimony went to, +was, you know, we went to Mar-a-Lago, we went to these other +spas, Mr. Alessi collected cards from people. I mean, that's +what that testimony was. It had nothing to do with Carolyn or +the others that relate to Carolyn. +MR. ROHRBACH: If the issue is just, how old was +when she met the defendant, there would be no +need for testimony about whether the defendant also went to the +Breakers to recruit massage therapists. It would just be, on +what date did the encounter happen with +THE COURT: All right. I'm going to take a careful +look through the transcript to see how and when and to what +extent the defense, I think, reasonably -- I could reasonably +interpret to put in question Ms. Maxwell's knowledge as to the +age of the individuals. +Am I hearing you correctly that, in the absence of +this instruction, that the defense would make no argument at +closing regarding specifically Ms. Maxwell's knowledge of the +age of any individuals that the jury might conclude are alleged +victims? +MR. PAGLIUCA: I would like to consult with the person + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2807 +who's going to be giving the closing argument. +THE COURT: I think she's standing over your shoulder. +MS. STERNHEIM: No. +MR. PAGLIUCA: No. +MS. STERNHEIM: Surprise. It's not me. +MR. PAGLIUCA: I can give the Court that answer before +we leave today, if that's all right with the Court. +MR. ROHRBACH: If I may just say, your Honor, I'm not +even sure that these things can be pulled apart. An argument +that these people were older is so intertwined with an argument +that she thought these people were older that, even if they +didn't say the words about that in their closing, I think the +jury would assume that, absent some more affirmative +stipulation, so the government would have to rebut it. A +conscious avoidance theory is an appropriate way to do so. +THE COURT: Yes. It's a fair point. And I'm going to +look carefully at relevant portions of the transcript, but I do +think it is sufficiently in issue that it's appropriate to give +the instruction. I would consider, as part of my calculus in +coming to a final resolution, if the defense were to indicate +it wouldn't specifically make that argument. But - +MS. STERNHEIM: We'll get you that answer as soon as +we can. It will be following the break, I think. +MR. ROHRBACH: Your Honor, the other -- we've also +articulated a theory that there are flight records showing the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2808 +defendant traveling with some of the minor victims. I assume +the defendant is going to say that she didn't know the purposes +of the trips. To the extent the purpose was sexual abuse, the +government would argue that at a minimum this she did know, if +she didn't she consciously avoided knowing, why Jeffrey Epstein +was traveling repeatedly with these minors. +THE COURT: The other point is, from the openings, I +don't know if it will be a theme of the closing, but the +distancing of Ms. Maxwell from Mr. Epstein and what he did was +clearly a theme of the opening, and so that implicates +knowledge throughout the counts. +So my strong inclination is that it's appropriate +here. That's my conclusion. That's my conclusion. I'm going +to look back through relevant portions of testimony on the age +issue, but I think even the age issue - well, not the age +issue. Knowledge of age. Specific arguments as to knowledge +of age aside, knowledge of age is intertwined with arguments +regarding age. And in any event, there are, as a result of the +opening, questions about Ms. Maxwell's knowledge of what +Mr. Epstein is alleged to have been doing that I think it's +sort of a standard instance of the applicability of a conscious +avoidance instruction. +So my conclusion is to include it. +Next. +MR. EVERDELL: Next, your Honor -- let me make sure. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2809 +I believe the next one is at page 61. +THE COURT: Did you have something before that? +MR. ROHRBACH: No, page 69. +THE COURT: OK. Page 61. +I have something before that. There is a pronoun on +page 60, line 5, "he" should be replaced with "she." +MR. EVERDELL: That's fine, your Honor. +MR. ROHRBACH: Yes, your Honor. +THE COURT: And what page was it, Mr. Everdell? +MR. EVERDELL: The next page is 61, your Honor. +That's instruction 44, credibility of witnesses. +THE COURT: OK. +MR. EVERDELL: Your Honor, we would just propose that +there were a number of witnesses who, it came out, had felony +convictions, and there is +a Sand instruction on this. It's +instruction 7-12. And we would ask that it be included, at +least in part, in the credibility of witnesses instruction. I +can read that to you, your Honor, if you like. +THE COURT: I gather this was not an original +proposal. +MR. EVERDELL: No. We didn't know if it would come +in. +THE COURT: Oops. All right. I'll take your -- my +clerks will submit language, but go ahead. +MR. EVERDELL: Sure. I have Sand in front of me, and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2810 +I can read the full instruction. +THE COURT: And the proposal is to include it where? +MR. EVERDELL: In instruction 44, in the credibility +of witnesses. +THE COURT: Right. +Where? +MR. EVERDELL: I think it could be either after the +second paragraph, before the third paragraph, or after the +third paragraph, which goes on to the next page before the +first full paragraph on that page. +THE COURT: OK. +MR. EVERDELL: I'm happy to read it if you like, or +you can just -- it's up to the Court. +THE COURT: I don't have it yet. So go ahead. +MR. EVERDELL: OK. So the way it reads in Sand is, +"You have heard the testimony of a witness who was previously +convicted of a crime punishable by more than one year in jail. +This prior conviction was put into evidence for you to consider +in evaluating the witness's credibility. You may consider that +fact -- you may consider the fact that the witness who +testified is a convicted felon in deciding how much of his" -- +I think maybe "his or her testimony to accept and what weight +if any it should be given." +MR. ROHRBACH: Your Honor, we're not familiar with +this instruction being given in this district, and obviously +witnesses with felony convictions testify regularly. The + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 73 of 95 +2811 +commentary as it stands suggests that the point of this +instruction is just to tell the jury why this was -- the felony +conviction was even put before them in the first place. And I +don't think a jury is going to be confused or misled about why +that testimony was offered. So I don't think there is a need +for this sort of instruction. +THE COURT: Do you have any examples of it being used? +MR. EVERDELL: Your Honor, I don't have at my +fingertips. I can try to find some if there are. +THE COURT: This is my standard credibility +instruction. Certainly given in multiple trials in which +felony convictions came in. I don't think I've ever given it +or been asked to give it. +MR. EVERDELL: Your Honor, I would point out, I think +in a lot of trials, maybe in the ones you've done before, there +was probably an instruction about cooperating witnesses which +builds in this language, and obviously you don't have one here, +so it's often included in the charge in a separate instruction. +THE COURT: Well, this is a new request. I'll take a +10ok. We'll look at it. And when I send you the redline +you'll either see it or not. +MR. EVERDELL: In the meantime, your Honor, I'll try +to find other examples if I can. +THE COURT: OK. Looks like I have given it as a +separate instruction, testimony of felons. "You've heard the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2812 +testimony of witnesses who were previously convicted of crimes +punishable by more than one year in jail. This prior +conviction was put into evidence for you to consider in +evaluating the witness's credibility. You may consider the +fact that the witness who testified was a convicted felon in +deciding how much of his testimony to accept and what weight if +any it should be given." Looks like I gave that in my -- in +the United States v. Berry. +MR. EVERDELL: I think we've been using that as a +model in this charge, your Honor, so we would request a similar +instruction here. +THE COURT: I would add it, as I did in that last +case, as a standalone instruction. +Mr. Rohrbach. +MR. ROHRBACH: Your Honor, this is the first we've +hoard of this proposal. So if we could have a few hours after +the charge conference to give it some thought. We can file a +letter saying either, we agree, or, if we have objections to +it, articulating those. +THE COURT: I think that's fair, and I will look too +since it's a new suggestion. I think my proposal would be to +just do it as a standalone instruction at, maybe what would be +45-A? +MR. EVERDELL: That's fine, your Honor. +THE COURT: Between 45 and '6. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 75 of 95 +2813 +So that's the proposal. And when would you like to +put in a letter? +MR. ROHRBACH: Depends on what time we finish. +MR. EVERDELL: First thing, your Honor. +MR. ROHRBACH: If we finish by noon, by 2 or 3? +THE COURT: OK. Let's do 2 o'clock. +MR. ROHRBACH: OK. +THE COURT: Thank you. +Next. +MR. EVERDELL: Next, your Honor, is page 68, +instruction no. 50, the uncalled witnesses charge. The request +here is that this not be included, and I think the reason being +that, in this case, it isn't really accurately summarizing the +state of play, because, you know, for example, there were +witnesses who took their Fifth Amendment rights and refused to +testify as defense witnesses because they invoked their Fifth +Amendment rights. The government does have the option of +giving those witnesses immunity to testify. And so they +actually control, more than we do, whether or not a witness can +appear - +THE COURT: To be clear, that didn't happen. They +didn't call that witness. +MR. EVERDELL: We had a witness who invoked their +Fifth Amendment rights or had written the Court that they +planned to invoke, and that we called and was under subpoena + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 76 of 95 +2814 +that we intended to call as a witness. +THE COURT: There was a lawyer letter indicating that +they had received a subpoena and they intended to invoke. I +asked many, many times if there was an application with respect +to it. I never got one. So I'm not sure how to think of that. +It's certainly true that, if someone invokes, the defense can't +offer immunity the way that the government can. That's true in +every case. This charge is quite standard, though standardly +objected to, but I don't know that I see anything in this case +that would distinguish its application based on what you've +just indicated. +MR. EVERDELL: In addition to what I had just +indicated, just for purpose of completeness, there are a number +of witnesses who, based on the witness testimony in this case, +there would be people who the government -- who we normally may +have considered calling as a witness but who the government +clearly could have charged, criminally, based on the testimony +we heard. And I won't name names if we don't want to do that. +But I think we probably know who we're talking about here. And +that is, you know, had we tried to call that witness or those +witnesses, they undoubtedly would have invoked their Fifth +Amendment rights. In fact, as some of them -- one of them was +not called by the government and would have had to have been +given statutory immunity or granted immunity to be able to +testify, by the government, if they had decided to call them. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2815 +So there is more than just the one witness who indicated that +she was going to invoke had the defense called her. There were +other co-conspirators who the government chose not to call, not +to immunize, and we couldn't possibly call in our defense +without -- because we can't give any immunity ourselves. +MR. ROHRBACH: Your Honor, this is true in basically +every conspiracy case and every gang case that is prosecuted in +this district. There are unindicted co-conspirators. Yet this +instruction is given and is the run-of-the-mill instruction, as +the Court said, in cases in this district. +MR. EVERDELL: Your Honor, if the Court is inclined to +give the instruction, I can propose an alternative. +THE COURT: I will take an alternative. +MR. EVERDELL: If we can just eliminate the language +in the title of the charge that says "equally available to both +sides" and just have "the uncalled witnesses." +I believe there's also language that says "equal +opportunity." +THE COURT: Or lack of opportunity. +MR. EVERDELL: Yes. +MR. ROHRBACH: This is the uncalled witness +instruction, your Honor. This is the instruction given, +suggested by Sand and given by this Court. I have five +examples right here where the Court has given this instruction. +THE COURT: As I say, it's always given, always + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +objected to. +So here's just a slight change. +Line 4. "Each party +had an opportunity to call any of these witnesses." +MR. EVERDELL: We would accept that, your Honor. +THE COURT: It's a similar meaning. It's not quite +equal. I'll adopt that. "Each party had an opportunity to +call any of the witnesses." +MR. ROHRBACH: If your Honor is thinking of that +change, we would ask to just include that in our letter later. +THE COURT: That's fine. So the proposal would be +that, line 1, cut "equally available to both sides" from the +heading, and then, line 4, cut "equal opportunity or lack of +opportunity" and change to "an opportunity." +MR. EVERDELL: Yes, your Honor. +THE COURT: I think it's clearly true, Mr. Rohrbach, +this is standard language, and I've given it a slightly, +slightly altered meaning, to take emphasis off of "equal +opportunity." So I think it still captures the meaning of the +charge. +2816 +MR. ROHRBACH: I just -- we will think about it and +include it in our letter. But just to preview for the Court, +part of our concern is that the most obvious witness who was +available to both sides and who we expect the defense to +comment on is +who was described as a victim +but did not testify and she was fully available to the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2817 +defendants. They did not call her. To the extent the main +issue here is +testimony, that she was equally +available to both sides. +MR. EVERDELL: It's not +that I'm +thinking of, your Honor. I'm happy to say the name. It's +THE COURT: OK. +I mean, suppose -- look, as I said, +I've only slightly changed the meaning. It's the same meaning +but it takes emphasis off of "equal." I don't know what the +defense is going to focus on in its closings, how much of the +focus will be the absence of individuals. +MR. EVERDELL: I expect we'll be talking about the +absence of individuals, your Honor. +THE COURT: All right. I'll hear from you in your +letter. I'm keeping the charge. And it will either be the +standard charge or the very slight modification I've proposed. +Next. +MR. EVERDELL: Your Honor, page 69. +THE COURT: OK. +MR. EVERDELL: That's the particular investigative +techniques charge. We were prohibited from the Court's rulings +and from eliciting evidence and from arguing this point about +particular investigative techniques, and so we -- +THE COURT: Well, to be clear, not on cross with +respect to witnesses called. But I don't need to repeat my + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +ruling. But the ruling is what the ruling is. What's the +request? +2818 +MR. EVERDELL: The request is to eliminate the charge +on this point because we couldn't -- we weren't supposed to, +and nor did -- I think we tried to abide by the Court's ruling +to not talk about particular investigative techniques or elicit +evidence on that point. And so if we're not going to be +permitted to elicit or argue that point to the jury, then it +doesn't seem like they need to be instructed on that point. +MR. ROHRBACH: This is a +• legally correct instruction. +As the Court has ruled many times now in this case, particular +investigative techniques are not required. The defense made +that point, as they could, on cross through the case, and I +assume it will be, as they can in the defense's summation. And +this is a correct statement of the law on which the jury should +be instructed. +MR. EVERDELL: Sand has filled three volumes of +correct statements on law, your Honor. That doesn't mean that +they get into a jury charge. +THE COURT: I think I've always included this charge, +so it's not just a rarely invoked Sand charge. I mean, as you +talked about yesterday, there were questions you were going +to - ask. +MR. EVERDELL: Special Agent Young. +THE COURT: — Young, thank you -- that either -- some + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2819 +of which were asked of the relevant investigative agents or +arguments that could be made based on the absence of evidence +in the record and the like. And my ruling was what it was, +which didn't foreclose entirely the opportunity with respect to +cross-examination and the like. I suspect this will be part of +the defense's arguments in closing, so it's appropriate to +include the charge. +MR. EVERDELL: Understood. +Just as long as we're allowed to argue, are permitted +to argue in closing about absence of evidence consistent with +the Court's ruling. +THE COURT: Absolutely, so long as the inference is +available in the record. +And I'll just pause, because I made a note to say +this. I have a decent memory, and my afternoon and tomorrow +will be spent reviewing much of the trial testimony. I don't +want objections during closings, but that requires -- I gather +it's Ms. Menninger that's doing the closing and Ms. Moe, who +are absent today. So for both sides, any inference argued had +better be from the transcript or the documents, and any +objections should be rare and not based on your interpretation +of the available evidence but the fact of the available +evidence. We should get through closings without objections. +MR. EVERDELL: Understood, your Honor. +MR. ROHRBACH: Understood on our part, your Honor. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 82 of 95 +2820 +THE COURT: Thank you. +MR. ROHRBACH: This is the instruction where the +government also has a request, unless Mr. Everdell has anything +else on 69. +MR. EVERDELL: I do not. +MR. ROHRBACH: Here the government would request that +the Court include the traditional "government is not on trial" +sentence. +THE COURT: That I didn't permit. +MR. ROHRBACH: I saw that, your Honor. We just wanted +to raise it with your Honor again. Our view is that it's +something the defense put in issue in their -- came very close +to the line of putting in issue in their opening and has been a +theme of the defense case so far, and we assume they will come +close to the line but hopefully not cross the line in their +defense summation. And in light of that, it is an instruction +that the circuit has said is appropriate. And so we think, in +anticipation of what we expect in the defense's summation, we +think it is an appropriate inclusion in this instruction. +MR. EVERDELL: Your Honor, I don't think there's any +need to anticipate. If there's an issue about what we say, +we're going to be very careful about the Court's ruling. We're +going to do our level best to make sure we stay within the four +corners of the ruling. But I think this instruction as written +is appropriate. I suppose the government, if they want to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +raise something before the charge is given based on the +closing, they can. +THE COURT: I think this is what I typically use, so +we'll stick with that. And obviously closings will not cross +the line as to what I've forbidden, or that may become +necessary. +2821 +MR. EVERDELL: Yes, your Honor. +MR. ROHRBACH: Understood, your Honor. I think that, +just to sort of complete the point, the government's particular +concern is the argument about the empty chair and the +government's motivations for this prosecution, which is +somewhat different than the particular investigative techniques +point that's elsewhere in this instruction, which is why we +thought the additional sentence +is necessary. +THE COURT: I didn't permit and there will be no +argument about the government's motivation. +MR. EVERDELL: That's clear, your Honor. +MR. ROHRBACH: Thank you, your Honor. +MR. EVERDELL: All right. Your Honor, we're all set. +Page 73. +THE COURT: Anything before that? +MR. ROHRBACH: No. That was the last edit from the +government, actually. +THE COURT: OK. 73. +MR. EVERDELL: This is the preparation of witnesses + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2822 +instruction, instruction 55. The government can correct me if +I'm wrong. +I don't think we had any testimony about preparing +witnesses, so I don't know if this instruction is necessary. +THE COURT: No. There was. For sure. +MR. EVERDELL: OK. Maybe I'm mistaken about that. +THE COURT: "How many times did you meet with the +government?" +MR. EVERDELL: OK. +THE COURT: For example. Maybe every, every -- +MR. EVERDELL: OK. I stand corrected. +THE COURT: Other than that, you've got it. +MR. EVERDELL: Other than that, OK. +All right. I think that's all we have, apart from the +verdict sheet. +THE COURT: OK. Anything else, Mr. Rohrbach? +MR. ROHRBACH: No. Thank you, your Honor. +THE COURT: OK. The verdict sheet. +MR. EVERDELL: The verdict sheet, your Honor, is just +tracking some of the changes. +THE COURT: Wait, wait. Sorry. Yes. +•. I had two +more that we caught this morning. Page 78, line 13, it says +"solely be," but it should be "solely by." +MR. EVERDELL: Sorry, what line is that, your Honor? +THE COURT: 13. +MR. EVERDELL: OK. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2823 +THE COURT: And then there was one more heading, that +had that errant "Iwo" in it. +•, page 52, instruction 37, that +heading also has the word "Two" in it for some reason. +MR. EVERDELL: Yes, your. +THE COURT: Verdict sheet. +MR. EVERDELL: Your Honor, the edits here are just to +track changes we've adopted elsewhere. So as to Count One, +"conspiracy to entice an individual under the age of 17 to +travel. " +MR. ROHRBACH: That's fine, your Honor. +THE COURT: OK. "An individual." Right. All right. +So Count One, we'll adopt that and add "under the age of 17." +MR. ROHRBACH: This is actually in Count One also, +should be "individuals," plural, I think, in light of the +changes we've made? +THE COURT: Right. It's a conspiracy count. +MR. ROHRBACH: Yes, your Honor. +THE COURT: OK, Mr. Everdell. +MR. EVERDELL: Count Iwo, the same thing. +THE COURT: Sorry. I just wanted your adoption, +"conspiracy to entice individuals under the age." +MR. EVERDELL: Yes, your Honor. +THE COURT: So we'll cut "an" and make it plural. +MR. EVERDELL: Yes, your Honor. +THE COURT: Go ahead. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2824 +MR. EVERDELL: Count Iwo, "enticement of an individual +under the age of 17." +And then we would propose "(Jane only)," +to add the word "only, " your Honor. +THE COURT: So adding, after "an individual," "under +the age of 17," adding in the parentheses, after the word +"Jane, " "only." +MR. EVERDELL: Correct. +THE COURT: OK. +MR. EVERDELL: Count Three, to transport and then take +out the word "a minor, " this would be, I guess, "individuals +under the age of 17." +MR. ROHRBACH: Agreed, your Honor. +THE COURT: OK. I will make that change to +"individuals under the age of 17," taking out "a minor." +MR. EVERDELL: And then Count Four, "transportation of +an individual," adding "under the age of 17" and adding the +word "only" after "Jane." +THE COURT: OK. +MR. ROHRBACH: That's fine, your Honor. +THE COURT: All right. Make that change, adding +"under the age of 17" and then adding "only" after the word +"Jane." +MR. EVERDELL: Let's just skip over Count Five for a +second. Count Six. +THE COURT: "Only." + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +MR. EVERDELL: Carolyn only, and it would say "sex +trafficking of." +THE COURT: "An individual." +MR. EVERDELL: "Under the age of 18." +MR. ROHRBACH: That's fine, your Honor. +THE COURT: Taking out "a minor," adding "an +individual under the age of 18," and then adding "only" after +"Carolyn." +MR. EVERDELL: Correct, your Honor. +THE COURT: OK. +MR. EVERDELL: Moving back to Count Five, it's a +little cumbersome, I understand, the way the language is. But +it would say "sex trafficking conspiracy of individuals under +the age of 18." +THE COURT: OK. Mr. Rohrbach. +MR. ROHRBACH: We think it's a little unclear to say +"conspiracy to commit sex trafficking of individuals under the +age of 18"? +MR. EVERDELL: That's fine. +THE COURT: So we'll change Count Five to "conspiracy +to commit sex" -- how do you want to say it? +MR. EVERDELL: "conspiracy to commit sex trafficking +of individuals under the age of 18." +THE COURT: 17. +MR. ROHRBACH: 18 for this. +2825 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 88 of 95 +2826 +THE COURT: Sorry. 18, Count Five. +All right. So we'll make that change. +MR. ROHRBACH: The government has just one edit, if +Mr. Everdell is finished on the other. +MR. EVERDELL: Which one? +MR. ROHRBACH: Which is on the top of the verdict +sheet. +After "please indicate your verdict with a checkmark," +it's a "T" in parentheses. +THE COURT: That's so odd. Yes. We'll convert that +to a checkmark. +OK. That's it from the verdict sheet? +MR. ROHRBACH: Nothing from the government. +MR. EVERDELL: Nothing from the defense, your Honor. +MS. STERNHEIM: Judge, I have something unrelated to +the charge in the verdict sheet. +THE COURT: All right. Give me one moment just to go +through my to do list. So I have two open issues that I'1l +hear from the government by letter by 2. Once I have that, +I'll make my conclusions with respect to those. We'll send the +parties a redline version of the changes made and a clean +version, which will be the final version, unless -- I'll set a +time when I send it to you, by a certain time. You indicate +any errors that were implemented in the implementation of the +changes. Otherwise that will be final. Same for the verdict +sheet. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2827 +Ms. Sternheim, go ahead. +MS. STERNHEIM: Thank you, Judge. I don't know if the +Court has found out if any of the jurors are having issues +about staying later on Monday. +THE COURT: They were all fine. +MS. STERNHEIM: OK, because I just wanted to say that +we are motivated, and I think the government would join me, in +having us complete all of the closing arguments and the charge +on Monday. +THE COURT: Yes. I think we can do that. +MS. COMEY: Yes, your Honor. +THE COURT: Which gets to my next to-do item, which +is -- I realize we don't have the relevant people, but I think +Ms. Moe had indicated two to three hours. +MS. COMEY: That's right, your Honor. +THE COURT: Iwo sounds about right to me. +MS. STERNHEIM: That's even better to us. +THE COURT: I mean, length of trial, the complexity of +the charges, this should be a two-hour closing. +MS. COMEY: Your Honor, understood. We did, I will +note, streamline our case significantly, and there were a +number of exhibits that were not published to the jury, and I +think we were explicitly told, that's for closing, when we +wanted to do it with witnesses. So it's a little cumbersome, +because there is more work to be done connecting up a number of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 90 of 95 +2828 +paper exhibits that we were not able to show to the jury. So +that's what might push it back two hours. So I would ask for +the Court's indulgence to two and a half hours, in light of the +fact that we really didn't get to show the jury all of the +exhibits, and it's going to take more time to walk them through +those exhibits that they haven't even seen. +THE COURT: All right. So two and a half, and two and +a half. +MS. STERNHEIM: They should five minutes for rebuttal. +And it will be fine. +THE COURT: Can you do 30 for the rebuttal? +MS. COMEY: I would ask for the Court's indulgence for +a little more than 30 if I may, just to have a little bit of a +cushion. +THE COURT: All right. 35. +MS. COMEY: Thank you, your Honor. +THE COURT: So we're going to start at 9. We're going +to do a very short midmorning break. We're going to do a short +lunch. The jurors' lunch will be here, I think, 20 minutes. +Let's say 30 minutes for you all to have lunch too. Given +that, we should get through closings and the charge tomorrow +and potentially they can start deliberating, depending on what +time it is. But I agree -- +MR. EVERDELL: Your Honor, just on the issue of +timing, thinking it through, so we start at 9, we start right + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2829 +at 9 and the government has a two and a half hour closing, that +puts us at 11:30, roughly, give or take. It would be the +defense's request we don't break the defense closing through +lunch. So I don't know how that impacts the schedule. +THE COURT: We do the best we can, is what I always +say. +MR. EVERDELL: Understood. +THE COURT: We'll see where we are. +We'll adjust and +try to not break anything. +I'll have lunch here early, so that that's a +possibility. +MR. EVERDELL: Thank you, your Honor. +THE COURT: But, yes, I agree. And, you know, the +charge, I think it was about 80 pages. My favorite part of the +job is reading the charge. +MS. STERNHEIM: And ours to listen. +THE COURT: Nothing better. But I would guess an hour +or so, we should get there. +OK. And the other thing I have on my to-do list, I +always have the parties agree on the exhibits that are going +back to the jury, and I get that on the record, so forgive me +that I'm not sure exactly where we are under COVID protocols. +There was a time under COVID protocols where only electronic +exhibits went back. I think, and +isn't here to +tell me what's what, but I think now paper can go. Why don't + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2830 +you all confer. Go ahead, Ms. Sternheim. +MS. STERNHEIM: I'm going to wait until you finish and +then I'11 -- +THE COURT: What I'd like to do, when we meet, before +the jury comes in tomorrow -- not tomorrow -- Monday, as much +as I'd like to do it tomorrow. We'll meet at 8:30 on Monday, +and I would like to get on the record the parties' agreement as +to exactly what's going back to the jury, and +will +give you our -- actually, we'll try to get that to you today or +tomorrow - list of what we have as admitted exhibits, and you +can agree or tell us if we've got anything wrong. And I'll get +your agreement on that list of admitted exhibits as well. +Go ahead. +MS. STERNHEIM: Thank you, Judge. My recommendation +for efficiency purposes would be for the parties to agree on +what portions of the transcript should be redacted in case the +jury wants it, so that we don't have to do readback and then +make copies of the transcript could go in. +MS. COMEY: Agreed, your Honor. +THE COURT: That is understood. Absolutely. So +you'll have that ready by Monday. +MS. STERNHEIM: Yes. +THE COURT: Great. +Thank you. +Yes. And it is my practice to get that agreement and +then send the paper back. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2831 +MS. STERNHEIM: We'll work on that. I know that the +court reporters have often been very helpful in helping us do +that as well. +THE COURT: All right. Anything else? +MR. ROHRBACH: On that point, your Honor, the parties +are conferring on the redacted exhibits, and I anticipate we'll +get a letter probably later today if not hopefully later today +about exactly what the proposed redacted exhibits are, so +that's finished in advance of the closing. +MR. EVERDELL: We're working on that. +THE COURT: OK. And have you worked out logistics on +closings for the sealed material? +MS. COMEY: Yes, your Honor. I believe the plan is to +do what we did with the video exhibits, which is to have the +presentation from the parties up on the jurors' screens but not +displayed on the public screens or in the overflow room. And +we've also been working to get podium turned so that it's +facing the jurors. +And then I think there will be paper copies of the +presentations of the parties, for counsel who have screens that +are facing the gallery. +THE COURT: Right. So there will be no - orally, +you're not going to refer to any real names of witnesses who +testified by pseudonym, etc. That will at times be shown to +the jury during the presentation, but that won't be publicly + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2832 +hone. +MS. COMEY: That's exactly right, your Honor. And to +the extent there are images that were sealed, those would also +not be shown to the public but would be shown to the jury. +THE COURT: OK. Understood. Any questions about +that? +MR. EVERDELL: No, your Honor. +THE COURT: Any demonstratives of any kind planned, +other than -- +MS. COMEY: The PowerPoint presentation, your Honor, +but -- +THE COURT: - the PowerPoint, that does anything +other than show admitted evidence or testimony? +be some portions of the charge, +once it's finalized. It's possible that there would be text of +the final charge on the slides. +But I don't think there would +be anything beyond that, or excerpts of the transcript from the +trial. +THE COURT: Right. +MR. EVERDELL: Actually on that point I didn't know +what the Court's practice was on that, whether the Court allows +the final charge excerpts to be used in the closing or whether +we do something else. +THE COURT: I do allow it. +MR. EVERDELL: OK. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 765 Filed 08/10/22 Page 95 of 95 +283 +THE COURT: But I'll hear if anybody has an objection. +MS. COMEY: No, your Honor. +MR. EVERDELL: No, your Honor. +THE COURT: OK. Anything else on that? +MR. EVERDELL: No. I think we just have to work a few +redactions out. +THE COURT: And I think we have one more minor edit. +It was just a minor thing, but we can't find it. +Let me just note, I want to thank the court staff who +worked on Saturday to make this possible, and my thanks to +counsel and the parties for doing it. I appreciate everybody's +willingness to work on a Saturday. Thank you. +Page 51, line 13, missing the word "at." "The +government has to prove that at least one of the overt acts." +So inserting "at." +MR. EVERDELL: No objection, your Honor. +MR. ROHRBACH: Yes. +THE COURT: All right. We'll make that change. +With that, thank you, everyone. I will see you Monday +at 8:30. +(Adjourned to 8:30 a.m., +December 20, 2021) \ No newline at end of file diff --git a/vision-fixhub/court-05/5ecc6807d88be146e59320d37ada27045e4034ed1686b03620e597f560f75a46.receipt.json b/vision-fixhub/court-05/5ecc6807d88be146e59320d37ada27045e4034ed1686b03620e597f560f75a46.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..52e3f98965dca56d995cb415be74d866f049f55f --- /dev/null +++ b/vision-fixhub/court-05/5ecc6807d88be146e59320d37ada27045e4034ed1686b03620e597f560f75a46.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -11453, + "dataset": "marble-joined", + "doc_id": "5ecc6807d88be146e59320d37ada27045e4034ed1686b03620e597f560f75a46", + "engine": "marble-apple-vision", + "event_count": 160, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "0df18ae06b54de3ee5e97886977aefce5ca26556760138466a7f4df924dc0372", + "output_sha256": "bccf9e1c3e038c4da06694b705a44058fc4ad414257cdc7892de9ae68732c0cd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5ee5b7b16b7cd1256b7eec2d59afb0fc40ee2b21ab9b08f14e60b86e105be464.md b/vision-fixhub/court-05/5ee5b7b16b7cd1256b7eec2d59afb0fc40ee2b21ab9b08f14e60b86e105be464.md new file mode 100644 index 0000000000000000000000000000000000000000..96863d28017f90ff145ad8c9c76175b6f643e9ed --- /dev/null +++ b/vision-fixhub/court-05/5ee5b7b16b7cd1256b7eec2d59afb0fc40ee2b21ab9b08f14e60b86e105be464.md @@ -0,0 +1,70 @@ +Case 1:20-cr-00330-PAE Document 726 +Filed 07/13/22 Page 1 of 3 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC#:_ +DATE FILED: 7/13/22 +United States of America, +-V- +Ghislaine Maxwell, +20-CR-330 (AJN) +ORDER +Defendant. +ALISON J. NATHAN, Circuit Judge, sitting by designation: +The Court is in receipt of the parties' proposed redactions to motions that were not +previously docketed. See Dkt. No. 698. With one exception, the Court concludes that the +proposed redactions are narrowly tailored to protect information subject to Fed. R. Evid. 412 and +the privacy interests of witnesses, including individuals subject to the Court's pseudonym order, +and individuals who were anticipated to be called as witnesses at trial, but were not ultimately +called. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). The Court will +file unredacted copies of all items under seal. +The Court concludes, however, that the proposed redactions to Dkt. No. 725 are not +narrowly tailored. The private information of victim-witnesses who are discussed in the letter +may be protected by narrow redactions. However, there is no basis to redact the letter's general +request to identify the proper scope of cross-examination. Accordingly, the Defendant is +ORDERED to confer with the Government and docket proposed revised redactions on or before +12:00 p.m. on Friday, July 15, 2022. The letter at Dkt. No. 725 was filed under temporary seal +at Dkt. No. 712. Because the Court concludes that sealing in not justified, the Clerk of Court is +respectfully directed to strike the entry at Dkt. No. 712 from the docket. +1 + + +Case 1:20-cr-00330-PAE Document 726 Filed 07/13/22 Page 2 of 3 +The Court's +also received an email from Defense counsel inquiring whether to +docket three joint letters regarding jury strikes that were previously filed with the Court, but not +docketed. Because docketing the letters would not undermine the important interest of +protecting juror anonymity and privacy, the parties are ORDERED to docket the three letters on +or before 12:00 p.m. on Friday, July 15, 2022. +Finally, to ensure a complete record, the Court has identified four additional documents +that have not previously been docketed nor subject of a sealing request: +• November 19, 2021 Administrator +Motion to Quash Defendant's Rule +17(c)(3) subpoena, with exhibits +• November 22, 2021 Defendant's Response to Motions to Quash Defendant's Rule +17(c)(3) subpoena +December 6, 2021 Jane's Opposition to Defendant's Motion to Call Counsel to +Testify +• December 15, 2021 Jane's Opposition to Defendant's December 13, 2021 Motion to +Call Counsel to Testify +The parties are ORDERED to confer with each other and counsel for the relevant movants and +indicate on or before 12:00 p.m. on Friday, July 15, 2022, whether there are any requests to +seal or redact the outstanding documents. Any documents not subject to a sealing request must +be docketed on ECF by that same date. Any proposed redactions must be justified by reference +to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga. +This resolves Dkt. No. 698. +SO ORDERED. +2 + + +Case 1:20-cr-00330-PAE Document 726 Filed 07/13/22 Page 3 of 3 +Dated: July 13, 2022 +New York, New York +Alia f. Notor +ALISON J. NATHAN +United States Circuit Judge +Sitting by Designation +3 diff --git a/vision-fixhub/court-05/5ee5b7b16b7cd1256b7eec2d59afb0fc40ee2b21ab9b08f14e60b86e105be464.receipt.json b/vision-fixhub/court-05/5ee5b7b16b7cd1256b7eec2d59afb0fc40ee2b21ab9b08f14e60b86e105be464.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..976983ecc5a89492ff114d193d9986bb14d7e29b --- /dev/null +++ b/vision-fixhub/court-05/5ee5b7b16b7cd1256b7eec2d59afb0fc40ee2b21ab9b08f14e60b86e105be464.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "5ee5b7b16b7cd1256b7eec2d59afb0fc40ee2b21ab9b08f14e60b86e105be464", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "437a83742826cee41518f6d144c3b71514e2ccf91cd6c80681e36cb789f89b7b", + "output_sha256": "16043606a38bf965a35a4cfebd4d0a6d7549694e0596471342755998b406e60b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5f08973af186032fc569cfd3d57c6d33ad49e224298186d994d5672d45796fcc.md b/vision-fixhub/court-05/5f08973af186032fc569cfd3d57c6d33ad49e224298186d994d5672d45796fcc.md new file mode 100644 index 0000000000000000000000000000000000000000..601c818faf545b903f7d8639c88a4ff9cea8ce96 --- /dev/null +++ b/vision-fixhub/court-05/5f08973af186032fc569cfd3d57c6d33ad49e224298186d994d5672d45796fcc.md @@ -0,0 +1,97 @@ +Case 1:22-cv-10904-JSR Document 186-42 Filed 06/14/23 +_Page 1 of 4 + + + +Case 1:22-cV-10904-JSR Document 186-42 Filed 06/14/23 Page 2 of 4 +Message +From: +Sent: +To: +Subject: +Margarita +|I/O=USVIEDAEXCH/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MAGARITA A. +10/2/2019 2:22:17 PM +Joy Penn [jpenn@usvieda.org]; Sandra Bess [sbess@usvieda.org] +FW: URGENT - NY Times INQUIRY: Follow-up questions for comment - NYT +Good Day Ladies, +Please see the recent request from NY Times. Your feedback on the response is appreciated. I personally think the +questions are opening us up to public scrutiny. +Margarita +Managing Director, Economic Development +Email: mabenjamin@usvieda.org +Phone: 340-714-1700 Ext 1611 +Fax: 340-774-8106 +www.usvieda.org +Economic Development Authority +8000 Nisky Shopping Center, Suite 620 +ST. +U.S. Virgin Islands 00802 +From: Kamal I. +Sent: Wednesday, October 2, 2019 1:45 PM +To: Shanell Petersen < spetersen@usvieda.org>; Tracy Bhola, Esq. ; Wayne Biggs, Jr. +; Margarita + +Cc: Henry C. Smock ; Kevin Rodriquez ; Semele A.C. L + +Subject: Re: URGENT - NY Times INQUIRY: Follow-up questions for comment - NYT +Good afternoon Colleagues, +Please have a response prepared for review as per our media response protocol. +Thank you. +Kind regards, +Kamal +Kamall. +Chief Executive Officer +Email: klatham@usvieda.org +Phone: 340-714-1700 Ext 1111 +Fax: 340-774-0990 +www.usvieda.org +VI-JPM-000017233 + + +Case 1:22-cV-10904-JSR Document 186-42 Filed 06/14/23 Page 3 of 4 +Economic Development Autharity +8000 Nisky Shopping Center, Suite 620 +St. +. U.S. Virgin Islands 00802 +On Oct 2, 2019, at 12:39 PM, Shanell Petersen wrote: +Good afternoon, +Please see the additional inquiry from New York Times in need of immediate review below. +Respectfully, +Shanell +Shanell Petersen +Managing Director, Marketing & 2040 Vision +Email: spetersen@usvieda.org +Phone: 340-714-1700 Ext 1511 +Fax: 340-777-1103 +www.usvieda.org +Economic Develogment Authority +8000 Nisky Shopping Center, Suite 620 +St. +U.S. Virgin Islands 00802 +From: Eder, Steve [mailto:steve.eder@nytimes.com] +Sent: Wednesday, October 02, 2019 11:44 AM +To: Shanell Petersen; Matthew +Subject: Follow-up questions for comment - NYT +Good morning, Shanell - We are planning an article relating to Mr. Epstein's finances and +businesses in USVI. The piece will raise the point that USVI has been criticized for not closely +overseeing beneficiaries of the tax incentive programs. I've included a couple questions below +for VIEDA: +- Was VIEDA comfortable with the answers it received from Mr. Epstein about his business +practices & activities over the years? Should VIEDA have pressed Mr. Epstein about his +business affairs? +- Was VIEDA satisfied with the return USVI's return on Mr. Epstein's businesses? +VI-JPM-000017234 + + +Case 1:22-cv-10904-JSR Document 186-42 Filed 06/14/23 Page 4 of 4 +Please send any responses today, 10/2, by 5 p.m. ET. +Thank you. +Steve and Matt +This electronle message is intended to be viewed only by the Individual or entity to whom it is addressed. It may contain Information that is +privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this communication is +strictly prohibited without our prior permission. If the reader of this message is not the intended recipient, or the employee or agent +esponsible for delivering the message to the intended recipient, or If you have recelved this communication in error, please notify us +Immediately by return e-mail and delete the original message and any coples of it from your computer system. +VI-JPM-000017235 \ No newline at end of file diff --git a/vision-fixhub/court-05/5f08973af186032fc569cfd3d57c6d33ad49e224298186d994d5672d45796fcc.receipt.json b/vision-fixhub/court-05/5f08973af186032fc569cfd3d57c6d33ad49e224298186d994d5672d45796fcc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..620acc2ee03b03bdcd53560f1b57f2d7145286a6 --- /dev/null +++ b/vision-fixhub/court-05/5f08973af186032fc569cfd3d57c6d33ad49e224298186d994d5672d45796fcc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -182, + "dataset": "marble-joined", + "doc_id": "5f08973af186032fc569cfd3d57c6d33ad49e224298186d994d5672d45796fcc", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "0869479fd72935a75c660bff793ef3086bd13c71783f49584ffe8187b44b4fc9", + "output_sha256": "c6a528fde207b5af320c6bc14d532237f8b1aeebbb37d6afb4705d899e766da9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5f5f3f2815d669296e88e470cb00faf0eaf0149442a1db911ee4ee74f08996d0.md b/vision-fixhub/court-05/5f5f3f2815d669296e88e470cb00faf0eaf0149442a1db911ee4ee74f08996d0.md new file mode 100644 index 0000000000000000000000000000000000000000..6e508c7cf302ea597a279a7ead9d692b05c58e4b --- /dev/null +++ b/vision-fixhub/court-05/5f5f3f2815d669296e88e470cb00faf0eaf0149442a1db911ee4ee74f08996d0.md @@ -0,0 +1,497 @@ +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 1 of 10 + + + +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 2 of 10 +1 +2 +3 +4 +5 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +VS. +JPMORGAN CHASE BANK, N.A., +Defendant. +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +No. 22-cv-10904-JSR +v. +JAMES EDWARD STALEY, +Third-Party Defendant. +THE ORAL DEPOSITION OF SANDRA BESS was taken on +the 18th day of May, 2023 at the Ritz-Carlton Hotel, +6900 Great Bay, Nazareth, Charlotte Amalie, St. +U.S. Virgin Islands, between the hours of 8:43 a.m. and +11:53 a.m. pursuant to Notice and Federal Rules of Civil +Procedure. +Reported by: +DESIREE D. +Registered Merit Reporter +| Reporting Services +P.O. Box 307501 +St. +Virgin Islands +(340) 714-0269 + + +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 3 of 10 +15 +1 +2 +3 +4 +5 +done for the period. +I see. So if there were a renewal coming +up and there was no recent compliance report, you +would prepare a summary of their compliance? +MR. ACKERMAN: Objection to form. +(By Mr. Neiman:) Is that fair? You can +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +e. +answer. +Yes, sir. +All right. Now, these compliance reports +that you prepare for a particular certificate holder, +how often would you put together a compliance report? +A compliance report should be done +annually, but because the agency had some backlog as +we termed it, sometimes the report would take +probably three years before completion, five years +before completion, and sometimes you'd have one +that's done on an annual basis. +Would it be unusual for a company to not +get a compliance report until nine years after they +started as a certificate holder? Would that be +unusual? +It is -- should not be unusual 7but it +maybe has happened in one or two cases. +Okay. So not the normal practice but might +have happened one or two times. + + +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 4 of 10 +16 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MR. ACKERMAN: Objection to the +form. +THE WITNESS: Yes, sir. +(By Mr. Neiman:) Okay. All right. Now, +when you're doing these compliance reports, do you do +any review of what's in the press about the +beneficiary or the people who are the individuals +behind the beneficiary? +No, sir. +e. +So there's no process, for example, of +seeing if there are press accounts indicating that a +beneficiary is engaged in unlawful activity? +A. No, sir. +And no process for seeing if the people who +stand behind a beneficiary are engaged in illegal +activity? +e. +No, sir. +Do you have -- from your experience as a +compliance officer, is one of the things that you get +information about how much the certificate holder has +benefited from the various tax incentives they've been +granted? +If I understand your questions, you're +asking me about the certificate - the owner, but we +usually do a cost benefit analysis based on the + + +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 5 of 10 +106 +1 +2 +3 +4 +5 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Break taken.) +VIDEOGRAPHER: Okay. We are going +back on the record. The time is +11:37 a.m., Wednesday, May 17, 2023. +We +are on the record. +MR. NEIMAN: Ms. Bess, thank you +for your time this morning. I have no +further questions for you. +MR. ACKERMAN: I guess we should +probably ask Mr. Staley's counsel first +whether he has questions. +MR. WOHLGEMUTH: No question for +Mr. Staley. +MR. ACKERMAN: Okay. I do have a +few questions, Ms. Bess. +CROSS EXAMINATION +BY MR. ACKERMAN: +You and I have met before, my name is David +Ackerman. I am with the law firm of Motley Rice +representing the Government of the Virgin Islands and +you at this deposition. +You described earlier in your testimony +a backlog. Do you recall using that term? +A. Yes, sir. +Okay. What did you mean by backlog? + + +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 6 of 10 +107 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +When I was - when I was initially +employed by the Virgin Islands Economic Development +apparently there were no compliance reviews +done for +the beneficiaries. +So, the reports that were done we +would - that was in existence, I think that - if I +can recall, the -- that agency was formed in 1988. +The compliance unit was officially +formed in August of 2021 (sic), and so they began +hiring. So, any applicants or matters that were +prior to me being aboard, they were just there, they +probably may have done a report or two, because I +think there was only one compliance officer at the +time. +When I got there, there were at that +time, three. So backlog means that, yes, there were +matters that were before us and what we were getting. +And like I said, at that time, they would go up as +high as 140. +We would - St. +would be given +the st. +matters. St. Croix would be given the +St. Croix matters. So everything was backlogged, and +that is the reason Mr. Vanessa Fahie in the exhibit +that was just presented was hired. She was a +contract employee. + + +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 7 of 10 +108 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. You said - I think, I want to make +sure I didn't mishear you, that the compliance unit +was formed in August of which year? +Please, don't quote me as being the thing. +I - officially, I think to the best of my +recollection, 2001. +Q. +Okay. I think you might have said 2021, +and that's the only reason I wanted to clarify that. +Thank you. +How long did it take you to typically +prepare a compliance report? +Depending on the amount of years, and +depending on the size of the company because the +matter that we just referred to could have had five +to ten employees. I have had companies with 400 +employees. So, the employee count is what would +stall us. +And then gathering the information, it +typically should be six weeks, but sometimes it could +take us months. +How many months for large companies? +Months could take you more than a year. +Wow. +So, more than a year. +How many reports per year would you or one + + +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 8 of 10 +109 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +of your compliance officers typically complete? +We were required to have at least eight, +sometimes six. It fluctuated based on the companies +that were in question. But typically, we would have +maybe four, five in a good year. +And that is -- and again, there were how +many compliance officers total in the EDA? +Okay. When I left, there were five. +Prior to that, four. Could be from four. +Was your only responsibility at the EDA to +complete compliance reports? +Yes, it was. +Okay, thank you. +When you were working on a compliance +report, what role did the certificate play in +your - if any, in your preparation of that +compliance report? +The certificate was the focus point of the +report, because usually typically the shell would +start with all of the highlights listed on the +certificate and then we'd fill in as we go along. +Did you look at matters outside of the +certificate requirements when preparing a compliance +report? +Could you repeat the question? + + +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 9 of 10 +110 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Yes. When you were preparing your +compliance reports, would you look at issues that were +outside of the certificate requirements that were +listed? +If I am understanding the question, I +would typically review the application, which would +-- because that's what we're given when we get a +certificate. +We get the application, what was listed +as -- in the application. +We would also gather the +public hearing and the executive session of the +matter. +And so those are the reports that we +reviewed, just to check to see what might have been +discussed, what issues might have been brought up. +Just to include it in the -- just to possibly look to +see what do I need to zone in on or just double check +something on. +Okay. But when you are preparing your +compliance report, would you look at aspects of the +company's business that would have no relation to the +conditions that were set forth in the certificate? +Typically, no. +Why not? +Because we're focused only on what was + + +Case 1:22-cv-10904-JSR Document 283-16 Filed 08/14/23 Page 10 of 10 +111 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +part of the contract. +e. +That was your job, right? +That was my job. +You testified earlier this morning that you +were aware that -- from the news that Mr. Epstein was +arrested for bringing young ladies to his private +island. +Do you recall that testimony? +MR. NEIMAN: Objection. +Foundation. +THE WITNESS: I recall saying +those words, yes. +(By Mr. Ackerman:) Okay. When -- do you +know when you read those news reports? +Possibly - if I recall, I was doing the +Southern Trust report in 2018, if I remember. 2018, +thereabouts. +Okay. Thank you. I want to pull +Exhibit 6, if you would, please. +And if you would look at the employment +section which is on page 6 of Exhibit 6. Would you +let me know when you're there? I'm sorry, it's on +page 6 of your report. It's the document, the +number is 23084 at the bottom. +I'm there. \ No newline at end of file diff --git a/vision-fixhub/court-05/5f5f3f2815d669296e88e470cb00faf0eaf0149442a1db911ee4ee74f08996d0.receipt.json b/vision-fixhub/court-05/5f5f3f2815d669296e88e470cb00faf0eaf0149442a1db911ee4ee74f08996d0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1b37cb46578ffa53910fab33dad1b206ffec802c --- /dev/null +++ b/vision-fixhub/court-05/5f5f3f2815d669296e88e470cb00faf0eaf0149442a1db911ee4ee74f08996d0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -198, + "dataset": "marble-joined", + "doc_id": "5f5f3f2815d669296e88e470cb00faf0eaf0149442a1db911ee4ee74f08996d0", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "40c9809cb2535f49bc1ec85f412e8244be89b6cc575891336781980b36126de3", + "output_sha256": "56a5e43be3f8942451c8779fdcf11f1bfd8f2196e30ac426283f374c77446a61", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5f6c49dc0dab4a342ced4e61444e55264c061a0e175fc5121404c90abb84389a.md b/vision-fixhub/court-05/5f6c49dc0dab4a342ced4e61444e55264c061a0e175fc5121404c90abb84389a.md new file mode 100644 index 0000000000000000000000000000000000000000..0e31cc84af2e7533ac028a4a37ed14e26d2e18c7 --- /dev/null +++ b/vision-fixhub/court-05/5f6c49dc0dab4a342ced4e61444e55264c061a0e175fc5121404c90abb84389a.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 243-13 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/5f6c49dc0dab4a342ced4e61444e55264c061a0e175fc5121404c90abb84389a.receipt.json b/vision-fixhub/court-05/5f6c49dc0dab4a342ced4e61444e55264c061a0e175fc5121404c90abb84389a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e2b64367e4b40df4907b4db6e7ef0729aae07a8c --- /dev/null +++ b/vision-fixhub/court-05/5f6c49dc0dab4a342ced4e61444e55264c061a0e175fc5121404c90abb84389a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "5f6c49dc0dab4a342ced4e61444e55264c061a0e175fc5121404c90abb84389a", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "6ec1eabe018762dfbad14f2cb92957f99c294cacf79f0d17f1bb4ba1287496d1", + "output_sha256": "178974b8410ac1ed521b6da8ff82bb95b0691e416fa80dde92d50dd0a53b9c51", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5f70d31997e4354a97f1f940ca22af6dbee77e42c200d0d8a8aa5d0832596c3a.md b/vision-fixhub/court-05/5f70d31997e4354a97f1f940ca22af6dbee77e42c200d0d8a8aa5d0832596c3a.md new file mode 100644 index 0000000000000000000000000000000000000000..86f450cf8d3dea3cc2b8a2e24d0b3eb7ae3136a2 --- /dev/null +++ b/vision-fixhub/court-05/5f70d31997e4354a97f1f940ca22af6dbee77e42c200d0d8a8aa5d0832596c3a.md @@ -0,0 +1,32 @@ +Case 1:22-cV-10904-JSR Document 265-43 Filed 08/07/23 Page 1 of 2 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 265-43 Filed 08/07/23 Page 2 of 2 +Staley, Jes +"jeevacation@gmail.com' +3/20/2011 1:45:05 PM +Re: +Agree +From: Jeffrey Epstein +To: Staley, Jes +Sent: Sun Mar 20 09:21:21 2011 +Subject: +I m working on getting steve cutler the comfort he needs. +$$$$$$$$$$$$$$$$$$** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved diff --git a/vision-fixhub/court-05/5f70d31997e4354a97f1f940ca22af6dbee77e42c200d0d8a8aa5d0832596c3a.receipt.json b/vision-fixhub/court-05/5f70d31997e4354a97f1f940ca22af6dbee77e42c200d0d8a8aa5d0832596c3a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..10b9baefc39a204ea8f5c95cba1715b184acd593 --- /dev/null +++ b/vision-fixhub/court-05/5f70d31997e4354a97f1f940ca22af6dbee77e42c200d0d8a8aa5d0832596c3a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -35, + "dataset": "marble-joined", + "doc_id": "5f70d31997e4354a97f1f940ca22af6dbee77e42c200d0d8a8aa5d0832596c3a", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "4c2d229c6ddc83b6320f390bc04e0b61c6a06c94c3c6df01e63300f8e4a98ab0", + "output_sha256": "1cb1fcdd5f925727c381887ccca7e22c2c2003b1b68cabc23edb62af364db086", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5f7b67f405795ade404429615655d306192cc47037dbc4da44937af5b69c77dd.md b/vision-fixhub/court-05/5f7b67f405795ade404429615655d306192cc47037dbc4da44937af5b69c77dd.md new file mode 100644 index 0000000000000000000000000000000000000000..284aecf46fbf1117180a1b83e205b679495c7455 --- /dev/null +++ b/vision-fixhub/court-05/5f7b67f405795ade404429615655d306192cc47037dbc4da44937af5b69c77dd.md @@ -0,0 +1,22 @@ +Case 1:22-cV-10904-JSR Document 186-30 Filed 06/14/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 186-30 Filed 06/14/23 Page 2 of 2 +Date: +Tuesday. February 162016 11:44 PM +Subject: Re: Thank you +From: +jeffrey E. +To: +Cecile de Jongh < +@yahoo.com>: +Glad +On Tuesday, 16 February 2016, Cecile de Jongh < +@yahoo.com > wrote: +Jeffrey, +Thank you for the wonderful lunch on GSJ. We had a lovely lunch hour there and Anna, of course, +fed us well. GSJ is really very nice and I think everyone is in agreement that we just might like it +better than LSJ. :-) Thank you again for the invitation to visit the island. +With warm regards, +Cecile diff --git a/vision-fixhub/court-05/5f7b67f405795ade404429615655d306192cc47037dbc4da44937af5b69c77dd.receipt.json b/vision-fixhub/court-05/5f7b67f405795ade404429615655d306192cc47037dbc4da44937af5b69c77dd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5f94c2ad49ad9a637c19eaf646e5e6f8b8da2811 --- /dev/null +++ b/vision-fixhub/court-05/5f7b67f405795ade404429615655d306192cc47037dbc4da44937af5b69c77dd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -663, + "dataset": "marble-joined", + "doc_id": "5f7b67f405795ade404429615655d306192cc47037dbc4da44937af5b69c77dd", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "03f8b36d23f08b6b65430a94ec38028ab068f1acfb863b1f74798939171dd629", + "output_sha256": "f9cc46a10e91ca526cd0bfd2b5a295dc4177c02ec961e50ff1e3c9db38005972", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5f8b6d1787fc2fc7bf4cb8bf35ff016751a3687460721850933595e12f479c09.md b/vision-fixhub/court-05/5f8b6d1787fc2fc7bf4cb8bf35ff016751a3687460721850933595e12f479c09.md new file mode 100644 index 0000000000000000000000000000000000000000..e4c8111fe862a45715bfb3111d1f4e335a18dd73 --- /dev/null +++ b/vision-fixhub/court-05/5f8b6d1787fc2fc7bf4cb8bf35ff016751a3687460721850933595e12f479c09.md @@ -0,0 +1,202 @@ +Case 1:22-cv-10904-JSR Document 250 Filed 07/31/23 Page 1 of 5 +WILMERHALE +By ECF +Felicia H. Ellsworth +617 526 6687 +1 617 526 5000 +felicia.ellsworth@wilmerhale.com +United States District Court +Southern District of New York +Daniel +| Moynihan United States Courthouse +500 Pearl Street +New York, NY 10007-1312 +Re: +Jane Doe 1 v. JPMorgan Chase Bank, N.A. v. James E. Staley, 22-cv-10019 (S.D.N.Y.) - +Opposition to Third-Party Defendant James Staley's Letter Alleging Waiver +Dear Judge Rakoff: +JPMorgan Chase Bank, N.A. ("JPMC") filed a third-party complaint against former +employee James Staley earlier this year after lawsuits sought to impose liability on the bank due +to Mr. Staley's alleged personal misconduct and knowledge of Epstein's misconduct derived from +his deep personal friendship with Epstein, which he failed to disclose to JPMC. In its case against +Mr. Staley, JPMC alleged, inter alia, claims for indemnity and contribution. See Jane Doe 1 v. +JPMorgan Chase Bank, N.A., 22-cv-10019, Dkt. 59. +.' Since that time, JPMC entered a settlement, +preliminarily approved by this Court, to resolve this litigation, but maintains that Mr. Staley is +responsible for that settlement amount. Mr. Staley, in a third misguided effort to suggest a +privilege waiver by JPMC, now claims that, by maintaining its claim against Mr. Staley while +settling the claims brought by the class, JPMC waived privilege related to its settlement. This +argument is legally flawed and factually baseless, and this effort to invade JPMC's privilege fails +just like the prior two. +After JPMC's settlement with the Doe class was announced, Mr. Staley asked the Court to +exclude the settlement amount as damages (denied), extend fact discovery by 60 days (denied), or +for discovery into the "reasonableness" and "causation" of the settlement. See July 7, 2023, Minute +Entry. He was granted limited discovery, id., which JPMC has produced. In his telephone +application for this discovery, Mr. Staley disclaimed seeking privileged communications at that +time. Two days later, he reversed course, asserting the Court's Order " [de] clear" that JPMC +had placed settlement-related communications "at issue" and waived privilege. +Hereinafter, all docket citations are to Case No. 22-cv-10019, except where noted +2 +Mr. Staley previously argued that JPMC had waived privilege (1) over communications of +in-house counsel by placing the knowledge of its General Counsel "at issue," and (2) over +communications regarding Mr. Staley's role with respect to Epstein's accounts through a +"selective disclosure." Dkt. 196. Both arguments were rejected. June 28, 2023, Minute Entry. +Mr. Staley was also permitted to depose a JPMC 30(b)(6) witness about the settlement, +provided that "the deposition should take place no later than 7/21/23." Id. JPMC offered to make +a witness available on July 19 (or July 25), but Mr. Staley refused, preferring to petition the Court +regarding privilege. +Wilmer Cutler Pickering Hale and Dorr uP, 60 State Street, Boston, Massachusetts 02109 +Beijing Berlin Boston Brussels Denver Frankfurt London Los Angeles New York Palo Alto San Francisco Washingtor + + +Case 1:22-cv-10904-JSR Document 250 Filed 07/31/23 Page 2 of 5 +Page 2 +WILMERHALE +Mr. Staley argues that JPMC's claims place "at issue" its privileged communications +related to settlement. That is incorrect. The applicable, binding case law is clear that "at issue" +waiver only occurs where a party relies on the privileged communications, and that seeking as +damages the amount for which a party settled does not alone place attorney-client privileged +communications at issue. Here, JPMC has not relied, and will not rely, on privileged +communications to prove either aspect of its claims identified in Mr. Staley's letter: +"reasonableness" and "causation." In short, JPMC has neither the intention nor the need to use its +communications with counsel about the settlement to make its case. Under these circumstances, +Mr. Staley does not come close to meeting the high standard required to show waiver. +The narrowness of "at issue" waiver is well-established. Because the attorney-client +privilege serves a vital purpose, "rules which result in the waiver of this privilege and thus possess +the potential to weaken attorney-client trust, should be formulated with caution." In re Cnty. of +Erie, 546 F.3d 222, 228 (2d Cir. 2008). Thus, the Second Circuit rejected the test from Hearn v. +Rhay, 68 F.R.D. 574 (E.D. Wash. 1975) which required only that information be "1 +[de] +relevant to the case" to be placed "at issue"—holding instead that, for waiver to occur, "a party +must rely on privileged advice from his counsel to make his claim or defense." In re Cnty. of Erie, +546 F.3d at 229; see 2002 +R. Buchalter Alaska Tr. v. Phila. Fin. Life Assur. Co., 2016 +WL 1060336, at *2 (S.D.N.Y. Mar. 11, 2016) ("[T]he Court in Erie explicitly rejected the socalled "Hearn test."); see also Deutsche Bank Trust Co. of Ams. v. Tri-Links Inv. Trust, 43 A.D.3d +56, 64 (Ist Dep't 2007) (*ITJhat a privileged communication contains information relevant to +issues the parties are litigating does not, without more, place the contents of the privileged +communication itself 'at issue' in the lawsuit; if that were the case, a privilege would have little +effect. Rather, "at issue' waiver occurs when the party has asserted a claim or defense that he +intends to prove by use of the privileged materials." (cleaned up)).* +First, Mr. Staley asserts that JPMC waived privilege by the mere act of "bringing an +indemnification action" that makes relevant "the issue of reasonableness of the settlement." See +Staley Letter at 2.5 This is not the law. See Leviton Mfg. Co., Inc. v. Greenberg Traurig LLP, +2010 WL 4983183, at *4 (S.D.N.Y. Dec. 6, 2010) ("Like the Second Circuit, New York courts +will not find waiver merely because privileged information is relevant to the issues being +litigated."); Veras Inv. Partners, LLC v. Akin Gump Strauss Hauer & Feld LLP, 52 A.D.3d 370, +372 (Ist Dep't 2008) ("[I]t was error ... to find waiver on the basis of relevance alone."). JPMC +does not dispute that the reasonableness of the settlement is an aspect of its damages claim against +Mr. Staley, but that alone does not establish waiver. Rather, New York courts hold that privileged +communications are not placed at issue by seeking to recover a settlement as damages, unless the +Other circuits have likewise concluded that Hearn is "of dubious validity" because its +analysis "rest[s] on a conclusion that the information sought is relevant and should in fairness be +disclosed." Rhone-Poulenc Rorer, Inc. v. Home Indem. Co., 32 F.3d 851, 864 (3d Cir. 1994); see +also In re Intron, Inc., 883 F.3d 553, 563-565 (5th Cir. 2018). "Relevance is not the standard for +determining whether or not evidence should be protected from disclosure as privileged, and that +remains the case even if one might conclude the facts to be disclosed are vital, highly probative, +directly relevant or even go to the heart of an issue." Rhone-Poulenc Rorer, 32 F.3d at 851. +Although JPMC logically seeks to recover the damages related to the settlement in the Doe +case (No. 22-cv-10019), Mr. Staley's Letter was filed only on the USVI docket (at Dkt. 248). + + +Case 1:22-cv-10904-JSR Document 250 Filed 07/31/23 Page 3 of 5 +Page 3 +WILMERHALE +party seeks to rely on those communications. Nomura Asset Cap. Corp. v. Cadwalader, +Wickersham & Taft LLP, 62 A.D.3d 581, 582 (Ist Dep't 2009) ("Nor does the question of the +reasonableness of the settlement amount that plaintiff seeks to recover, without more, put plaintiff's +privileged communications with its attorneys concerning the settlement 'in issue."); see also +v. Beer, 2010 WL 2653650, at *6 (S.D.N.Y. July 2, 2010) ("[T]he legal advice that the +plaintiffs received prior to settling ... is no doubt relevant to their claim for reimbursement .... +However, they are not relying on that advice to demonstrate the reasonableness of their decision +to settle. Consequently, under County of Erie, the attorney-client privilege has not been +forfeited."), aff'd in relevant part, 2010 WL 3422723, at *6 (S.D.N.Y. Aug. 24, 2010); +AngioDynamics, Inc. v. Biolitec, 2010 WL 11541926, at *3-5 (N.D.N.Y. May 25, 2010) ("[W]e +reject [the] argument that [plaintiff's] initiation of this ... indemnification action constituted a +waiver of its attorney-client privilege regarding all communications it may have made with counsel +concerning the settlement of the underlying actions."). +The cases Mr. Staley cites are inapposite. Mr. Staley's primary citation (see Staley Letter +at 2 & 3), Scotstoun Shipping Co. v. Diplomatic Marine, Inc., 1980 WL 6688497 (S.D.N.Y. Jan. +21, 1980), predates the Second Circuit's rejection of the Hearn test and relies expressly on Hearn +to support its relevance-based finding of waiver. A number of Mr. Staley's other cites decided +under the inapplicable substantive law of other states—likewise rely on Hearn's since-rejected +relevance standard. See, e.g., l +v. Meridian Yachts, Ltd., 2008 WL 2229552, at *10-11 (S.D. +Fla. May 28, 2008) (relying on 11th Cir. case applying the Hearn test, GAB Bus. Servs., Inc. v. +Syndicate 627, 809 F.2d 755, 762 & n. 11 (11th Cir. 1987)); Union Pac. R.R. Co. v. Loram Maint. +of Way, Inc., 2006 WL 8459287, at *4 (D. Utah Feb. 1, 2006) (waiver based on "relevance").® +What is more, the reasonableness of JPMC's settlement-assessed according to an +"objective standard," Deutsche Bank, 43 A.D.3d at 65- can (and will) be demonstrated in multiple +ways without resorting to privileged communications.? First, this Court will be asked, in the +context of its Fed. R. Civ. P. 23(e)(2) inquiry, to assess the settlement's "reasonableness." Second, +JPMC will present non-privileged evidence of that reasonableness. Mr. Staley will have the +opportunity to depose any expert that JPMC might use for that purpose, and he has also been +granted leave to take a 30(b)(6) deposition on the topic. Third, if he chooses, Mr. Staley can +challenge the settlement's reasonableness using the relevant, non-privileged materials at his +disposal: documents produced in discovery that bear on JPMC's potential liability and legal filings +6 +Meanwhile, Mr. Staley's sole case from New York, DH Holdings Corp. v. Marconi Corp. +PLC, 809 N.Y.S.2d 404 (Sup. Ct. 2005) which he relegates to a footnote, Staley Letter at 2, n.2— +has both been directly rejected by the First Department, see Deutsche Bank, 43 A.D.3d at 62 +(reversing the trial court which "follow[ed] DH Holdings"), and draws its rule of decision +indirectly from Hearn, see DH Holdings, 809 N. Y.S.2d at 406 (quoting Arkwright Mut. Ins. Co. v. +Nat 'l Union Fire Ins. Co., 1994 WL 510043, at *11 (S.D.N.Y. 1994) (quoting Hearn)). +"[C]ase law frequently ends the inquiry into 'at issue' waiver once it is established that the +party does not intend to use such materials as proof." Windsor Sec., LLC v. Arent Fox LLP, 273 +F. Supp. 3d 512, 519-20 (S.D.N.Y. 2017); see also Bovis Lend Lease, LMB, Inc. v. Seasons +Contracting Corp, 2002 WL 31729693, at *17 (S.D.N.Y. Dec. 5, 2002) ("Generally, where a party +does not itself place in issue the matter as to which the privileged communications are relevant, +the privilege is not waived."). + + +Case 1:22-cv-10904-JSR Document 250 Filed 07/31/23 Page 4 of 5 +Page 4 +WILMERHALE +from the Doe case. Nomura, 62 A.D.3d at 582 ("No reason appears why the reasonableness of the +settlement cannot be determined with the copious materials that defendant has already received +...."); Deutsche Bank, 43 A.D.3d at 65 (*[NJon-privileged material [from the other case] provides +a more-than-ample basis ….. to litigate the reasonableness of [a party's] decision to settle ...."). +When presented with these materials, this Court is no doubt equipped to assess both legal risk and +reasonableness (or aid a jury in doing so). +Mr. Staley's second argument that this material is placed "at issue" because JPMC "must +also prove that Staley "caused' the potential liability," Staley Letter at 2-fares no better. JPMC +has no intention of relying on its own privileged communications about settlement to establish this +causal connection, because JPMC does not allege Mr. Staley "caused" potential liability through +any conduct in 2023 (when these communications occurred). Instead, as JPMC has contended in +both its Third-Party Complaint, Dkt 59, and its Opposition to Mr. Staley's Motion to Dismiss, Dkt. +121, JPMC's claims are based on Mr. Staley's conduct at the time he was a JPMC employee. +JPMC has alleged—and will prove at trial that Mr. Staley caused any potential liability the bank +faced or faces because his actions (i.e., advocating for retaining Mr. Epstein as a client and +vouching for Mr. Epstein's character, without revealing the true nature of his relationship with +Epstein and his alleged involvement in Epstein's wrongdoing, in response to efforts by other bank +employees to terminate the relationship) were a "direct and proximate cause of JPMC's decision +to continue to do business with Epstein until 2013." Dkt. 59, 1140, 41; see also Dkt. 121 at 13. In +sum, JPMC's proof regarding the manner in which Mr. Staley "caused" potential liability is wholly +distinct (and over a decade removed) from its privileged communications about settlement. +As before, the cases Mr. Staley cites do not aid his argument. He again cites Scotstoun +Shipping Co., but, as above, the "relevance" rule applied there has been rejected in New York. It +might be that Mr. Staley would like to put forward a defense theory that JPMC settled due to +"concerns about negative publicity and regulatory risk" as opposed to because of the liability +exposure caused by Mr. Staley. Staley Letter at 2. But a possible defense Mr. Staley might raise +cannot work a waiver. See Leviton Mfg. Co., Inc., 2010 WL 4983183, at *4 ("Simply because +those communications might be useful in undermining [plaintiff's claim] does not mean that the +attorney-client privilege has been impliedly waived."); Gardner v. Major Auto Cos., 2014 WL +1330961, at *7 (E.D.N.Y. Mar. 31, 2014). The other case Mr. Staley cites— In re Namenda Direct +Purchaser Antitrust Litig., 2017 WL 2226591, at *5 (S.D.N.Y. May 19, 2017) supports JPMC. +n that case, which involved allegations of anticompetitive conduct by a patentholder defendant il +ettling multiple lawsuits (that had argued invalidity), the defendant alleged the settlements wer +lawful compromises. Id. at *1-2. There, unlike here, the party's own allegations involved "factual +assertions" about its "subjective beliefs" regarding settlement. Id. at *4-5. Yet, still, the Court did +not find waiver due to the possibility that even "subjective beliefs" about the rationale for +settlement might be shown through nonprivileged evidence. Id. at *5. Here, JPMC has not alleged +any subjective beliets in support of the idea that Mr. Staley caused the damages it seeks. That +causal question can be determined entirely based on nonprivileged documentary and testimonial +evidence related to Mr. Staley's tenure at the bank. +For the foregoing reasons, Mr. Staley's requested relief should be denied. + + +Case 1:22-cv-10904-JSR Document 250 Filed 07/31/23 Page 5 of 5 +Page 5 +Sincerely, +Is/ Felicia H. Ellsworth +Felicia H. Ellsworth +WILMERHALE \ No newline at end of file diff --git a/vision-fixhub/court-05/5f8b6d1787fc2fc7bf4cb8bf35ff016751a3687460721850933595e12f479c09.receipt.json b/vision-fixhub/court-05/5f8b6d1787fc2fc7bf4cb8bf35ff016751a3687460721850933595e12f479c09.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..28a4c3d76607c6ffd1119fe7cff91eb8d87b891b --- /dev/null +++ b/vision-fixhub/court-05/5f8b6d1787fc2fc7bf4cb8bf35ff016751a3687460721850933595e12f479c09.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -228, + "dataset": "marble-joined", + "doc_id": "5f8b6d1787fc2fc7bf4cb8bf35ff016751a3687460721850933595e12f479c09", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "5ff4f8713a2f1bda5c5e3a46fd5cb1431f9e2a9648999e319ee8c31a63bbcd3a", + "output_sha256": 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b/vision-fixhub/court-05/5fc31425faaa763d5e572eb59ccaed425d2a2f4741cead95d668effab85f96b9.md new file mode 100644 index 0000000000000000000000000000000000000000..f9f6f7f295209fc23f33ba12e980e84538a77119 --- /dev/null +++ b/vision-fixhub/court-05/5fc31425faaa763d5e572eb59ccaed425d2a2f4741cead95d668effab85f96b9.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 311-48 Filed 08/25/23 Page 1 of 1 + +Filed Under Seal diff --git a/vision-fixhub/court-05/5fc31425faaa763d5e572eb59ccaed425d2a2f4741cead95d668effab85f96b9.receipt.json b/vision-fixhub/court-05/5fc31425faaa763d5e572eb59ccaed425d2a2f4741cead95d668effab85f96b9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d59bd95a5687775a7471e6ed396a458791080c38 --- /dev/null +++ b/vision-fixhub/court-05/5fc31425faaa763d5e572eb59ccaed425d2a2f4741cead95d668effab85f96b9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "5fc31425faaa763d5e572eb59ccaed425d2a2f4741cead95d668effab85f96b9", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "d9200a8e4b20bae09a043eaa7a4ec5faa11c4cb828f9bf27bbf04283b82c09fe", + "output_sha256": "8fae88532477c0c2c48874389590e1ed7ed43a6ab135392af4186172136c1ad1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5fc39b87ac25e5841437f54c79080ca728d0d4f545d39464e0677a8dc99a128b.md b/vision-fixhub/court-05/5fc39b87ac25e5841437f54c79080ca728d0d4f545d39464e0677a8dc99a128b.md new file mode 100644 index 0000000000000000000000000000000000000000..e1a9d292c69e86ed6b3f20926758cb214eb272bf --- /dev/null +++ b/vision-fixhub/court-05/5fc39b87ac25e5841437f54c79080ca728d0d4f545d39464e0677a8dc99a128b.md @@ -0,0 +1,63 @@ +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +Case No. 1:22-cv-10904-JSR +v. +JPMORGAN CHASE BANK, N.A., +Defendant. +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +NOTICE OF MOTION TO COMPEL DISCOVERY RESPONSES +CONCERNING TEMPORAL SCOPE AND DOCUMENT CUSTODIAN +Pursuant to Rule 37 of the Federal Rules of Civil Procedure, Plaintiff, the Government of +the United States Virgin Islands ("Government"), respectfully moves for an Order compelling +Defendant JPMorgan Chase Bank, N.A. ("JPMorgan") to provide discovery responses covering +the full temporal scope of the Government's claims through 2019 and documents for custodian +James Dimon. The reasons in support of the Government's motion are set forth in the +Memorandum of Law filed herewith. As directed in this Court's February 23, 2023 email +confirming decisions on the parties' discovery applications made during the February 22, 2023 +telephone call with the Court, the Government's motion and supporting Memorandum of Law are +submitted before "5:00 PM today." Pursuant to the same email, JPMorgan's opposition is due by +5:00 PM on February 28, 2023, and there will be no reply and no oral argument. Id. + + +Casese 1:224 101896453R Bouument 57 Filed 302923723 79age 2107 2 +Dated: February 23, 2023 +CAROL +ESQ. +ACTING ATTORNEY GENERAL +Is/ Linda +Linda +(pro hac vice) +Mimi Liu (pro hac vice pending) +David I. Ackerman +Paige Boggs (pro hac vice) +MOTLEY RICE LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Fax: (202) 232-5513 +Isinger@motleyrice.com +mliu@motleyrice.com +dackerman@motleyrice.com +pboggs@motleyrice.com +Carol +(pro hac vice) +Acting Attorney General of the +nited States Virgin Island +irgin Islands Department of Justic +34-38 Kronprindsens Gade +St. +, U.S. Virgin Islands 00802 +Tel: (340) 774-5666 ext. 10101 +Attorneys for Plaintiff Government of the +United States Virgin Islands +3/9/23 +After considering the arguesents of +coursed for and against thes +mister, the count gront, the seation. +5O ORDERES +1907 +3-823 +2 diff --git a/vision-fixhub/court-05/5fc39b87ac25e5841437f54c79080ca728d0d4f545d39464e0677a8dc99a128b.receipt.json b/vision-fixhub/court-05/5fc39b87ac25e5841437f54c79080ca728d0d4f545d39464e0677a8dc99a128b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9191f51a7f1a18ff9cf5950b754ba84a0bff13b2 --- /dev/null +++ b/vision-fixhub/court-05/5fc39b87ac25e5841437f54c79080ca728d0d4f545d39464e0677a8dc99a128b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "5fc39b87ac25e5841437f54c79080ca728d0d4f545d39464e0677a8dc99a128b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "ef8c5efe8937006c43afd51b8865abdf15ab665a210296306b6f7ccffebee5b4", + "output_sha256": "de2e27f70ecd6cda0694f3cef2a62ed05f81cdd98a55be46a5dd0b866154c1ca", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5fc5383dc517d0c9b993ededd9f55a45290a9d382deec4091d40c64d617f5fe9.md b/vision-fixhub/court-05/5fc5383dc517d0c9b993ededd9f55a45290a9d382deec4091d40c64d617f5fe9.md new file mode 100644 index 0000000000000000000000000000000000000000..c9c22079fc1c876cd37f5280b640245434a7c428 --- /dev/null +++ b/vision-fixhub/court-05/5fc5383dc517d0c9b993ededd9f55a45290a9d382deec4091d40c64d617f5fe9.md @@ -0,0 +1,259 @@ +Case 1:22-cV-10904-JSR Document 270-17 Filed 08/07/23 Page 1 of 7 + + + +Case 1:22-cv-10904738RcoDocument 70 dontadsled: O807@3mRagedief 7 +An official website of the United States government +Here's how you know +THE UNITED STATES +DEPARTMENT & JUSTICE +000 - CONFIDENTIALITY AND MEDIA CONTACTS POLICY +1-7.001 +1-7.100 +1-7.110 +1-7.120 +1-7.200 +1-7.210 +1-7.300 +1-7.310 +1-7.400 +1-7.410 +1-7.500 +1-7.510 +1-7.600 +1-7.610 +1-7.700 +1-7.710 +1-7.800 +1-7.900 +Purpose +General Need for Confidentiality +Unathorized Disclosures of Classified Information +Whistleblower Protections +Designation of Media Representative +Reporting Media Contacts +Department of Justice Components +United States Attorneys +Disclosure of Information Concerning Ongoing Criminal, Civil, or Administrative Investigations +Comments on Requests for Investigations +Release of Information in Criminal, Civil, and Administrative Matters-Disclosable Information +Disclosure of Information Concerning Person's Prior Criminal Record +Release of Information in Criminal, Civil, and Administrative Matters-Non-Disclosure +Concerns of Prejudice +Guidance for Media Contacts +Assisting the News Media +Freedom of Information (FOIA) +Office of the Inspector General +1-7.001 - Purpose +The Department of Justice (DOJ) Confidentiality and Media Contacts Policy (the Policy) applies to all DOJ personnel, +including employees, contractors, detailees, and task force partners. +The Policy governs the protection and release of information that DOJ personnel obtain in the course of their work, and +it balances four primary interests: (1) an individual's right to a fair trial or adjudicative proceeding; (2) an individual's +interest in privacy; (3) the government's ability to administer justice and promote public safety; and (4) the right of the +public to have access to information about the Department of Justice. +The Policy provides internal guidance only and does not create any rights enforceable in law or otherwise. DOJ +components may promulgate more specific policies, consistent with and subject to this Policy. +[updated April 2018] +1-7.100 - General Need for Confidentiality +Much of DOJ's work involves non-public, sensitive matters. Disseminating non-public, sensitive information about DOJ +matters could violate federal laws, employee non-disclosure agreements, and individual privacy rights; put a witness or +law enforcement officer in danger; jeopardize an investigation or case; prejudice the rights of a defendant; or unfairly +damage the reputation of a person. +1/6 + + +Case 1:22-cv-10904738RcoDocument 970 dotadled 0907@3mRage.Bief 7 +DOJ personnel should presume that non-public, sensitive information obtained in connection with work is protected +from disclosure, except as needed to fulfill official duties of DOJ personnel, and as allowed by court order, statutory or +regulatory prescription, or case law and rules governing criminal and civil discovery. Other than as necessary to fulfill +DOJ official duties, disclosure of such information to anyone, including to family members, friends, or even colleagues, +is prohibited and could lead to disciplinary action. Unauthorized disclosures of sensitive personal or proprietary +information could lead to criminal prosecution or administrative action. +[updated April 2018] +1.7.110 - Unauthorized Disclosures of Classified Information +Only DOJ personnel with the appropriate security clearance and a specific need to know should have access to +classified information. Those with access must take every precaution to ensure that such information is safeguarded. +It is against the law to disclose classified information to someone not authorized to receive it. Deliberate unauthorized +disclosures of classified information, which can endanger national security and undermine DOJ's law enforcement and +intelligence work, will be prosecuted to the fullest extent of the law. DOJ will also pursue all available administrative +remedies, including revocation of a security clearance or disciplinary action up to termination of employment. +[updated April 2018] +1-7.120 - Whistleblower Protections +DOJ personnel may report to their management or to the Office of the Inspector General (OIG) any concerns they have +with government policies or actions. It is illegal under 5 U.S.C. § 2302 for a Department employee to "take or fail to +take, or to threaten to take or fail to take," a personnel action against a Department employee or applicant in reprisal for +making a protected disclosure involving (1) any violation of any law, rule or regulation, (2) gross mismanagement, (3) a +gross waste of funds, (4) an abuse of authority, or (5) a substantial danger to public health or safety, or for cooperating +with or disclosing information to the OIG or the U.S. Office of Special Counsel. +Nothing in this Policy is intended to conflict with or limit whistleblower protections, such as those provided in 5 U.S.C. +§§ 2302-2303 and applicable regulations. Rather, the provisions of this Policy "are consistent with and do not +supersede, conflict with, or otherwise alter the employee obligations, rights, or liabilities created by existing statute or +Executive order relating to (1) classified information, (2) communications to Congress, (3) the reporting to an Inspector +General of a violation of any law, rule, or regulation, or mismanagement, a gross waste of funds, an abuse of authority, +or a substantial and specific danger to public health or safety, or (4) any other whistleblower protection. The definitions, +requirements, obligations, rights, sanctions, and liabilities created by controlling Executive orders and statutory +provisions are incorporated into this [Policy] and are controlling." 5 U.S.C. § 2302(b)(13). +For more information on whistleblower rights and protections, see the Whistleblower Protection page on OIG's website +at https://oig.justice.gov/hotline/whistleblower-protection.htm. +[updated April 2018] +1-7.200 - Designation of Media Representative +Each United States Attorney's Office and DOJ component field office shall designate at least one person to act as a +point of contact on matters pertaining to the media. The DOJ Office of Public Affairs (OPA) shall designate a media +point of contact for Main Justice components. +[updated April 2018] +1-7.210 - Reporting Media Contacts +2/6 + + +Case 1:22-cv-10904738RcoDooument 070+ dontadsiled: 08K07@3rmRageudief 7 +DOJ personnel must report to their designated media representative any contact with a member of the media about a +DOJ matter. DOJ components may, as they deem appropriate, exclude from this requirement the ministerial +confirmation of matters of public record, such as the spelling of a charged defendant's name or the date of the next +court hearing. If the contact concerns suspected classified or grand jury subject matter, DOJ personnel must +immediately notify a supervisor. +[updated April 2018] +1-7.300 - Department of Justice Components +Public affairs officers at the headquarters level of DOJ components are responsible for coordinating news media +contacts with the Director of OPA. +[updated April 2018] +1-7.310 - United States Attorneys +Each of the 93 United States Attorneys will exercise discretion and sound judgment, consistent with this Policy, as to +matters affecting their own district, but must coordinate their news media contacts with OPA in cases that transcend +their district or are of national importance. The United States Attorney has responsibility for all matters involving the +local media. +[updated April 2018] +1-7.400 - Disclosure of Information Concerning Ongoing Criminal, Civil, or Administrative +Investigations +A. Any communication by DOJ personnel with a member of the media relating to a pending investigation or case +must be approved in advance by the appropriate United States Attorney or Assistant Attorney General, except in +emergency circumstances. For administrative investigations not overseen by a U.S. Attorney or Assistant +Attorney General, approval must be obtained from the Assistant Attorney General for Administration. Where the +investigation is being handled by the Office of the Inspector General, approval must come from the Inspector +General. +B. DOJ generally will not confirm the existence of or otherwise comment about ongoing investigations. Except as +provided in subparagraph C of this section, DOJ personnel shall not respond to questions about the existence of +an ongoing investigation or comment on its nature or progress before charges are publicly filed. +C. When the community needs to be reassured that the appropriate law enforcement agency is investigating a +matter, or where release of information is necessary to protect the public safety, comments about or confirmation +of an ongoing investigation may be necessary, subject to the approval requirement in subparagraph A. +[updated April 2018] +1-7.410 - Comments on Requests for Investigations +Individuals, groups, and organizations occasionally send letters requesting that a person or entity be investigated for +violations of law. Sometimes, the requestor then publicizes the request. +Receipt of a request to open an investigation may be publicly acknowledged, but care should be taken to avoid implying +that the referral will lead to an investigation. There is a distinction between reviewing a request and opening an +investigation. +3/6 + + +Case 1:22-cv-10904738RcoDocument 070 dontadsed: D8K07@3rtmRage Sif 7 +Any acknowledgment, which must be approved by the appropriate United States Attorney or Assistant Attorney +General, should state that such requests are referred to the proper investigative agency for review, that all allegations +are reviewed in light of the Principles of Federal Prosecution (see JM 9-27.000), and that DOJ ordinarily does not +confirm or deny the existence of an investigation. +The same considerations apply if there is an investigation already underway. +[updated April 2018] +1-7.500 - Release of Information in Criminal, Civil, and Administrative Matters-Disclosable +Information +Subject to limitations imposed by law or court rule or order, and consistent with the provisions of this Policy, DOJ +personnel may make public the following information in any criminal case in which charges have been brought: +A. The defendant's name, age, residence, employment, marital status, and similar background information; +B. The substance of the charge, as contained in the complaint, indictment, information, or other public documents; +C. The identity of the investigating or arresting agency and the length and scope of the investigation; and +D. The circumstances immediately surrounding an arrest, including the time and place of arrest, resistance, pursuit, +possession and use of weapons, and a description of physical items seized during the arrest. +A news release issued before a finding of guilt should state that the charge is merely an accusation, and the +defendant is presumed innocent until proven guilty. +In civil and administrative cases, subject to limitations imposed by law or court rule or order, and consistent with +the provisions of this Policy, DOJ personnel may release similar identification material regarding parties and the +concerned government agency or program, along with a summary of the claim and an explanation of the +government's interest. +The public policy significance of a case may be discussed by the appropriate United States Attorney or Assistant +Attorney General when doing so would further law enforcement goals. +[updated April 2018] +1-7.510 - Disclosure of Information Concerning Person's Prior Criminal Record +During an investigation or before trial, DOJ personnel generally may not provide to the media any information +concerning a person's prior criminal record. When a prior conviction is an element of the current charge, such as in the +case of a felon in possession of a firearm, DOJ personnel may confirm the identity of the defendant and the general +nature of the prior charge if such information is part of the public record in the case. +[updated April 2018] +1-7.600 - Release of Information in Criminal,Civil, and Administrative Matters-Non-Disclosure +DOJ personnel shall not make any statement or disclose any information that reasonably could have a substantial +likelihood of materially prejudicing an adjudicative proceeding. +[updated April 2018] +4/6 + + +Case 1:22-cv-10904738RcoDocument 070 dontadsled: 08K07@3mRage Gief 7 +1-7.610 - Concerns of Prejudice +Because the release of certain types of information could prejudice an adjudicative proceeding, DOJ personnel should +refrain from disclosing the following, except as appropriate in the proceeding or in an announcement after a finding of +guilt: +A. Observations about a defendant's or party's character; +B. Statements, admissions, confessions, or alibis attributable to a defendant or party, or the refusal or failure of the +accused to make a statement; +C. Reference to investigative procedures, such as fingerprints, polygraph examinations, ballistic tests, or forensic +services, including DNA testing, or to the refusal by the defendant to submit to such tests or examinations; +D. Statements concerning the identity, testimony, or credibility of prospective witnesses; +E. Statements concerning anticipated evidence or argument in the case; and +F. Any opinion as to the defendant's guilt, or the possibility of a plea of guilty to the offense charged, or the +possibility of a plea to a lesser offense. +DOJ personnel should not encourage or assist news media in photographing or televising a person held in +custody. DOJ personnel should not voluntarily disclose a photograph of a defendant unless it serves a law +enforcement function or unless the photograph is already part of the public record in the case. +[updated April 2018] +1-7.700 - Guidance for Media Contacts +A. Press conferences should be held only for significant newsworthy actions, or if an important law enforcement +purpose would be served. Before holding a press conference or making comments on a pending investigation +regarding another DOJ component, the U.S. Attorney or Assistant Attorney General shall coordinate any +comments, including written statements, with the affected component. +B. There are circumstances when media contact may be appropriate after indictment or other formal charge, but +before conviction. In such cases, communications with the media should be limited to the information contained +in publicly available material, such as an indictment or other public pleadings. +C. DOJ personnel must avoid making public statements that violate DOJ guidelines, regulations, or legal +requirements, including those imposed by case law, applicable bar policies, and local court rules. +D. In juvenile proceedings, special rules apply and should be followed to ensure that the identity of a minor is not +revealed. See JM 9-8.000, et al. +E. In cases where the IRS has provided information to DOJ, care should be taken to comply with applicable +statutory disclosure provisions, including 26 U.S.C. § 6103. When communicating with the media, DOJ +personnel should attribute the immediate sourcing of information to the public record of the judicial proceeding. +No information should be provided from IRS materials, even if those materials are located in DOJ files. +F. In clemency matters, DOJ acts both as prosecutor and as advisor to the President. Any communications +concerning clemency should be approved by OPA and the Deputy Attorney General to ensure that there is no +infringement upon the President's prerogative in exercising his clemency powers. +5/6 + + +Case 1:22-cv-10904738RcoDocument 070 dontadsed: 08K07@3rtmRageustief 7 +[updated April 2018] +1-7.710 - Assisting the News Media +A. DOJ personnel shall not prevent lawful efforts by the news media to record or report about a matter, unless by +reason of a court order. DOJ personnel may enforce access restrictions that apply to all persons, such as a +crime scene perimeter. +B. In order to promote the aims of law enforcement, including the deterrence of criminal conduct and the +enhancement of public confidence, DOJ personnel, with the prior approval of the appropriate United States +Attorney or Assistant Attorney General, may assist the news media in recording or reporting on a law +enforcement activity. The United States Attorney or Assistant Attorney General shall consider, among other +things, whether such assistance would: +1. Unreasonably endanger any individual; +2. Prejudice the rights of any person; or +3. Be otherwise proscribed by law. +C. In cases where a search warrant or arrest warrant is to be executed, no advance information will be provided to +the news media without the express approval of the appropriate United States Attorney or Assistant Attorney +General. This requirement also applies to operations in preparation for the execution of a warrant. +[updated April 2018] +1-7.800 - Freedom of Information (FOIA) +Nothing contained in this Policy is intended to control access to DOJ records under the Freedom of Information Act +(FOIA). +[updated April 2018] +1-7.900 - Office of the Inspector General +A. Consistent with the independence of its operations under the Inspector General Act of 1978, OIG is exempt from +the requirements of this Chapter regarding media contacts and approvals. OIG should, however, timely inform +the Attorney General, or the Deputy Attorney General upon delegation, about any significant media issues in +matters handled by OIG. +[updated April 2018] +‹ 1-6.000 - DOJ Personnel As Witnesses +UR +1-8.000 - Congressional and +House Relations › +6/6 \ No newline at end of file diff --git a/vision-fixhub/court-05/5fc5383dc517d0c9b993ededd9f55a45290a9d382deec4091d40c64d617f5fe9.receipt.json b/vision-fixhub/court-05/5fc5383dc517d0c9b993ededd9f55a45290a9d382deec4091d40c64d617f5fe9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..226c78a4267a6093f69f201928a0005d798f9d75 --- /dev/null +++ b/vision-fixhub/court-05/5fc5383dc517d0c9b993ededd9f55a45290a9d382deec4091d40c64d617f5fe9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -557, + "dataset": "marble-joined", + "doc_id": "5fc5383dc517d0c9b993ededd9f55a45290a9d382deec4091d40c64d617f5fe9", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "342b751c7b6cfc797c6ec96acd563baa02641ff439cf387254d78223ba3bfeaa", + "output_sha256": "c71f302fd1e3a2eb1a9eb466ee9749b76022e5432d2790646f17a5906abf7f8b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5fc781403be37273fe16de65235d4e18208ca53c3834c2d3adc4d606be1439e0.md b/vision-fixhub/court-05/5fc781403be37273fe16de65235d4e18208ca53c3834c2d3adc4d606be1439e0.md new file mode 100644 index 0000000000000000000000000000000000000000..d531c68e6b17ce2bebe746eb3d1f4ec22bf018a8 --- /dev/null +++ b/vision-fixhub/court-05/5fc781403be37273fe16de65235d4e18208ca53c3834c2d3adc4d606be1439e0.md @@ -0,0 +1,63 @@ +Case 1:22-cV-10904-JSR Document 186-65 Filed 06/14/23 Page 1 of 3 + + + +Case 1:22-cV-10904-JSR Document 186-65 Filed 06/14/23 Page 2 of 3 +Date: +Tuesday. June 22 2010 02:36 PM +Subject: Re: +From: +Jeffrey Epstein +To: +Cecile de Jongh < +@yahoo.com>: +thanks,, where and when would john like to meet. ? +On Tue, Jun 22, 2010 at 10:33 AM, Cecile de Jongh - +@yahoo.com > wrote: +I spoke to Kenn. He does not know who Mr. Carpenter is but the head of customs is Mr. Louis +Harrigan. Kenn will call Harrigan to find out who Carpenter is. He will discuss with you on Thursday. +DISCLAIMER: The information contained in this e-mail may be privileged, confidential, and protected from disclosure. If you +are not the intended recipient, you are hereby notified that any dissemination, distribution or duplication of this communication +is strictly prohibited. If you have received this communication in error, please notify the sender immediately and delete all +copies. +From: Jeffrey Epstein +To: Cecile de Jongh < +@yahoo.com> +Sent: Tue, June 22, 2010 9:20:07 AM +Subject: +who is charge of customs in the v.i.. I used to have a great relationship with gloria Lambert the airport +supervisor. I would like to know who is now in her place, or her boss. woudl ken hobson know. ? there is a +mr carpenter ,who has been difficult lately, not sure why? +******** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation/@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. +Ф •Ф•**•••************************************************** +The information contained in this communication is + +ESTATE_JPM024879 + + +Case 1:22-cV-10904-JSR Document 186-65 Filed 06/14/23 Page 3 of 3 +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. + +ESTATE_JPMO24880 diff --git a/vision-fixhub/court-05/5fc781403be37273fe16de65235d4e18208ca53c3834c2d3adc4d606be1439e0.receipt.json b/vision-fixhub/court-05/5fc781403be37273fe16de65235d4e18208ca53c3834c2d3adc4d606be1439e0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..18600eefeb2fde3db2e6c022d976e56f16fe057c --- /dev/null +++ b/vision-fixhub/court-05/5fc781403be37273fe16de65235d4e18208ca53c3834c2d3adc4d606be1439e0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -71, + "dataset": "marble-joined", + "doc_id": "5fc781403be37273fe16de65235d4e18208ca53c3834c2d3adc4d606be1439e0", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "22eefd94a4597fa18aa83685276f3fb97f1793fb38a94e0ac7c59902f8bc3a56", + "output_sha256": "2deca70b5d194fdcabfa1e9734da8205fa10b034132fa20b513b9c9ad5acd79b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5fd2c71981216d34034758199e41b596d5f4f1e5994f820d89ae1ea36b7d214d.md b/vision-fixhub/court-05/5fd2c71981216d34034758199e41b596d5f4f1e5994f820d89ae1ea36b7d214d.md new file mode 100644 index 0000000000000000000000000000000000000000..1fed0de7ba63903cb1248e664c515ccd65fd34f1 --- /dev/null +++ b/vision-fixhub/court-05/5fd2c71981216d34034758199e41b596d5f4f1e5994f820d89ae1ea36b7d214d.md @@ -0,0 +1,5346 @@ +Case 1:22-cv-10904-JSR Document 311-67 Filed 08/25/23 Page 1 of 181 + + + +Cafete22-28-4090805BSBoDocenteßt 167 Fift0382223 PAgga Bfof 481 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Case No. 22-cv-10904-JSR +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A., +Defendant/Third-Party Plaintiff. +JURY TRIAL DEMANDED +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +JAMES EDWARD STALEY, +Third-Party Defendant. +JPMORGAN CHASE BANK, N.A.'S THIRD-PARTY COMPLAINT +AGAINST JAMES EDWARD STALEY +Pursuant to Federal Rule of Civil Procedure 14(a), Defendant JPMorgan Chase Bank, +N.A. ("JPMC"), by its undersigned counsel, files this Third-Party Complaint against Third-Party +Defendant James Edward "Jes" Staley ("Staley") for indemnity, contribution, breach of fiduciary +duty, and breach of the faithless servant doctrine. In support, JPMC alleges as follows: +PRELIMINARY STATEMENT +On December 27, 2022, Plaintiff the Government of the United States Virgin Is- +lands ("the USVI") filed this action entitled Government of the United States Virgin Islands v. JP + + +Castle22-28-4090805BSBoDocenteßt 167 Fift 0382223 PAge 3fof 481 +Chase Bank, N.A., Case No. 22-cv-10904-JSR (S.D.N.Y.). The USVI filed a First +Amended Complaint on January 10, 2023 ("USVI Complaint"). Dkt. 17 (attached as Ex. A). JPMC +moved to dismiss that complaint (Dkt. 39) and has not yet filed an answer. +2. This Court consolidated this case for pretrial purposes with a case brought against +JPMC by Jane Doe 1 ("Doe") on behalf of herself and others, Doe v. JPMorgan Chase Bank, N.A., +22-cv-10019-JSR (S.D.N.Y.). Doe filed a First Amended Complaint on January 13, 2023 ("Doe +Complaint") (attached as Ex. B). JPMC has moved to dismiss that complaint and has not yet filed +an answer. +This Third-Party Complaint references unproven allegations in the Doe Complaint +and the USVI Complaint. To be clear, JPMC does not admit those allegations, denies all liability, +and disputes both Doe's and the USVI's right to recover under the law from JPMC. Rather, if +JPMC is responsible for any damages to Doe, it is entitled to recover the entire amount of any +damages from Staley as indemnification or a percentage of those damages in contribution. JPMC +also brings independent claims against Staley for breach of fiduciary duty and violation of the +faithless servant doctrine. +PARTIES +JPMC is a national bank whose main office is located in Columbus, Ohio, as des- +On information and belief, third-party defendant Staley is a citizen and resident of +ignated in its Articles of Association. +New York, New York. +6. +JURISDICTION +This Court has subject matter jurisdiction over JPMC's third-party claims under 28 +U.S.C. § 1367(a) because they are so related to Doe's claims that they form part of the same case +or controversy under Article III of the United States Constitution. +2 + + +Cafase22-28-4090805BSRoDoventeßt 167 Fill 0382223 PRggв Фfof481 +7. +Section 1367(b) does not divest this Court of supplemental jurisdiction because +Doe has asserted claims under federal law, and this Court has jurisdiction over those claims under +28 U.S.C. § 1331. +8. +This Court has supplemental jurisdiction over JPMC's third-party claims against +Staley because: (i) its claims do not raise novel or complex issues of state law; (ii) its claims do +not predominate over Doe's claims; and (ill) no exceptional circumstances compel this Court to +decline jurisdiction. 28 U.S.C. § 1367(c). +VENUE +Venue is proper in this district under the doctrine of ancillary venue. +10. Venue is also proper in this district as Staley is a resident of this district, and a +substantial part of the property and events that are the subject of the action are situated in this +district. +DOE'S COMPLAINT +11. +Doe seeks damages from JPMC for herself and other individuals allegedly exploited by Jeffrey Epstein ("Epstein") under New York intentional tort law, New York negligence +law, and the federal Trafficking Victims Protection Act ("TVPA"). Ex. B, 111 286 490. +12. +Doe alleges, among other things, that she was a victim of Epstein's "sex trafficking +scheme" and that "from 2006 through 2013, Epstein sexually abused Jane Doe 1 on a number of +occasions in New York, Florida, New Mexico, and the United States Virgin Islands." Id., 19 94- +99. +13. +JPMC denies Doe's tort allegations that it: knew of or committed some overt act in +furtherance of Epstein or others battering Doe; acted intentionally to cause Doe emotional distress; +caused her injuries; or had a duty to her to protect her from Epstein's acts. JPMC also denies Doe's +3 + + +Cafase22-28-4090805BSRoDoventeßt 167 Fifel0382223 PAgge 5fof481 +TVPA allegations that it: "perpetrate[d]" sex trafficking; "participate[d]" in an Epstein sex-trafficking venture; "knowingly" received benefits from any alleged participation; or knew that an +Epstein venture trafficked Doe. JPMC also denies that: it aided or abetted any alleged acts unlawful +under the TVPA; attempted to aid or abet or otherwise participate in the alleged sex trafficking +venture; conspired to participate or benefit from the alleged sex trafficking venture; or obstructed +any investigation into the alleged sex trafficking venture. JPMC has moved to dismiss Doe's complaint because it is without legal merit, and it will more fully detail its factual denials of Doe's +claims if it is required to answer her complaint. +THE USVI'S COMPLAINT +14. The USVI seeks damages from JPMC under four claims: (1) a claim for participating in a sex trafficking venture under the TVPA (18 U.S.C. §§ 1591(a)(2) and 1595(d)); (2) a claim +under its own civil RICO statute (14 V.I.C. §§ 604(e) and 605(a)) for participating in an enterprise +which violates the TVPA; (3) a claim under its civil RICO statute for violating the Bank Secrecy +Act (31 U.S.C. § 5322(a)); and (4) a claim under its deceptive business practices act. Ex. A, 19 92- +136. +15. +JPMC denies the USVI's allegations that it: knowingly benefited from or participated in a sex-trafficking venture; engaged in racketeering or an otherwise criminal organization; +engaged in unfair competition; or failed to abide by federal banking laws. JPMC has moved to +dismiss the USVI's complaint because it is without legal merit, and it will more fully detail its +factual denials of the USVI's claims if it is required to answer the USVI's complaint. +JAMES STALEY +16. +From 1979 to 2013, JPMC employed Staley in various positions. From 2001 to +2009, Staley was the Chief Executive Officer of JPMC's Asset Management line of business. In +4 + + +Cafete22-28-4090805BSBoDocenteßt 167 Fill 0382223 PAgg5 6f481 +2009, Staley became the Chief Executive Officer of JPMC's Corporate and Investment Banking +line of business. +17. At all times during his employment, Staley had a duty of loyalty to JPMC, and he +was required to act in good faith in JPMC's best interests. That duty required Staley to refrain from +activities that he knew would damage JPMC, either financially or reputationally, and to report to +JPMC any facts or knowledge relevant to his duties that could affect JPMC's reputation or that +was relevant to JPMC's decisions to retain a client whose business with JPMC might damage that +reputation. Instead, if the allegations of Doe and the USVI are true, Staley repeatedly abandoned +the interests of JPMC and served his own and Epstein's interests. +18. +Beginning in at least 2006 through 2012, Staley signed a written affirmation each +year entitled "Code of Conduct [year] Affirmation Record." In each of those affirmations, Staley +pledged: "I agree, as a condition of employment, to remain in compliance with the Code and the +supplemental policies that apply to me, all as amended from time to time." +19. +Each version of the JPMC Code of Conduct in effect from 2006 through 2012 emphasized that all JPMC employees must "conduct the firm's business in accordance with the highest ethical standards, respecting the firm's customers, suppliers, and other business counterparties, +dealing responsibly with the firm's assets, and complying with applicable legal and regulatory +requirements." +20. +JPMC's Code of Conduct also expressly prohibited, among other things, engaging +in outside activities that, even if outside the scope of employment, "reflect adversely on JPMorgan +Chase or give rise to a real or apparent conflict of interest with your duties to the firm." +21. +Upon his departure from JPMC in 2013, Staley executed an Agreement and Release +with JPMC in which he agreed to continue to be bound by the JPMC's Code of Conduct and also +5 + + +Castle22-28-4090805RSRoDocenteßt 167 Fift 0382223 PAge 6 bfof481 +affirmed that he had advised the Company of all facts of which he was aware that he believed may +constitute a violation of the Company's Code of Conduct and/or the Company's legal obligations. +DOE'S ALLEGATIONS +22. +Doe alleges that "Staley knew without any doubt that Epstein was trafficking and +abusing girls" and that "all of [Epstein's] staff, including his main attorney and accountant, worked +full time to conceal the illegal operation." Ex. A, 1| 128. +23. +Doe repeatedly alleges in her complaint that JPMC knew of or participated in Ep- +sex trafficking venture "through Staley." See, e.g., id., 9 200 ("Not only was JP +(through Staley) well aware of the allegations, but JP +(through Staley) knew the identities +of co-conspirators and many of the victims."); see also id., 11 135, 164, 205-206, 230-231, 239, +327-328, 360. +24. +Doe also alleges, "Staley had observed victims personally, and he was aware that +Epstein was shelling out millions of dollars to attorneys to take on these well-founded allegations." +Id., 9200. +25. +Doe alleges that Staley "personally observed Doe as a sex trafficking and abuse +victim at times including through his departure from JP +in 2013." Id., 9115. +26. +Doe further alleges that Staley "personally spent time with young girls whom he +met through Epstein on several occasions"; "personally visited young girls at Epstein's apartments +located at 301 East 66th Street"; "personally observed Epstein around young girls"; and personally +observed, "Epstein sexually grab young women in front of him." Id., 9| 227; see also id., 9 226. +27. +Doe alleges that "one of Epstein's friends used aggressive force in his sexual assault +of her and informed Jane Doe 1 that he had Epstein's permission to do what he wanted to her." Id., +6 + + +Castle22-28-4090805RSRoDocenteßt 167 Fill 0382223 PAgge 8f481 +9 107. Upon information and belief, Staley is this person, who she described as a "powerful financial executive" she had historically been afraid to identify. +28. +Doe also alleges that Staley promised to "use his clout within JP | +to make +Epstein untouchable." Id., 9 132. She claims that despite his alleged knowledge of the sex trafficking scheme, Staley repeatedly thwarted JPMC's efforts to sever ties with Epstein. Id., 11 184, 188. +THE USVI'S ALLEGATIONS +29. +The USVI alleges that between 2008 and 2012, Staley had "a close personal relationship and 'profound' friendship" with Epstein, and that their correspondence "even suggest[s] +that Staley may have been involved in Epstein's sex-trafficking operation." Ex. A, 9 53. +30. +Further, the USVI alleges that Staley visited Epstein's residence in Palm Beach in +January 2009 and that this visit corresponded with Epstein wiring $2,000 to a woman with an +Eastern European surname. Id., 1| 54. +31. +In addition, the USVI alleges after Staley emailed Epstein in late August 2009 that +he would be in London a week later, Epstein asked whether Staley would need anything during +his visit, and Staley replied, "Yep." Id., 1 55. According to the USVI, on August 31, 2009, Epstein +wired $3,000 to the same Eastern European woman. Id. +32. +The USVI alleges that on July 10, 2010, Staley emailed Epstein, "Maybe they're +tracking u?? That was fun. Say hi to Snow +" Epstein responded, "what character would you +like next." Staley replied, "Beauty and the Beast....." Epstein responded, "well one side is available." Ex. A, 961. +33. +In its First Amended Complaint, the USVI alleges that Staley had knowledge of +Epstein's sex trafficking venture, as well as a role in convincing JPMC to maintain Epstein as a +JPMC client. See, e.g., id., 19 47, 52-63, 71-73. + + +Castle22-28-4090805BSBoDocenteßt 167 Fift0382223 PAgg 8 9fof481 +STALEY CONCEALED HIS PERSONAL ACTIVITIES WITH EPSTEIN AND HIS +CONFLICT OF INTEREST WITH JPMC +34. +While JPMC held discussions regarding Epstein, Staley was apparently in regular +contact with Epstein. However, Staley never disclosed to anyone at JPMC that he had witnessed, +was aware of, or participated in any of the activities described in paragraphs 22 through 33. +35. +In 2013, JPMC "terminated its relationship with Epstein." Ex. A, 9| 50. +36. +At no point did Staley disclose to JPMC, nor did JPMC otherwise know, the information about Staley's personal activities contained in paragraphs 22 through 33. +37. +Staley did not disclose this information despite having a fiduciary duty to do so and +JPMC asking him to offer his views as to whether JPMC should retain Epstein as a client. +38. +Even upon his departure from JPMC, and in spite of his explicit affirmation that he +had reported to JPMC any violations of the Code of Conduct, Staley did not disclose to JPMC the +information about his personal activities contained in paragraphs 22 through 33. +39. +Instead, Staley repeatedly abandoned the interests of JPMC in pursuit of his own +personal interests and benefits and those of Epstein. +40. +Staley's failure to disclose the information alleged— although JPMC does not admit +that Doe's and the USVI's allegations are true-was a direct and proximate cause of JPMC's decision to continue to do business with Epstein until 2013. +41. +In addition, Staley's abandonment of the interests of JPMC in favor of his own +personal interests and benefits and those of Epstein was a direct and proximate cause of JPMC's +decision to continue to do business with Epstein until 2013. +42. +Accordingly, to the extent that Staley knew of, participated in, or witnessed sexual +abuse associated with Epstein and did not report it to, actively concealed it from, or misrepresented +his knowledge to JPMC, Staley, not JPMC, is responsible for any injuries Epstein may have caused +8 + + +Casease 2:22109D0908RSBodDov 8111767 FeeD38085283 Flagge91 4$4181 +to the USVI, even though the alleged knowledge, participation, and observations were not in connection with the performance of his duties for JPMC. +COUNT I: INDEMNIFICATION +43. +JPMC repeats and realleges paragraphs 1 through 42 hereof as if fully set forth +herein. +44. +JPMC is not liable to the USVI or any other person for any of the claims, if true, +made by the USVI in its complaint. +45. +As an employee of JPMC, Staley had a preexisting relationship with JPMC sufficient to give rise to a common-law duty to indemnify JPMC for any liability JPMC may have +based on Staley's conduct. +46. The USVI seeks to hold JPMC liable based in substantial part on the acts or omissions of Staley, whom the USVI alleges was the primary actor (along with Epstein) responsible +for its injuries. +47. +If the USVI is successful on its claims, Staley is solely liable to the USVI, or liable +to JPMC for all sums awarded to the USVI and against JPMC, if any, at trial. +48. +Should the USVI succeed on any of its claims and JPMC denies that it is liable to +the USVI —Staley is liable to JPMC by way of indemnification for all damages awarded to the +USVI, together with costs, attorneys' fees, and such other relief as the Court deems just and appropriate. +COUNT II: CONTRIBUTION +JPMC repeats and realleges paragraphs 1 through 48 hereof as if fully set forth +49. +herein. +50. +contribution. +Courts in the United States Virgin Islands have recognized a common law right to +9 + + +Cafase22-28-4090805RSRoDodemteßt 167 Fifele 0382323 Pagg4O bff 481 +51. +Contribution is also permitted under the TVPA. +52. +In its First Amended Complaint, and through the ongoing discovery process, the +USVI alleges that Staley had knowledge of Epstein's purported sex trafficking venture, as well as +a role in convincing JPMC to maintain Epstein as a JPMC client. See, e.g., Ex. A, 919 47, 52-63, +71-73. +53. +If the USVI is successful on its claims and JPMC denies that it is legally liable to +the USVI —Staley's actions caused or substantially contributed to any resulting damages. +54. +If the USVI is successful on its claims —and JPMC denies that it is legally liable to +the USVI — Staley is solely liable to the USVI, jointly and severally liable to the USVI, or liable +to JPMC for all sums awarded to the USVI and against JPMC, if any, at trial. +55. +Should the USVI succeed on any of its claims -and JPMC denies that it is legally +liable to the USVI —Staley is liable to JPMC by way of contribution for all damages awarded to +the USVI, jointly and severally, together with costs, attorneys' fees, and such other relief as the +Court deems just and appropriate. +56. +COUNT III: BREACH OF FIDUCIARY DUTY. +JPMC repeats and realleges paragraphs 1 through 55 hereof as if fully set forth +herein. +57. +Under New York law, an employee owes a fiduciary duty to their employer. That +duty requires the employee to exercise the utmost good faith and loyalty in the performance of his +duties at all times and to refrain from acting in any manner inconsistent with his agency or trust. +58. +Staley owed a fiduciary duty to JPMC. +59. +Based on the allegations of Doe and the USVI—which JPMC does not admit and +has not yet answered +-as well as the additional facts alleged herein, Staley continuously breached +10 + + +Cafase22-28-4090805RSRoDodemteßt 167 Fifele 0382323 Pagga 12f01481 +his fiduciary duty, acting against the interests of JPMC and in his own personal interests and benefits and those of Epstein. +60. +Staley breached his fiduciary duty by engaging in inappropriate conduct in his personal dealings with Epstein outside the scope of his employment that was harmful to JPMC's +reputation and that posed a conflict of interest. By failing to report to, or fraudulently concealing +from, JPMC relevant facts that he knew and actions he observed relating to Epstein, including with +respect to JPMC's evaluations of Epstein's banking relationship, Staley harmed JPMC. +61. +On the basis of the allegations of Doe and the USVI and the additional facts alleged +herein, Staley affirmatively misrepresented the true facts of his and Epstein's personal interactions +and activities to JPMC and repeatedly provided misleading information to JPMC when vouching +for Epstein's character and conduct. +62. +Staley's failure to report material facts to JPMC continued for years, from at least +2000 through his departure from JPMC in 2013, through to the filing of this complaint. +63. +Staley's breach of fiduciary duty was a direct and proximate cause of JPMC's decision to continue to do business with Epstein until 2013. +64. As a result of Staley's breach of fiduciary duty, JPMC suffered adverse publicity +from press coverage of the lawsuits from Doe and the USVI. +65. +In addition to damages for the cost of defending Doe's and the USVI's actions, in +the event JPMC has to pay any amounts in damages, Staley's breach of fiduciary duty will have +caused those losses. +66. +In light of Staley's intentional and outrageous conduct in failing to disclose pertinent information and abandoning JPMC's interests in favor of his own and Epstein's personal +interests, JPMC is entitled to punitive damages. +11 + + +Cafase22-28-4090805RSRoDodemteßt 1-67 Fifele 0382323 P8gg42 3f1481 +COUNT IV: VIOLATION OF THE FAITHLESS SERVANT DOCTRINE +67. +JPMC repeats and realleges paragraphs 1 through 66 hereof as if fully set forth +herein. +68. An employee owes a duty of utmost loyalty to his employer. +69. +An employee who is faithless in the performance of his services breaches the duty +of loyalty, and he is not entitled to receive compensation for those services. +70. +Based on the allegations of Doe and the USVI—which JPMC does not admit and +has not yet answered —as well as the additional facts alleged herein, Staley breached his duty of +loyalty and acted as a faithless servant to JPMC. +71. +On the basis of the allegations of Doe and the USVI and the additional facts alleged +herein, Staley abandoned the interests of JPMC and served his own and Epstein's interests. +72. As noted above, Staley failed to report his knowledge of and personal conduct with +Epstein to JPMC and instead consistently and misleadingly vouched for Epstein's good character +and conduct while JPMC was deliberating on whether JPMC should continue to do business with +Epstein. +73. +On the basis of the allegations of Doe and the USVI and the additional facts alleged +herein, Staley's activities constitute misconduct that rises to the level of a breach of a duty of +loyalty or good faith. +74. +Staley's activities based upon Doe's and the USVI's allegations and the additional +allegations alleged herein demonstrate that Staley substantially violated the JPMC Code of Conduct in a way that permeated his service to JPMC in material and substantial part. +75. +On the basis of the allegations of Doe and the USVI and the additional facts alleged +herein, Staley's acts of disloyalty occurred repeatedly, lasted for years, and persisted despite numerous opportunities to correct them. +12 + + +Cafase22-28-4090805RSRoDodemteßt 1-67 Fifele 0382323 Pagg43 ฿f1481 +76. Staley's acts of disloyalty also occurred in his primary area of responsibility. +77. On the basis of the allegations of Doe and the USVI and the additional facts alleged +herein, Staley persisted for years—from at least 2006 until his departure from JPMC in 2013—in +protecting Epstein in the face of attempts by JPMC to end the company's relationship with Epstein, +omitted material information, made misrepresentations in the process, and continued to do so. +78. +As a result of Staley's faithless service, JPMC is entitled to recover all compensation paid to Staley during the time period of his disloyalty. +79. +In light of Staley's intentional and outrageous conduct in failing to disclose pertinent information and abandoning JPMC's interests in favor of his own and Epstein's personal +interests, JPMC is entitled to punitive damages. +PRAYER FOR RELIEF +WHEREFORE, based on the foregoing, Defendant/Third-Party JPMC prays for judgment against Staley as follows: +1. In the event JPMC is found liable for any of the USVI's claims in this action, for indemnity against Staley for all damages awarded to the USVI; +2. In the event JPMC is found liable for any of the USVI's claims in this action, for contribution against Staley for his proportionate share of the amount awarded to the USVI; +3. For all damages caused to JPMC by Staley's breach of fiduciary duty, including any +damages awarded to the USVI or Doe and JPMC's costs of defending those actions; +4. For all compensation paid to Staley during the time period of his disloyalty, from at +least 2006 through 2013; +5. For punitive damages for Staley's breach of fiduciary duty and violation of the faithless servant doctrine; +6. For all costs and attorneys' fees associated with this third-party action; and +13 + + +Cafase22-28-4090805RSRoDodemteßt 167 Fifele0382323 Pagg445f1481 +7. For such other such relief as the Court deems just and appropriate. +DEMAND FOR JURY TRIAL +JPMC demands a trial by jury on all issues so triable pursuant to Rule 38 of the Federal +Rules of Civil Procedure. +Dated: March 8, 2023 +MASSEY & GAIL LLP +/s/ Leonard A. Gail +Leonard A. Gail (pro hac vice) +Rachel Morse (pro hac vice) +Caitlin Kovacs (pro hac vice) +50 East Washington Street, Suite 400 +Chicago, IL 60602 +(t) (312) 283-1590 +lgail@masseygail.com +rmorse@masseygail.com +ckovacs@masseygail.com +Respectfully submitted, +WILMER CUTLER PICKERING +HALE AND DORR LLP +Is/ Felicia H. Ellsworth +Felicia H. Ellsworth +John J. Butts +60 State Street +Boston, +_ 02109 +(t) (617) 526-6000 +(f) (617) 526-5000 +felicia.ellsworth@wilmerhale.com +john.butts@wilmerhale.com +M. +Robert L. Boone +Hillary Chutter-Ames +7 World Trade Center +250 Greenwich Street +New York, NY 10007 +(t) (212) 230-8800 +(f (212) 230-8888 +robert.boone@wilmerhale.com +hillary.chutter-ames@wilmerhale.com +Ronald C. Machen +2100 Pennsylvania Avenue NW +Washington, DC 20037 +(1) (202) 663-6000 +(f) (202) 663-6363 +ronald.machen@wilmerhale.com +Attorneys for JPMorgan Chase Bank, N.A. +14 + + +Casase2222 20909045RSDoDomene81106I Filed 08/08/23 Page 16068581 + + + +Casase 222200909045/SDDomene814061 Filed 08/@8/23 Page 27068581 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904 JSR +ACTION FOR DAMAGES +JURY TRIAL DEMANDED +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +FIRST AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL +Plaintiff Government of the United States Virgin Islands ("Government") files this +Complaint against JPMorgan Chase Bank, N.A. ("JP +") for violations of Trafficking +Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and +Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and +Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges as +follows: +PARTIES +The Attorney General of the United States Virgin Islands (hereinafter "Virgin +Islands") brings this parens patriae action on behalf of the Plaintiff, Government of the Virgin +Islands, pursuant to 15 U.S.C. § 1595(d) and 3 V.I.C. § 114 and her statutory authority to enforce +the laws of the Virgin Islands and protect public safety. +2. +The Attorney General, pursuant to her authority to represent the Government of the +United States Virgin Islands, also acts on behalf of, and with the lawfully delegated authority of, +the Virgin Islands Department of Licensing and Consumer Affairs under 12 V.I.C. § 327 in regard +to Count Four of the Government's Complaint alleging violations of the Virgin Islands Consumer + + +Casase2222-020909045PSDoDomeme817061 Filed 08/08/23 Page 3868581 +Fraud and Deceptive Business Practices Act. +3. +This action stems from an enforcement action the Government filed against the +Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey +Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations +Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke et al., Case No. ST-20- +CV-14 (Super. Ct. V.I. Jan. 15, 2020). The Attorney General brings this action, after presenting +her findings to JP +in September 2022, in her ongoing effort to protect public safety and to +hold accountable those who facilitated or participated in, directly or indirectly, the trafficking +enterprise Epstein helmed. The investigation revealed that JP +knowingly, negligently, and +unlawfully provided and pulled the levers through which recruiters and victims were paid and was +indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial +institutions can connect- +—or choke-human trafficking networks, and enforcement actions filed +and injunctive relief obtained by attorneys general are essential to ensure that enterprises like +Epstein's cannot flourish in the future. +4. +Defendant JPMorgan Chase Bank, N.A. is an American multinational investment +bank and financial services company headquartered in New York City and incorporated in +Delaware. +At all relevant times, JP | +including, but not limited to, the acts and practices described herein. +engaged in business in the Virgin Islands, +As described below, based on documents reviewed and interviews conducted by +the Government, JP +knowingly facilitated, sustained, and concealed the human trafficking +network operated by Jeffrey Epstein from his home and base in the Virgin Islands, and financially +benefitted from this participation, directly or indirectly, by failing to comply with federal banking +2 + + +Casase2222-020909045PSDoDomeme817061 Filed 08/08/23 Page 4968581 +regulations, +facilitated +and concealed wire and cash transactions that raised suspicion of-and were in fact part of-a +criminal enterprise whose currency was the sexual servitude of dozens of women and girls in and +beyond the Virgin Islands. Human trafficking was the principal business of the accounts Epstein +maintained at JP +7. +Upon information and belief, JP +I turned a blind eye to evidence of human +trafficking over more than a decade because of Epstein's own financial footprint, and because of +the deals and clients that Epstein brought and promised to bring to the bank. These decisions were +advocated and approved at the senior levels of JP +1, including by the former chief executive +of its asset management division and investment bank, whose inappropriate relationship with +Epstein should have been evident to the bank. Indeed, it was only after Epstein's death that JP +belatedly complied with federal banking regulations regarding Epstein's accounts. +JURISDICTION, VENUE, AND RELATED CASE +8. +This action is brought pursuant to and based on federal and Virgin Islands statutes, +including the federal Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595 ("TVPA"), +and the federal Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336 and its implementing regulations +("'BSA"). +This Court has federal question subject-matter jurisdiction pursuant to 28 U.S.C. +§ 1331 because the Government's TVPA and BSA-based causes of action arise under federal law. +10. +This Court has supplemental jurisdiction over the Government's Virgin Islands law +claims pursuant to 28 U.S.C. § 1367(a) because these claims are so related to those arising under +or based on federal law as to form part of the same case or controversy under Article III of the +United States Constitution. +3 + + +Casase 222200909045/SDDomen814061 Filed 08/@8/23 Page 8068581 +11. This Court is an "appropriate district court of the United States" in which for the +Government to obtain appropriate relief under 18 U.S.C. § 1595(d) and venue is proper under 28 +U.S.C. § 1391(b)(2) because Defendant maintains its principal place of business within this +judicial district, so that this Court may exercise general personal jurisdiction over Defendant, and +because many of the alleged acts and omissions of Defendant giving rise to the Government's +claims took place within this judicial district, so that this Court may exercise specific personal +jurisdiction over Defendant. +12. +Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is +related to Doe 1 v. JP +Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because +both actions arise from a common nucleus of operative fact involving Defendant JP +alleged participation, directly or indirectly, in Epstein's sex-trafficking venture by facilitating +payments to women and girls, channeling funds to Epstein to fund the operation, and concealing +Epstein's criminal conduct by failing to comply with federal banking regulations. +BACKGROUND +I. +Federal and State Legal Requirements +13. +is subject to federal laws, including the BSA and the Uniting and +Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct +Terrorism Act of 2001, Pub. L. No. 107-56, 115 Stat. 272 ("USA PATRIOT Act"), which amended +certain BSA regulations. +14. +Under both the BSA and USA PATRIOT Act, JP +is required to implement +adequate, risk-based anti-money laundering ("AML") policies and systems to detect and prevent +money laundering or other use of the institution's services to facilitate criminal activities. This +includes, but is not limited to, maintaining a due diligence program, filing suspicious activity +4 + + +Casase 222200909045/SDDomene814061 Filed 08/@8/23 Page B1068581 +reports ("SARs") when the financial institutions detect suspicious behavior and currency +transaction reports ("CTRs") for currency transactions or series of currency transactions that +exceed $10,000 in a 24-hour period, preventing structuring or assistance with structuring of +transactions undertaken for the purpose of evading federal reporting requirements, and maintaining +systems to prevent money laundering. +15. +The FDIC and the other federal banking regulators, including the Federal Reserve +Board and Office of the Comptroller of the Currency, formed an interagency organization known +as Federal Financial Institutions Examination Council ("FFIEC*"). +16. To provide further guidance to banks on what BSA compliance requires, FFIEC +published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). +The BSA Manual explains that an effective SAR program is essential: +Suspicious activity reporting forms the cornerstone of the BSA reporting system. It +is critical to the United States' ability to utilize financial information to combat +terrorism, terrorist financing, money laundering and other financial crimes +Examiners and banks should recognize that the quality of SAR content is critical to +the adequacy and effectiveness of the suspicious activity reporting system.! +17. +Pursuant to the BSA Manual, "[p]roper monitoring and reporting processes are +essential to ensuring that the bank has an adequate and effective BSA compliance program. +Appropriate policies, procedures, and processes should be in place to monitor and identify unusual +activity. "2 When a bank detects suspicious activity, it is required to report that information within +30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network +(FinCEN"). The reporting requirement ensures that the government is able to monitor and act +' FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual, Suspicious Activity +Reporting at 1 (2014) +https://bsaaml.ffiec.gov/docs/manual/06_AssessingComplianceWithBSARegulatoryRequirement +s/04.pdf. +" Id. at 2. +5 + + +Casase 222200909045/SDDomen814061 Filed 08/@8/23 Page 2268581 +when alerted to potential illegal conduct. +18. +Appendix F of the BSA Manual includes examples of suspicious transactions that +may indicate money laundering, terrorist financing, or fraud, including: +Funds transfer activity is unexplained, repetitive, or shows unusual patterns; +The currency transaction patterns of a business show a sudden change +inconsistent with normal activities; +c. +Unusual transfers of funds occur among related accounts or among accounts +d. +that involve the same or related principals; +Currency is deposited or withdrawn in amounts just below identification or +reporting thresholds; +e. +Regarding nonprofit or charitable organizations, financial transactions +occur for which there appears to be no logical economic purpose or in which +there appears to be no link between the stated activity of the organization +and the other parties in the transaction; +f. +Funds are sent or received via international transfers from or to higher-risk +locations. +19. +In addition, the CICO Act, 14 V.I.C. § 600, incorporates violations of Virgin Islands +Law and federal felonies, which includes the BSA's criminal-liability provisions. +Il. +Jeffrey Epstein's Criminal Conduct +20. +Jeffrey Epstein was a resident of the Virgin Islands. +21. +In 2008, Epstein pled guilty to one count of solicitation of prostitution with a minor +in Palm Beach, Florida. As a result of that conviction, Epstein was forced to register as a sex +offender in the Virgin Islands. +6 + + +Casase2222 020909045FSDoDomeme817061 Filed 08/08/23 Page 83068581 +22. +Epstein was a Tier 1 offender under Virgin Islands law based upon his Florida +conviction of procuring a minor for prostitution. +23. +On January 15, 2020, the Government filed a lawsuit against Jeffrey Epstein's +estate and related individuals and entities for violation of the CICO Act, 14 V.I.C. §§ 600 to 614, +and civil conspiracy, which the Government recently settled. As laid out in the Government's +Second Amended Complaint, ST-20-CV-14, ("SAC") (attached as Exhibit 1), Epstein created a +network of companies and individuals who participated in, directly or indirectly, and conspired with +him in a pattern of criminal activity related to the sex trafficking, forced labor, sexual assault, child +abuse, and sexual servitude of these young women and children. SAC 11 43-75. Epstein and his +associates trafficked underage girls to the Virgin Islands, held them captive, and sexually abused +them, causing them grave physical, mental, and emotional injury. Id. +24. +To accomplish this criminal activity, Epstein formed an association in fact with +both companies and non-profit organizations that he owned and operated, as well as individuals, +who were willing to participate in, directly or indirectly, facilitate, and conceal Epstein's criminal +activity in exchange for Epstein's bestowal of financial and other benefits, including sexual +services and forced labor from victims. Id. 11 at 157-195. +25. +In October 2012, the Southern Trust Company—one of the companies Epstein +owned applied for economic benefits from the Virgin Islands Economic Development +Commission ("EDC"') so the company could provide "cutting edge consulting services" in the area +of "biomedical and financial informatics." Id. 11 157-158. Southern Trust Company received a 10- +year package of economic incentives running from February 1, 2013 until January 31, 2023 that +included a 90% exemption from income taxes and 100% exemptions from gross receipts, excise, +and withholding taxes in the Virgin Islands. Id. 9 159. +7 + + +Casase 222200909045/SDDomene814061 Filed 08/@8/23 Page 9468581 +26. +Southern Trust, in fact, appeared to perform no informatics or data-mining services +during this period. Instead, Southern Trust funded the Epstein Enterprise (defined below), acting as +a conduit for payment to foreign women, credit cards, airplanes and other instrumentalities. Id. +11 167-173. +27. +This illicit association of Epstein, businesses, and his associates constitutes what is +referred to herein as the "Epstein Enterprise." Specifically included in the Epstein Enterprise were +the following companies and non-profit organizations, all of which had accounts with JP +2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, +Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, +LLC, NES, LLC, Plan D, LLC, Southern Financial, LL.C, and Southern Trust Company. +28. +Epstein used his wealth and power to create the Epstein Enterprise, which engaged +in a pattern of criminal activity by repeatedly procuring and subjecting underage girls and young +women to unlawful sexual conduct, sex trafficking, and forced labor. +29. Many of these women, particularly after Epstein's conviction in 2008, were +trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, +these women were recruited and, in several instances, required to marry other Epstein victims in +order to maintain their immigration status and their availability to Epstein. Id. 19 62- 63, 78, 86. +30. +As also alleged in the Second Amended Complaint, recruiters and victims were paid +in cash or through entities set up by Epstein and/or his associates. Id. 9 100. Many of these companies +were shell companies, that existed merely to transfer money to other accounts, or to shelter Epstein's +assets from judgment. Id. " 116. +31. +Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co- +Executors of Epstein's Estate, authorized or directed many of the transactions in JP| +accounts +8 + + +Casase: 222v400804SSRD®oceer84067 Fle0302 Page 15@/f331 +held by Epstein or related entities. Id. 11 8-10, 76-117. +32. +Epstein and the Epstein Enterprise continued trafficking and sexually abusing +young women and female children until Epstein was arrested by federal law enforcement +authorities on July 6, 2019 on federal charges for the sex trafficking of minors. +33. +Epstein was found dead on August 10, 2019 while in custody in a federal detention +center in New York on charges for sex-trafficking crimes. Id. 9 7. +ALLEGATIONS +Jeffrey Epstein Was an Extremely High-Risk Customer +34. +Jeffrey Epstein's reputation as a sex trafficker and abuser of women and girls was +well-known and well-publicized for more than a decade before his death. +35. +abused women and girls. +Between 2005 and 2013, there were numerous press reports that Epstein sexually +36. +In March 2005, there were press reports that Epstein paid a 14-year old girl in Palm +Beach, Florida for a "massage" and then molested her. Following these allegations, multiple +underage girls, many of them high school students, told police that Epstein also hired them to give +sexual massages. +37. +Throughout 2006 when Epstein was arrested in Palm Beach, Florida for +solicitation of a minor-there was extensive press regarding the nature and extent of Epstein's +sexual offenses, including the existence of dozens of victims. +38. +In 2008, Epstein pled guilty to sexual offenses in Palm Beach, Florida, including +solicitating a minor for prostitution. Epstein was sentenced to 18 months in jail and was required +to register as a sex offender. +39. +In 2009, the non-prosecution agreement between Epstein and the United States +9 + + +Casase: 2222ve*00804SSRD®oceer84067 Fle0023 Page 126@/f381 +became public. It revealed allegations that Epstein may have used interstate commerce to induce +minors to engage in prostitution, engaged in illicit sexual conduct with minors, and trafficked +minors. +40. +In 2010, press reports noted allegations that Epstein was involved with Eastern +European women in particular and that a modeling agency he helped fund brought "young girls.. +• often from Eastern Europe" to the United States on Epstein's private jets.? +Il. +Trafficker +Knew Epstein Was a Felon, Registered Sex Offender, and Alleged Child +41. +did business with Jeffrey Epstein from as early as 1998 to 2013. In that +time, JP +serviced approximately fifty-five Epstein-related accounts collectively worth +hundreds of millions of dollars. +42. +On information and belief, based on the Government's review of financial records, +information from and regarding victims of Epstein's trafficking, and other publicly available +information, at least 20 individuals paid through JP +accounts were victims of trafficking +and sexual assault in Little St. James, New York, and/or other Epstein properties. These women +were trafficked and abused during different intervals between at least 2003 and July 2019, when +Epstein was arrested and jailed, and these women received payments, typically multiple payments, +between 2003 and 2013 in excess of $1 million collectively. Epstein also withdrew more than +$775,000 in cash over that time frame from JP +accounts, especially significant as Epstein +was known to pay for "massages," or sexual encounters, in cash. Financial information also +reflects payments drawn from JP +accounts of nearly $1.5 million to known recruiters, +including to the MC2 modeling agency, and another $150,000 to a private investigative firm. +3 +I. Jeffrey Epstein Pedophile Billionaire and His Sex Den, The Daily Beast (July +22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. +10 + + +Casase: 2222ve*00804SSRD®oceer84067 Fled0023 Page 127 aff331 +43. +knew early on that Epstein was an extremely high-risk client but +decided, at multiple points during the relationship, to continue servicing Epstein's accounts +because of his vast wealth and connections with other high net worth individuals. +44. +In 2006, JP +Global Corporate Security Division found "[s]everal +newspaper articles ... that detail the indictment of Jeffrey Epstein in Florida on felony charges of +soliciting underage prostitutes." At that time, JP +decided to continue doing business with +Epstein but concluded his account "should be classified as high risk" and require special approval. +45. +In a 2010 internal email, JP +risk management division discussed new +allegations against Epstein: "See below new allegations of an investigation related to child +trafficking - are you still comfortable with this client who is now a registered sex offender." +Another JP +employee responded: "In my short tenure working on the account these stories +pop up including these from the summer." +46. +In January 2011, JP +AML compliance director requested re-approval for +the bank's relationship with Epstein from JP +then-General Counsel "in light of the new +allegations of human trafficking ..." Another JP +employee responded: "I thought we did +that in approving a S50 million new line of credit last month?" +47. In JP +January 2011 review of Epstein's accounts, the bank concluded +there were "no material updates" but noted: +A few news stories during 2010 connects Jeffrey Epstein to human trafficking. The +usage closely going forward +48. In March 2011, JP +Global Corporate Security Division reported: +"Numerous articles detail various law enforcement agencies investigating Jeffrey Epstein for +11 + + +Casase: 2222ve*00804SSRD®oceer8067 Fled0023 Page 12Baff331 +allegedly participating, directly or indirectly, in child trafficking and molesting underage girls. +Jeffrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding solicitation +for an undisclosed amount." The report also identified the following "derogatory information"; +a. "Jean Lue Brunel, owner of MC2 Model Management and Jeffrey Epstein +engaged in racketeering that involved luring in minor children for sexual play for +money. In addition, Brunel was a frequent passenger on Epstein's private jet and +often visited Epstein in jail." +b. "MC2 Model Management received $1 million from Epstein in 2005. It is +unknown if the money was given as a secret investment or payment for services +as a procurer." +49. +In August 2011, when conducting a Know-Your-Customer review, JP +flagged an account relating to Ghislaine Maxwell-Epstein's former companion who recently was +sentenced to 20 years in prison for conspiring with Epstein to sexually abuse minors. Maxwell +wanted to set up an account for her "personal recruitment consulting business." In an internal +email, JP +AML Director asked: "What does she mean by personal recruitment?? Are +you sure this will have nothing to do with Jeffrey? If you want to proceed, I suggest that we flag +this as a High Risk Client." +50. +In 2013the year that JP +terminated its relationship with Epstein-JP +flagged in Epstein's history that "[p]er bank policy, felons [like Epstein] are considered +high risk and require additional approval." +51. +banking relationship with Epstein was known at the highest levels of +the bank. For instance, an August 2008 internal email states, "I would count Epstein's assets as a +probable outflow for '08 ($120mm or so?) as I can't imagine it will stay (pending Dimon review)." +12 + + +Casase: 2222ve*00804SSRD®ocueer84067 Fled0023 Page 120@ff331 +I. Head of JP +Private Bank Had Close Personal Relationship With Epstein +52. +Former senior executive, Jes Staley ("Staley"), developed a close relationship with +Epstein when Staley was the head of JP L +Private Bank, which is a segment of JP +business dedicated to extremely wealthy clients with at least $10 million in assets. +53. +Between 2008 +and 2012, Staley exchanged approximately 1,200 emails with +Epstein from his JP +email account. These communications show a close personal +relationship and "profound" friendship between the two men and even suggest that Staley may +have been involved in Epstein's sex-trafficking operation. They also reveal that Staley +corresponded with Epstein while Epstein was incarcerated and visited Epstein's Virgin Islands +residence on multiple occasions. Epstein even advised Staley in connection with Staley's salary +negotiations at JP +in July of 2008. +54. +On December 30, 2008, Epstein and Staley discussed via email Staley's visit to +Epstein's residence in Palm Beach, Florida. Epstein wrote that he would not be home the following +Sunday, but that Staley was welcome to use the house. Staley replied that he would instead make +arrangements to visit Epstein in Palm Beach in early January. On January 8, 2009 around the +time of Staley's scheduled visit to Palm Beach Epstein wired $2,000 from his JP| +account +to a woman with an Eastern European surname. +55. +Between August 27 and 29, 2009, Staley communicated via email to Epstein that +he would be in London in a week. Epstein inquired whether Staley would need anything while in +London, and Staley replied, "Yep." On August 31, 2009, Epstein wired $3,000 from his JP| +account to the same Eastern European woman Epstein paid in January 2009. +56. +Staley sent an email to Epstein on November 1, 2009, when Epstein was +incarcerated and Staley was presumably visiting Little St. James, saying: +13 + + +Casase: 2222ve*00804SSRD®oceer8067 Fled0023 Page 150@/f331 +So when all hell breaks lo[o]se, and the world is crumbling. I will come here, and +be at peace. Presently, I'm in the hot tub with a +wine. This is an +amazing place. Truly amazing. Next time, we're here together. I owe you much. +And I deeply appreciate our friendship. I have few so profound. +57. On December 4, 2009, Staley told Epstein via email: "I realize the danger in +sending this email. But it was great to be able, today, to give you, in New York City, a long +heartfelt, hug." +58. +The next day, Epstein wrote to Staley, "you were with Larry, and I had to put up +with ..." and attached a picture of a young woman (shown below). Staley quipped, "don't tell me +a M +wine." Epstein replied, "always thoughts of alcohol." +59. +picture of' a young woman (shown below). +On December 20, 2009, Epstein sent an email to Staley that was blank except for a +14 + + +Casase: 2222ve*00804SSRD®oceer8067 Fled0023 Page 1flaff331 +60. +On January 15, 2010, Staley emailed Epstein, referring to Little St. James, "Arrived +at your harbor. Someday, we have to do this together." +61. +In July 2010, Staley sent an email to Epstein, saying: "Maybe they're tracking u? +That was fun. Say hi to Snow +" Epstein responded: "[W]hat character would you like next?" +When Staley said "Beauty and the Beast", Epstein replied: "well one side is available." +62. +None of the emails between Epstein and Staley were flagged in connection with +risk reviews of Epstein's accounts. Moreover, JP +allowed Staley to remain a decisionmaker on Epstein's accounts. JP +even tasked Staley to discuss the human trafficking +allegations with Epstein. +63. In July 2013- +-several months after Staley left JP +to join another financial +institution-JP +Compliance Officer terminated JP | +relationship with Epstein. +64. +At the time of Epstein's death in 2019, Staley was the Chief Executive Officer of +Barclays; however, Staley stepped down from that position in November 2021 after British +15 + + +Casase: 2222v400904SSRD®oceer84067 Fled0023 Page 132@/f331 +financial regulators concluded an investigation into Staley's characterization of his relationship +with Epstein. +IV. JP +| Ignored Obvious Red Flags Relating to Epstein's Accounts +65. +Despite JP +claims that it would closely monitor Epstein's accounts, JP +ignored numerous red flags related to Epstein's accounts and failed to comply with federal +banking regulations. +66. +Between 2003 and 2013, Epstein and/or his associates used Epstein's accounts to +make numerous payments to individual women and related companies. 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. For example, Epstein paid more than +S600,0000 to Jane Doe 1, a woman who-according to news reports contained in JP +due +diligence reports—Epstein purchased at the age of 14. Like other women who received payments +from Epstein, Jane Doe 1 listed Epstein's apartments on 66th Street in New York City as her +address, which should have been a red flag to JP +67. +Epstein and/or his associates also made significant cash withdrawals and 95 foreign +remittances with no known payee. For example, Hyperion Air, Inc.the Epstein-controlled +company that owned Epstein's private jet-issued over $547,000 in checks payable to cash +purportedly for "fuel expenses when traveling to foreign countries." Additionally, between January +2012 and June 2013, Hyperion converted more than $120,000 into foreign currency. Many of these +cash withdrawals either exceeded the $10,000 reporting threshold or were seemingly structured to +avoid triggering the reporting requirement. This is particularly significant since it is well known +that Epstein paid his victims in cash. SAC 1 100. +68. +In addition, Epstein and/or his representatives appeared to be misusing JP +16 + + +Casase: 2222ve*00804SSRD®oceer84067 Fled0023 Pag1@ff331 +accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and +Enhanced Education. Epstein made payments from these accounts with no clear nexus to the +organization's charitable purpose. For example, Epstein and/or his representative used the +C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known +victims, and over $20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or +his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and +$15,000 to +a firm owned by Epstein's reportedly prior +girlfriend. +69. +Each of these red flags was serious; together, they suggest a pattern of potentially +illegal conduet that should have prompted action by JP +Despite this, JP +2013 +compliance report describes "nothing unusual" in Epstein's account transactions, confirms that +Epstein's transaction activity appears "reasonable, normal, and expected for the type of business +or industry in which the client engages", and denies that any "unusual... activity" was detected, +noting that "Compliance reviews activity regularly." Moreover, the frequency of Epstein's +payments and the fact that the vast majority of account activity was payments to women and cash +withdrawals rather than business activity should have been enough to trigger action. +70. +Even as late as May 2013—mere months before JP +terminated Epstein's +account- +-JP +provided lines of credit to Epstein of up to $50 million. +Epstein Brought Additional High Net Worth Clients to JP| +71. +In addition to his own holdings with JP +, Epstein helped, or promised to +help, Staley recruit ultrawealthy clients to JP +A few examples are laid out below. +72. +In 2004, Epstein introduced Staley to Glenn +the owner of Highbridge +Capital Management—one of the country's largest hedge funds. This laid the groundwork for JP +17 + + +acquisition of Highbridge—a move that helped catapult Staley's career. +73. +In 2011, Epstein and Staley had extensive discussions regarding the creation of a +"very HIGH profile" donor advised fund ("DAF"), which is an investment account established to +support charitable organizations, headed by the +Epstein pitched the +DAF +as an "exclusive club" with a minimum $100 million donation where JP +would act as the +fiduciary. +VI. +Reveals Systematic Failures +74. +75. +76. Further, it does not appear from the Government's investigation that JP +engaged in any investigation of the source of Epstein's funds. For example, in 2012, an internal + + +Casase: 2222v400804SSRD®ocueer84067 Fle08023 Pag5@/f381 +email from JP +identified the following questions for Epstein regarding his account activity: +QUESTION: For checking account: +Review the activity for the period overall and explain how the client's transactions +profile agrees with or doesn't agree with expectations for the client based on the +client relationship (purpose of accounts, occupation, business activity, etc.D] +Compliance reviewed regularly +Questions for Asset/brokerage Account: +What is the purpose/intended use of the accounts)? Please provide a detailed +description of how the Client Direct Asset/Brokerage Accounts) will be used by +the client. +Investments/trading/wealth accumulation +**Review the activity for the period overall and explain how the client's transaction +profile agrees with or doesn't agree with expectations for the client based on the +client relationship (purpose of accounts, occupation, business activity, etc.): +Compliance reviewed regularly +Yet, there is no evidence that JP +pursued or received a response from Epstein even though +was required to conduct this minimum level of due diligence pursuant to 31 C.F.R. +§ 1010.620(b)(3). +77. +also seemingly did no due diligence on the nature of the various business +entities for which it held accounts for Epstein, which appear to have no legitimate business purpose +and, upon information and belief, were part of Epstein's criminal enterprise in the Virgin Islands. +78. +In January 2013the year JP +terminated Epstein's accounts the Office +of the Comptroller of the Currency ("OCC") entered into a consent order with JP +regarding +deficiencies in the bank's overall program for BSA/AML compliance. The OCC found— +consistent with the Government's findings here—that JP +failed to develop adequate due +diligence on customers and failed to comply with federal banking regulations. In fact, the OCC +noted that JP +"failed to identify significant volumes of suspicious activity" 4 +79. +After JP +terminated Epstein's accounts, Epstein moved his accounts to +4 NYSDFS Consent Order at 2-4 (Jan. 14, 2013), https://www.occ.treas.gov/newsissuances/news-releases/2013/nr-occ-2013-8a.pdf. +19 + + +Casase: 2222v400804SSRD®oceer84067 Fled0023 Pag26@/f381 +Deutsche Bank from 2013 to 2018. +80. +The New York State Department of Financial Services ("NYSDFS"") investigated +Deutsche Bank for failures to monitor Epstein's accounts. On July 6, 2020, the NYSDFS and +Deutsche Bank entered into a Consent Order with a $150 million penalty, which stated, in relevant +parts: +a. +C. +"The Bank's fundamental failure was that, although the Bank properly +classified Mr. Epstein as high-risk, the Bank failed to scrutinize the activity +in the accounts for the kinds of activity that were obviously implicated by +Mr. Epstein's past. The Bank was well aware not only that Mr. Epstein had +pled guilty and served prison time for engaging in sex with a minor but also +that there were public allegations that his conduct was facilitated by several +named co-conspirators. Despite this knowledge, the Bank did little or +nothing to inquire into or block numerous payments to named coconspirators, and to or on behalf of numerous young women, or to inquire +how Mr. Epstein was using, on average, more than $200,000 per year in +cash." +"Whether or to what extent those payments or that cash was used by Mr. +Epstein to cover up old crimes, to facilitate new ones, or for some other +purpose are questions that must be left to the criminal authorities, but the +fact that they were suspicious should have been obvious to Bank personnel +at various levels. The Bank's failure to recognize this risk constitutes a +major compliance failure." +"These errors are unacceptable in the context of a major international bank +20 + + +Casase: 2222ve*00904SSRD®oceer84067 Fled03023 Page 27 aff331 +and inexcusable in the context of the heightened scrutiny that should have +occurred in the monitoring of a high-risk customer." +81. +The NYSDFS also found fault with Deutsche Bank's failure to obtain answers +regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May +2018 email, a compliance officer submitted an inquiry ... about payments to the accounts of +women with Eastern European surnames at a Russian bank, and asking for an explanation of the +purpose of the wire transactions and Epstein's relationship with the counterparties." +82. +failures to appropriately monitor Epstein's accounts and comply with +federal banking regulations are even more egregious than Deutsche Bank's failures because JP +failed to demonstrate even basic due diligence and continued its relationship with Epstein +for over a decade, despite the glaring indications of criminal activity. +83. +84. +So, too, was JP +• decision to allow Jes Staley to serve as an investigator +and decision-maker with respect to Epstein's accounts, despite glaring red flags regarding Staley's +relationship with Epstein, was a blatant failure of compliance. +VII. +Fraudulently Concealed Its Continuing Violations +85. +continuous illegal conduct has caused repeated and continuous injury. +86. +knew +- including at the highest level of the bank-that Epstein was an +extremely high-risk client. Between 2005 and 2013, there were myriad reports that Epstein +sexually abused women and girls. In 2008, Epstein pled guilty to sexual offenses and registered as +SId. at 15. +21 + + +Casase: 2222v400804SSRD®oceer84067 Fle0023 Pag2Baff331 +a sex offender. Despite JP +acknowledgement that it needed to closely monitor Epstein, +ignored numerous red flags and failed to comply with federal banking regulations until +years later after JP +was no longer benefiting from Epstein's business. +87. +also engaged in a course of conduct aimed at fraudulently concealing +its illegal conduct, including by failing to timely comply with federal banking regulations in order +to profit from Epstein's wealth and connections. +88. +A key purpose of federal banking regulations is to give law enforcement real-time +information so that it can act to detect violations of the law and protect public safety. +89. +The Government of the Virgin Islands did not know, and could not have known, +that Epstein used JP +to facilitate his trafficking enterprise or that JP +turned a blind +eye to unusual cash transactions and wires and failed to carry out or follow up on basic due +diligence and to timely comply with federal banking regulations, as required by the law. +90. +Over more than a decade, JP +clearly knew it was not complying with +federal regulations in regard to Epstein-related accounts as evidenced by its too-little too-late +efforts after Epstein was arrested on federal sex trafficking charges and shortly after his death, +when JP +belatedly complied with federal law. +91. +The continued illegal conduct by JP +has caused repeated and continuous +injury. JP +illegal conduct was not completed nor were all damages incurred until the +wrongdoing ceased in August 2019 when JP +began belatedly complying with federal +banking regulations in regard to Epstein-related accounts. +22 + + +Casase: 222v400804SSRD®oceer84067 Fle0023 Pag2Đaff331 +CAUSES OF ACTION +COUNT ONE +Participating in a Sex-Trafficking Venture +Violation of Trafficking Victims Protection Act +18 U.S.C. §§ 1591(a)(2), 1595(d) (Parens Patriae) +The Government restates and realleges paragraphs 1 to 91 of this Complaint as if +92. +fully set forth herein. +93. +The Government brings this Count as parens patriae on behalf of the residents and +visitors of the United States Virgin Islands and pursuant to the Attorney General's express +statutory authority. +94. +knowingly and intentionally participated in Epstein's sex-trafficking +venture that was in and affecting interstate and foreign commerce, together and with others, in +violation of 18 U.S.C. § 1591(a)(2) by facilitating payments to women and girls, channeling funds +to Epstein to fund the operation, and concealing Epstein's criminal conduct by failing to comply +with federal banking law. +95. +knowingly and intentionally benefitted financially from and received +value for its participation in the sex-trafficking venture in which Epstein and his co-conspirators, +with JP +knowledge or reckless disregard of the fact, would use means of force, threats +of force, fraud, coercion, and a combination of such means to sexually abuse young women and +underage girls, including by causing them to engage in commercial sex acts, in the Virgin Islands +and elsewhere. +96. +Among the financial benefits that JP +received for participating in and +facilitating Epstein's sex-trafficking venture was the deposit of funds that Epstein a Virgin +Islands resident- +-and Epstein-controlled entities located in the Virgin Islands made to JP +profited from the use of these deposits. Epstein and Epstein-controlled entities located +23 + + +Casase: 2222ve*00804SSRD®oceer84067 Fled0023 Pag25@/f381 +in the Virgin Islands deposited these funds in exchange for JP +facilitation of and +participation in Epstein's sex-trafficking venture. +97. Also, among the financial benefits that JP +received for participating in and +facilitating Epstein's sex-trafficking venture were referrals of business opportunities from Epstein +and his co-conspirators. JP +profited from, or expected to profit from, these referred +business opportunities. Epstein referred business entities and business opportunities to JP L +in exchange for its facilitation of and participation in Epstein's sex-trafficking venture. +98. +financially profited from the deposits made by Epstein and Epsteincontrolled entities located in the Virgin Islands and from the business opportunities referred to JP +by Epstein and his co-conspirators in exchange for its known facilitation of and implicit +participation in Epstein's sex trafficking venture. +99. +knew and recklessly disregarded and concealed the fact that it was +Epstein's pattern and practice to use the channels and instrumentalities of interstate and foreign +commerce to recruit, entice, harbor, transport, provide, obtain, and maintain young women and +underage girls for purposes of causing them to engage in commercial sex acts in violation of 18 +U.S.C. § 1591(a)(1). +100. JP +and its employees had actual knowledge that they were facilitating +Epstein's sexual abuse and sex-trafficking conspiracy to recruit, entice, harbor, transport, provide, +obtain, and maintain young women and underage girls to engage in commercial sex acts through +the means of force, threats of force, fraud, abuse of process, and coercion. +101. Despite this knowledge, JP | +intentionally paid for, concealed, facilitated, +and participated in Epstein's and his co-conspirators' violations of 18 U.S.C. § 1591(a), which JP +knew and was in reckless disregard of the fact that Epstein and his co-conspirators would +24 + + +Casase: 2222ve*00804SSRD®oceer8067 Fled0023 Page26laff331 +use its bank accounts and financial transactions to coerce, defraud, and force young women and +underage girls to engage in commercial sex acts. +102. +, through its employees and agents and their role in facilitating the +financial aspect of Epstein's enterprise, actively facilitated or participated in the sex-trafficking +conspiracy in which Epstein and his co-conspirators led young women and underage girls in the +Virgin Islands and elsewhere to believe that they would be rewarded if they cooperated with +Epstein and his co-conspirators and acquiesced to their demands. +103. JP +committed this affirmative conduct knowing or in reckless disregard of +the fact that Epstein would use cash transactions and financial support provided by JP +as +a means to defraud, force, and coerce commercial sex acts from young women and underage girls. +104. In addition to having actual knowledge that it was participating in and facilitating +the Epstein sex-trafficking venture, JP +also knew that it was participating in and +facilitating a venture that was engaged in coercive sex trafficking in violation of 18 U.S.C. § +1591(a)(1). +105. In exchange for facilitating and covering up Epstein's commercial sex trafficking, +employees received financial benefits and career advancement from JP +106. Facilitating and covering up Epstein's sex trafficking venture was a means for JP +employees to obtain economic success and promotion within JP | +107. +knowing and intentional conduct has caused serious harm to the +Virgin Islands and its residents, including without limitation financial harm, by facilitating the +commission of sexual abuse against young women and underage girls, including their engagement +in commercial sex acts, in the Virgin Islands. +25 + + +Casase: 22224#0804 SIRD Doceer& MR Fleet02805223 Page 202@f/3EB1 +108. +tortious conduct in violating the TVPA was outrageous and intentional +because it was in deliberate furtherance of a widespread and dangerous criminal sex-trafficking +venture operated in and from the Virgin Islands. JP +tortious conduct also evidenced a +high degree of moral turpitude and demonstrated such wanton disregard for the safety of young +women and underage girls in the Virgin Islands and elsewhere as to imply a deliberate indifference +to its legal obligations. +109. By virtue of these knowing and intentional violations of 18 U.S.C. § 1591(a)(2), JP +is liable to the Government for all appropriate relief under 18 U.S.C. § 1595(d), including +damages suffered by the Government and/or Epstein's victims, punitive damages, restitution, +appropriate injunctive relief, fines, reasonable attorneys' fees, and all such other relief as the Court +deems appropriate. +COUNT TWO +Criminal Activity—Participating, Directly or Indirectly, in a Sex-Trafficking Venture +Violation of Trafficking Victims Protection Act, 18 U.S.C. § 1591(a)(2), +actionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. §§ 604(e) and 605(a) +110. +The Government restates and realleges paragraphs 1 to 109 of this Complaint as if +funny set forth herein. +111. The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail +criminal activity and lessen its economic and political power in the Territory of the Virgin Islands +by establishing new penal prohibitions and providing to law enforcement and the victims of +criminal activity new civil sanctions and remedies." 14 V.I.C. § 601. +112. +At all times material herein, JP +| was a "person" identified in 14 V.I.C. § +604(1). +26 + + +Casase: 2222ve*00804SSRD®oceer84067 Fled0023 Pag28aff331 +113. At all times material herein, Epstein and his co-conspirators were engaged in an +illicit sex-trafficking "enterprise" as defined in 14 V.I.C. § 604(h). +114. At all times material herein, JP +supported and/or was associated with the +Epstein sex-trafficking enterprise by providing banking and payment-processing services to +Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or +incorporated in the Virgin Islands. +115. +In providing banking and payment-processing services to Epstein and Epsteincontrolled entities in return for profits realized both from Epstein's and Epstein-controlled entities' +accounts and from receiving referrals by Epstein of other high-value banking clients, JP +knowingly, intentionally, and willfully benefitted financially and by receiving things of value from +its participation, directly or indirectly, in Epstein's sex-trafficking venture and enterprise, in +violation of 18 U.S.C. § 1591(a)(2). +116. JP +knowing, intentional, and willful receipt of financial benefits and +things of value from its facilitation and participation in Epstein's sex-trafficking venture and +enterprise through the financial infrastructure it provided and concealed constitutes a felony under +18 U.S.C. § 1591(b) and "criminal activity" as defined in 14 V.I.C. § 604(e). +117. By knowingly, intentionally, and willfully receiving financial benefits and things +of value from its participation, directly or indirectly, via financing in Epstein's sex-trafficking +venture and enterprise, JP +enabled Epstein to have ready and reliable access to and use of +resources with which to recruit, entice, harbor, transport, provide, obtain, and maintain young +women and underage girls for purposes of causing them to engage in commercial sex acts in the +Virgin Islands and elsewhere. JP +thereby unlawfully conducted and/or participated in, +27 + + +Casase: 2222ve*00804SSRD®oceer84067 Fle002 Page 281aff331 +directly or indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal +activity in violation of 14 V.I.C. § 605(a). +118. JP +illegal activity has caused serious harm to the Virgin Islands and its +residents, including without limitation financial harm, by facilitating the commission of sexual +abuse against young women and underage girls, including their facilitation and participation, +directly or indirectly, in commercial sex acts, in the Virgin Islands. +119. By virtue of this pattern of illegal activity in furtherance of the Epstein sextrafficking enterprise, JP +is liable to the Government for all appropriate civil remedies +under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein's +victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive +relief, attorneys' fees and costs, and all such other relief as the Court deems appropriate. +COUNT THREE +Criminal Activity—Willfully Failing To Comply With Federal Banking Law, +Violation of Bank Secrecy Act, 31 U.S.C. $ 5322(a), as it incorporates +, actionable under Virgin Islands +Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 604(e) and 605(a) +120. The Government restates and realleges paragraphs 1 to 119 of this Complaint as if +fully set forth herein. +121. The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail +criminal activity and lessen its economic and political power in the Territory of the Virgin Islands +by establishing new penal prohibitions and providing to law enforcement and the victims of +criminal activity new civil sanctions and remedies." 14 V.I.C. § 601. +122. +At all times material herein, JP +_ was a "person" as defined in 14 V.I.C. +§ 604(1). +28 + + +Casase: 2222v400804SSRD®ocueer84067 Fle002 Pag305@/f331 +123. At all times material herein, Epstein and his co-conspirators were engaged in an +illicit sex-trafficking "enterprise" +as defined in 14 V.I.C. § 604(h). +124. At all times material herein, JP +was employed by and/or associated with +the Epstein sex-trafficking enterprise by providing banking and payment-processing services to +Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or +incorporated in the Virgin Islands. +125. In providing banking and payment-processing services to Epstein and Epsteincontrolled entities, JP +knowingly, intentionally, and willfully failed to comply with federal +banking regulations in violation of 31 U.S.C. § 5322(a), +From accounts maintained and served at JP +Epstein and Epstein-controlled entities received payments of large dollar amounts for no apparent +business or other lawful purpose and made repeated cash payments, sometimes in amounts and +patterns designed to evade federal reporting requirements, to young women and/or underage girls +who were sexually abused and coerced into engaging in commercial sexual acts in the Virgin +Islands and elsewhere. +126. +knowing, intentional, and willful failure to comply with federal +banking regulations constitutes a felony under 31 U.S.C. § 5322(a) and "criminal activity" as +defined in 14 V.I.C. § 604(e). +29 + + +Casase: Fled10023 Pag 316@ff3E81 +127. By knowingly, intentionally, and willfully failing to comply with federal banking +regulations, JP +enabled Epstein to have ready and reliable access to and use of resources +with which to recruit, entice, harbor, transport, provide, obtain, and maintain young women and +underage girls for purposes of causing them to engage in commercial sex acts in the Virgin Islands +and elsewhere. +thereby unlawfully conducted and/or participated in, directly or +indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal activity +in violation of 14 V.I.C. § 605(a). +128. JP +illegal activity has caused serious harm to the Virgin Islands and its +residents, including without limitation financial harm, by facilitating the commission of sexual +abuse against young women and underage girls, including their engagement in commercial sex +acts, in the Virgin Islands. +129. By virtue of this pattern of illegal activity in furtherance of the Epstein sextrafficking enterprise, JP +is liable to the Government for all appropriate civil remedies +under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein's +victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive +relief, attorneys' fees and costs, and all such other relief as the Court deems appropriate. +COUNT FOUR +Unfair Methods of Competition +Violation of Virgin Islands Consumer Fraud +and Deceptive Business Practices Act, 12A V.I.C. § 304 +130. The Government restates and realleges paragraphs 1 to 129 of this Complaint as if +fully set forth herein. +131. +Section 304 of Title 12A of the Virgin Islands Code provides that "Ti]t is unlawful +for any person to engage in unfair methods of competition ... in the conduet of any trade or +commerce." +30 + + +Casase: Fled0B023 Pag Pag327 aff3E31 +132. JP +is a "person" as defined in 12A V.I.C. § 303(h). +133. +provision of banking services and payment processing for Epstein and +Epstein-controlled entities constitutes "[t]rade or commerce" as defined in 12 V.I.C. § 303(k). +134. +In return for knowingly and intentionally participating in, directly or indirectly, +facilitating, and concealing by failing to comply with federal banking regulations regarding +Epstein-related accounts, JP +both profited from the use of the funds in their accounts and +received referrals of other high-value business opportunities from Epstein and his co-conspirators. +135. By receiving referrals of high-value business opportunities from Epstein and his +co-conspirators in return for participating in, directly or indirectly, facilitating, and concealing by +failing to comply with federal banking regulations regarding Epstein-related accounts, JP +unlawfully and unjustly enriched itself at the expense of other banks that complied with their legal +obligations. This conduct constitutes an unfair method of competition in violation of 12A V.I.C. § +304. +136. By virtue of its knowing, intentional, and repeated acts constituting unfair +competition, JP +is liable to the Government for all appropriate civil remedies under 12A +V.I.C. S§ 328 and 332, including damages, civil penalties awarded on a per-violation basis +pursuant to 12A V.I.C. § 328(b), appropriate injunctive relief, attorneys' fees and costs, and all +such other relief as the Court deems appropriate. +REQUEST FOR RELIEF +The Government respectfully requests that the Court enter judgment in its favor, and +against JP +as follows: +31 + + +Casase: 2222ve*00804SSRD®ocueer84067 Fle0302 Pag3฿aff331 +A. That the Court award the Government compensatory, consequential, general, and +nominal damages, as suffered by the Government and/or Epstein's victims, and +punitive damages, all against JP | +in amounts to be awarded at trial; +B. That the Court award the Government punitive and exemplary damages against JP +in an amount to be determined at trial; +C. That the Court order JP L +to pay appropriate fines to the Government +pursuant to 18 U.S.C. § 1591(b) in amounts to be determined at trial; +D. That the Court order JP +to provide restitution of all ill-gotten gains to the +Government pursuant to 18 U.S.C. § 1593 and 14 V.I.C. § 607(a)(6) and pursuant +to 14 V.I.C. § 608(c)(4) to protect the rights of victims and innocent persons in the +interest of justice and consistent with the purposes of the CICO Act, in amounts to +be determined at trial; +E. +That the Court award the Government treble damages against JP +pursuant +to 14 V.I.C. § 607(c) in an amount to be determined at trial; +F. +That the Court order JP +to pay appropriate civil penalties to the +Government pursuant to 14 V.I.C. § 607(e) and 12A V.I.C. § 328(b) and pursuant +to 14 V.I.C. § 608(c)(4) to protect the rights of victims and innocent persons in the +interest of justice and consistent with the purposes of the CICO Act, in amounts to +be determined at trial; +G. +That the Court enter an injunction pursuant to 14 V.I.C. § 607(a)(2) and 12A V.I.C. +§ 328(a)(2) to prevent further illegal conduct and any concealment of illegal +conduct; +32 + + +Casase: 2222ve*00804SSRD®oceer84067 Fle0023 Pag3/Đaff331 +H. +That the Court order JP +to provide disgorgement of all ill-gotten gains to +the Government pursuant to 14 V.I.C. § 607(a)(6) and pursuant to 14 V.I.C. +§ 608(c)(4) to protect the rights of victims and innocent persons in the interest of +justice and consistent with the purposes of the CICO Act, in amounts to be +determined at trial; +I. +That the Court award the Government attorneys' fees and costs pursuant to 18 +U.S.C. § 1595, 14 V.I.C. § 607(c), and 12A V.I.C. § 332 in amounts to be +determined after trial; and +J. +That the Court award the Government and order JP +to provide all such +other relief as the Court deems appropriate. +JURY DEMAND +The Government demands a jury trial on all issues so triable. +Dated: January 10, 2023 +CAROL +1. ESQ. +ACTING ATTORNEY GENERAL +/s/ David I. Ackerman +DAVID I. ACKERMAN (NYS Bar #4110839) +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 849-4962 +dackerman@motleyrice.com +CAROL +(NYS Bar #2941300) +Admitted Pro Hac Vice +Acting Attorney General of the United States +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +St. +I. U.S. Virgin Islands 00802 +Tel.: (340) 774-5666 ext. 10101 +33 + + +Casase: 2222ve*00804SSRD®oceer84067 Fle0023 Page 30@/f381 +LINDA +(NYS Bar #2473403) +Admitted Pro Hac Vice +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Isinger@motleyrice.com +PAIGE BOGGS +Admitted Pro Hac Vice +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 386-9629 +pboggs@motleyrice.com +34 + + +Cassé:2222ve4090804SISRDDmr0eer811062 Fiet1080508 Page5dfof3181 + + + +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +Jane Doe 1, individually and on +behalf of all others similarly +situated +CLASS ACTION COMPLAINT +Plaintiffs, +JURY TRIAL DEMANDED +V. +JP| +Case No.: 22-cv-10019-JSR +Chase Bank, N.A., +Defendant. +) +/ +FIRST AMENDED INDIVIDUAL AND CLASS ACTION COMPLAINT +Plaintiff Jane Doe 1 files this first amended individual and civil class action +complaint for damages and other relief under (among other provisions of law) the +United States federal anti-sex trafficking statute, 18 U.S.C. § 1591, et seq.—the +Trafficking Victim Protection Act ("TVPA") and for aiding and abetting, +intentional infliction of emotional distress, and negligence related to sexual offenses +as defined in article one hundred thirty of the penal law, pursuant to the New York +Adult Survivors Act, N.Y. CPLR §214-j. The suit arises from Defendant JP +Chase Bank, N.A.'s (hereinafter "JP +") participation and intentional +involvement in Jeffrey Epstein's widespread and well-publicized sex-trafficking +operation, as well as the direct financial benefits it received therefrom. +knew that it was providing the financial lifeblood for Epstein's +1 + + +international sex-trafficking organization from 1998 through August 2013. In +exchange for that crucial financial support, JP +knowingly and intentionally +benefited and received things of value from Epstein and his sex-trafficking +operation. And that crucial financial support allowed Epstein to successfully rape, +sexually assault, and coercively sex traffic Jane Doe 1 and the numerous other +members of the Class proposed below (the "Class"). JP | +knew that Epstein +was regularly committing violations of New York Penal Law Art. 130, including, +and especially, New York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66, +and acted to enable, aid and abet, and facilitate Epstein's commission of such +offenses against countless young women, including Jane Doe 1 and Class Members. +also knew that Epstein would use means of force, threats of force, +fraud, abuse of legal process, exploitation of power disparity, and a variety of other +forms of coercion to cause young women and girls to engage in commercial sex acts. +Knowing that it would earn millions of dollars in exchange for facilitating Epstein's +sex abuse and trafficking, JP +chose profits over following the law. +Specifically, JP +chose participating in and facilitating Epstein's sextrafficking conspiracy for many years, including through the criminal investigation +and incarceration of Jeffrey Epstein, in order to churn profits. +Jane Doe 1 makes the following allegations on information and belief and +believes that substantial additional evidentiary support will exist for the allegations +2 + + +Casade? 12224000SFD dOn/G2 FileD Fegg: 8450 1128181 +set forth herein after a reasonable opportunity for discovery: +1. JURISDICTION, VENUE, AND TIMELINESS +1. +This action is brought pursuant to various federal and state statues, +including the federal TVPA, 18 U.S.C. § 1589 through § 1595. This Court has +federal question subject-matter jurisdiction pursuant to 28 U.S.C. §1331, because +Jane Doe 1 +—individually and on behalf of the other Class members proceeds +under the federal TVPA statute. +This Court also has supplemental jurisdiction over the state law claims +recounted below pursuant to 28 U.S.C. § 1367(a), because all claims alleged herein +are part of a uniform pattern and practice and form part of the same case or +controversy. +3. +This Court is "an appropriate district court of the United States" in +accordance with 18 U.S.C. § 1595, in which to bring this action. Venue is proper in +this District under 28 U.S.C. § 1391(b)(2), because Epstein, his co-conspirators, and +all conducted substantial activities in this District and knowingly aided +and abetted, facilitated, and directly participated in Epstein's illegal venture through +actions that originated in this District. In addition, Epstein sexually abused and +trafficked Jane Doe 1 and members of the Class is this District. +Often these acts of sexual abuse and commercial sex acts, committed +by Jeffrey Epstein and certain select friends of his, took place in Jeffrey Epstein's +3 + + +Casade? 1222409008IBED docent/BEZ fee DOGB Fegg 5561128181 +New York mansion, located within this District at 9 East 71st Street in New York +City. Epstein also used his New York mansion to harbor his victims and as a base +from which to transport them to other locations outside of New York. +5. +A substantial part of the acts, events, and omissions giving rise to this +cause of action occurred in this District. +6. +This action has been timely filed pursuant to 18 U.S.C. § 1595(c)(1), +which provides that a plaintiff shall have ten years after the cause of action arose to +file suit against any person who knowingly benefits, financially or by receiving +anything of value from participation in a venture which that person knew or should +have known violated the laws against sex trafficking. This action is also timely +because the conspiracy continued until recently. This action is also timely under +New York's Adult Survivor's Act, N.Y. CPLR § 214-j. +7. +II. PARTIES +Jane Doe 1 is a U.S. citizen and was at all relevant times a resident of +and domiciled in the State of New York. +Plaintiff Jane Doe 1 is using a pseudonym to protect her identity +because of the sensitive and highly personal nature of this matter, which involves +sexual assault. +9. +Jane Doe 1 is also at serious risk of retaliatory harm because the coconspirators who participated in the Epstein sex-trafficking venture had and +4 + + +CabsteR 1222409008IBED dame/BG2 FileD Figg 5056118181 +continue to possesstremendous wealth and power and have demonstrated a clear +ability to cause her serious harm. +10. +Jane Doe I's safety, right to privacy, and security outweigh the public +interest in her identification. +11. +Jane Doe I's legitimate concerns outweigh any prejudice to Defendant +by allowing her to proceed anonymously. +12. As discussed below, many other women are similarly situated to Jane +Doe 1 and also need to proceed anonymously for the same reasons. The identities of +most of these other women are known to Defendant. +13. Defendant JP +_ is a global financial institution headquartered in +New York, New York. +14. Defendant JP +is licensed by the New York State Department +of Financial Services to operate a foreign bank branch in the State of New York. +15. Defendant JP +currently conducts substantial business in this +District and conducted substantial business at the time of events covered in this +complaint. +16. As one example of business conducted in this District, JP +ordinarily trades shares on the New York | +Exchange, located in this District. +As another example, JP +maintains branch banks within this District. +17. JP| +financial activities, including the events alleged herein, +5 + + +CabsteR 1222e40I900SIBHD d00eme1/BGZ FileDGE FRgge675618181 +were in and affecting interstate and foreign commerce. In connection with the acts +alleged in this complaint, Defendant, directly or indirectly, used the means and +instrumentalities of interstate commerce, including, but not limited to, the mails, +interstate telephone communications, and the facilities of national securities +markets. +18. JP +is responsible, under United States law and otherwise, for +the acts of its officers, directors, employees, and agents, including the acts described +in this complaint. The acts alleged were committed by JP +officers, +directors, employees, and agents were within actual and apparent scope of their +employment and with the intention, at least in part, to benefit JP +III. INTRODUCTION +19. Jeffrey Epstein's sex-trafficking venture operated in many respects as +a sex-themed cult designed to ensnare vulnerable young women and indoctrinate +them into Epstein's carefully constructed world in which Epstein was their messiah. +Epstein and his co-conspirators preached the gospel of Epstein. Epstein's victims +were taught to do what he said, and he would protect them; but disobey him, and he +would punish them; and continue to disobey, and he would cause them serious harm +from which they could never recover. +20. +Once in Epstein's clutches, each victim was taught and understood that +she must be completely compliant with every demand Epstein had for her; otherwise, +6 + + +she would certainly suffer serious reputational, financial, and psychological harm. +By using these and other means of force, threats of force, fraud, threats of abuse of +the legal process and coercion, Epstein and his co-conspirators sexually trafficked +and sexually abused Jane Doe 1 and the other members of the Class. +21. The Epstein sex-trafficking venture originated in the early 1990's. +From its inception until Jeffrey Epstein's arrest by the FBI for sex trafficking in 2019 +(and his subsequent death on August 10, 2019, by apparent suicide), the venture +operated primarily for the purpose of luring young women and girls into a position +where Jeffrey Epstein and his co-conspirators could coerce them to engage in +commercial sex acts and commit sexual offenses against them. His venture also +operated to conceal its sex trafficking from law enforcement organizations. And his +venture provided financial and other benefits to those who assisted and enabled the +venture. +22. The Epstein sex-trafficking venture was well-structured from the +beginning and grew increasingly more complex and powerful as it victimized more +young women and as its relationship with Defendant JP | +grew. +23. Epstein could not and did not act alone. He created and maintained his +sex-trafficking venture with the assistance of other influential individuals and +entities who knew he was sexually abusing and sexually trafficking young women +and girls and provided support to facilitate his sexual abuse and sex trafficking +7 + + +operation. +24. +Epstein's +sex-trafficking venture was not possible without the +assistance and complicity of a financial institution specifically, a banking +institution +-which provided special treatment to Jeffrey Epstein and the sextrafficking venture, thereby ensuring its continued operation and sexual abuse and +sex-trafficking of young women and girls. Without the financial institution's +participation, Epstein's sex trafficking scheme could not have existed and flourished. +25. Epstein's victims were young women and girls, who suffered severe +abuse as Epstein's sex-trafficking victims and who believed they had to remain loyal +to the venture at all costs to survive. Epstein victimized hundreds of young women +and girls with the assistance of a wide network of co-conspirators, including JP +26. Epstein's sexual abuse and sex trafficking scheme was supported by +virtually unlimited wealth, derived from select wealthy individuals who acted as the +financial engine behind the sex-trafficking operation, in exchange for sexual and +other benefits. +27. Epstein masterfully assessed the specific needs and vulnerability of +each of his targeted victims. He then closed the trap on his victims with offers of +money, food, shelter, medical care for them or family members, travel, schooling, +and career opportunities. +Epstein groomed the young women and girls, +8 + + +caaase2P28+401000988RDDamenteßY B87 Fit 0038333 Pagg& 60b8CB81 +indoctrinating them to believe that the sexual abuse was normal. +28. +Epstein fraudulently represented to the victims that he would take care +of them in various ways, which ultimately allowed Epstein to cause them to engage +in commercial sex acts with himself and, on occasion, select others, as well as to +create the opportunity for Epstein to sexually abuse them. +29. The Epstein sex-trafficking venture's purpose included enticing, +obtaining, harboring, and transporting the young victims without drawing unwanted +attention from law enforcement. The venture had everything a sex-trafficking +organization needed-funding, infrastructure, the appearance of legitimacy, and a +complicit banking institution. It was by many accounts the most powerful and +wealthiest sex-trafficking venture ever created. +30. The Epstein sex-trafficking venture knowingly used means of force, +threats of force, fraud, coercion (including threats of serious harm or physical +restraint), and abuse of law and the legal process, to cause Jane Doe 1, and many +dozens of others similarly situated women to engage in commercial sex acts. +31. +The Epstein sex-trafficking venture operated in and affected interstate +and foreign commerce. Epstein recruited, solicited, coerced, harbored, transported, +and enticed some of his victims, including Jane Doe 1 and others similarly situated, +to engage in commercial sex acts in, among other places, New York (including the +Southern District of New York), Florida, the U.S. Virgin Islands, New Mexico, +9 + + +OSas:222#₽80#9385D0000 me 6X868 7H786000888323 12099D6260 BB81 +England, and France. +32. The Epstein sex-trafficking venture operated throughout the world from +in and around (at least) 1998 through (at least) in and around August 10, 2019, when +Epstein died by apparent suicide. Thereafter, through at least July 2020, to and +including the date of this complaint, members of the sex-trafficking venture +continued to further the venture by concealing the activities and extent of the +venture. +33. The manner of operation for Epstein's particular sexual abuse and sex +trafficking operation was widely publicized. He would lure young girls or women +to one of his luxurious mansions, under the guise of being a wealthy philanthropist, +able to advance careers, education, or provide other life necessities, and once inside +he would force his would-be victim into providing a massage that would turn sexual, +and from there he would cause each of his unsuspecting victims to engage in a +variety of commercial sex acts. +34. +Once in his presence, each victim knew it was no option to disobey +Epstein. It was well known and understood that he was one of the most powerful +and connected people in the United States, able to help any of these young victims +and capable and willing to seriously harm any of his victims. +35. While Epstein's abuse began in the early 1990s with the use of his +paramour turned madame, Ghislaine Maxwell ("Maxwell"), Epstein's appetite for +10 + + +OSas222/0₽80#9385RD0000 me 62868 7 #Be 0008885323 109941 830 BB81 +sexually abusing young women and girls grew over the years. +36. By (at least) 1998, Epstein's sex trafficking venture had crystalized into +criminal conspiracy. By 1998, each victim was being directed to recruit other +vulnerable victims and being paid handsomely, typically in cash, for each +recruitment, creating a pyramid scheme of abuse. +37. +A Florida criminal investigation uncovered that the number of victims +of Epstein's sex-trafficking conspiracy grew exponentially in and around the early +2000s. +38. +While Epstein did pay victims and his many co-conspirators using wire +transfers and checks, because there were hundreds of victims, Epstein could not pay +all of his victims with traceable wires. +39. One primary reason why Epstein's sex-trafficking venture and +conspiracy accumulated new victims at an alarming rate in the late 1990s and +accelerated even faster by 2000 was Epstein's access to unlimited amounts of cash +and his knowledge that he had a complicit bank-JP +through which he +could operate his illegal abuse organization without fear of being reported to law +enforcement. +40. Without exorbitantly large amounts of cash, Epstein's operation could +not effectively operate, as newly recruited victims were each paid hundreds of +dollars in cash immediately after Epstein sexually abused them, as hush money. +11 + + +CaGas:172224Đ80493857D000009 8868 7 FEed000888582 3 209g-293 0 BB8 1 +41. Each victim was also informed that she would be paid hundreds of +dollars in cash for each additional victim she recruited, and Epstein made good on +those promises of large cash payments to keep his victims quiet and complicit. +42. The public documents and articles stemming from the 2006 arrest made +abundantly clear that Epstein was doling out thousands of dollars in cash every +single day as hush money to victims he was sexually abusing and to victims he was +using to recruit additional victims. +43. If Epstein paid every victim with wire transfers or checks and left a +documented money trail, his illegal sexual abuse and sex trafficking operation would +have been easily uncovered; however, with access to unlimited amounts of cash, +Epstein was able to commit the most egregious sexual crimes many times a day +without leaving a paper trail. +44. Accordingly, Epstein's constant expansion of sexual abuse and +trafficking required cash on hand for Epstein to pay each victim as hush money for +the abuse she was suffering as well as each victim's finder's fee for bringing another +victim. +45. To access the large amount of cash needed to maintain his active sexual +abuse of young women, it was essential that the financial institution where he banked +be complicit in his operation, and more specifically that Epstein bank at a financial +institution that would allow him to constantly withdraw cash from his accounts +12 + + +OSas222#₽80#9885D0000me 8868 7-#Be 000888823 129gt B6660 BB8 1 +without following anti-money laundering and reporting laws. +46. +To put it plainly, Epstein needed a bank that knew he was engaging in +illegal activity and did not care, which Epstein had in JP | +47. This scheme of paying victims to recruit other victims worked +effectively for Epstein. It not only allowed expansion through the recruitment of +other victims in a pyramid scheme or spiderweb fashion, but it also gave each victim +hope that she could avoid future sexual abuse she could bring someone else who +would get abused in her place. +48. Epstein's aptitude as a sex-trafficker and appetite as a sexual abuser did +not suffer because of his Florida incarceration in 2008. Even while he was in jail in +Florida, Epstein brazenly continued to sexually abuse young girls and women from +his work-release office. +49. Once out of jail and off work release, Epstein continued to collect +young women and lure them through force, fraud, or coercion into one of his +mansions, primarily his townhouse located at 9 East 71 Street, New York, NY, +where he would sexually abuse each one. +50. Epstein's sexual abuse and sex-trafficking operation continued as it had +in the past, although it became more elaborate, creating more phony companies, +opening more bank accounts, withdrawing excessive amounts of cash, and +delivering money to victims through wires, payroll, direct deposits, and other means +13 + + +OSas:7222#₽80#9385D0000me 67868 7-#Be 0008885823 R99165ÜBB81 +known to his financial institution as evidence of the continuation of his criminal sex +trafficking scheme. +51. +As time went by, especially after Epstein's Florida arrest, the news +articles and lawsuits about his activities continued to mount. More information +became publicly available that Epstein was continuing to abuse young women and +was using professionals on his payroll to help him conceal his illegal activity and +give him ostensible cover as a purported well-connected money manager. +52. As a registered sex offender discovered to be sexually abusing multiple +young women each day through a pyramid-type recruiting scheme that required the +transfer of millions of dollars to continue the operation, a complicit bank became +more important than ever. +53. As further detailed below, JP +worked closely with Epstein +through every step of the sex trafficking operation's expansion and growth in some +of its most prolific of years +between around 1998 through 2013. +IV. THE TRAFFICKING VICTIMS PROTECTION ACT +54. The Trafficking Victims Protection Act (TVPA) outlaws sex trafficking +activities that affect interstate or foreign commerce or take place within the territorial +jurisdiction of the United States. It is to be construed broadly because it serves a +remedial purpose and uses intentionally broad language. +55. The TVPA forbids, among other things, the following sex-trafficking +14 + + +conduct: +(a) Whoever knowingly +(1) in or affecting interstate or foreign commerce, or within +the special maritime and territorial jurisdiction of the +United States +recruits, +entices, harbors, transports, +provides, obtains, advertises, maintains, patronizes, or +solicits by any means a person; or +(2) benefits, financially or by receiving anything of value, +from participation in a venture which has engaged in an +act described in violation of paragraph (1), +knowing, or, except where the act constituting the violation of +paragraph is advertising, in reckless disregard of the fact, that means of +force, threats of force, fraud, coercion described in subsection (e) (2), or +any combination of such means will be used to cause the person to +engage in acommercial sex act, or that the person has not attained the +age of 18 years and will be caused to engage in a commercial sex act, +shall be punished as provided in subsection (b). +18 U.S.C. § 1591(a). +56. +The TVPA also forbids (among other things) conspiring to violate 18 +U.S.C. § 1591. 18 U.S.C. § 1594(c). +57. +The TVPA also contains an explicit "civil remedy" provision which +allows an individual who is a victim of a violation of Chapter 77 of Title 18 (e.g., +violation of 18 U.S.C. §§ 1591-94) to bring a civil action against the perpetrator and +any person or entity who knowingly benefits, financially or by receiving anything of +value from participation in an illegal sex-trafficking venture. 18 U.S.C. § 1595(a). +58. +Unlike the criminal penalties provisions in the TVPA, the civil +15 + + +OSas222/0₽80#9885D0000me 6868 7-#Be 0008885323 9g+66060 BB8 1 +remedies provision contains a "constructive knowledge" provision. This provision +allows +civil action to be brought not only against a person or entity who +participated in a venture known to have engaged in illegal sex trafficking but also +against a person or entity who participated in a venture that the person or entity +should have known had engaged in illegal sex trafficking. 18 U.S.C. § 1595(a). This +expansive provision is known as the "constructive knowledge" provision, which +provides an alternative to proving actual knowledge as part of civil damages claim. +59. In the paragraphs that follow, wherever Jane Doe 1 alleges that +Defendant acted with actual knowledge, or in reckless disregard of the fact, that the +Epstein sex-trafficking venture used means of force, threats of force, fraud, coercion, +abuse of process, or some combination thereof to cause a person to engage in +commercial sex acts, the Plaintiff also allege that, at a bare minimum, Defendant +should have known that the Epstein sex-trafficking venture had used such means to +engage in illegal sex trafficking in violation of 18 U.S.C. §§ 1591-94—i.e., that they +had constructive knowledge of Epstein's sex trafficking. +60. In this complaint, Jane Doe 1 and other members of the Class also +allege that JP +was willfully blind to the fact that was facilitating and +participating in Epstein's sex-trafficking venture. +V. FACTUAL ALLEGATIONS +A. The Epstein Sex-Trafficking Venture and Conspiracy +16 + + +CaGasiI7222гsAĐ80493857D0000m0e 7 7H#Be6000888582 3 R09g170860BB8 1 +61. During all times relevant to this complaint, Jeffrey Epstein was an +extraordinarily wealthy man with multiple residences in the United States, including +a New York City mansion, a Palm Beach mansion, and an island in the U.S. Virgin +Islands. +62. Beginning in and around 1998 and continuing through the summer of +2019, Jeffrey Epstein knowingly established and ran a sex-trafficking venture and +conspiracy in violation of 18 U.S.C. §§ 1591-95. As part of the venture, Epstein +used means of force, threats of force, fraud, coercion, abuse of legal process, and a +combination of these means to cause young women and girls from all over the world +to engage in commercial sex acts and to sexually abuse them. Epstein and others +also conspired to violate 18 U.S.C. § 1591. +63. In creating and maintaining this network of victims in multiple states +and in other countries to sexually abuse and exploit, Epstein worked and conspired +with others, including employees and associates who facilitated his conduct by, +among other things, recruiting victims, coercing victims, and scheduling their sexual +abuse by Epstein at his New York mansion, his Palm Beach mansion, and his island +in the U.S. Virgin Islands. +64. Epstein and his co-conspirators used Epstein's vast (yet mysterious) +wealth and connections to other rich and powerful individuals to lure victims into +his home for seemingly innocuous activity. Victims were initially recruited to speak +17 + + +OSa&222/#₽80#9885RD0000 me 67868 7-#Be 0008881323 12099189560 BB8 1 +with an allegedly philanthropic Epstein and provide "massages" to him. +65. +Epstein and +his co-conspirators had perfected a scheme for +manipulation and abuse of young females. As part of the scheme, a female +"recruiter" would approach a young female and strike up a conversation in an effort +to quickly learn about the young female's background and any vulnerabilities they +could expose. The recruiter would then manipulate the young female into coming +back to one of Epstein's residences by offering the young female something she +needed. At times, the recruiter's lure would be a modeling opportunity, money for +education, help for the young female's family, and a whole host of other related +offers depending on their target's situation. Once in the residence, the recruiter and +Epstein would work in concert to impress and intimidate the young female with +displays of vast wealth, including having employees that were butlers and maids +formally dressed around the house. They would also strategically place photographs +of very powerful political and social figures amongst photographs and art displaying +nude females in an effort to normalize the sexual abuse. They would normalize the +sexual abuse by placing a massage table and spa related products around the massage +area in an effort to legitimize the area where the abuse was set to occur. Once +abused, Epstein and his co-conspirators continued to manipulate the victims, using +their financial power, promises, and threats to ensure that the victim returned as +directed and remained compliant with their demands. +18 + + +CaGas:172224Đ80493857D000008868 7H886000888582 3 209g1 90660 BB8 1 +66. Once at the home and trapped in Epstein's bedroom the victims would +be instructed to remove their clothing. Epstein would then force the massages to +become increasingly sexual in nature, typically including one or more forced sex +acts. Epstein would use means of force, threats of force, or fraud to coerce the +victims to participate in these sex acts and to cause them to return and continue to +engage in commercial sex acts with him. Epstein and his associates then paid his +victims hundreds of dollars in cash for each sexual encounter. +67. In this District and elsewhere, Epstein perpetuated this pattern of abuse +in similar ways, hundreds of times. +68. Moreover, Epstein actively encouraged and coerced his victims to +become recruiters themselves, forcing them to recruit additional girls to be similarly +sexually abused and causing the number of victims to grow exponentially. Epstein +incentivized his victims to become recruiters by paying these victim-recruiters +hundreds of dollars for each girl that they brought to Epstein. In so doing, Epstein, +through this system of paying victims to recruit others whom he would in turn pay +to recruit others, created a sexual abuse and sex trafficking spider web and +maintained a steady supply of new victims to exploit. +69. Epstein was skilled at ascertaining his victim's greatest fears and +aspirations and targeted those fears and aspirations to coerce and trap his victims +into performing commercial sex acts and to be subject to sexual abuse. +19 + + +OaGasea222глФĐĐ0#9S85D0дo0mоe BRER 7HFB6000К88I323R0992D70Ü BB81 +70. Among other things, Epstein sexually abused his many victims and +caused his victims to engage in commercial sex acts, specifically sex acts for which +his victims received things of value, including money, promises of educational and +career advancement, a place to live, and promises that Epstein would provide various +forms of assistance. +71. Epstein provided things of value to his victims in order to coerce them +to engage sex acts with him and on occasion his friends, co-conspirators, or other +victims. +72. As one means of coercing victims to engage in commercial sex acts, +Epstein and his co-conspirators threatened that harm would come to victims if they +did not comply with his demands that they perform commercial sex acts. +73. As another means of coercing victims to engage in commercial sex acts, +Epstein and his co-conspirators fraudulently promised to further victims' +educational or career aspirations if they would comply with his sexual demands. +These promises were a quid pro quo for the sex acts that occurred. +74. +As one means of coercing victims to engage in commercial sex acts, +Epstein and his co-conspirators would give his victims money to stay quiet about the +assault or as a "finder's fee" for bringing other young women. Epstein would also +provide them with living accommodations, clothing, education, or other necessities, +exploiting the vulnerabilities of his often poor and underprivileged victims. +20 + + +OSas222/0₽80#9385RD0000 me 62868 7-#Be 0008881323112099287200 BB81 +75. In addition to coercing commercial sex acts from his victims, Epstein +also committed coercive sexual offenses against them as defined in New York Penal +Law § 130, as described in greater detail below. +76. +Throughout around 1998 through about July 2019, the Epstein's sextrafficking venture recruited, solicited, enticed, harbored, obtained, provided, and +transported hundreds of victims to cause them to engage in commercial sex acts with +Epstein and Epstein's friends. +77. At all relevant times, Epstein maintained numerous apartment units at +301 East 66" Street in New York City, where Epstein's co-conspirators often stayed +and which operated as stash houses where numerous victims were kept over the +years. +78. JP +knew of the 301 East 66"h Street Epstein properties and knew +that these units operated as victim stash houses. +79. In 2006, Jeffrey Epstein was arrested in Florida after state and federal +law enforcement discovered that he had sexually abused more than 30 children in +his Palm Beach, Florida mansion. During that investigation, the government +concluded that Epstein and his co-conspirators had committed federal criminal acts +constituting violations of the TVPA and other federal laws, including 18 U.S.C $8 +2422(b), 2423(f), 2423(b), 2424 (e); 18 U.S.C § 371; 18 U.S.C §§ 1591(c)(1), +1591(a)(1), 1591(a)(2); as well as state crimes in violation of Florida Statutes §8 +21 + + +CaGasiI7222гwAĐ80493857D0000m0e 8X868 7H#Be6000888582 3 R099฿233 0 BB8 1 +796.07 and 796.03, against dozens of young women. +80. +As a consequence of the Florida investigation, Epstein pled guilty to +two felonies, was permanently labeled a "Registered Sex Offender," and was jailed +in 2008. Epstein also entered into a non-prosecution agreement with the U.S. +Attorney's Office for the Southern District of Florida barring his prosecution (and +prosecution of his known and unknown co-conspirators) for violations of the TVPA +and other sex offenses in Florida. When the U.S. Attorney's Office entered into that +non-prosecution agreement with Epstein, it had not received reports from JP +about vast sums of cash that it was providing Epstein. Nor did JP +provide +any other assistance in the investigation. +81. Epstein's criminal case in Florida and the many related news reports +left no doubt about Jeffrey Epstein and his extraordinary penchant for sex abuse and +trafficking of young females. For instance, it was reported that up until the time of +his Florida arrest in July 2006, Epstein had been sexually abusing during that year +and the previous year three to four young females per day; it was a full-time job for +him. +82. +Beginning with his 2006 Florida arrest and for years moving forward, +Epstein was embroiled in dozens of public lawsuits detailing his sexual abuse of +females, and thousands of news stories circulated worldwide about his illegal sexual +proclivities. +22 + + +OSas:222/#₽80#9885D0000 me 6868 7-#Be 0008881323 19928706Ü BB81 +83. Epstein paid millions of dollars to settle sexual abuse lawsuits filed +against him by many victims. The money used to make settlement payments was +paid from Epstein-related entity accounts at JP +And while he was paying +to settle these claims, Epstein was continuing to abuse new victims—all facts known +to JP +84. +In addition to the many civil lawsuits seeking damages for sexual abuse, +Epstein's victims also filed a public lawsuit against the Unites States under 18 U.S.C. +§ 3771, the Crime Victim's Rights Act ("CVRA"), further exposing Epstein's sexual +crimes as well as his secret Non-Prosecution Agreement with the Federal +Government. +85. Epstein recruited, solicited, enticed, harbored, obtained, provided, and +transported his victims to cause them to engage in commercial sex acts in ways that +were in and affecting interstate and foreign commerce, including using means of +interstate communications (such as cell phones) and means of interstate and foreign +travel (such as aircraft that he owned and controlled). +86. Epstein transported his victims in interstate and foreign commerce, +including transportation to and from his mansion in this District. +87. The Epstein sex-trafficking venture transported victims across state +boundaries between New York, Florida, New Mexico, New Jersey, Massachusetts, +the U.S. Virgin Islands, and elsewhere, and in foreign commerce between the United +23 + + +OSas:222/#₽80#9385RD0000 me 67868 7HREe 00083853231109924350 BB81 +States and Europe, especially Eastern Europe. +88. +At all times relevant to this complaint, the Epstein sex-trafficking +venture was a group of two or more individuals associated in fact, even if they were +not a formal legal entity. Indeed, members of the Epstein sex-trafficking venture +referred to it as "The Organization." Epstein was continuously at the hub of The +Organization, which operated throughout the times indicated in this complaint. +On July 2, 2019, the United States Attorney's Office for the Southern +District of New York filed a sealed, two-count Indictment against Epstein, including +one count of sex trafficking conspiracy and one count of sex trafficking for violations +of 18 U.S.C. § 1591, in part due to Epstein's criminal activities in his New York +Mansion located at 9 East 71st Street. See United States v. Jeffrey Epstein, Case No. +1:19-cr-00490 (S.D.N.Y.). +90. On July 8, 2019, Epstein was arrested pursuant to the New York +Indictment. +91. On August 10, 2019, prison guards found Epstein unresponsive in his +Metropolitan Correctional Center jail cell, where was awaiting trial on the federal +sex trafficking charges. He was later pronounced dead from apparent suicide. +92. In July 2020, Epstein's co-conspirator in the sex-trafficking venture, +Maxwell, was arrested on federal sex-trafficking charges filed in the Southern +District of New York. The charges alleged that she had assisted, facilitated, and +24 + + +OaGas222гл/ФĐĐ0#9885D0дo0umоe BT868 7FFBe000К88T323 R0992B66Ü BB81 +contributed to Epstein's abuse of sex-trafficking victims, helping Epstein to recruit, +groom, and ultimately abuse his victims. See United States v. Maxwell, Case No. +1:20-cr-00330 (S.D.N.Y.). +On December 29, 2021, after a weeks-long jury trial during which +witnesses testified about Epstein's sex-trafficking operation in painstaking detail, +Maxwell was found guilty on five federal sex-traffficking counts and is now serving +nearly 20 years in federal prison for these crimes. +B. Consistent With Jeffrey Epstein's Uniform Pattern and Practice, Jane +Doe 1 Was Forced to Engage in Commercial Sex Acts with Epstein by +Means of Force, Fraud, and Coercion. +94. Jane Doe 1 was living with her mother when she met Jeffrey Epstein in +2006. +95. At that time, Jane Doe 1 was a ballet dancer in New York. Another +young female who had also fallen prey to Jeffrey Epstein's sex trafficking scheme +recruited Jane Doe 1 to meet Epstein. +96. Epstein and his co-conspirators had a long history of grooming, +indoctrinating, controlling, and ultimately committing sexual offenses against +young, vulnerable women like Jane Doe 1. Epstein and his co-conspirators +constantly reminded Jane Doe 1 how powerful and important Epstein was. Jane Doe +1 was chastised if she refused Epstein's sexual demands and told she should be +grateful that Epstein was willing to help her with her career and education. She came +25 + + +CaGasiI7222zoAĐ80493857D0000mee 8X868 7H#Ee6000888582 3 R09g2฿7060 BB8 1 +to believe what she was told. +97. +The well-oiled Epstein sex abuse and trafficking venture included +frequent statements to Jane Doe 1 and other victims by Epstein and his +co-conspirators that: (1) Epstein possessed extraordinary wealth, power and +influence; (2) Epstein's business and political friends, including world leaders, also +included some of the most powerful people in the world; (3) Epstein had the ability +to advance or destroy nearly anyone financially, reputationally, and otherwise; +(4) medical and other life necessities would be denied victims if they, including Jane +Doe 1, failed to perform commercial sex acts for Epstein; and (5) Epstein could take +away Jane Doe I's and other victims' life necessities such as shelter or housing if +she or they failed to perform those acts. +98. Jane Doe 1 was exceptionally vulnerable to being victimized by +Epstein. His sex-trafficking venture targeted vulnerable young women and Jane Doe +1 was soon indoctrinated and unable to extricate herself. Jane Doe 1 was sexually +abused and trafficked by Epstein for several years. Having been conditioned that +the sexual abuse was "normal" and knowing that everyone surrounding Epstein, +including accountants, lawyers, and other important people, were aware of the sex +abuse, Jane Doe 1 was coerced into a cult-like life controlled and manipulated by +Epstein and others doing Epstein's bidding. +99. +Over the ensuing years, from 2006 through 2013, Epstein sexually +26 + + +OSas:222/#₽80#9385D0000 me 67868 7-#Be 000888532311099278860 BB81 +abused Jane Doe 1 on a number of occasions in New York, Florida, New Mexico, +and the United States Virgin Islands in direct violation of Article 130 of New York's +Penal Law, including but not limited to the following: +a. Sexual misconduct as defined in §130.20, inasmuch as Jeffrey Epstein +engaged in sexual intercourse with Plaintiff without Plaintiff's consent; +b. Rape in the first degree as defined in §130.35, inasmuch as Jeffrey +Epstein engaged in sexual intercourse with Plaintiff by forcible +compulsion; +c. Criminal sexual act in the first degree as defined in §130.50, inasmuch +as Jeffrey Epstein engaged in oral sexual conduct with Plaintiff by +forcible compulsion; +d. Forcible touching as defined in §130.52, inasmuch as Jeffrey Epstein, +intentionally and for no legitimate purpose, engaged in the forcible +sexual touching of Plaintiff for the purpose of degrading or abusing her +or for the purpose of gratifying his own sexual desire; and +e. Sexual abuse in the third degree as defined in §130.66, inasmuch as +Jeffrey Epstein inserted a foreign object in the vagina of Plaintiff by +forcible compulsion. +100. Jane Doe 1 was also coercively trafficked to Jeffrey Epstein's friends +for commercial sex acts in this District. +101. Epstein used means of force, threats of force, fraud, coercion, abuse of +process, and a combination of such means to cause Jane Doe 1 to engage in +commercial sex acts. +102. Epstein recruited Jane Doe 1 to cause and force her to engage in +commercial sex acts in ways that were in and affecting interstate and foreign +27 + + +OSas:222/0₽80#9885RD0000 me 6X868 7-#Be 000888323110992В750 BB8 1 +commerce, including use of cell phones and means of interstate transportation (such +as aircraft that he owned or controlled). +103. Epstein transported Jane Doe 1 from New York to other states to cause +her to engage in commercial sex acts. +104. Jane Doe 1 wanted to escape from the Epstein sex-trafficking venture, +yet Epstein and his supporting team of co-conspirators increased the tactics of fraud, +force, or coercion to cause her to remain compliant in fulfilling Epstein's sexual +demands. +105. Jeffrey Epstein controlled Jane Doe 1 financially, emotionally, and +psychologically. He used his knowledge of Jane Doe 1's aspirations, fears, and +problems to manipulate her until she was completely controlled by and dependent +upon him. +106. When Epstein went to jail for sex offenses in Florida, he maintained +contact with Jane Doe 1. He and employees of his business entities, which were +created to support and legitimize Epstein's sexual abuse and sex-trafficking +enterprise, including HBRK, NES, Financial Trust, and Florida Science Foundation, +caused Jane Doe 1 to be transported to Florida to engage in commercial sex with +Epstein in his Florida residence while on so-called "work release" from jail, while +he was still wearing his ankle monitor. +107. There came a time when Epstein forced Jane Doe 1 to give massages to +28 + + +OSas222#₽80#9885RD0000 me 6868 7-#Be 00088813231999298660 BB81 +certain of his powerful friends. During some of these massages Jane Doe 1 was +sexually abused, by force and against her will, by Epstein's friends whom she had +been required to massage. At least one of Epstein's friends used aggressive force in +his sexual assault of her and informed Jane Doe 1 that he had Epstein's permission +to do what he wanted to her. Out of fear, Jane Doe 1 has still not named this powerful +financial executive publicly. +108. Epstein and his co-conspirators withdrew large sums of cash from JP +to make cash payments to victims, including Jane Doe 1, in furtherance of +the sex-trafficking operation. +109. Jane Doe 1 was regularly paid cash by Epstein or one of his coconspirators that was withdrawn from one of Epstein's accounts at JP +110. As alleged more fully below, JP +knew that its accounts were +being used for Epstein's sex-trafficking venture based on a number of facts, +including but not limited to the identity of the individuals making the withdrawals +and wire transfers, the vast size of the withdrawals and transfers, the identity of the +recipients, the account opening activity, the pattern of the financial activity, the +personal relationship between Epstein and at least one high-ranking executive with +as detailed more thoroughly below, and Epstein's well-documented +criminal history and involvement in trafficking. +111. Over the ensuing years, Epstein threatened Jane Doe 1 in many ways +29 + + +CaGas:172224Đ80493857D000009 8868 7 FEed000888583 3 209988860 BB8 1 +including threatening that if she did not abide by his demands, she would lose contact +with people she cared about and that those people would also suffer serious harm. +112. Epstein would alternate promises and threats to secure Jane Doe I's +compliance with his demands, including demands that she engage in commercial sex +acts with him and others. In some instances, Epstein would pay Jane Doe 1 directly +in cash obtained from JP +for sex acts. +113. Epstein and his co-conspirators continued to coerce Jane Doe 1 in +various ways until her ultimate escape around the end of 2013. +114. Epstein and his co-conspirators continued to coerce Jane Doe 1 to +engage in commercial sex with Epstein, through the use of Epstein's force, fraud +(such as false promises, including the continued promise to assist Jane Doe I's sister +medically) and coercion (making it clear that if she did not abide then she would +suffer serious financial and reputational harm), through the end of 2013. +115. James "Jes" Staley ("Staley"), the then-head of JP +private +banking division, was a regular visitor of Epstein's during that period of time, +through and beyond 2013, and personally observed Jane Doe 1 as a sexual trafficking +and abuse victim at times including through his departure from JP| +in 2013. +C. JP +Role in the Sex-Trafficking Venture +1. Banking laws and regulations exist to prevent funding of criminal ventures. +116. The Federal Bank Secrecy Act ('BSA") requires financial institutions +30 + + +OSa&222#080#9385RD0000 me 6X868 7-#Be 000888182312099983830 BB81 +to have adequate anti-money laundering ("AML") policies and systems in place. +New York state law also requires financial institutions to devise and implement +systems reasonably designed to identify and report suspicious activity and block +transactions prohibited by law. +117. All regulated institutions are expected to configure systems based on +their unique risk factors, incorporating parameters such as institution size, presence +in high-risk jurisdictions, and the specific lines of business involved, and the +institutions have an affirmative duty to ensure that their systems run effectively. +118. In addition to having effective AML controls in place, it is also +necessary for financial institutions to monitor their customers for the purpose of +preventing their customers from facilitating criminal activity using the institutions' +facilities. +119. As part of preventing criminal activity, Know Your Customer ("KYC") +and customer due diligence are critically important, and financial institutions must +collect customer information at the time of establishing new relationships with +clients, including as necessary to assess the risks associated with the client. To +properly consider these risks, financial institutions must consider relevant factors +such as the nature of the client's business, the purpose of the client's accounts, and +the nature and duration of the relationship. +120. Financial institutions must also conduct KYC reviews for each client +31 + + +OaGasea222глФĐĐ0#9S85RD0д00umоe BRER 7H#B6000К88T823 12099983950 BB81 +relationship at intervals commensurate to the AML risks posed by the client, +including reviewing account activity to determine whether such activity fits with +what would have been expected given the nature of the account. Each client's AML +risk should also be re-assessed if material new information or unexpected account +activity is identified. +121. Financial institutions must also establish criteria for determining when +a client relationship poses too high of a risk and therefore must be terminated. A +financial institution may be liable under applicable laws if it maintains such a +relationship despite repeated indications of facilitation of improper transactions. +2. JP +directly participated in Epstein's sex-trafficking venture. +122. With the encouragement of Staley, JP +knowingly and +intentionally participated in the Epstein sex-trafficking venture by (among other +things) providing the financial underpinnings for Epstein to have ready and reliable +access to resources—including cashto recruit, lure, coerce, and entice young +women and girls to cause them to engage in commercial sex acts and other +degradations. +123. In or about 1998, in furtherance of his rapidly growing sexual abuse +and sex trafficking operation, Epstein realized that he needed a reliable banking +institution that would provide the necessary legitimate appearance for his operation, +allow him to open many accounts for illegitimate companies, ignore red flags and +32 + + +OSas222#₽80#9885RD0000 me 62868 7H78600088323 12999839360 BB81 +relevant state and federal banking laws, permit him to transfer money without +questioning, +allow him access to abundant cash, and to otherwise knowingly +facilitate the commercial aspect of his commercial sex trafficking enterprise. +Epstein found all of those things in JP +124. From about 1998 through 2013 (and following), JP +knowingly +and intentionally participated in the Epstein sex-trafficking venture by (among other +things) providing the essential financial underpinnings for the venture. It also +financially benefited from that participation. There can be no doubt that JP +conduct, as described below, was outrageous and intentional. +125. Around 2000, Epstein developed a key relationship to expanding +exploitative sexual abuse and his sex-trafficking operation when he began working +with Staley, the then-head of JP +private banking division. +126. Before meeting Staley, Epstein was a serial sexual abuser of young girls +and women, with an insatiable desire to sexually abuse females that were, in his +words, "the younger, the better." +127. Before Staley, Epstein relied heavily on the massive wealth bestowed +upon him primarily by one individual, Leslie (Les) Herbert Wexner ("Wexner"), to +give him the appearance of grand importance while relying on his then-madame, +Maxwell, to find and groom young women to be abused. +128. It has been reported that Wexner claims Epstein stole the money from +33 + + +OSas:222/#₽80#9885RD0000 me 67868 7-#Be 000888132311209968850 BB81 +him. Nonetheless, the origin of Epstein's money was always a mystery, with Epstein +claiming to be a money manager to a stable of clients who entrusted him with a +minimum of $1 billion. JP +I knew that was a lie. Staley knew without any +doubt that Epstein was trafficking and abusing girls and that all of his staff, including +his main attorney and accountant, worked full time to conceal the illegal operation. +129. However, Epstein could not expand his operation to the level it +ultimately reached without a complicit financial banking institution that would +ignore red flags and assist him in paying hundreds of young females in wire transfers +and cash and allow him access to hundreds of thousands of dollars in cash to pay +hush money to his growing number of victims. +130. Staley was the key to making all of Epstein's depraved dreams of sexual +abuse and sex trafficking of countless young women possible. With his help, the +number of victims of the Epstein sex-trafficking operation began to grow on a +vertical trajectory beginning in and around 2000. +131. When Epstein and Staley first teamed up, in or around 2000, Staley was +the head of JP +private banking division and was later promoted to CEO of +Asset Management in 2001. +132. The relationship between Epstein and Staley was symbiotic and special. +Epstein agreed to bring many ultra-high wealth clients to JP +and in +exchange, Staley would use his clout within JP +to make Epstein +34 + + +OSa&222#080#9885RD0000 me 6868 7-#Be 000888823120999858660 BB81 +untouchable. +133. Staley bragged within JP +about Epstein's value to the bank and +used his position in the bank to silence any critics of the relationship between JP +and Epstein. +134. This meant that JP +would keep Epstein on as a client at all +costs, including failing to act on any red flags and ultimately allowing him to run +and grow an operation designed to sexually abuse and traffic countless young girls +and women. +135. Once Epstein had JP +(through Staley) in his pocket, Epstein +moved on to his next target, another known sexual abuser, Jean-Luc Brunel, a +model scout who had suffered public disgrace for serial sexual abuse of young +females. +136. Epstein enlisted Brunel to recruit new victims from all over the world, +enticing them with promises of modeling careers before sexually abusing and +trafficking them through a modeling agency Epstein and Brunel established called +MC2. +137. In 2019, Brunel was arrested in France for sex trafficking related to his +relationship with Jeffrey Epstein and, like Epstein, was found hanging in his cell +from an apparent suicide. +138. There were several key figures who conspired and participated in +35 + + +OSas222/0₽80#9385RD0000 me 6X868 7-#Be 0008881823 299988860 BB81 +Epstein's international sex trafficking operation, most notably Ghislaine Maxwell, +Les Wexner, Jean Luc Brunel, and Jes Staley, acting through and on behalf of JP +139. In later years, Deutsche Bank swapped in for JP +and provided +the necessary complicit financial institution for the operation, not coincidentally onboarding Epstein's trafficking operation through a former JP +banker, Paul +Morris. +140. These co-conspirators were essential to Epstein's operation. Without +Maxwell, Epstein would never have been able to recruit his first victims and bring +them into his abusive lair. Maxwell approached young, vulnerable victims and +painted Epstein as an altruistic messiah who could help them. Once the girls were +in Epstein's clutches, Maxwell groomed them to make them feel comfortable being +sexually exploited and abused. +141. Without Brunel, Epstein would not have been able to expand his +international recruiting of young victims and, specifically, aspiring models he could +lure in with promises of opportunities. +142. Without Wexner, Epstein's sex-trafficking operation could never have +occurred to the extent that it did, as Epstein needed the appearance of extraordinary +wealth to attract his victims and force them to stay silent. +143. However, +even with Wexner's funding of Epstein's operation, +36 + + +ОaGase1222zФĐ00#9S85RD0дo0mоe BRER 7H#B6000К88I32312099698860 BB81 +Epstein's sexual abuse of hundreds of women would have been limited because the +money trail from Epstein's accounts to the many victims and recruiters would have +quickly exposed his illegal venture. +144. Therefore, Epstein could not risk having a typical banking relationship +where the bank might uncover something suspicious and report him to law +enforcement. +• The final essential ingredient Epstein needed to expand his sexual +abuse of young women and sex trafficking enterprise was therefore a financial +institution that would know—but not care that Epstein was sexually abusing +women on a daily basis and paying out millions in hush money. Indeed, Epstein +needed an institution that would in fact assist and participate in that activity, and that +would support his enterprise and conceal it if he was ever caught. +145. JP +provided the final component Epstein needed, and Staley +had a special relationship with Epstein and made sure Epstein and his illegal sexual +abuse organization were absolutely protected by the bank. +146. From the beginning of the Epstein/Staley relationship, Staley +understood that Epstein's money was only a part of the incentive to protect Epstein's +operation. +147. During the Palm Beach Police Department's 2005 investigation into +Epstein's sexual abuse of minor children, the detectives pulled message pads left by +Epstein's assistant from his trash as well as a search warrant executed at Epstein's +37 + + +OaGase1a222zлФĐ00#9S85RD0дo0umоe BRER 7HFBe000К88I5823 209968956Ü BB81 +Palm Beach, Florida mansion. +148. According to those message pads, Staley was a frequent caller to +Epstein's Florida home throughout the course of Epstein's banking relationship with +IMPORTANT MESSAGE +Tefte y +N. THE TME 4:40M +" Joss stuly +PHONE! +MOBILE. + +TELEPHONED +PLEASE CALL +CAME TO SEE YOU +WILL CALLAGAN +WANTS TO SEE YOU +RUSH +RETURNED YOUR CALL +SPECIAL AITENTION +VESSAGE +IMPORTANT MESSAGE +FOR. +Mr. J.E. +DATE +м /: +12/21/09 +THE 10:20 SI +Jess Stanley +OF +п0w: (212) 837-2375 +TELEPHONED +PLEASE CALL +CAME TO SEE YOU +WILL CALL AGAIN +WANTS TO SEE YOU +RUSH +RETURNED YOUR CALL +SPECIAL ATTENTION +MESSAGE- +'Roturning four +Cell" +SAO01088 +SIGNED +IMPORTANT MESSAGE +FOR_ +JE +DATE — +3/18/05 +- TIME & 02AM +oF (212) 744 - 0770 +TELEPHONED +CAME TO SEE YOU +WANTS TO SEE YOU +RETURNED VOUR CALL +PLEASE CALL +WILL CALL AGAIN +RUSH +SPECIAL ATTENTION +MESSAGE +SIGNED. +IMPORTANT MESSAGE +FOR_MR: EPSTEIN +DATE +05/21/04 +THe 6.49 PM +_ JES +STALEY +OF L HE +MEE 212 744. 0770 +TELEPHONED +PLEASE CALL +CAME TO SEE YOU +WILL CALL AGAIN +WANTS TO SEE YOU +RUSH +RETURNED YOUR CALL +SPECIAL ATTENTION +MESSAGE.- +' CALL ME * +SAO2834 +SIGNED_ +BIGNED +38 + + +OSas:222/#₽80#9885RD0000 me 6868 7-#Be 000888582311996006Ü BB81 +IMPORTANT MESSAGE +FOR. +TR ERSTEIN +DATE - +ON JEFF STALEY +OF +MOSE 2/2 744 0770 +TELEPHONED +CAME TO SEE YOU +WANTS TO SEE YOU +RETURNED YOUR CALL +/ PLEASE CALL +WILL CALL AGAIN +RUSH +SPECIAL ATTENTION +MESSAGE +CALLED +AM. +PM. +IMPORTANT MESSAGE +FOR +DATE. +м.К +J.F +1/11/05 +TME 6:27 A1- +Jess Stelay +00(00) 912-7145 +TELEPHONED +PLEASE CALL +CAME TO SEE YOU +WILL CALL AGAIN +WANTS TO SEE YOU +RUSH +RETURNED YOUR CALL +SPECIAL ATTENTION +MESSAGE +Fl6256 call ma +back!" +SA +SIGNED. +SIGNED +149. On at least one occasion it appears Staley and Les Wexner called +Epstein together. +IMPORTANT MESSAGE +MIL. ETSTEN +IME +_AM. +DATE. +M.- +OF- +LES SESS +TELEPHONED +CAME TO SEE YOU +WANTS TO SEE YOU +RETURNED YOUR CALL +PLEASE CALL +WILL CALL AGAIN +RUSH +SPECUL ATTENTION +MESSAGE. +SAO2852 +150. As long as Epstein's money stayed at JP| +Staley also knew that +Wexner, Epstein's client who had turned over a power of attorney to Epstein, would +likewise keep his money with JP +Wexner's money was said to amount to +39 + + +OSas:222/#₽80#9885D0000 me 67868 7-#Be 00088882372999$0960 BB81 +over a billion dollars. +151. Epstein made clear that Wexner was not the only JP +client +whose allegiance to the bank Epstein controlled. Staley knew that Epstein "collected +people" and was close with many ultra-wealthy individuals that he could bring into +the bank, and Epstein did bring additional customers to the bank in exchange for JP +aiding and facilitating his international sex trafficking operation. These new +customers made JP +even more profitable. Along the way, Epstein gave +credit for these new bank customers to Staley, which made Staley even more +powerful within JP +152. Epstein controlled Staley like he did his many victims: by flaunting his +power and connections to the extremely wealthy. Epstein made it clear to Staley +that if JP +ever decided to terminate its relationship with Epstein, the bank +would lose Wexner and the other wealthy connections Epstein had promised JP +153. Staley and Epstein's relationship grew closer as the years went on. In +fact, during the criminal investigation into Epstein in 2005, Staley flew on Epstein's +plane along with +individuals who had bank +accounts through Epstein at JP +and who were publicly identified as +Epstein's co-conspirators in trafficking offenses. +154. Rather than merely providing routine banking for Epstein, JP +40 + + +OaGas7222г/ФĐĐ0#9S85RD0д00mоe 6T868 7F#B6000838T823 0008381823120999*1930 BB81 +went far beyond what a non-complicit bank would have done and instead assisted +Epstein in setting up the necessary financial structure to operate his sex-trafficking +venture. +155. Specifically, money was paid from Epstein affiliated JP +accounts to victims of trafficking and to known Epstein co-conspirators. Money was +also withdrawn from Epstein affiliated JP | +accounts in cash to pay victims +in furtherance of the sex trafficking operation. +156. JP +also deliberately failed to follow routine banking practices +of review Epstein's accounts against the backdrop of the public information outing +him as a serial sex abuser and reporting Epstein for what was obviously a sex +trafficking operation he was running. JP +for example, purposely and +deliberately failed to timely file required Suspicious Activity Reports ("SARs") for +large cash and other suspicious activities of Epstein. In short, instead of providing +ordinary and routine banking, JP +instead assisted Epstein in covering up his +past crimes and committing new ones. +157. Acting on behalf of JP +Staley assured Epstein that the two +were close friends and he would help Epstein and his operation in any way he could. +advised Epstein strategically about opening new accounts for additional +Epstein-related entities and assured him his cash needs would be satisfied +permitting Epstein to continue to pay hush money to victims that could harm Epstein + + +CaGasłI7222zsAĐ80493857D0000m0e 8X868 7H#Ee6000888582 3 R09g$29560 BB8 1 +in the criminal investigation. +158. JP +chose not to cooperate with law enforcement and other +investigations into Epstein's sex trafficking, because it knew it would be exposed as +assisting in Epstein's scheme. +159. During a trip to the U.S. Virgin Islands in January 2007, Jane Doe 1 +was repeatedly raped and coerced into commercial sex. She was paid $10,000 in +hush money, which Epstein's agents apparently withdrew from JP| +in cash. +Epstein told Jane Doe 1 he expected her to remain loyal to him and compliant, +making clear that if she did not, then she would suffer serious harm. +160. Epstein was one of the most coveted clients of JP +because of +the financial benefits he provided to JP +and its officers and employees, +including Staley. Through the years, Staley helped accumulate other protectors of +Epstein within JP +161. The New York Times reported in 2019 that Mary C. Erdoes, one of JP +highest-ranking executives intervened to keep Epstein as a client after he +pled guilty to sex crimes and was registered a sex offender. +162. With JP +complicity, Epstein was free to sexually abuse +hundreds of women, paying millions in hush money, without the fear of detection +by law enforcement. Epstein used the support of a reputable institution-JP +-to help cover up his sex-trafficking venture. +42 + + +163. JP +cared about profiting and showed absolute loyalty to +Epstein, including a willingness to violate banking laws, ignore multiple red flags of +criminality, and participate directly in sex trafficking to enable Epstein to fulfill his +abusive sexual appetite at the expense of countless vulnerable young women. +164. As Epstein's criminal sex trafficking venture expanded, he needed +more protection and support from JP| +became more deeply involved with JP +Through Staley and others, Epstein +providing JP +with more +financial benefits. And. as a quid pro quo, JP +allowed Epstein to transfer +massive amounts of hush money to his victims and recruiters. JP +allowed +Epstein to withdraw hundreds of thousands of dollars in cash so that all the payments +were not traceable (the most obvious red flag for any criminal enterprise). +165. As another example of JP +_ and Staley's benefit from assisting +Epstein, a highly profitable deal for JP +was the Highbridge acquisition. +166. In 2004, when Epstein's sex trafficking and abuse operation was +running at full speed, Epstein served up another big financial payday for JP| +167. Epstein was close friends with Glenn | +, the billionaire who ran +Highbridge Capital Management. +168. Through Epstein's connection, it has been reported that Staley arranged +for JP +to buy a majority stake in +fund, which resulted in a sizeable +profit for JP +This arrangement was profitable for both Staley and JP +43 + + +ОaGas222zФĐĐ0#9S85RD0дocmюe 6T868 7F#B6000К88B23199Ф195Ü BB81 +further incentivizing JP +to ignore the suspicious activity in +Epstein's accounts and to assist in his sex-trafficking venture. +169. For example, despite that Epstein was not FINRA-certified, Epstein +was paid more than $15 million for his role in the Highbridge/JP +deal. +170. Moreover, Highbridge, a wholly-owned subsidiary of JP | +trafficked young women and girls on its own private jet from Florida to Epstein in +New York as late as 2012. +171. Staley and JP +benefited from Epstein's sex-trafficking +operation because, in exchange for JP +knowing participation in that +operation, Epstein generated millions of dollars for JP +directly and +indirectly. Because Staley was generally in charge of Epstein's JP| +accounts, +he also benefited in the receipt of massages, private jet flights with victims or coconspirators of the operation, and other things of value. +172. Over many years, some JP +executives lobbied within JP +to sever ties with Epstein due to the sex-trafficking allegations against him. +leadership ignored their pleas and ultimately decided each time to keep +Epstein as a client. JP +decided that, because it was receiving such large +monetary benefits from Epstein, it would continue participating in the Epstein sextrafficking venture by providing its financial infrastructure. +173. Epstein offered his business, and the many millions it generated, +44 + + +OSas:222#₽80#9385D0000 me 6868 7-#Be 00088823 1999฿5060 BB81 +exclusively to JP +because JP +was willing to knowingly aid Epstein's +sex trafficking operation and to help conceal it. JP +knew that if it stopped +aiding and concealing the operation, it would lose Epstein's accounts and the +substantial financial benefits resulting from handling those accounts. +174. In addition to housing Epstein's accounts, JP +also housed +accounts for numerous of Epstein's co-conspirators, including Epstein's main sextrafficking madame, Maxwell, who is now serving 20 years in prison for sextrafficking related to her participation in Epstein's operation. +175. In 2022, JP +representative +McHugh testified in +Maxwell's criminal sex-trafficking trial that between 1999 and 2007, Epstein +transferred approximately $31 million to Maxwell, an amount believed to be +payment for her role in Epstein's sex trafficking venture. +176. In addition to the necessary financial infrastructure provided by JP +, as late as 2012, a JP +subsidiary company assisted with transporting +certain Epstein sex-trafficking victims by private jet from Florida to Epstein in New +York. +177. Ultimately, JP +financially benefited by earning millions of +dollars for its participation in the Epstein sex-trafficking venture. +178. Throughout its relationship with Epstein, JP| +violated numerous +banking laws and regulations in order to conceal and continue its lucrative venture +45 + + +OSas:7222/#₽80#9885RD0000 me 6868 7HREe 0008881323 2999฿69060 BB81 +facilitating the Epstein sexual abuse and sex-trafficking scheme. +179. For example, JP +allowed Epstein and his agents to "structure" +cash withdrawals to further the sex-trafficking venture. +180. As another example, JP +failed to file with the federal +government the required SARs that financial institutions must file with the Financial +Crimes Enforcement Network ("FinCEN") whenever there is a suspected case of +money laundering or fraud. Timely filing of these reports is required by the Bank +Secrecy Act and related laws and regulations. These reports are tools that the federal +government uses to detect and prosecute, among other illegal activities, sex +trafficking in violation of the TVPA. While JP +was providing Epstein vast +sums of cash each year, it was required to timely file SARs about Epstein's +suspicious and unusual cash transactions. +181. JP +failure to timely file SARs about Epstein's sex-trafficking +venture, in spite of numerous red flags, was wrongful and purposeful. +182. A recent amended complaint filed by the government of the U.S. Virgin +Islands against JP +in this Court describes some of the red flags JP| +simply ignored: +Between 2003 and 2013, Epstein and/or his associates +used Epstein's accounts to make numerous payments to +individual women and related companies. 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. +46 + + +OaGase222глФĐĐ0#9S85RD0дo0mоe BT868 7H#B6000К88T323 1099$7986Ü BB81 +For example, Epstein paid more than $600,0000 to Jane +Doe 1, a woman who-according to news reports +contained in JP +due diligence reports-Epstein +purchased at the age of 14. Like other women who +received payments +from Epstein, Jane Doe 1 listed +Epstein's apartments on 66th Street in New York City as +her address, which should have been a red flag to JP +Epstein and/or his associates also made significant cash +withdrawals and 95 foreign remittances with no known +payee. For example, Hyperion Air, Inc.—the Epsteincontrolled company that owned Epstein's private jet— +issued over $547,000 in checks payable to +cash +purportedly for "fuel expenses when traveling to foreign +countries." Additionally, between January 2012 and June +2013, Hyperion converted more than $120,000 into +foreign currency. Many of these cash withdrawals either +exceeded the +: $10,000 reporting threshold or were +seemingly structured to avoid triggering the reporting +requirement. This is particularly significant since it is well +known that Epstein paid his victims in cash. +In addition, Epstein and/or his representatives appeared to +be misusing JP +accounts for Epstein's purported +charitable +organizations, including the C.O.U.Q. +Foundation and Enhanced Education. Epstein made +payments trom these accounts with no clear nexus to the +organization's charitable purpose. For example, Epstein +and/or his representative used the C.O.U.Q. Foundation +account to pay $29,464.66 to three young women, +including two known victims, and over $20,000 to a +company called Phoenix Realty Home Inc. +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., +Case No. 22-cv-10904-JSR, Amended Complaint (Dkt. 16) at 16-17 (S.D.N.Y. +47 + + +OSas:7222#₽80#9885D0000me 62868 7-#Be 0008885323 12999$89560 BB81 +Jan. 10, 2023).' +183. In taking the steps described above, JP | +obstructed, attempted +to obstruct, and interfered with the federal government's enforcement of the TVPA, +including the U.S. Attorney's Office for the Southern District of Florida's criminal +investigation of Epstein in and around 2006 to 2008 and the U.S. Attorney's Office +for the Southern District of New York's criminal investigation leading to his +indictment in 2019. +184. Over the many years of the venture between JP +and Epstein, +numerous JP +executives, and several compliance officers, demanded that JP +sever ties with Epstein and his criminal organization due to the public sextrafficking allegations against Epstein. But JP +leaders and those in control +of those decisions were influenced by Staley to continue to support Epstein. Given +all the surrounding circumstances and Staley's knowledge, JP +decisions +to support Epstein were made with knowledge that he was operating a sex-trafficking +' Jane Doe 1 hereby adopts by reference the substantive factual allegations +regarding JP +participation in Epstein's sex-trafficking venture and +conspiracy found the U.S. Virgin Islands' (USVI) Amended Complaint against JP +into this Amended Complaint. See Fed. R. Civ. P. 10(c). A copy of that +amended complaint is attached to this complaint as Exhibit 1. With regard to issues +concerning the scope and duration of JP +participation in the venture and +conspiracy, as well as the nature of the venture and conspiracy, Jane Doe 1 relies on +her own complaint. Jane Doe 1 does not believe any of the substantive factual +allegations by the USVI are inconsistent with hers. But, if any inconsistency exists, +Jane Doe 1 relies solely on her allegations. +48 + + +Caste? 1229004901935D 0000emeR17867 FeDOMCRE FiRge5000288181 +venture and conspiracy. +185. +In 2013, due to the overwhelming publicity about Epstein's illegal +sexual activities, and the departure of Staley from JP | +1 JP L +realized +that its claims to not knowing what Epstein was doing were no longer facially +plausible. Accordingly, and reluctantly, JP +stopped being Epstein's banker. +186. While JP +stopped being Epstein's banker, it did not make a +clean break of things by disclosing its actions in support of the conspiracy to the +authorities. Nor did it communicate its abandonment of its conspiring with Epstein +and others in a manner reasonably calculated to reach Epstein's co-conspirators. +187. While JP +stopped being Epstein's banker, it continued to take +subsequent actions to promote the venture and conspiracy. For example, it +deliberately and willfully continued to fail to timely file SARs about the suspicious +activities it had seen. And it continued to recommend Epstein as good client to +others how inquired. +188. After losing Staley, Epstein no longer had his primary protector at JP +In order to continue to operate, Epstein would need to find a new bank. As +alleged in greater detail in another complaint pending before this Court, Epstein +found that new bank to facilitate his sex trafficking venture-Deutsche Bank. See +Jane Doe 1 v. Deutsche Bank Aktiengesellschaft et al., Case No. 22-cv-10018-JSR, +Amended Complaint (S.D.N.Y. Jan. 13, 2023). +49 + + +Caste? 122900401935 000emeR17867 FOCRE FIggy 55106 288181 +3. JP| +knew about Epstein's sex-trafficking venture and conspiracy. +189. As explained above, between (at least) 2000 and 2005, Epstein +provided clients to JP +and, in exchange, JP +allowed Epstein to do +as he pleased with his JP +accounts. JP +directly aided Epstein's sex +trafficking venture by allowing Epstein to engage in structuring violations and other +financial maneuvers required to maintain and conceal his criminal enterprise. JP +financially benefited from allowing Epstein to use his JP | +accounts +to run his sex trafficking venture. +190. However, in 2006, Epstein's relationship with JP +hit a snag +when Epstein was publicly exposed for sexually abusing dozens of young women +and girls, several as young as 14 years old. There were hundreds of pages of police +reports and news articles revealing that Epstein was a serial sexual abuser and +trafficker, and that his operation depended on his accessing nearly unlimited cash to +use as payments to his victims. +191. With respect to the specific discoveries, the authorities found that some +of the victims "went to Mr. Epstein's house only once, some went there as much as +100 times or more." +192. It was publicly revealed in the investigation that Epstein was sexually +abusing three to four young females every single day of his life and that he was +paying each victim hundreds of dollars in hush money, usually in cash. +50 + + +193. The criminal investigation also publicly revealed that Epstein was +paying countless recruiters to constantly bring him more victims, making clear that +quick access to cash at a financial institution was the lifeblood for his sex-trafficking +venture. +194. The money trail into Epstein's accounts was a dead giveaway that +Epstein was engaging in crimes and the recipients of his money exposed the type of +crimes. +195. At this point (and earlier), JP +knew that Jeffrey Epstein was an +international sex trafficker. To the extent JP +could publicly feign plausible +deniability before Epstein's arrest in 2006, thereafter its ability to play dumb +thereafter was eviscerated, as the details of his daily sexual abuse of young females +came to public light and when he ultimately was required to register as a sex +offender. +196. JP +undoubtedly knew about Epstein's arrest in 2006. +197. Because Epstein was so publicly exposed as a sex trafficker and abuser, +one of his primary financial engines, Les Wexner, abandoned him and separated +himself from Epstein. +198. The federal criminal case against Epstein was under investigation from +(at least) 2006 through 2008, when Epstein eventually entered his guilty plea, +registered as a sex offender, and went to jail. +51 + + +Caste? 1229004901535D 000emeR17867 FDOCRE FIgg 55008288181 +199. In the summer of 2008, Epstein's Non-Prosecution Agreement +("NPA") with the U.S. Department of Justice was made public when it was unsealed +in connection with a challenge to the NPA by two of his victims. Among other +things, the agreement outlined the possible federal sex offense charges that could +have resulted from the investigation, including TVPA charges. +200. Epstein's legal team also garnered significant publicity between 2006 +and 2008, not only because of their well-known names but also the unusual number +of them. Epstein hired Roy Black, Ken Starr, Jay Lefkowitz, Guy +Michael +Tien, Lily Ann +Gerald Lefcourt, Guy Fronstein, Jack Goldberger, and +more. All of these lawyers were now on Epstein's payroll and millions of dollars +were being shelled out to these attorneys from JP +accounts to pay for his +legal defense of the most heinous of sexual abuse allegations. Not only was JP +(through Staley) well aware of the allegations, but JP| +(through +Staley) knew the identities of co-conspirators and many of the victims. Staley had +observed victims personally, and he was aware that Epstein was shelling out millions +of dollars to attorneys to take on these well-founded allegations. +201. In 2008, around the same time Epstein was pleading guilty to felony +sex offenses and registering as a lifetime sex offender, JP +learned that +another of its high value clients, Bernie Madoff, was running the largest Ponzischeme in modern history through his accounts at JP| +This led to JP +52 + + +reviewing its clientele with the directive of severing ties with any problematic +customers. +202. With indisputable publicly available knowledge that Epstein was a +sexual offender who was using his wealth to run a sexual abuse and trafficking +operation, any responsible bank providing only routine banking support would have +cut ties with Epstein. +203. However, rather than cut ties with Epstein, Staley, acting on behalf of +and within the scope of his actual and apparent employment, personally +visited Epstein when he was serving his jail sentence in Florida and arranged for an +even tighter connection between JP +and Epstein. +204. After Epstein was released from his Florida incarceration, he picked up +right where he left off-abusing young women on a daily basis, paying recruiters, +and paying hush money to victims. JP +continued its supporting actions as +well, continuing its role in Epstein's sex trafficking conspiracy and allowing it to +continue to flourish. Epstein continued abusing and trafficking with the same +frequency as he had been for years, and he could do so because he had a bank that, +even though it knew what he was doing, would not turn on him. +205. After Staley went to visit Epstein in Florida while Epstein was +incarcerated on sex offenses, Epstein and JP +relationship continued to +grow through Staley. Ultimately, after Epstein's release from jail, Staley and +53 + + +Caste? 1229d04901S35D 0io0eme817B67 FDOCRE FIgg 535061288181 +Epstein spent significant time together at Epstein's townhouse in New York City. +Staley also visited Epstein on his private island in the United States Virgin Islands +an island commonly dubbed "Pedophile Island." These visits were within the actual +and apparent scope of Staley's employment at JP | +206. Acting through Staley and to protect its financial benefits from dealing +with Epstein, JP +made clear to Epstein that he could continue to fund his +sexual abuse operation through JP +and it would continue to conceal the +illegal operation. JP +and Epstein agreed, tacitly and otherwise, that Epstein +could continue to fund his sex-trafficking venture through JP| +and JP +would reap the financial benefits from its connection with Epstein. +207. After his arrest in 2008, dozens of public lawsuits were filed against +Epstein, revealing greater details of Epstein's sexual abuse of young women. +208. The lawsuits detailed millions in payments that Epstein was making to +recruiters, co-conspirators, cover-guys (such as his longtime fixer/lawyer and +fixer/accountant), and his victims. +209. Through the civil lawsuits, evidence (such as the previously referenced +message pads) taken from Epstein's trash by police or through prior search warrants, +as well as flight logs and black books began to publicly surface, shedding further +public light on the expansiveness of Epstein's sex-trafficking operation. +210. Through the lawsuits, other relevant information also became public +54 + + +Caste? 1229004901535D 000emeR17867 FeDOMCR FIgg 55006288181 +and was widely published: Epstein had no college degree, he had never obtained +any specialized license, none of the companies with whom he was associated had +any legitimate business structure or purpose, and he had no documented expertise +that would provide the requisite skill or knowledge to amass his vast wealth. +211. Epstein's victims' court challenge against Epstein's federal NPA also +continued between 2008 and 2013 (and beyond) and attracted significant media +attention. Indeed, between around 2006 and 2013, hundreds of press reports outlined +the allegations underlying the NPA and to varying degrees detailed the involvement +of Epstein's alleged co-conspirators, including Lesley Groff, +Some articles reported that +had invoked +their Fifth Amendment right against self-incrimination. +212. Additionally, press reports during this time noted allegations that +Epstein was involved with Eastern European women in particular and that a +modeling agency he helped develop with his friend and known sexual abuser, Jean +Luc Brunel, brought "young girls ... often from Eastern Europe" to the U.S. on +Epstein's private jets. +213. At all times material hereto, JP +was aware of the foregoing +information and more about Epstein's sex trafficking activities. When some +executives on the board at JP +made strong and successful arguments, leading to JP +recommended cutting ties with Epstein, Staley +keeping Epstein as a +55 + + +Caste? 1229004901535D 000emeR17867 FDOCR FIRg 5608288181 +customer. +214. In support of maintaining its relationship with Epstein, JP| +CEO of private banking, Mary Erdoes, argued that Epstein was too valuable of a +client to let go and played a pivotal role in maintaining the relationship. +215. Upon information and belief, internal documents also reflect JP +knowledge of the extensive publicly available information about Epstein's +sex-trafficking scheme. +216. JP +including its CEO Jamie Dimon and the highest levels of +the bank, made the decision to monitor the public news being disseminated about +Epstein, knew that Epstein had been arrested for sexual offenses against young +women, knew that Epstein was a registered sex offender, knew that Epstein's coconspirators like Ghislaine Maxwell were involved in the sex trafficking operation, +knew that Epstein had paid to settle a number of civil lawsuits related to sexual abuse +of underage girls, and still made an intentional decision to keep Epstein on as a client. +217. JP| +including its CEO Jamie Dimon and the highest levels of +the bank, knew of Jes Staley's personal involvement with Epstein and yet still +allowed Staley to remain a decision maker for JP | +on Epstein accounts. +218. Even before the sexual abuse investigation in Florida, media reports +raised questions about the facts that nobody knew how Epstein made his fortune nor +what he did to continue making the millions of dollars needed to support his life. +56 + + +Caste? 229004901935D 000emeR17867 FDOCRE FIgg 55808288181 +219. Media reports also appeared about Epstein's prior SEC violations in his +job at Bear Stearns arose. A former business partner of Epstein's, Steven +Hoffenberg, even explained how Epstein assisted him in running a massive Ponzi +scheme that landed Hoffenberg in prison. JP | +was aware of these and other +reports. +220. Epstein, it was reported, claimed to be a financial bounty hunter and +money manager to those who would entrust him with $1 billion or more, yet JP +, with access to Epstein's accountants, knew Epstein's stated profession was +a lie. +221. Despite the false rumors he had created to conceal his true "business," +Epstein was exposed as literally nothing other than a sex trafficker and abuser of +young females, a fact easily discernible by any responsible financial institution with +whom he was banking. +222. For JP +, a sophisticated financial institution legally responsible +for complying with Know Your Customer laws and other banking obligations, the +details of Epstein's sexual abuse and trafficking were not a surprise. Even so, JP +never cooperated in any civil or criminal case against Epstein, because to +do so would reveal JP +complicity in Epstein's operation. +223. For example, in 2009, one of Jeffrey Epstein's sexual abuse victims +served a subpoena on JP +in connection with a civil case. JP +refused +57 + + +to comply with the subpoena, making it abundantly clear whose side JP +was +on. +224. JP +never timely filed required SARs about Epstein's suspicious +transactions, including large cash transactions, which would have revealed to law +enforcement authorities the sex-trafficking venture. +225. Fearful that Epstein could turn on the bank for its participation in the +sex-trafficking venture, JP +(and its agent, Staley) remained incentivized to +maintain and grow the relationship and to assist in concealing Epstein's suspicious +and illegal banking practices. +226. To be clear, during his years as a top executive at JP +Staley +was not only one of Epstein's closest pals, but more importantly, he was a frequent +visitor at Epstein's townhouse, including visiting the massage room; Staley met +many of Epstein's trafficking victims, including Jane Doe 1; Staley visited the +Epstein-owned victim stash house apartments at 301 East 66 Street, and Staley +personally observed the sexual abuse of young women, including Jane Doe 1. These +actions were within the scope of Staley's employment at JP| +227. Staley was well aware that Epstein was running a sex trafficking +venture, based on that facts that he: (1) went to Epstein's house in New York many +times; (2) personally spent time with young girls whom he met through Epstein on +several occasions; (3) personally visited young girls at Epstein's apartments located +58 + + +Caste? 1229004901535D 000emeR17867 FDOCRE FIggy 59060 288181 +at 301 East 66*" Street; (4) personally visited Epstein on his island; (5) was frequently +calling and emailing with Epstein; (6) personally observed Epstein around young +girls, (7) personally observed Epstein sexually grab young women in front of him; +and (8) even visited Epstein in Florida while Epstein was serving his jail sentence. +All of these circumstances, and more, gave Staley direct and actual knowledge that +Epstein was engaged in sex-trafficking venture. +228. As a result of Staley's direct and actual knowledge of Epstein's sextrafficking venture, JP +had direct and actual knowledge of Epstein's sextrafficking venture. +229. Due to Staley's knowledge, JP +knew that Epstein had no job +and still helped open dozens of accounts for Epstein, allowing him to transfer money +with no underlying legitimate business operation. +230. Through Staley and other officers and employees, JP +saw that +Epstein's JP +accounts were almost exclusively used to pay for: (1) living +and travel expenses; (2) expenses related to apparent criminal activity; (3) lawyers +relating to his Florida criminal case; (4) lawyers defending civil lawsuits (including +paying for all of the witnesses' and co-conspirators' attorneys); (5) sex-abuse victim +settlements; (6) private investigators to investigate sex abuse victims; and (7) +extravagant lifestyles for his many co-conspirators. +231. Through Staley and other officers and employees, JP +: (1) knew +59 + + +Caste? 229004901535D 0000emeR1/B67 FOCRE FIgg 66l106 288181 +that Epstein was always surrounded by young women and girls; (2) knew Epstein's +stated public profession of financial advisor was false; (3) knew Epstein had no real +expertise in business investing; (4) knew that his accounts, including many business +accounts, had underlying legitimate business activity; (4) saw Epstein's regular, +suspicious, and large cash withdrawals; (5) saw Epstein's frequent payments to +known co-conspirators; (6) knew that Epstein was funding a modeling agency with +Jean-Luc Brunel (an already exposed sexual abuser); (7) knew that Epstein was +making regular transfers in even, hundred-dollar increments; (8) knew that Epstein +was arrested in Florida and required to register as a sex-offender; (9) knew that +Epstein's co-conspirators had bank accounts at JP +associated with his +accounts; and (10) knew that Epstein's madame, Ghislaine Maxwell, was paid +millions of dollars by Epstein. +232. JP +had awareness of all the facts listed in the previous +paragraphs because, among other things, Staley, in the course his employment at JP +regularly visited Epstein's home in Manhattan, Epstein's Island, and +Epstein's victim stash house on East 66* Street. +233. During a 2019 investigation by the UK Financial Conduct Authority +into Staley's relationship with Epstein, JP +produced more than 1,200 emails +exchanged between Staley and Epstein between 2008 and the end of Staley's tenure +at JP +These emails were accessible to JP +and written in Staley's +60 + + +Cacastel 1228e DOIS diocenteR/BEZ FOCAR F0gg 602081583081 +capacity as an officer and employee of JP +All of the information contained +in those emails is imputed to JP +including information about sexual and +related topics. These emails show, among other things, the close personal +relationship between Epstein and Staley, that Epstein and Staley communicated and +visited while Epstein was incarcerated, and that Staley visited Epstein's private +island on multiple ocasions. +234. Despite knowledge of Epstein's illegal trafficking operation and the +fact that one of JP +top executives being so in bed with the operation, JP +continued to aid Epstein in his sex trafficking enterprise. +235. JP +through its agents and employees such as Staley, had direct +and specific knowledge that Epstein was operating a sex-trafficking venture and that +he needed extraordinary banking infastructure from JP +to successfully +operate that illegal venture. +236. JP| +also knew that +women +with Epstein-facilitated bank accounts at JP +whom Staley knew well, were +involved in the trafficking. +237. Importantly, in January 2007, in the heart of the federal criminal +investigation, Epstein trafficked Jane Doe 1 to the U.S. Virgin Islands where she was +repeatedly raped. Not coincidentally, she was taken on Epstein's private jet the +same one Staley traveled on +-with +, the same + + +Cataste? 1228090ISS bioDenteR/BEZ F00928 F0g 623081683081 +account-holding passengers Staley traveled with and who were identified +by the U.S. Government as Epstein's criminal co-conspirators. +238. JP +also knew from the press that Epstein was a registered sex +offender who was always surrounded by young girls. Even so, JP +conspired +with Epstein to assist him to operate the financial side of the sex-trafficking scheme. +239. JP +knew, through Staley and other information, without any +doubt that Epstein was a serial abuser and that sex-trafficking was his everyday +lifestyle. JP +also knew that without the bank's complicity, Epstein could +not pay for commercial sex acts, for co-conspirators, for his co-conspirators' +lawyers, for his own legal dream team, or for his private planes to traffic women to +his New York mansion and island to abuse. +240. Numerous of Epstein's co-conspirators had JP +accounts tied to +Epstein accounts. During the time when +were publicly outed +as co-conspirators of Epstein's, they each had JP +accounts that were noted +as Epstein-related accounts, putting JP +on clear notice that the criminal +organization Epstein was running through the bank was an expansive one of sexual +abuse and trafficking. +241. MC2, the Epstein/Brunel modeling agency that was used to expand the +trafficking scheme internationally, was funded through JP| +loans on Epstein +accounts. This agency was started at a time when Brunel had already been publicly +62 + + +Cataste? 1228e OODS biocenteR/BEZ FOR F10ggy 6G4b0 1683081 +ostracized from other known modeling agencies because he was a child sex abuser, +a fact which JP +was aware. +242. All of Epstein's connections that were known to JP +were either +very wealthy individuals, companies that had no verifiable legitimate purpose, +internationally known sex-abusing model scouts, publicly identified co-conspirators +in the Epstein sex trafficking operation the crimes of which were identified in a +public non-prosecution agreement, and young women and girls who could not +possibly have a legal and legitimate connection to Epstein. JP +knew all of +this against the backdrop of their client-Epstein-having no professional expertise +or legitimate business with legitimate banking needs. +243. JP +worked with Epstein to open new accounts in the name of +companies that had no plausible legitimate purpose, move money from one account +to another to mask payments to sexual abuse victims or co-conspirators, make wire +transfers to trafficking recruiters, and worked with Epstein's agents to make his sex +trafficking conspiracy less obvious to law enforcement authorities and others. +244. It is well known-and JP +did know-that a large number of +cash transactions by a customer can be an indicator of criminal activity generally +and sex trafficking in particular, and JP +knew Epstein was a sex trafficker +constantly needing access to large amounts of cash. +245. Payments to victims of sex trafficking are often made in cash to avoid +63 + + +leaving a "paper trail" for law enforcement or other investigators to follow. +246. Forced sexual exploitation of victims has been estimated to generate +approximately $100 billion in yearly illicit profits, according to a recent study (2018) +by the Financial Action Task Force entitled "Financial Flows from Human +Trafficking." +247. Given the illegal nature of sex trafficking, individuals perpetrating the +crime, as well as laundering the proceeds of that crime, may be identifiable by +observing financial transactions and information obtained by financial institutions in +the course of conducting their customer due diligence and the behavior of offenders. +248. Sex trafficking organizations have the need for large amounts of cash +because many illegal transactions are often necessary to keep the organization +functioning. The techniques that financial institutions use to detect other criminal +enterprises using their accounts can also be employed to detect sex trafficking. For +example, sex trafficking organizations often use assets for money laundering (such +as cash, real estate, cars, etc.) that other criminal organizations use. +249. Sex trafficking organizations may also make cash deposits and +withdrawals below customer identification thresholds to avoid triggering additional +scrutiny or bank reporting requirements. Sex trafficking organizations may also use +multiple accounts to disguise the nature of their illegal transactions, thereby +"laundering" the funds involved. +64 + + +Cataste? 1228e DOSSED biocenteR/BEZ FOR F0gg 69606 1683081 +250. One indicator of sex trafficking can be media coverage of an account +holder's activities relating to sex trafficking. +251. Another indicator of sex trafficking can be recurring payments for +transportation of logistics service in the late night or early morning. A similar +indicator can be significant payments for transportation or logistics (car rental, taxi, +and ride sharing service transactions). +4. Epstein used JP +accounts for the sex-trafficking venture, and JP +knowingly and directly benefits from the venture. +252. Over the course of the relationship, Epstein and his representatives used +accounts to send dozens of wires, directly and indirectly, to coconspirators in the sex-trafficking venture. +253. Over the course of the relationship, Epstein and his representatives also +obtained vast sums of cash from JP +to fund the sex-trafficking venture. +254. JP +was aware that the recipients of some of these wire transfers +and cash described in the previous paragraphs were to Epstein's co-conspirators and +that the wire and cash transfers were in furtherance of the Epstein sex-trafficking +venture. +255. JP +was aware that known co-conspirators of Epstein also had +accounts. +256. Epstein used JP | +accounts to pay, through wire transfers and in +cash, for coerced commercial sex acts by Jane Doe 1 and other Class Members. +65 + + +Cataste? 1228090ISSED biocenteR/BEZ F002 F0gg 66/08 183081 +257. Given JP +knowledge about Epstein's past sex trafficking, its +continuation of its financial relationship with Epstein was, at a minimum, in reckless +disregard of the fact that Epstein was using means of force, threats of force, fraud, +coercion (and a combination of such means) to cause Epstein's victims to engage in +commercial sex acts. +258. +If a financial institution decides to do business with a high-risk client, +that institution is required to conduct due diligence commensurate with that risk and +to tailor its transaction monitoring to detect suspicious or unlaw ful activity based on +what the risk is. JP +knowingly, intentionally, deliberately, and maliciously +failed to do so with regard to its relationship with Epstein. +259. JP +was well aware not only that Epstein had pled guilty and +served prison time for engaging in sex with a minor but also that there were public +allegations that his conduct was facilitated by several named co-conspirators. +260. Despite its knowledge, JP +deliberately did little or nothing to +inquire into or block numerous payments to named co-conspirators, and to or on +behalf of numerous young women, or to inquire how Epstein was using hundreds of +thousands of dollars per year in cash. JP +intentionally failed to conduct this +basic inquiry, knowing that an inquiry would reveal the sex-trafficking scheme. +Instead, it chose to continue to financially benefit from its relationship with Epstein +and his co-conspirators. +66 + + +Cataste? 1228 DOSSED dicenteR/BEZ FOR FOggy 608081683081 +261. Hush money, financial compensation to recruiters, and compensation +to victims was integral to Epstein's scheme, without which his sex-trafficking +conspiracy could not effectively operate. The ability to send wire transfers and cash +to young females was critical to Epstein's ability to coerce his victims into +commercial sex acts. +262. Suspicious wire transfers and withdrawals of millions of dollars in cash +are basic hallmarks of any major criminal enterprise. A bank that would allow +Epstein to operate in this blatant criminal fashion was necessary for him to continue +to operate his sex-trafficking conspiracy and for the continued abuse of hundreds of +young women. +263. In January 2013 - the year JP +terminated Epstein's accounts +the Office of the Comptroller of the Currency ("OCC") entered into a consent order +with JP +regarding deficiencies in the bank's overall program for BSA/AML +compliance. The OCC found that JP +failed to develop adequate due +diligence on customers and failed to comply with federal banking regulations. In +fact, the OCC noted that JP +"failed to identify significant volumes of +suspicious activity."2 +264. Before JP +became Epstein's banker, Epstein was only able to +~ See NYSDFA Consent Order at 2-4 (Jan. +14, 2013), +https://occ.treas.gov/news-issuances/news-releases/2013/nr-occ-2013-8a.pdf. +67 + + +abuse young women sporadically and in fear of being caught. Once JP +became Epstein's banker, it eliminated that fear, agreeing and conspiring with +Epstein to ensure that the suspicious money trail that would reveal Epstein's +operation would be concealed. +265. JP +desire to maintain its profitable relationship with Epstein +led it to avoid taking steps that would have documented its involvement in Epstein's +sex-trafficking venture. +266. JP +knowingly and intentionally benefited financially and in +other ways from its participation in Epstein's sex-trafficking venture, with +knowledge, or with reckless disregard of the fact, that Epstein used means of force, +threats of force, fraud, and coercion (and combinations thereof) to force young +women and girls into engaging in commercial sex acts. +267. As recounted throughout this complaint, JP +financially +benefited by earning millions of dollars from its participation in the Epstein-sextrafficking venture. The benefits that JP +received came directly from its +participation in the sex-trafficking venture and because of its participation in that +venture. In other words, there was a causal relationship between JP +conduct furthering Epstein's sex-trafficking venture and its receipt of the financial +benefits with actual (and constructive) knowledge of that causal relationship. +268. By facilitating and financing Epstein's commercial sex acts in interstate +68 + + +and foreign commerce, JP +earned interest, commissions, fees, and other +financial benefits directly from its connection with Epstein, Epstein-related entities, +and others acting in concert with Epstein. Epstein provided those financial benefits +to JP +precisely because it was facilitating his sex-trafficking venture—-and +knew that was the reason that Epstein was providing them with those +financial benefits. +269. JP +benefited by receiving things of value from its participation +in the Epstein sex-trafficking venture. Among the various things of value it received +were (1) connections with Jeffrey Epstein, his co-conspirators, and his wealthy +friends and associates; (2) additional deposits from Epstein, his co-conspirators, and +his wealthy friends and associates; (3) the opportunity to earn financial benefits from +the funds that had been deposited with it. JP +knowingly and intentionally +received these things of value as a direct result of its participation in the Epstein sextrafficking venture and because it was furthering Epstein's sex-trafficking venture. +270. JP +knowingly and intentionally financed Epstein's illegal sextrafficking venture. JP +knew that if it did not finance Epstein's illegal sextrafficking venture, then it would lose valuable Epstein-related accounts. Faced with +the choice between profiting from Epstein's sex-trafficking venture or following the +law, JP +chose to profit. +271. In violation of various banking laws and regulations, including various +69 + + +"Know Your Customer" and anti-structuring laws, JP +regularly authorized +cash withdrawals and deposits for the Epstein sex-trafficking venture, which allowed +Epstein, his co-conspirators, and those they directed to conduct the business of the +sex-trafficking venture. +272. JP +knowing and intentional banking law violations allowed +Epstein and his various corporations to stay "under the radar" and continue the sex +trafficking operation without close scrutiny or interference. +273. Among the young women and girls whose sex trafficking and sex abuse +participated in, benefited from, aided and abetted, and furthered were +Jane Doe 1 and the Class Members. +D. The Statute of Limitations +274. The statute of limitations under the TVPA is ten years after the cause +of action arose, or ten years after the victim reaches eighteen years of age, if the +victim was a minor at the time of the alleged offense. 18 U.S.C. § 1595(c)(1), (2). +The TVPA causes of actions for Jane Doe 1, and the other Class Members, arose +within ten years of the filing of this complaint. Epstein's sex-trafficking venture +constituted a criminal conspiracy and a sex-trafficking venture that operated +continuously from around 1998, through and including September 2013, and up to +and following Epstein's death in 2019. The conspiracy and venture undertook +criminal actions in violation of the TVPA throughout those years, including 2013 +70 + + +and after, thereby automatically bringing all actions in furtherance of the conspiracy +and venture within TVPA's statute of limitations. +275. The New York Adult Survivors Act has opened up a one-year revival +window for the statute of limitations regarding intentional and negligent torts +connected to violations of the New York Penal Law Chapter 130. See New York +State, Governor Hochul Signs Adult Survivors Act, Governor Kathy Hochul (May +24, +2022), +https://www.governor.ny.gov/news/governor-hochul-signs-adultsurvivors-act ("For many survivors, it may take years to come to terms with the +trauma of sexual assault and feel ready to seek just."). +VI. CLASS ACTION ALLEGATIONS +276. Jane Doe 1 brings this action pursuant to Federal Rule of Civil +Procedure 23(b)(3) and 23(c)(4) on behalf of herself and the following Class: +All women who were sexually abused or trafficked by Jeffrey Epstein during +the time when JP| +| maintained bank accounts for Epstein and/or +Epstein related-entities, which included January 1, 1998, through in or about +August 2013, both dates inclusive, and continuing to the time of Epstein's +death on August 10, 2019 (the "Class Period"). +277. Jane Doe 1 reserves the right to seek leave to modify this definition, +including the addition of one or more subclasses, after having the opportunity to +conduct discovery. +278. Numerosity: The Class consists of dozens of women, making joinder +impracticable, in satisfaction of Fed. R. Civ. P. 23(a)(1). The exact size of the Class +71 + + +and the identities of the individual Class members are ascertainable through records +maintained by the Epstein Estate and JP +including but not limited to JP +records for Epstein-related accounts (e.g., account ledgers reflecting +payments from Epstein to Class members). +279. Typicality: Jane Doe 1's claims are typical of the claims of the other +Class members she seeks to represent. The claims of Jane Doe 1 and the other Class +members are based on the same legal theories and arise from the same unlawful +pattern and practice of JP +participation in, conspiring to join in, and +funding of the Epstein's sexual abuse and Epstein's sex-trafficking venture. +280. Commonality: There are many questions of law and fact common to +the claims of Jane Doe 1 and the other Class members, and those questions +predominate over any questions that may affect only individual Class members, +within the meaning of Fed. R. Civ. P. 23(a)(2) and (b)(3). Class treatment of +common issues under Fed. R. Civ. P. 23(c)(4) will materially advance the litigation. +281. Common questions of fact and law affecting Class members include, +but are not limited to, the following: +a. Whether the Epstein sex-trafficking venture and conspiracy caused its +victims to engage in commercial sex acts in violation of Trafficking +Victims Protection Act, 18 U.S.C. § 1591(a)(1); +b. Whether the Epstein sex-trafficking venture and conspiracy recruited, +72 + + +Cacastel 1228e ODISSE diocenteR/BEZ FOI Figgy 8001683081 +enticed, solicited, harbored, provided, obtained, and transported victims +in ways that were in or affecting interstate or foreign commerce; +c. Whether Epstein and his co-conspirators used means of force, fraud, +coercion, and abuse of legal process, or a combination of such means, +to sexually abuse the victims and to cause victims to engage in +commercial sex acts; +d. Whether JP +knowingly and intentionally assisted, facilitated, +and supported the Epstein sex-trafficking venture's pattern and practice +of coercively forcing victims to engage in commercial sex acts; +e. Whether JP +benefited financially or by receiving things of +value from its participation in a venture which has engaged in sex +trafficking in violation of TVPA, 18 U.S.C. § 1591(a)(1); +f. Whether JP | +knew or should have known that the Epstein sextrafficking venture had engaged in violations of the TVPA, 18 U.S.C. +§ 1591(a); +g. Whether JP +was part of conspiracy to violate 18 U.S.C. § +1591(a), in violation of 18 U.S.C. § 1594(c); and +h. Whether JP +| committed intentional and negligent acts or +omissions that facilitated sexual abuse which would constitute a sexual +offense as defined in article 130 of New York Penal Law committed +73 + + +against such persons who were eighteen years of age or older. +282. Absent a class action, most of the Class members would find the cost +of litigating their claims to be cost-prohibitive and will have no effective remedy. +The class treatment of common questions of law and fact is also superior to multiple +individual actions or piecemeal litigation, in that it conserves the resources of the +courts and the litigants and promotes consistency and efficiency of adjudication. +283. Adequacy: Jane Doe 1 will fairly and adequately represent and protect +the interests of the other Class members she seeks to represent. Jane Doe 1 has +retained counsel with substantial experience in prosecuting complex litigation and +class actions. Jane Doe 1 and her counsel are committed to vigorously prosecuting +this action on behalf of the other Class members and have the financial resources to +do so. Neither Jane Doe 1 nor her counsel have any interests adverse to those of the +other Class members. +284. This action has been brought and may properly be maintained as a class +action against JP +pursuant to Rule 23 of the Federal Rules of Civil Procedure +because there is a well-defined community of interest in the litigation and the +proposed Class is easily ascertainable from JP +records. +285. Superiority: A class action is superior to all other available methods +for the fair and efficient adjudication of this controversy because: +a. Joinder of all Class Members is impracticable; +74 + + +b. The prosecution of individual remedies by members of the Class will +tend to establish inconsistent standards of conduct for JP +result in the impairment of Class Member's rights and the disposition +of their interests through actions to which they were not parties; +c. Class action treatment will permit a large number of similarly-situated +persons +to prosecute their common claims in a single forum +simultaneously, efficiently, and without the unnecessary duplication of +effort and expense that numerous individual actions would engender; +d. Absent a class action, Class Members will continue to suffer losses and +be aggrieved and JP +will escape liability for its criminal and +tortious conduct and be able to continue to violate New York and +federal law without remedy; +e. Class treatment of this action will cause an orderly and expeditious +administration of class claims, economies of time, effort and expense +will be fostered, and uniformity of decisions will be ensured; +f. Jane Doe 1 and her counsel are unaware of any class action brought +against JP +by victims for the violations alleged in this action; +g. The forum is desirable because Jane Doe 1 conducted the subject +business with Jeffrey Epstein in this District and Class Members were +consequently trafficked in this District; and, +75 + + +h. This action presents no difficulty that would impede its management by +the Court as a class action. +VII. CAUSES OF ACTION +COUNT I +AIDING, ABETTING, AND FACILITATING +BATTERY +286. Plaintiff Jane Doe 1 realleges and incorporates by paragraphs 1 - 285, +as if fully set forth in this Count. +287. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +288. Between about 1998 and 2013, in this District in New York, Jeffrey +Epstein intentionally committed batteries and other intentional tortious conduct, +including crimes in violation of New York Penal Law Chapter 130 such as New +York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66 (hereinafter +"Chapter 130 crimes"), against Jane Doe 1 and the Class Members. Epstein +committed the intentional tortious conduct and crimes against Jane Doe 1 and Class +Members and when they were 18 or older. As described throughout this complaint, +Epstein intentionally and non-consensually touched Jane Doe 1 and the Class +Members in a harmful and offensive manner that resulted in substantial injuries, +including damages from physical and psychological injury, extreme emotional +distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and +76 + + +invasion of privacy. +289. The resulting injuries that Jane Doe 1 and the Class Members suffered +include injuries directly and proximately suffered as a result of sex offenses +committed by Epstein and other co-conspirators and criminalized under article 130 +of the New York Penal Laws. The offenses included sexual intercourse without +consent and oral sexual conduct without consent, forbidden by New York Penal Law +§ 130.20. The offenses included forcible touching of sexual or other intimate parts +without consent, forbidden by New York Penal Law §§ 130.20, 130.35, 130.50, +130.52, and 130.66. +290. Regardless of when the tortious conduct (e.g., battery) and Chapter 130 +Crimes were committed by Epstein, the conduct and crimes are now civilly +actionable, regardless of any statute of limitations to the contrary, because they are +covered by the one-year "look back" window in New York Adult Survivors Act. +See N.Y. C.P.L.R. § 214-j. +291. Between about 1998 and 2013, JP +knowingly and intentionally +aided, abetted, and facilitated Epstein's intentional tortious conduct (e.g., battery), +through Chapter 130 Crimes recounted in the preceding paragraphs of this Count. +Because JP +criminally aided, abetted, and facilitated Epstein's conduct and +crimes in violation of Chapter 130, it is vicariously and otherwise liable for damages +caused by the conduct and crimes. +77 + + +292. Between about 2000 and 2013, when it provided substantial assistance +to Epstein, JP +was well aware of its important and substantial role as a part +of Epstein's intentionally tortious and illegal activity in committing Chapter 130 +Crimes. +293. As a direct and proximate result of Epstein's tortious conduct and +crimes, which JP +knowingly and intentionally aided, abetted, and facilitated, +Jane Doe 1 and the Class Members have in the past suffered, and in the future will +continue to suffer, substantial damages, including damages from physical and +psychological injury, extreme emotional distress, humiliation, fear, psychological +trauma, loss of dignity and self-esteem, and invasion of her privacy. +294. At the time of Epstein's batteries, intentionally tortious conduct, and +crimes against Jane Doe 1 and the Class Members, JP +was well aware of +Epstein's sex-trafficking venture and that its concrete steps in furtherance of the +venture were aiding, abetting, and facilitating his batteries, tortious conduct, and +crimes. +295. At the time of Epstein's crimes against Jane Doe 1 and the Class +Members, JP +knowingly provided substantial assistance in Epstein's +tortious conduct and crimes. That knowing substantial assistance went beyond mere +knowledge and approval of Epstein's wrongdoing. For example, JP +knowingly and intentionally provided the cash and the financial support that made +78 + + +Caste? 1229004901535D 000emeR17867 FDOCRE FIgg79030288181 +it possible for Epstein to commit the coercive sex offenses described in the preceding +paragraphs in this Count. Without that cash and financial support, Epstein could not +have committed his tortious conduct and crimes—a fact that JP +knew. +296. JP +knowingly and intentionally committed both substantial acts +in support of Epstein and substantial deliberate omissions in support of Epstein. For +example, JP +deliberately omitted to take important steps (such as timely +filing SARs) that substantially assisted Epstein to commit his crimes against Jane +Doe 1 and Class Members in violation of New York Penal Law Chapter 130. +297. In aiding, abetting, and facilitating Epstein's intentional tortious +conduct and crimes, JP +could readily foresee direct and proximate injury to +Jane Doe 1 and the Class Member. JP +should have foreseen direct and +proximate injury from its actions and inactions to Jane Doe and the Class Members. +Indeed, JP | +did foresee injury to Epstein's victims, including Jane Doe 1 and +Class Members. +298. In aiding, abetting, and facilitating Epstein's tortious conduct and +crimes, JP +committed intentional torts directed against Jane Doe 1 and the +Class Members. JP +aiding, abetting, and facilitating Epstein's tortious +conduct and crimes were its own wrongful acts and omissions. JP +had a +duty not to commit tortious conduct and crimes-specifically aiding, abetting, and +facilitating New York sex crimes as described above- +— directed against Jane 1 and +79 + + +Caste? 1229004901935D 000emeR17867 FDOCRE FIggy 88136288181 +the Class Members. +299. As a result of the foregoing, JP +is liable civilly for damages it +directly, tortiously, and criminally caused to Jane Doe 1 and the Class Members. +Jane Doe 1 and the Class Members according are entitled to bring a cause of action +for damages for physical, psychological, or other injury or condition suffered as a +direct and proximate result of JP +| aiding, abetting, and facilitating +Epstein's tortious conduct and crimes described above and for damages for physical, +psychological, or other injury or condition suffered as a direct and proximate result +of Epstein's tortious conduct and crimes. +300. By virtue of acting intentionally, outrageously, and with a high degree +of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal +indifference to civil obligations, JP +is liable to Jane Doe 1 and other +Members of the Class for punitive damages. +COUNT II +INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS +301. Plaintiff Jane Doe 1 realleges and incorporates by paragraphs 1 - 285, +as if fully set forth in this Count. +302. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +303. As a direct and proximate result of aiding, abetting, and facilitating +Epstein's tortious conduct and sex crimes in violation of Chapter 130, JP +80 + + +Caste? 229004901535D 000emeR17867 FDOCRE FIggy 88238288181 +intentionally inflicted emotional distress against Jane Doe 1 and the Class Members. +304. JP +actions, described above, constitute extreme and +outrageous conduct that shocks the conscience. +For example, JP +intentionally and knowingly participated in Epstein's sex-trafficking venture, as +outlined above. JP +had a legal duty not to participate in, facilitate, or aid and +abet Epstein's sex-trafficking venture and Epstein's Chapter 130 Crimes. +305. JP +conduct was especially extreme and outrageous due to +Jane Doe 1 and the Class Members' particular vulnerabilities as targets of a sextrafficking venture. +306. JP +intended to cause, and did cause, Jane Doe 1 and the Class +Members severe emotional distress. At the very least, JP +recklessly +disregarded a substantial probability that its actions in aiding, abetting, and +facilitating Epstein's sex crimes would cause Jane Doe 1 and the Class Members +severe emotional distress. +307. Because JP +intentionally inflicted extreme emotional distress +on Jane Doe 1 and the Class Members, it is liable to Jane Doe 1 and the Class +Members for damages they suffered as a direct and proximate result. +308. As a direct and proximate result of JP +conduct, Jane Doe 1 +and the Class Members have in the past and will in the future continue to suffer +substantial damages from psychological and physical injury, including extreme +81 + + +Cataste? 1228090ISSED biocenteR/BEZ FOR FAgg 8Ж38183081 +emotional distress, humiliation, fear, psychological trauma, loss of dignity and selfesteem, and invasion of privacy. JP +aiding, abetting, and facilitating +Epstein's sex crimes in violation of Chapter 130 directly and proximately caused +Epstein's sex crimes. +309. By virtue of acting intentionally, outrageously, and with a high degree +of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal +indifference to civil obligations, JP +is liable to Jane Doe 1 and other +Members of the Class for punitive damages. +COUNT III +NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE TO +PREVENT PHYSICAL HARM +310. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +311. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +312. In addition to any duties that might arise as a financial institution +(alleged in the next Count, below), JP +owed a duty to Jane Doe 1 and the +Class Members to exercise reasonable care to avoid conduct that created a risk of +physical harm to them. JP +duties included a duty to exercise reasonable +care to avoid conduct that would combine with Epstein's crimes, and permit +Epstein's crimes, in violation of Chapter 130. +82 + + +313. JP +own conduct in providing financial and other support for +Epstein's sex trafficking venture set forces in motion that directly and proximately +injured and caused physical harm to Jane Doe 1 and the Class Members. These +forces that JP +set in motion caused Epstein's intentional tortious conduct +and Chapter 130 Crimes against Jane Doe 1 and the Class Members, causing +physical harm and in themselves constituted physical harm to Jane Doe 1 and the +Class Members. JP +owed Jane Doe 1 and the Class Members a duty not to +set those forces in motion because they unreasonably created a risk of physical harm. +314. JP +reasonably could foresee, and did in fact foresee, that its +negligent failure to prevent physical harm would result in physical harm to Jane Doe +1 and the Class Members. JP +owed a duty to prevent that physical harm. +315. JP +failed to act objectively reasonably in failing to take +precautions to prevent Epstein's intentional tortious conduct and sex-trafficking and +sex crimes in violation of Chapter 130, which were committed against Jane Doe 1 +and the Class Members. If JP +had acted reasonably to prevent physical +harm, it would not have supported and allowed Epstein's tortious conduct and sextrafficking and sex crimes to occur. JP +owed Jane Doe 1 and the Class +members a duty to act objectively reasonably. +316. At the time of JP +own negligent conduct, JP +both +realized and should have realized the likelihood that it was creating an opportunity +83 + + +Caste? 12290049019135D 000emeR17867 FeDOMCR FIgg 82361288181 +for Epstein to commit intentional tortious conduct and Chapter 130 Crimes against +Jane Doe 1 and the Class Members. Indeed, JP +knew that its own conduct +was necessary to create Epstein's opportunities to engage in that conduct and commit +those crimes. JP +owed Jane Doe 1 and the Class Members a duty not to +create those opportunities for Epstein. +317. JP +breaches of its legal duties were the direct—i.e., the butfor-cause of physical and psychological injuries to Jane Doe 1 and the Class +Members. Without JP +breaches of legal duties, those injuries would not +have occurred. The injuries that occurred were readily foreseeable to JP +318. Jane Doe 1 and the Class Members were easily within the zone of +foreseeable harm from the JP +negligent acts and omissions. JP +negligent acts and omissions foreseeably created substantial risk of Jeffrey Epstein +and his co-conspirators committing sex crimes against young women with whom he +was in contact. Tragically, Jane Doe 1 and the Class Members fell within that zone. +319. Because of JP +negligent failure to prevent physical harm to +Jane Doe 1 and the Class Members, it is liable to Jane Doe 1 and the Class Members +for damages suffered as a direct and proximate result. +320. As a direct and proximate result of JP +negligent failure to +prevent physical harm, Jane Doe 1 and the Class Members have in the past and will +in the future continue to suffer substantial damages from psychological and physical +84 + + +Caste? 1229004901535 0000emeR17867 FDOCR FIggy 88636288181 +injury, including extreme emotional distress, humiliation, fear, psychological +trauma, loss of dignity and self-esteem, and invasion of privacy. JP +aiding, abetting, and facilitating Epstein's tortious conduct and sex crimes in +violation of Chapter 130 directly and proximately caused Epstein's sex crimes. +321. By virtue of acting intentionally, outrageously, and with a high degree +of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal +indifference to civil obligations, JP +is liable to Jane Doe 1 and other +Members of the Class for punitive damages. +COUNT IV +NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE AS A +BANKING INSTITUTION PROVIDING NON-ROUTINE BANKING +322. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +323. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +324. JP +owed a duty to Jane Doe 1 and the Class Members not to +knowingly provide non-routine banking support and assistance for Epstein that it +knew, and reason to know, would lead to and support intentional tortious conduct +and Chapter 130 Crimes by Epstein against Jane Doe 1 and the Class Members. +325. As described in detail above, JP +did not merely provide routine +banking support for Epstein. Instead, it participated in, aided and abetted, and +85 + + +Cataste? 1228090ISSED biocenteRt/BEZ FOR F0g 88/8183081 +facilitating his sex-trafficking venture and his commission of intentional tortious +conduct and Chapter 130 crimes. JP +also knew, and was willfully blind to +the fact, that it was going beyond providing routine banking support but instead +facilitating Epstein's sex-trafficking venture and his commission of tortious conduct +and Chapter 130 crimes. +326. As an example, in providing hundreds of thousands of dollars in cash +to Epstein and his co-conspirators in circumstances where it knew that the cash +would be used to facilitate coercive sex acts, JP +took substantial actions +outside the scope of a routine, lawful, and ordinary customer relationship. +327. As another example, JP | +deliberately failed to follow numerous +banking requirements in connection with financial dealings with Epstein, including +AML rules, KYC rules, and anti-structing rules. In deliberately ignoring and failing +to follow those rules, JP +acted in a non-routine way to facilitate and support +Epstein's and his co-conspirators' intentional torts, sex-trafficking, and commission +of Chapter 130 Crimes. JP +• through Staley, knew that Epstein was abusing +females sexually on a daily basis and through that knowledge, developed a special +relationship with Epstein. As a banking institution providing the necessary +infrastructure to the sex trafficking operation, JP +developed a special +relationship with Epstein and thus undertook an obligation to protect others from his +abuse. +86 + + +Caste? 229004901535 0000emeR17867 FDOCRE FIgg 88 B8288181 +328. Likewise, JP +, acting through Staley, having observed Jane Doe +1 in circumstances indicating sexual abuse and trafficking, and whose relationship +with Epstein was always maintained for the benefit of JP +owed a duty to +protect the victims from the abuse of Jeffrey Epstein about which Staley, on behalf +of JP +was well aware. +329. JP +also owed Jane Doe 1 and the Class Members a duty of care +because it affirmatively and intentionally chose not to investigate Epstein's +suspicious banking activities even after being confronted with explicit information +that Epstein was using JP +to further a sex-trafficking venture harming Jane +Doe 1 and the Class Members. JP +chose not to do so because it knew what +the investigation would reveal, and that it would need to end its lucrative relationship +with Epstein as a result of the investigation. Once JP +had information about +Epstein's use of JP +for a sex-trafficking venture, and once it knew or has +reason to know that it was providing material support to that venture, it owed a duty +of care to investigate suspicious banking activity. +330. But for JP +Epstein could not have successfully run and +expanded his sexual abuse organization. Epstein could not have abused the hundreds +of victims that he did without JP +331. JP +failed to act objectively reasonably by failing to comply +with relevant banking laws and regulations with regard to its interactions with +87 + + +Epstein and his co-conspirators. JP L +owed a duty to Jane Doe 1 and the Class +Members to act objectively reasonably in its interactions with Epstein and his coconspirators and to exercise reasonable care to prevent them from engaging in +foreseeable tortious and criminal activity by using JP| +exceptional and nonroutine banking infrastructure. +332. JP +owed a legal duty to Jane Doe 1 and the Class Members to +act objectively reasonably and to not deliberately ignore banking obligations, +including KYC and AML laws and regulations described above, so as to provide +Epstein and others with an opportunity to engage in tortious conduct, coercive sextrafficking and Chapter 130 Crimes. +333. Under KYC, AML, and related laws and regulations, JP +had +special duties not ignore tortious conduct and crimes being committed by its +customers duties above and beyond any duties that the general public may have. +The inquiries that banks must make include duties to inquire about specific +individuals who banks know are being harmed. The regulations establish a duty of +care that must be followed by banks, including JP +These duties exist at +least in situations where a bank is knowingly going beyond offering routine banking +for its customers and instead offers banking infrastructure specially adapted to +facilitate tortious conduct and crimes. +334. JP| +also owed Jane Doe 1 and the Class Members a duty of care +88 + + +because it knew, and had reason to know, that Epstein and his co-conspirators were +using JP +to facilitate a sex-trafficking venture, raising a duty to make a +reasonable inquiry about suspicious activity. +335. JP +owed Jane Doe 1 and the Class Member a duty not to +deliberately and purposely fail to file SARs—filings which would have alerted +federal authorities to Epstein's and his co-conspirators' illegal activities, including +committing Chapter 130 Crimes. +336. JP +also owed Jane Doe 1 and the Class Members a duty to +prevent physical harm to them when confronted with explicit information that +Epstein and his co-conspirators were using JP +non-routine banking to +further a sex-trafficking venture harming Jane Doe 1 and the Class Members. Once +had information about Epstein's use of JP +for a sex-trafficking +venture that was physically harming Jane Doe 1 and the Class Members, it owed +them a duty of care to investigate and prevent Epstein's and his co-conspirators' +suspicious, tortious, and criminal activities. +337. In the exercise of reasonable care, JP | +and its employees knew, +and should have known, of the dangerous propensities of Jeffrey Epstein and his coconspirators to commit intentional torts and violations of article 130 of New York +Penal Law against women and girls with whom he was in close proximity, including +Jane Doe 1 and the Class Members. +89 + + +Caste? 1229004901935D 000emeR17867 FeDOMCR Fegg 99106 288181 +338. JP +breached its legal duties to Jane Doe 1 and the Class +Members as described above. JP +breach of its duties led to it failing to +prevent Epstein from committing intentional torts and Chapter 130 Crimes against +Jane Doe 1 and the Class Members. JP +realized that Epstein were +committing intentional torts and Chapter 130 Crimes against Jane Doe 1 and the +Class Members. +The criminal activity that harmed Jane Doe 1 and the Class +Members included foreseeable intentional torts as well as TVPA and Chapter 130 +Crimes committed by the Epstein. +339. As a direct and proximate result of the breach of legal duties by JP +Jane Doe 1 and the Class Members repeatedly suffered direct and +foreseeable injuries from Epstein and his co-conspirators, including injuries from +federal and state sexual offenses (including sexual assaults) and resulting emotional +distress, mental pain and suffering, and other physical, psychological, and other +injuries. +340. The breaches of JP +legal duties were the direct—i.e., the butfor cause of these physical and psychological injuries to Jane Doe 1 and the Class +Members. Without JP +breaches of its legal duties, those injuries would +not have occurred. The injuries that occurred were readily foreseeable to JP +341. The injuries that Jane Doe 1 and the Class Members suffered included +injuries directly and proximately suffered while they were adults who were present +90 + + +Caste? 1229004901535D 000emeR17867 FeDOMCRE FIgg99208288181 +in this District. These injuries are permanent in nature and Jane Doe 1 and the other +Class Members will continue to suffer these losses in the future. +342. JP +could reasonably foresee that their actions and omissions in +facilitating Epstein's sex trafficking enterprise would lead to intentional torts and +sex offenses against Jane Doe land the Class Members. Indeed, JP +was +aware, and should have been aware, that Epstein was a high risk to commit sex +offenses against young women and girls. +343. Jane Doe 1 and the Class Members were easily within the zone of +foreseeable harm from JP +negligent acts and omissions. JP| +acts +and omissions foreseeably created substantial risk of Jeffrey Epstein and his coconspirators committing intentional torts and sex crimes against young women with +whom he was in contact. Tragically, Jane Doe 1 and the Class Members fell within +that zone. +344. While the foregoing allegations easily make out a clear case of +negligence, this case does not involve mere negligence. Instead, Defendants' +tortious conduct in this case evinced a high degree of moral turpitude and +demonstrated such wanton dishonesty as to imply a criminal indifference to civil +obligations. It also involved outrageous and intentional acts and omissions, because +it was a deliberate attempt to further the crimes of a widespread and dangerous +criminal sex trafficking organization. JP +tortious conduct was directed +91 + + +Caste? 1229004901535D 0000emeR17867 FeDOMCRE FIgg99308288181 +specifically at Jane Doe 1 and other Members of the Class, who were the victims of +Epstein's sexual abuse and sex trafficking organization. +345. As a result of JP +negligent actions and omissions described +in this Count, Jane Doe 1 and the Class Members have sustained both general and +specifical damages from physical and psychological injury in substantial amounts. +346. By virtue of acting intentionally, outrageously, and with a high degree +of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal +indifference to civil obligations, JP +is liable to Jane Doe 1 and other +Members of the Class for punitive damages. +COUNT V +KNOWING BENEFICIARY IN A SEX-TRAFFICKING VENTURE IN +VIOLATION OF THE TRAFFICKING VICTIMS PROTECTION ACT, +18 U.S.C. §§ 1591(a)(2), 1595 +347. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +348. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +349. JP +knowingly and intentionally benefitted, financially and by +receiving things of value, from participating in, assisting, supporting, and facilitating +an illegal coercive sex-trafficking venture that was in and affecting interstate and +foreign commerce, together and with others, in violation of 18 U.S.C. § 1591(a)(2). +350. JP +took many concrete steps to aid and participate in Epstein's +92 + + +Caste? 1229004901535D 0000emeR17867 FeDOMORE FIggy 93400 1288181 +sex-trafficking venture. Among the concrete steps that JP +took to aid Epstein +was providing vast sums of cash, which made the sex-trafficking venture possible. +Providing Epstein with large sum of U.S. currency caused JP +to receive +financial benefits. JP +willingness to provide large amounts of cash to +Epstein was the quid pro quo for it receiving financial benefits from Epstein. +351. The cash that JP +provided was necessary for Epstein to coerce +Jane Doe 1 as well as other Class Members to engage in commercial sex acts. The +cash directly formed part of the commercial nature of the sex acts. The cash was +also a necessary and required part of Epstein's recruitment of Jane Doe 1 and other +victims of his sex-trafficking venture. By providing cash that JP +knew +would be used to fund the sex trafficking venture, JP +actively participated +in the recruitment of victims of the venture. +352. The cash that JP +provided went far beyond providing routine +banking opportunities for a client. It was far from routine for JP +to provide +substantial sums of cash per year to Epstein, who did not have an apparent legitimate +need for such extravagant sums. Moreover, the circumstances in which Epstein was +requesting such large amounts were far from routine and raised numerous "red +flags"—taking it well outside routine circumstances. +353. JP +providing large sums of cash to Epstein, under the +circumstances of this case, was entirely inconsistent with the ordinary duties of a +93 + + +Caste? 1229004901535D 000emeR17867 FDOCRE FIgg 995051288181 +bank or its employees. +354. The reason that JP +ignored the numerous red flags about +Epstein was to receive financial benefits from Epstein and his sex-trafficking +venture. JP +knew that it would gain far-from-routine financial benefits by +ignoring the red flags associated with Epstein and by participating in his sextrafficking venture. +355. Among the concrete steps that JP +took to aid and participate in +the Epstein sex-trafficking venture were opening up numerous accounts at JP +for Epstein, his related entities, and associates. By opening these accounts, +received many benefits from participating in Epstein's venture. The +opening of these accounts was affirmative conduct that caused JP +to receive +those benefits. +356. Among the concrete steps that JP +took to aid the Epstein sextrafficking venture, between about 2000 and continuing through about August 2013, +concealed its delivery of vast sums of cash (likely hundreds of thousands +of dollars) to Epstein and his associates. In order to benefit from the Epstein sextrafficking venture, JP +willfully failed to timely file required SARs with the +federal government, because doing so would imperil its ability to profit from the +sex-trafficking venture. JP +concealment of the cash transactions caused it +to receive financial benefits through continuation of the Epstein sex-trafficking +94 + + +Cataste? 1228 DOSSED dicenteR/BEZ F0028 F0g 996061683081 +venture. +357. Among the concrete steps that JP| +took to aid the Epstein sextrafficking venture were its failure to follow AML requirements. This failure was +not just passive facilitation, but a deliberate omission by JP| +This omission +was specific act of concealment, which allowed Epstein to continue funding his sextrafficking venture through suspicious transactions that would have otherwise been +prevented. +358. By taking the concrete steps outlined above (along with the others +alleged in this complaint), JP +knowingly participated in sex trafficking and +furthered the Epstein sex-trafficking venture. The concrete steps above constituted +taking part in the sex-trafficking venture and were necessary for its success. The +concrete steps above constituted active engagement by JP| +in Epstein's sextrafficking venture. +359. JP| +knowingly and intentionally benefited financially from, and +received value for, its participation in the sex-trafficking venture, in which Epstein, +with JP +knowledge, or its reckless disregard of the fact, that Epstein would +use means of force, threats of force, fraud, coercion, and a combination of such +means to cause Jane Doe 1, as well as other Class Members, some of whom were +under the age of eighteen, to engage in commercial sex acts. +360. JP +actually knew, through Staley and other officers and +95 + + +Caste? 12290049015135D 0000emeR17867 FeDOHOR FIREB8181 +employees, that it was participating in a particular sex-trafficking venture—i.e., the +coercive Epstein sex-trafficking venture outlined above. JP +knowledge +went far beyond having an abstract awareness of sex trafficking in general. Indeed, +discussed internally Epstein's specific sex trafficking and the large +amounts of cash that JP +was giving him. Thus, JP +did not simply +fail to adequately detect signs of Epstein's sex trafficking; it did detect multiple signs +of Epstein's coercive sex-trafficking venture and continued to participate in the +venture. JP +knew that the venture was on-going, which was why Epstein +required vast sums of cash. +361. JP +actions extend well beyond a situation of failing to train +its staff about recognizing the warning signs of sex trafficking. JP| +employees did recognize the signs of Epstein's sex trafficking. Indeed, JP +employees knew about Epstein's sex-trafficking venture. But JP| +decided to +continue facilitating the Epstein sex-trafficking venture rather than ending its +participation in the venture. +362. Among the signs that JP +was facilitating Epstein's sex +trafficking venture were those facts that came to the attention of JP +employees discussed above, which caused those employees to escalate issues +regarding Epstein's coercive sex-trafficking venture to more senior levels. +363. Among the signs that JP +was facilitating Epstein's sex +96 + + +Caste? 1229004901535 0000emeR17867 FeDOMCR FIggy 89808288181 +trafficking venture were those facts that came to the attention of JP| +were +those facts that came to its attention through Jes Staley's observations of Epstein's +sex trafficking. Because of those observations, Staley—and JP| +-knew to a +certainty that Epstein was engaged in sex trafficking. +364. JP +actual knowledge extended to the fact that specific +individual women and girls were being coercively sex trafficked by Epstein between +the time of his on-boarding and the termination of its relationship with Epstein. Even +if JP +did not know all the names of Epstein's victims, it knew that specific +victims (e.g., Jane Doe 1) of a specific trafficker (Epstein) at a specific time period +(various dates between 2000-2013 and following) existed and were being forced to +engage in commercial sex acts. It also knew that some of the victims had eastern +European surnames. JP +was on notice, and knew, that such victims were +being coercively trafficked by Epstein's sex-trafficking venture. +365. One of JP +officers, Jes Staley, also knew the names of the +many of Epstein's sex trafficking victims. +366. JP +helped to conceal the names of Epstein's victims from the +public and from law enforcement and prosecuting agencies by helping to conceal the +existence of the sex-trafficking venture. Among the ways in which JP +helped to conceal the venture's existence was by providing the cash necessary for +the venture to avoid leaving a visible "paper trail." +97 + + +Caste? 1229004901535D 0000emeR17867 FeDOMCR Fgg 98300288181 +367. JP +concealment included failing to follow through on +enhanced monitoring that was required for someone like Epstein. JP +failed +to implement that enhanced monitoring specifically to help conceal Epstein's +ongoing sex-trafficking. JP +knew that if it implemented that enhanced +monitoring, it would have to stop providing Epstein with the cash needed to run his +sex-trafficking venture. +368. JP +concealment included failing to file required SARs for +Epstein's suspicious cash transactions. +369. In addition to having actual knowledge that it was participating in +Epstein's sex trafficking venture, JP L +had constructive knowledge that it was +participating in Epstein's sex trafficking venture. JP +also had constructive +knowledge that Jane Doe 1, as well as other Members of the Class, were being +coercively sex trafficked by Epstein. Its constructive knowledge extended to the +names of Epstein's victims, because Epstein and his associates knew the names of +the victims. Staley also the knew the names of many of the victims. +370. JP +had constructive knowledge of Epstein's sex-trafficking +venture because of specific acts by Epstein that put it on notice of a particular and +ongoing sex trafficking venture. Among the specific acts were Epstein's use of vast +sums of cash in circumstances that prompted JP | +employees to specifically +raise questions about Epstein's sex-trafficking. +98 + + +caaa$Ф2PZ#01001S8BRDDaDeEtBI B67 Fid Ф0R8233 Pagg4Ф806HB81 +371. Also among the specific acts giving rise to constructive knowledge +were the facts that associates of Epstein made numerous cash withdrawals from JP +accounts. The circumstances of these withdrawals gave the bank notice that +"structuring" was occurring to avoid alerting federal authorities. +372. Among the financial benefits that the JP +received for +participating in and facilitating Epstein's sex-trafficking venture were the deposit of +funds that Epstein and Epstein-controlled entities made to JP +profited from the use of these deposits. Epstein and Epstein-controlled entities +deposited these funds in exchange for JP +facilitation and participation in +the sex trafficking venture, including its willingness to provide large amounts of cash +in suspicious circumstances and to allow "structuring" of withdrawals to avoid +triggering reporting requirements. +373. Among the financial benefits that JP| +received for participating +in Epstein's sex-trafficking venture was referral of business opportunities from +Epstein and his co-conspirators. JP | +profited from these referred business +opportunities. Epstein referred business entities and business opportunities to JP +in exchange for its facilitation and participation in the sex trafficking +venture. These referrals were a quid pro quo for JP +participation in the +sex-trafficking venture. +374. JP +financially profited from the deposits made by Epstein and +99 + + +CaGast17272₽80#95857DdoomeBTE68 7 FEe=000838633 3 1299g-DDS60 BB81 +Epstein-controlled entities and from the business opportunities referred to JP +by Epstein in exchange for its facilitation and participation in Epstein's sex +trafficking venture. +375. JP +knowingly received financial benefits in return for its +assistance, support, and facilitation of Epstein's sex-trafficking venture. JP +knew that if it stopped providing assistance, support, and facilitation of Epstein's +sex-trafficking venture, it would no longer receive those benefits. +376. JP +knew, and was in reckless disregard of the fact, that it was +Epstein's pattern and practice to use the channels and instrumentalities of interstate +and foreign commerce, to entice, recruit, solicit, harbor, provide, obtain, and +transport young women and underage girls for purposes of causing commercial sex +acts, in violation of 18 U.S.C. § 1591(a)(1). +377. JP +and its employees had actual knowledge that they were +facilitating Epstein's sexual abuse and sex trafficking conspiracy to recruit, solicit, +entice, coerce, harbor, transport, obtain and provide Jane Doe 1 as well as other +Members of the Class, into commercial sex acts, through the means of force, threats +of force, fraud, abuse of process, and coercion, and a combination of all these means. +378. Despite such knowledge, JP +intentionally paid for, facilitated, +and participated in Epstein's violations of 18 U.S.C. § 1591(a)(1), which JP +knew, and were in reckless disregard of the fact that, Epstein would coerce, defraud, +100 + + +CaGas:17272₽00#98857D0000m 8X968 7 FEe 000838633 3 1299g-01.23508881 +and force Jane Doe 1, as well as other Members of the Class, to engage in +commercial sex acts. +379. JP +through its employees and agents (including Staley), +actively participated in the sex trafficking conspiracy and led Jane Doe 1, as well as +other Class Members, to believe that they would be rewarded if they cooperated and +acquiesced to Epstein's coercive demands. +380. JP +affirmative conduct was committed knowingly, and in +reckless disregard of the facts, that Epstein would use cash and financial support +provided by JP +as a means of defrauding, forcing, and coercing sex acts +from Jane Doe 1 as well as other Members of the Class. JP +conduct was +outrageous and intentional. +381. In addition to actual knowledge that it was participating in and +facilitating the Epstein sex-trafficking venture, JP | +also should have known +that it was participating in and facilitating a venture that had engaged in coercive sex +trafficking, as covered by 18 U.S.C. § 1595(a). +382. In exchange for facilitating and covering up Epstein's commercial sex +trafficking, the JP +officers and employees (including Staley) advanced in +their careers at JP +and received financial benefits therefrom by securing the +JP C +-Epstein relationship. +383. Facilitating and covering up Epstein's sexual trafficking and +101 + + +CaGastI7272гdĐ₽Э0#95857D0оошm09BTD68 7 FEd6000К38633 3 129gt-D2930 BB81 +misconduct was a means of obtaining economic success and promotion within the +hierarchy. +384. JP +knowing and intentional conduct has caused Jane Doe 1 +and the other Members of the Class serious harm including, without limitation, +physical, psychological, emotional, financial, and reputational harm. +385. JP +knowing and intentional conduct has caused Jane Doe 1 +and the other Members of the Class harm that is sufficiently serious, under all the +surrounding circumstances, to compel a reasonable person of the same background +and in the same circumstances to perform or to continue performing commercial +sexual activity, in order to avoid incurring that harm. +386. This case does not involve mere fraud. Instead, JP +criminal +conduct in violating the TVPA was outrageous and intentional, because it was in +deliberate furtherance of a widespread and dangerous criminal sex trafficking +organization. JP +criminal conduct also evinced a high degree of moral +turpitude and demonstrated such wanton dishonesty as to imply a criminal +indifference to civil obligations. JP +criminal conduct was directed +specifically at Jane Doe 1 and other members of the Class, who were the victims of +Epstein's sexual abuse and sex trafficking organization. +387. JP +outrageous and intentional conduct in this case is part of +a pattern and practice of JP +• profiting by undertaking illegal "high risk, high +102 + + +CaGas17272Đ₽80#95857D@оошне87#68 7H#Ee6000838683 3 T29g(-DB8ob0 BB81 +reward" clients. +388. By virtue of these knowing and intentional violations of 18 U.S.C. §§ +1591(a)(2), 1595, JP +is liable to Jane Doe 1 and the other Members of the +Class for the damages they sustained and reasonable attorneys' fees. +389. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ +1591(a)(2), 1595, JP +is liable to Jane Doe 1 and other members of the Class +for punitive damages. +PARTICIPATING IN A SEX TROFNCKING VENTURE IN VIOLATION +OF THE TRAFFICKING VICTIMS PROTECTION ACT, +18 U.S.C. §§ 1591(a)(1), 1595 +390. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +391. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +392. JP +knowingly and intentionally, through various means, +participated in, perpetrated, assisted, supported, facilitated a sex-trafficking venture +that was in and affecting interstate and foreign commerce, together and with others, +in violation of 18 U.S.C. § 1591(a)(1). +393. Among other things, JP | +knowingly and intentionally, through +various means, recruited, enticed, provided, obtained, advertised, and solicited by +various means Jane Doe 1, as well as other Class Members, knowing that Epstein +103 + + +CaGast17272гĐ₽80#95857DdoошmeeBTD68 7HFEe6000К38633 3P129gt-D#55b0 BB81 +would use means of force, threats of force, fraud, coercion, and a combination of +such means to cause Jane Doe 1, as well as other Class Members, some of whom +were under the age of eighteen, to engage in commercial sex acts. +394. JP +and its officers and employees (including Staley) had actual +knowledge that they were perpetrating and facilitating Epstein's sexual abuse and +sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain +and provide Jane Doe 1 as well as other Members of the Class, into commercial sex +acts, through the means of force, threats of force, fraud, abuse of process, and +coercion. +395. Despite such knowledge, JP +intentionally paid for, facilitated, +perpetrated, and participated in Epstein's violations of 18 U.S.C. § 1591(a)(1), which +knew, and were in reckless disregard of the fact that, Epstein would +coerce, defraud, and force Jane Doe 1, as well as other Class Members, to engage in +commercial sex acts. +396. As part of perpetrating TVPA violations and enticing and recruiting +victims, between on or about 2000 and August 2013, JP +delivery of vast sums of cash to Epstein and his associates. +concealed its +397. As part of perpetrating TVPA violations, JP +failed to file required SARs with the federal government. +also willfully +398. JP +affirmative conduct was committed knowing, and in +104 + + +reckless disregard of the facts, that Epstein would use cash and the financial support +provided by JP +as a means of defrauding, forcing, and coercing sex acts +from Jane Doe 1 as well as other Class Members. JP +conduct was +outrageous and intentional. +399. JP +knowing and intentional conduct has caused Jane Doe 1 +and the other Class Members serious harm including, without limitation, physical, +psychological, emotional, financial, and reputational harm. +400. JP +knowing and intentional conduct has caused Jane Doe 1 +and the other Members of the Class harm that is sufficiently serious, under all the +surrounding circumstances, to compel a reasonable person of the same background +and in the same circumstances to perform or to continue performing commercial +sexual activity, in order to avoid incurring that harm. +401. This case does not involve mere fraud. Instead, JP +criminal +conduct in perpetrating TVPA violations was outrageous and intentional, because it +was in deliberate furtherance of a widespread and dangerous criminal sex trafficking +organization. JP +criminal conduct (including Staley conduct on behalf of +also evinced a high degree of moral turpitude and demonstrated such +wanton dishonesty as to imply a criminal indifference to civil obligations. JP +criminal conduct was directed specifically at Jane Doe 1 and other +members of the Class, who were the victims of Epstein's sexual abuse and sex- +105 + + +CaGas17272/Đ₽80#95857Dò0ame8TD68 7 FEde000538683 3 129g(-DB300 BB81 +trafficking organization. +402. JP +outrageous and intentional conduct in this case is part of +a pattern and practice of JP +profiting by undertaking illegal and "high risk, +high reward" clients. +403. By virtue of its knowing and intentional violations of 18 U.S.C. §8 +1591(a)(1), 1595, JP +is liable to Jane Doe 1 and the other Members of the +Class for the damages they sustained and reasonable attorneys' fees. +404. By virtue of these intentional and outrageous violations of 18 U.S.C. §8 +1591(a)(1), 1595, JP +is liable to Jane Doe 1 and other members of the Class +for punitive damages. +COUNT VII +AIDING, ABETTING, AND INDUCING A SEX-TRAFFICKING VENTURE +IN VIOLATION OF THE TRAFFICKING VICTIMS PROTECTION ACT, +18 U.S.C. §§ 2, 1591(a)(1) & (2), 1595 +405. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1-285, as if fully set forth in this Count. +406. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +407. Acting through its officers and employees (including Staley), JP +aided, abetted, and induced Epstein's sex-trafficking venture that was in and +affecting interstate and foreign commerce, together and with others, in violation of +18 U.S.C. §8 2, 1591(a)(1) & (a)(2). +106 + + +CaGas:17272₽80#98857D0000m 8X968 7 FEe 000838633 3 129g-078860 BB81 +408. Under 18 U.S.C. § 2, JP +is punishable as a principal under 18 +U.S.C. §§ 1591(a)(1) & (a)(2) and thereby committed and perpetrated violations of +Chapter 77, Title 18, U.S. Code, when it aided, abetted, procured, and induced +Epstein's sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other +Class Members. +409. Under 18 U.S.C. § 2, JP | +committed and perpetrated crimes in +violation of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, and inducing +Epstein's and his conspirators sex-trafficking venture and sex trafficking of Jane +Doe 1, as well as other Class Members. As a consequence, Jane Doe 1, as well as +other members of the Class, are victims of JP +criminally aiding, abetting, +and inducing Epstein's violations of 18 U.S.C. $§ 1591(a)(1) & (a)(2). These actions +were in and affecting interstate and foreign commerce. +410. The crimes that JP +aided and abetted are (1) Epstein's +perpetrating of coercive sex trafficking, in violation of 18 U.S.C. § 1591(a)(1), and +(2) Epstein's co-conspirators' knowingly benefitting from coercive sex trafficking, +in violation of 18 U.S.C. § 1591(a)(2). These crimes were in and affecting interstate +and foreign commerce. +411. Epstein's co-conspirators benefitted financially and received things of +value from their participation in the Epstein sex-trafficking venture, including +payments and other compensation from Epstein. The co-conspirators who benefitted +107 + + +CaGas:17272₽00#98857D0000m 8X968 7 FEe 00038683 3 1299g-D89560 BB81 +financially include Ghislaine Maxwell, Lesley Groff, +412. Acting through its officers and employees (including Staley), JP +itself directly committed and perpetrated violations of Chapter 77, Title 18, +U.S. Code, including 18 U.S.C. §§ 1591(a)(1) & (a)(2), by aiding, abetting, and +inducing a sex-trafficking venture and the sex trafficking of Jane Doe 1, as well as +other Class Members. JP| +itself directly violated Chapter 77 by committing +and perpetrating these violations. +413. Among other things, JP | +aided, abetted, and induced Epstein's +sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other Class +Members, knowing that Epstein would use means of force, threats of force, fraud, +coercion, and a combination of such means to cause Jane Doe 1, as well as other +Class Members, some of whom were under the age of eighteen, to engage in +commercial sex acts. +414. By aiding, abetting, and inducing Epstein's sex-trafficking venture and +sex trafficking of Jane Doe 1, as well as other Class Members, JP +knowingly +benefited, both financially and by receiving things of value, from participating in +Epstein's sex-trafficking venture. +415. JP +and its officers and employees had actual knowledge that +they were aiding, abetting, and inducing Epstein's sexual abuse and sex trafficking +108 + + +CaGas:17272₽80#98857D000098T68 7 FEe=000838633 3 1299g-090660 BB81 +conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain and provide +Jane Doe 1 as well as other Members of the Class, into commercial sex acts, through +the means of force, threats of force, fraud, abuse of process, and coercion. JP +knew, and should have known, that Epstein had engaged in acts in violation +of the TVPA. +416. Despite such knowledge, JP +intentionally paid for and aided, +abetted, procured, and induced Epstein's and his co-conspirators violations of 18 +U.S.C. §§ 1591(a)(1) & (a)(2), which constituted perpetrating violations of those +laws under 18 U.S.C. § 2. JP +knew, and acted in reckless disregard of the +fact that, Epstein would coerce, defraud, and force Jane Doe 1, as well as other Class +Members, to engage in commercial sex acts. +417. JP +affirmative conduct of aiding, abetting, procuring, and +inducing Epstein's and his co-conspirators' violations was committed knowingly, +and in reckless disregard of the facts, that Epstein would use cash and financial +supported provided by JP +_ as a means of defrauding, forcing, and coercing +sex acts from Jane Doe 1 as well as other Class Members. JP| +conduct was +outrageous and intentional. +418. Acting within this District and in attempting to further the Epstein sextrafficking venture, after various times between about 1998 and 2013, JP | +knowingly and intentionally took substantial and significant steps to aid and abet +109 + + +CaGas:17272₽80#95857D00009 8X968 7 FEe 000838633 3 12199g D660 BB81 +Epstein's sex trafficking venture, including opened various brokerage accounts for +Epstein and Epstein-related individuals and entities. These accounts were in and +affecting interstate and foreign commerce +419. JP +knowing and intentional conduct of aiding, abetting, and +inducing Epstein's violations has caused Jane Doe 1 and the other Class Members +serious harm including, without limitation, physical, psychological, emotional, +financial, and reputational harm. +420. JP +knowing and intentional conduct of aiding, abetting, and +inducing Epstein's violations has caused Jane Doe 1 and the other Class Members +harm that is sufficiently serious, under all the surrounding circumstances, to compel +a reasonable person of the same background and in the same circumstances to +perform or to continue performing commercial sexual activity, in order to avoid +incurring that harm. +421. This case does not involve mere fraud. Instead, JP +criminal +conduct in aiding, abetting, and inducing Epstein's TVPA violations was outrageous +and intentional, because it was in deliberate furtherance of a widespread and +dangerous criminal sex trafficking organization. JP| +criminal conduct also +evinced a high degree of moral turpitude and demonstrated such wanton dishonesty +as to imply a criminal indifference to civil obligations. JP +criminal +conduct was directed specifically at Jane Doe 1 and other members of the Class, who +110 + + +CaGas:17272₽80#98857D0000m T68 7 FEe 000838633 3 1209g 18308881 +were the victims of Epstein's sexual abuse and sex trafficking organization. +422. JP +outrageous and intentional conduct in this case is part of +a pattern and practice of JP | +profiting by undertaking illegal "high risk, high +reward" clients. +423. By virtue of these knowing and intentional violations of 18 U.S.C. §§ +1591(a)(1), 1595, JP +is liable to Jane Doe 1 and the other members of the +Class for the damages they sustained and reasonable attorneys' fees. +424. By virtue of these intentional and outrageous violations of 18 U.S.C. §8 +1591(a)(1), 1595, JP +is liable to Jane Doe 1 and other members of the Class +for punitive damages. +COUNT VIII +CONSPIRACY TO COMMIT VIOLATIONS OF THE TRAFFICKING +VICTIM PROTECTION ACT, 18 U.S.C. §§ 1594(c), 1591, 1595 +425. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +426. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +427. JP +intentionally conspired with others, including Epstein and +his other co-conspirators, by agreement and understanding, to violate 18 U.S.C. $8 +1591(a)(1) & (a)(2) & 1591(d), and to further Epstein's sex-trafficking venture to +coerce commercial sex acts from Jane Doe 1 and other Class Members, all in +111 + + +CaGas:17272₽00#98857D0000mBT 7 FEe 000838633 3 129g 2830 BB81 +violation of 18 U.S.C. § 1594(c). JP | +officers and employees (e.g., Staley) +directly conspired with Epstein himself to further the sex-trafficking venture. +428. JP +conspiracy to violate 18 U.S.C. 1591(a)(1) & (a)(2) was +forbidden by 18 U.S.C. § 1594(c), and JP +thereby violated Chapter 77, Title +18. JP +conspiracy directly, proximately, and foreseeably harmed Jane Doe +1, as well as other members of the Class, by directly leading to their forcibly being +caused to engage in commercial sex acts and in other ways. JP +conspiracy +victimized Jane Doe 1 and the other members of the Class. +429. JP +conspiracy to violate 18 U.S.C. 1591(d) was forbidden by +18 U.S.C. § 1594(c), and JP +thereby violated Chapter 77, Title 18. JP +conspiracy directly, proximately, and foreseeably harmed Jane Doe 1, as +well as other members of the Class, by directly leading to their forcibly being caused +to engage in commercial sex acts and in other ways. JP +conspiracy +victimized Jane Doe 1 and the other Members of the Class. +430. JP +conspired with Epstein and his other co-conspirators to +further the Epstein sex-trafficking venture and with the purpose of facilitating +Epstein's illegal sex trafficking. JP L +had actual knowledge of Epstein's sextrafficking venture. JP +acted with the specific intent to violate 18 U.S.C. §S +1591(a)(1) & (a)(2), that is, with consciousness of the nature of Epstein's sextrafficking venture and with the specific intent to further venture. JP +112 + + +CaGas:17272#₽00#98857D0000mBT 7 FEe 000838633 3 129g B80b BB81 +Epstein had a meeting of the minds as to the essential nature of the plan. +431. JP +conspiracy with Epstein was part of its participation in his +sex-trafficking venture. Without JP +agreeing to facilitate the venture (by, +for example, conspiring to keep the existence of cash disbursals secret), Epstein +would not have been a position to move forward with his sex-trafficking venture and +to recruit and entice victims of the venture. +432. JP| +also conspired with Epstein and his other co-conspirators to +obstruct, attempt to obstruct, to interfere with, and to prevent the enforcement of the +TVPA, violating 18 U.S.C. § 1591(d). The conspiracy included an agreement to +keep Epstein's sex-trafficking venture secret or, at least, concealed to the greatest +extent possible. Among the means for keeping the venture secret were paying for +the commercial sex acts in cash, structuring cash withdrawals in a way to avoid +detection, and JP +failing to timely file SARs of Epstein's suspicious +activities. +433. Further actions regarding JP +conspiracy to obstruct TVPA +enforcement are outlined in Count X (obstruction) below in paragraph 472-86, which +are hereby incorporated by reference as if set forth in full in this Count. +434. Within this District, JP | +intentionally committed overt acts in +furtherance of the conspiracy, agreement, and understanding to violate 18 U.S.C. $ +1591(a) by knowingly playing an active role in assisting, supporting, and facilitating +113 + + +CaGas:17272₽80#9885D000009 T68 7 1886000838633 3 12199g 15508881 +the recruiting, enticing, coercing, harboring, transporting, and inducing and forcibly +causing Jane Doe 1 and other Class Members to engage in commercial sex acts, +through providing financial support for the Epstein sex-trafficking venture. A +number of those acts were committed by JP +officer, Jes Staley, acting +within the actual and apparent scope of his employment to further JP +interests. +435. Among the many overt acts intentionally committed by JP +in +furtherance of the sex-trafficking venture were creating and maintaining a special +and unusual financial relationship between JP +and Epstein within this +District designed to facilitate Epstein's sex-trafficking. The relationship went far +beyond providing routine banking opportunities. +436. Acting within this District and in furtherance of the Epstein sextrafficking venture, on or about August 19, 2013, JP +opened various +brokerage accounts for Epstein-related companies. JP +knew, and should +have known, that opening these accounts would facilitate Epstein's coercive sex +trafficking. +437. In furtherance of the Epstein sex-trafficking venture, between about +200 and August 2013, JP| +opened numerous financial accounts for Epstein, +his related entities, and associates. The accounts were in and affecting interstate and +foreign commerce. These accounts were opened within this District. +114 + + +CaGas:17272₽00#98857D0000m 8X968 7 FEe 000838633 3 1299g 56660 BB81 +438. In furtherance of the Epstein sex-trafficking venture, between about +2000 and August 2013 and following, JP +concealed its delivery of vast sums +of cash to Epstein and his associates. Among its affirmative acts of concealment, JP +willfully failed to timely file required SARs with the federal government. +439. JP +deliberately and purposely omitted to timely file appropriate +SARs about Epstein's cash transactions, wrongful omissions that were actions in +furtherance of its conspiracy. +440. JP +actions in furtherance of Epstein's conspiracy were +intertwined with Epstein's sex-trafficking venture, as the funding for the sextrafficking venture (and particularly cash for the venture) were essential tools for +Epstein to commit coercive commercial sex acts. +441. It was part of the conspiracy that JP | +would financially benefit +from providing financial support for the Epstein sex-trafficking venture. JP| +did financially benefit from its participation in the venture, including receiving +valuable deposits and business opportunities from Epstein. +442. JP +participation in furthering Epstein's sex-trafficking +venture was intentional and willful and, therefore, JP +intentionally and +willfully caused Epstein's commission of the forcible commercial sex acts with Jane +Doe 1 and other Class Members through its affirmative and overt acts supporting +Epstein. JP +knew, and was in reckless disregard of the fact, that means of +115 + + +CaGas:17272₽80#9885D0000m 8X968 7 FEe 000838633 3 1219g 68060B฿81 +force, threats of force, fraud, coercion, and a combination of such means would be +used by Epstein and his other co-conspirators to cause Jane Doe 1 and other Class +Members to engage in commercial sex acts. +443. JP +knew, acted in reckless disregard of the fact, and should +have known, that its conspiracy would directly and proximately lead to unlawful +coercive commercial sex acts by Epstein with young women and girls, including +Jane Doe 1 and other Class Members. +444. The conspiracy that JP +joined had specific knowledge that Jane +Doe 1, as well as other Members of the Class, were being coercively sex trafficked +by Epstein. The conspiracy's knowledge extended to the names of Epstein's victims, +because Epstein and his co-conspirators knew the names of the victims, including +Jane Doe 1's name. JP +, through its officer Jes Staley, also new many of the +names of the victims. +445. JP| +conspired to violate 18 U.S.C. § 1591(a) with Epstein and +through its affirmative acts and substantial support to Epstein committed, +perpetrated, and directly and proximately caused Jane Doe 1 and other Class +Members to engage in commercial sex acts through means of force, threats of force, +fraud, coercion, and a combination of such means. +446. In addition to acting with knowledge that they were conspiring to +support the Epstein sex-trafficking venture, JP +benefited financially from +116 + + +CaGast17272₽00#98857D0000m T68 7 FEe 000808633 3 1299g V8808881 +conspiring to participate in the Epstein sex-trafficking venture, which JP | +knew and should have known that had engaged in coercive sex trafficking in +violation of 18 U.S.C. § 1591(a)(1) & (a)(2), as well as obstruction of the +enforcement of the TVPA in violation of 18 U.S.C. § 1591(d). +447. JP +conspiracy has caused Jane Doe 1 and other Class +Members serious harm, including, without limitation, physical, psychological, +financial, and reputational harm. That harm was directly and proximately caused by +the conspiracy and the harm resulting from conspiracy was foreseeable. +448. JP +conspiracy has caused Jane Doe 1 harm that is sufficiently +serious, under all the surrounding circumstances, to compel a reasonable person of +the same background and in the same circumstances to perform or to continue +performing commercial sexual activity in order to avoid incurring that harm. +449. This case does not involve mere fraud. Instead, JP +criminal +conduct in conspiring to violate the TVPA was outrageous and intentional, because +it was in deliberate furtherance of a widespread and dangerous criminal sex +trafficking organization. JP +conspiracy also evinced a high degree of +moral turpitude and demonstrated such wanton dishonesty as to imply a criminal +indifference to civil obligations. JP L +conspiracy was directed specifically +at Jane Doe 1 and other members of the Class, who were the victims of Epstein's +sex trafficking organization. +117 + + +CaGas:17272₽80#95857D0000m B68 7 FEd 000838633 3 1299g 88560 BB81 +450. By virtue of these violations of 18 U.S.C. § 1594(c) JP +is liable +to Jane Doe 1 and the other Members of the Class for the damages they sustained +and reasonable attorneys' fees under 18 U.S.C. § 1595. +451. By virtue of its intentional and outrageous conspiracy to violate 18 +U.S.C. §8 1594(c), JP +is liable to Jane Doe 1 and other members of the Class +for punitive damages under 18 U.S.C. § 1595. +ATTEMPT TO COMMIT VIOLAOONS OF THE TRAFFICKING VICTIM +PROTECTION ACT, 18 U.S.C. §$ 1594(a), 1591, 1595 +452. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1-285, as if fully set forth in this Count. +453. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +454. JP +intentionally attempted to violate 18 U.S.C. § 1591(a)(1) +and (a)(2), and to further Epstein's sex-trafficking venture to coerce commercial sex +acts from Jane Doe 1 and other Class Members, all in violation of 18 U.S.C. § +1594(a). +455. JP +officers and employees, including Staley, deliberately took +substantial steps to attempt to violate 18 U.S.C. § 1591(a)(1) & (a)(2) within this +District. +456. JP +deliberately took substantial steps toward attempting to +118 + + +CaGas:17272₽80#95857D0000m TER 7 FEe 000838633 3 1229g 80560 BB81 +violate 18 U.S.C. § 1591(a)(1) & (a)(2), by providing substantial financial support +for the Epstein sex-trafficking venture. The financial support included hundreds of +thousands of dollars in cash. +457. Among the many substantial steps taken by JP| +to deliberately +attempt to violate 18 U.S.C. § 1591(a)(1) & (a)(2) were creating a special and +unusual financial relationship between JP | +and Epstein within this District +that was designed to, and did, facilitate Epstein's sex-trafficking venture and the sex +trafficking of Jane Doe 1, as well as other Members of the Class. +458. In attempting to further the Epstein sex-trafficking venture, between +about 2000 and August 2013, JP +opened numerous accounts for Epstein, his +related entities, and associates. The accounts were in and affecting interstate and +foreign commerce. JP +opened the accounts within this District for the +purpose of attempting to facilitate Epstein's sex-trafficking venture. +459. In opening numerous accounts for Epstein, his related entities, and +associates, JP +took a substantial step toward benefitting from participating +in Epstein's sex-trafficking venture. JP| +also took other substantial, concrete +steps toward benefitting from the venture. +460. It was part of the attempt to violate 18 U.S.C. 1591(a) that JP| +would financially benefit from participating in and providing financial support for +the Epstein sex-trafficking venture. JP +did financially benefit from its +119 + + +CaGas:17272₽80#98857D@oomeBTE68 7 FEe=000838683 3 129gt201060BB81 +participation in the venture, including receiving valuable deposits from Epstein and +Epstein-related entities into JP +461. JP| +attempt to violate the TVPA by furthering Epstein's sextrafficking venture was intentional and willful and, therefore, JP +intentionally and willfully caused Epstein's commission of sexual abuse and +commercial sex acts with Jane Doe 1 and other Class Members through its +affirmative and overt acts supporting Epstein. +462. JP +knew and acted in reckless disregard of the fact, that its acts +and conduct attempting to support and facilitate Epstein would lead to sexual abuse +and unlawful coercive commercial sex acts by Epstein with young women and girls, +including Jane Doe 1 and other Class Members. +463. In addition to acting intentionally and with knowledge that they were +supporting the Epstein sex-trafficking venture, JP| +benefited financially from +attempting to participate in the Epstein sex-trafficking venture which JP +should have known that had engaged in coercive sex trafficking in violation of 18 +U.S.C. § 1591(a)(1) & (a)(2). +464. This case does not involve mere fraud. Instead, JP +criminal +conduct in attempting to violate the TVPA was outrageous and intentional, because +it was a deliberate attempt to further the crimes of a widespread and dangerous +criminal sex trafficking organization. JP| +criminal attempts also evinced a +120 + + +CaGas:17272#₽80#95857D0000mBT 7 FEde000838633 3 129gt987308881 +high degree of moral turpitude and demonstrated such wanton dishonesty as to imply +a criminal indifference to civil obligations. JP +criminal attempt was +directed specifically at Jane Doe 1 and other members of the Class, who were the +victims of Epstein's sex trafficking organization. +465. JP +conduct has caused Jane Doe 1 and other Class Members +serious harm, including, without limitation, physical, psychological, financial, and +reputational harm. This harm was a direct, proximate, and foreseeable result of JP +attempt in violation of 18 U.S.C. § 1594(a). +466. By virtue of these violations of 18 U.S.C. § 1594(a), JP +is liable +to Jane Doe 1 and the other Members of the Class for the damages they sustained +and reasonable attorneys' fees under 18 U.S.C. § 1595. +467. By virtue of its intentional and outrageous attempt to violate 18 U.S.C. +§ 1594(a), JP | +is liable to Jane Doe 1 and other members of the Class for +punitive damages under 18 U.S.C. § 1595. +COUNT X +OBSTRUCTION OF THE ENFORCEMENT OF THE TRAFFICKING +VICTIM PROTECTION ACT, 18 U.S.C. § 1591(d) +468. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs +1 - 285, as if fully set forth in this Count. +469. Jane Doe 1 brings this Count individually and on behalf of the other +Class Members she respectively seeks to represent. +121 + + +CaGas:17272₽00#9885D000m T68 7 FEe 000838633 3 129gt22330 BB81 +470. JP +and its officers and employees (including Staley) knowingly +and intentionally obstructed, attempted to obstruct, interfered with, and prevented +the enforcement of 18 U.S.C. §$ 1591(a)(1) & (a)(2), all in violation of 18 U.S.C. § +1591(d). This activity is hereinafter referred to collectively simply as "obstruction." +471. JP +obstruction of the enforcement of 18 U.S.C. §§ 1591(a)(1) +and (a)(2) was forbidden by 18 U.S.C. § 1591(d), and JP | +thereby violated +Chapter 77, Title 18. JP +obstruction described here and in the preceding +paragraph directly, proximately, and foreseeably harmed Jane Doe 1, as well as other +members of the Class, by directly resulting in them coercively being caused to +engage in commercial sex acts and in other ways. +472. As outlined above, the United States Department of Justice (including +the U.S. Attorney's Office for the Southern District of New York and the U.S. +Attorney's Office for the Southern District of Florida) was investigating Epstein's +federal criminal liability for violating (among other laws) the TVPA up to and +following the return of an indictment against Epstein on or about July 8, 2019. On +or about that date, the U.S. Attorney's Office for the Southern District of New York +indicted Epstein (and unnamed "associates") for violating the TVPA. Later, on about +June 29, 2020, the same Office indicted Epstein's co-conspirator, Ghislaine +Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. +The federal criminal investigation of Maxwell included investigation of possible +122 + + +CaGas:17272₽00#95857D000ame BTS& 7 FEe=000838683 3 129gt2870b0 BB81 +violations of the TVPA. +473. By providing financing for Epstein's sex trafficking organization from +about 2000 through about August 2013, and concealing its actions thereafter, JP +obstructed, interfered with, and prevented the federal government's +enforcement of the TVPA against Epstein. To the extent that the federal government +was able to ultimately charge Epstein with TVPA violations, the filing of those +charges was delayed by JP +actions. Because of that delay, Jane Doe 1 as +well as other members of the Class, were coercively caused to engage in commercial +sex acts. +474. As one example of how JP +_obstructed, attempted to obstruct, +interfered with, and prevented the federal government's enforcement of the TVPA, +provided large amounts of cash to Epstein and his associates so that the +coercive commercial sex acts would escape the detection of federal law enforcement +and prosecuting agencies. JP +provided large amounts of cash to further the +Epstein sex-trafficking venture and with the purpose of helping Epstein evade +criminal liability for violating the TVPA. +475. As another example of how JP +obstructed, attempted to +obstruct, interfered with, and prevented the federal government's enforcement of the +TVPA, JP +did not follow AML and anti-structuring reporting requirements +found in the Banking Secrecy Act and other laws. These requirements included an +123 + + +CaGas:17272₽80#98857D000ame T68 7 FEe=000838633 3 12 9gt92350 BB81 +obligation that JP +would review transactions in the Epstein's JP | +accounts for a determination of whether they involved suspicious transactions. If JP +had observed these requirement imposed by law, then it would have +prevented many of the subsequent transactions committed by the Epstein sextrafficking venture. +knowingly did not follow these requirements +because it knew that doing so would have prevented Epstein's secret cash +transactions that were necessary to his sex-trafficking operation escaping knowledge +of federal investigative and prosecuting agencies. Without JP +cash, Jane +Doe 1, as well as other members of the Class, would not have been coercively forced +to engage in commercial sex act. +476. As another example of how JP +obstructed, attempted to +obstruct, interfered with, and prevented the federal government's enforcement of the +TVPA, JP +failed to timely file with the federal government the required +SARs that financial institutions must file with FinCEN whenever there is a suspected +case of money laundering or fraud. Timely filing of these reports is required by the +Bank Secrecy Act and related laws and regulations. These reports are tools that the +federal government uses to detect and prosecute, among other illegal activities, sex +trafficking in violation of the TVPA. By failing to timely file the required SARs +regarding Epstein's cash transactions, JP +obstructed, attempted to obstruct, +interfered with, and prevented the federal government's enforcement of the TVPA +124 + + +CaGast7272#₽80#95857D0000mBT 7 FEe 000838633 3 12 9gt23860 BB81 +by concealing from the federal government's attention Epstein's cash transaction in +aid of sex trafficking. +477. JP +disclosing the existence of a SAR. JP +can disclose its failure to file appropriate SARs without +is not protected from liability for +failure to file a required SAR. +478. JP +failure to timely file SARs about Epstein's sex-trafficking +venture, in spite of numerous red flags, was wrongful and purposeful. +479. If JP +had filed timely required SARs about Epstein's sextrafficking venture with the federal government, the appropriate federal agencies +would have been well positioned to investigate Epstein's sex-trafficking venture's +TVPA violations. JP +failure to timely file the required SARs obstructed +the federal government's ability to investigate those TVPA violations, including +violations harming Jane Doe 1 and other Class Members. IfJP +had timely +filed the required SARs, it would have prevented the continuation of Epstein's sex +trafficking venture, which required the ability to secretly use cash to payoff victims. +480. By providing large amounts of cash to Epstein and his associates, JP +intended and knew that Epstein's coercive commercial sex acts would +escape the detection of federal law enforcement and prosecuting agencies for some +period of time. JP +provided large amounts of cash to further the Epstein +sex-trafficking venture and with the purpose of helping Epstein evade criminal +125 + + +CaGas:17272#₽80#95857D000098768 7 FEe=000838633 3 129gt267060BB81 +liability for violating the TVPA. +481. JP +obstruction, attempted obstruction, interference with, and +prevention of the enforcement of the TVPA were all done intentionally and +knowingly. For example, JP +knew that Epstein was high risk-specifically, +high risk to violate the TVPA through continuing criminal sex trafficking activities. +482. JP +was well aware that Epstein had pleaded guilty and served +prison time for engaging in sex with a minor—a crime closely connected with sex +trafficking in violation of the TVPA. JP +_ was also well aware that there were +public allegations that his illegal conduct was facilitated by several named coconspirators. But JP +concealed from the federal government its numerous +cash payments to those co-conspirators. JP +continued its affirmative conduct +of providing cash to Epstein so that he could make those cash payments to his coconspirators with knowledge that such cash transaction did not produce a clear paper +trail. JP +intentional conduct obstructed, attempted to obstruct, in many +ways interfered with, and prevented the enforcement of the TVPA by federal +investigators and prosecuting agencies. +483. JP +relationship with Epstein in providing to his sextrafficking venture with vast sums of cash each year went far beyond a normal (and +lawful) banking relationship. JP| +knew, and intended, that its relationship +with Epstein would go far beyond a normal banking relationship. JP| +knew +126 + + +CaGas:7272₽80#98857D0000mBT 7 FEe 000838633 3 29gt27880 BB81 +that its decision to beyond a normal banking relationship with Epstein obstructed the +ability of federal law enforcement and prosecuting agencies to enforce the TVPA. +484. JP +obstruction of the federal government's TVPA and other +law enforcement efforts was intentional and willful and, therefore, JP +intentionally and willfully caused Epstein's commission of the forcible commercial +sex acts with Jane Doe 1 and other Class Members through its obstruction supporting +the concealment of Epstein's sex-trafficking venture. JP +knew that Epstein +and his other co-conspirators would use means of force, threats of force fraud, +coercion, and a combination of such means to cause Jane Doe 1 and Class Members +to engage in commercial sex acts. +485. JP +knew, acted in reckless disregard of the fact, and should +have known, that its obstruction in violation of 18 U.S.C. § 1591(d) would directly +and proximately lead to unlawful coercive commercial sex acts by Epstein with +young women and girls, including Jane Doe 1 and other Class Members. +486. JP +obstruction has caused Jane Doe 1 and other Class +Members serious harm, including, without limitation, physical, psychological, +financial, and reputational harm. That harm was directly and proximately caused by +the obstruction and the harm resulting from obstruction was foreseeable. +487. JP +obstruction has caused Jane Doe 1 harm that is sufficiently +serious, under all the surrounding circumstances, to compel a reasonable person of +127 + + +CaGas:7272#₽80#98857D0000mBT 7 FEe 000838633 3 12 9gt287560 BB81 +the same background and in the same circumstances to perform or to continue +performing commercial sexual activity in order to avoid incurring that harm. +488. This case does not involve mere fraud. Instead, JP +criminal +conduct in obstructing enforcement of the TVPA was outrageous and intentional, +because it was in deliberate furtherance of a widespread and dangerous criminal sex +trafficking organization. JP +obstruction also evinced a high degree of' +moral turpitude and demonstrated such wanton dishonesty as to imply a criminal +indifference to civil obligations. JP L +obstruction was directed specifically +at Jane Doe 1 and other members of the Class, who were the victims of Epstein's +sex trafficking organization. +489. By virtue of these violations of 18 U.S.C. § 1591(d), JP| +is liable +to Jane Doe 1 and the other Members of the Class for the damages they sustained +and reasonable attorneys' fees by operation of 18 U.S.C. § 1595. JP +perpetrated an obstruction of the TVPA, and therefore perpetrated a violation of +Chapter 77, Title 18. +490. By virtue of its intentional and outrageous obstruction to prevent +enforcement of the TVPA, in violation 18 U.S.C. § 1591(d), JP +is liable to +Jane Doe 1 and other members of the Class for punitive damages by operation of 18 +U.S.C. § 1595. +VIII. REQUEST FOR RELIEF +128 + + +CaGas:17272₽80#95857D0000m 8X968 7 FEe 000838633 3 12 9gt238660 BB81 +Jane Doe 1 respectfully requests that the Court enter judgment in her +favor, and against JP +as follows: +a. That the Court certify the Class, name Jane Doe 1 as Class +Representative, and appoint her lawyers as Class Counsel; +b. That the Court award Plaintiff and the other members of the Class +compensatory, consequential, general, nominal, and punitive damages +against Defendant in an amount to be determined at trial; +c. That the Court award punitive and exemplary damages against Defendant +in an amount to be determined at trial; +d. That the Court award to Plaintiff the costs and disbursements of the action, +along with reasonable attorneys' fees, costs, and expenses; +e. That the Court award pre- and post-judgment interest at the maximum +legal rate; and +f. That the Court grant all such other and further relief as it deems just and +proper. +JURY DEMAND +Plaintiffs demand a trial by jury on all claims so triable. +Dated: January 13, 2023 +Respectfully Submitted, +POTTINGER, LLC +By: /s/ +129 + + +CaGast17272/Đ₽80#98857Ddòoamee8TD68 7 FEe6000838633 3 129gtBB8%0 BB81 +425 N. Andrews Ave., Suite 2 +Fort Lauderdale, FL 33301 +(954)-524-2820 +Fax: (954)-524-2822 +Email: brad@epllc.com +POTTINGER +Brittany N. +1501 Broadway +Floor 12 +New York, NY +(954)-524-2820 +Fax: (954)-524-2820 +Email: brittany@epllc.com +David Boies +Boies Schiller Flexner LLP +55 Hudson Yards +New York, New York +Telephone: (212) 446-2300 +Facsimile: (212) 446-2350 +E-mail: dboies(@bsfllp.com +Sigrid McCawley +Pro Hac Vice +Boies Schiller Flexner LLP +401 E. Las Olas Blvd. Suite 1200 +Fort Lauderdale, FL 33316 +Telephone: (954) 356-0011 +Facsimile: (954) 356-0022 +Email: smccawley@bsfllp.com +130 \ No newline at end of file diff --git a/vision-fixhub/court-05/5fd2c71981216d34034758199e41b596d5f4f1e5994f820d89ae1ea36b7d214d.receipt.json b/vision-fixhub/court-05/5fd2c71981216d34034758199e41b596d5f4f1e5994f820d89ae1ea36b7d214d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..28400f1bab959ef4eb75c9e8e84165c6772a8e37 --- /dev/null +++ b/vision-fixhub/court-05/5fd2c71981216d34034758199e41b596d5f4f1e5994f820d89ae1ea36b7d214d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -2586, + "dataset": "marble-joined", + "doc_id": "5fd2c71981216d34034758199e41b596d5f4f1e5994f820d89ae1ea36b7d214d", + "engine": "marble-apple-vision", + "event_count": 274, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "0da5e9aca580505672a7e55390fc5356427585b2a36de71ae2ba10ebc182b285", + "output_sha256": "028a11438a809c5d5b83e6c80d7edbc1a6fca4bcce97f4f3a9b54d8ce24ae252", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/5fdd92bf32efa3b4d5a791b688026521a7a3e0f2dc3e5c3e1ea11d0a7a23c116.md b/vision-fixhub/court-05/5fdd92bf32efa3b4d5a791b688026521a7a3e0f2dc3e5c3e1ea11d0a7a23c116.md new file mode 100644 index 0000000000000000000000000000000000000000..81801502c821931d3ae9aefdac79d48988ea5363 --- /dev/null +++ b/vision-fixhub/court-05/5fdd92bf32efa3b4d5a791b688026521a7a3e0f2dc3e5c3e1ea11d0a7a23c116.md @@ -0,0 +1,208 @@ +Case 1:22-cv-10904-JSR Document 194-2 Filed 06/20/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 194-2 Filed 06/20/23, Page 2 of 3 +INDUSTRIAL DEVELOPMENT COMMISSION ANNUAL REPORT +Company Name & Address: +Telephone No.: +Name / Signature of Preparer: +Fiscal Year Ending December 31, 2000 +Financial Trust Company Inc. 6100 Red Hook Quarter B-3 St +(340) 775-2525 +Jeanne +USVI 00802 +(Name +Cade Burdene +(Signaterr) +Gross Sale (Ineligible Sales ) Eligible for Tax Benefits +Gross Wages Paid In the V.I. (Include vacation & sick pay, bonuses, overtime, ele.) +Avcrage No. of Employees; Full Time & (Part Time) +Average No. of Residents; Full Time & ( Part Time) +10 +10 +Average No. of Non-Residents; Full Time & Part Time +Other Employee Cost (Unemployment &: Health Insurance, Pension, Allowances, elc.) * +Employce Income Taxes Paid and Withheld +TAXES AND DUTIES (Provide dollar amguts paid, and value of exemption / refund for cach tax) +Gross Receipts: +Amount Paid +19, +Dollar Value of Exemption +Real Property Tax: +Amount Paid +Dollar Value of Exemption co +Excise Taxes: +Total Paid +RECEIVED +IS +Income Taxes: . +Dollar Value of ExemptinO CT 15 2001 +Total Paid +Dollar Value of Exemption Retan EXECUTIVE DIRECTORS +Customs Duties: +Total Paid +OFFICE +Dollar Value of Exemptionheimi +ST. THOMAS +Other: +Hotel room taxes paid +Other Taxes, Fees Paid to V.I. Gover +in en +TOTAL TAXES PAID: +TOTAL VALUE OF EXEMPTIONS AND/OR REFUNDS: +EXPENDITURES FOR GOODS, SERVICES, PLANT & EQUIPMENT +Eligible Suppliers +V.I. Supplers +Non-Local +Goods And Services +Raw Materials, +Components +Food, Beverages +Freight Charges +796 +Insurance +Legal: Accounting +73.726 +Advertising / Promotion +Utilities (Tel., Water, +_1.108 +Elect, etc.) +25,883 +Interest and Other +Banking Charges +Supplies +Repairs / Maintenance +Other (List Separately) += +4,466 +1,100 +.201,850 +Sub-total, Goods and +Services: +281,142 +66 +17,411 +9,846 +99281 +99.042 +154391 154157 +Capital Expenditures: +Building & Improvement +Leaschold Improvemenis +Machinery / Equipment +Furniture / Fixtures +106.070 +42,386 +2,083 +3,580 +10,115 +9,315 +Vehicles +Other (List Separately ) +Subtotal, Capital Expend. +150,539 +GRAND TOTALS +-491-691 +23.030 +27-782 +CUMULATIVE CAPITAL EXPENDITURE UNDER IDC CERTIFICATE +4,615 +-.101 +141 +4,413 +42405 +52735 +66.795 +77,085 +4,947 +2,273 +14.220 +-91.305 +Total +(1$S) + +64.409.495 +569,42l +57,437 +188,537 +2,576,380 +3,047 +6,461.932 +25,845,200 +750 +6.465.729 +28.421,580 +796% +4.615 01 +74,887 +1108 V +25.883 / +207 V +26.290 +10,946 +-360,247 +512,979- +DEFE +109650: 1457127 +57,448 / +20.691v +187.789 +-709-208 +.562.052 +HIGHLY CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER +VI-JPM-000012922 + + +Goods And Services +Dues +Postage and delivery +Airfare +Stockmarket services +Start up costs +Charitable contributions +Co-op marketing fee +Lodging and +transportation +Rent +Sub-total Oder +Case 1:22-CV-10904-JSR Document 194-2 Filed 06/20/23 ) Page 3 of 3 +INDUSTRIAL DEVELOPMENT COMMISSION ANNUAL REPORT +Fiscal Year Ending December 31, 2000 +Orker Expenditures +Eligible Supplier +VII. Suppliers +Non-Local +500 +3,772 +361 +18,070 +24.335 +24.350 +Total +(Tart) +189,350 +12,500 +201,850 +21,393 +73,616 +22697 +99251. +(TRAEL) +66-755 +424a5 +500 +3,772 +18,0704 +24,335 +24.71T INELIPELE +189,350 +d'e +-12,500 +21,393 - +73,616 * +• DEF Hol +368-247 +343,5.36." +HIGHLY CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER +VI-JPM-000012923 diff --git a/vision-fixhub/court-05/5fdd92bf32efa3b4d5a791b688026521a7a3e0f2dc3e5c3e1ea11d0a7a23c116.receipt.json b/vision-fixhub/court-05/5fdd92bf32efa3b4d5a791b688026521a7a3e0f2dc3e5c3e1ea11d0a7a23c116.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a909867d5d353dee7ea44595b9049c64c5134ba2 --- /dev/null +++ b/vision-fixhub/court-05/5fdd92bf32efa3b4d5a791b688026521a7a3e0f2dc3e5c3e1ea11d0a7a23c116.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -52, + "dataset": "marble-joined", + "doc_id": "5fdd92bf32efa3b4d5a791b688026521a7a3e0f2dc3e5c3e1ea11d0a7a23c116", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "a7ec5156d878889ffdf2fbb5622179af184762358b101dea75cd506b4cf720db", + "output_sha256": "25d299329a893e4dac2032c173fbb1bcce8d307868f68bd04e6ba32e9d6cad6b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/608bca7f979ac3fec973813c29cdcf2b39b6d8a51751df39161922b828c342a5.md b/vision-fixhub/court-05/608bca7f979ac3fec973813c29cdcf2b39b6d8a51751df39161922b828c342a5.md new file mode 100644 index 0000000000000000000000000000000000000000..0e68a6c4039de94da80e4dcd9c64b5d9adcdafef --- /dev/null +++ b/vision-fixhub/court-05/608bca7f979ac3fec973813c29cdcf2b39b6d8a51751df39161922b828c342a5.md @@ -0,0 +1,18 @@ +Case 1:22-cv-10904-JSR Document 54-4 Filed 02/22/23 Page 1 of 1 +Supreme Court of Virginía +AT RICHMOND +Certificate +I, Muriel-Theresa Pitney, Clerk of the Supreme Court of Virginia, +do hereby certify that +Meghan Shea Blaszak +was admitted to practice as an attorney and counsellor at the bar of this Court on +November 3, 2010. +I further certify that so far as the records of this office are +concerned, Meghan Shea Blaszak +is a member of the bar of this Court +in good standing. +Wities's my hand and seal of said Court +This 14th day of February +A.D. 2023 +Melindanan +eputy Clerk diff --git a/vision-fixhub/court-05/608bca7f979ac3fec973813c29cdcf2b39b6d8a51751df39161922b828c342a5.receipt.json b/vision-fixhub/court-05/608bca7f979ac3fec973813c29cdcf2b39b6d8a51751df39161922b828c342a5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d412656bbe445a97aca989ab3be075fd9b92a477 --- /dev/null +++ b/vision-fixhub/court-05/608bca7f979ac3fec973813c29cdcf2b39b6d8a51751df39161922b828c342a5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "608bca7f979ac3fec973813c29cdcf2b39b6d8a51751df39161922b828c342a5", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "73daf7f0a2ca2865b244b58b509ef2acdb8436868a611e87fd28239d280054fe", + "output_sha256": "6a1aaf7c4ae2e30360af32845930e6b63e4ef38f774aa924008ebf9076659da8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/608e002dc06a79eb5c4209dc2b82c4ea3cdb73d7e8f712a70c81318d1c30ada5.md b/vision-fixhub/court-05/608e002dc06a79eb5c4209dc2b82c4ea3cdb73d7e8f712a70c81318d1c30ada5.md new file mode 100644 index 0000000000000000000000000000000000000000..23d481159763a1dfbe3e41f8937e1a34c1870813 --- /dev/null +++ b/vision-fixhub/court-05/608e002dc06a79eb5c4209dc2b82c4ea3cdb73d7e8f712a70c81318d1c30ada5.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 241-21 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/608e002dc06a79eb5c4209dc2b82c4ea3cdb73d7e8f712a70c81318d1c30ada5.receipt.json b/vision-fixhub/court-05/608e002dc06a79eb5c4209dc2b82c4ea3cdb73d7e8f712a70c81318d1c30ada5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e6c82d1e53197b091cbb1fece159373a54256356 --- /dev/null +++ b/vision-fixhub/court-05/608e002dc06a79eb5c4209dc2b82c4ea3cdb73d7e8f712a70c81318d1c30ada5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "608e002dc06a79eb5c4209dc2b82c4ea3cdb73d7e8f712a70c81318d1c30ada5", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "81c4f288173a0de031ea1a22b2435d0f6f644060baa0d5d86d1f6cc411d07ae1", + "output_sha256": "0627df80d5a9e4e49283abf4b1f171d7d529c929751529025d37f6d1e1fd353f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/609dcd0e95b88481c4f2f662833fedc555bef9703e386e8fbea828906118ce03.md b/vision-fixhub/court-05/609dcd0e95b88481c4f2f662833fedc555bef9703e386e8fbea828906118ce03.md new file mode 100644 index 0000000000000000000000000000000000000000..483eb33cfeb7969f261a5fd5bc318900a6462809 --- /dev/null +++ b/vision-fixhub/court-05/609dcd0e95b88481c4f2f662833fedc555bef9703e386e8fbea828906118ce03.md @@ -0,0 +1,130 @@ +Case 1:22-cv-10904-JSR Document 267-6 Filed 08/07/23 Page 1 of 5 + + + +Case 1:22-cv-10904-JSR Document 267-6 Filed 08/07/23 Page 2 of 5 +COULS +US news +• This article is more than 8 years old +Jeffrey Epstein's donations to young pupils prompts US +Virgin Islands review + +Government to review corporate sponsorships after revelations +that convicted sex offender and friend of Prince Andrew funded +events for grade school pupils +Jon Swaine in New York +· @jonswaine +Tue 13 Jan 2015 08.56 EST +The government of the US Virgin Islands is to review its corporate sponsorships after it +emerged that Jeffrey Epstein, the convicted sex offender and friend to Prince Andrew, +gave gifts to school pupils and financed events for young children. +Epstein, who was jailed for soliciting girls as young as 14 for prostitution, funded a +department of education science fair for grade school pupils on the islands in October +last year. The 61-year-old paid to transport prize-winning children to the fair in St +and funded their accommodation. + + +Case 1:22-cv-10904-JSR Document 267-6 Filed 08/07/23 Page 3 of 5 +The Guardian has learned that Epstein's two Virgin Islands-based corporations have +also funded a summer camp for children with intellectual disabilities, provided a prize +for a school essay-writing competition, given computers to a pair of high-performing +14-year-old students who were heading to high school, and provided Kindle e-readers +to a school library. +The former banker lives on Little St James, a private island among the US-controlled +territory, where a woman who claims to have been Epstein's teenage "sex slave" +alleged in a court filing last month she was forced to have sexual relations with +Andrew. Buckingham Palace has strenuously denied this allegation. +Epstein is registered as a "Tier 1" sex offender with the US Virgin Islands department of +justice, whose online database allows residents to view his photograph and details of +his 11 cars. Shani Pinney, a department official, said on Monday that such offenders +were barred from working or volunteering in schools and from "loitering on school +property" - +Epstein financed the science fair through his philanthropic foundation, which he has +also used to donate to universities. In a statement, he described the event as "an +exciting and important incentive for students" and said it was aimed at "awarding +students for their impressive work". He also paid for more than 100 Microsoft Surface +tablets for pupils to use. +Weinberg, an attorney for Epstein, said in a statement: "Mr Epstein's +philanthropy is heartfelt and decades old. He has donated to a wide myriad of +charities, scientific initiatives, and education. These efforts have only a single objective +- to help those in need, and in this case, students who in the Virgin Islands are in need +of computers and other educational tools that provide them with a real opportunity to +learn and succeed." +The manager of Epstein's companies is Cecile de Jongh, who until last week was also +the first lady of the US Virgin Islands. Her husband, John, served two terms as governor +from 2007 until this year. The administration of the new governor, Kenneth Mapp, who +took office last week, said that it first learned of Epstein's involvement in the education +system from a Guardian inquiry on Monday. +Kimberly +, a spokeswoman for Mapp, said the administration would be +reassessing sponsorship deals. "Every situation is going to be reviewed individually," +said on Monday. "It is important to note that this all happened under the +previous administration". + + +Case 1:22-cv-10904-JSR Document 267-6 Filed 08/07/23 Page 4 of 5 +Epstein served 13 months in jail after signing a controversial plea agreement with the +US government. The FBI is said to have identified about 40 potential victims of the +former investment banker. +In a filing in a US court last month, +alleged that she was made to +engage sexually with Andrew at Epstein's Virgin Islands property, as well as locations +in London and New York. Epstein had previously been accused by attorneys for alleged +victims of using the island property for orgies with young female associates. +In addition to denying the allegation, Buckingham Palace has stressed that Andrew is +not a party to the lawsuit, which is filed at a federal court in Florida, and therefore is +not able to directly dispute +claim. +said that Governor Mapp, an independent, was monitoring the disclosures about +Epstein "very carefully". She said on Monday: "I can't speak for the governor, but if it +were up to me, there are certain people who would not be able to get on airplanes and +travel here." +Epstein's company for several years also funded a basketball tournament on the US +Virgin Islands for children as young as six. +Tobman, one of the organisers of the +tournament, said on Monday that Epstein's sponsorship would no longer be welcomed. +"I only read about his conviction a couple of days ago and wasn't previously aware of +it," said Tobman. "I wouldn't be happy with someone like that being involved and I +don't think we will be asking them for sponsorship again." Tobman later said that a +final decision would need to be reached with his fellow tournament organisers. +Reached by telephone on Monday, John De Jongh declined to answer questions about +Epstein. "I'm out of office now," he said. De Jongh did not respond to an email and +online message requesting comment. De Jongh's spokesman as governor did not +respond to a request for comment. Cecile de Jongh did not respond to a message left +with her office. Several US Virgin Islands education officials responsible for overseeing +the science fair declined to comment. +I hope you appreciated this article. Before you move on, I was hoping you would +consider taking the step of supporting the Guardian's journalism. +From Elon Musk to Rupert Murdoch, a small number of billionaire owners have a +powerful hold on so much of the information that reaches the public about what's +happening in the world. The Guardian is different. We have no billionaire owner or + + +Case 1:22-cv-10904-JSR Document 267-6 Filed 08/07/23 Page 5 of 5 +shareholders to consider. Our journalism is produced to serve the public interest - +not profit motives. +And we avoid the trap that befalls much US media - the tendency, born of a desire to +please all sides, to engage in false equivalence in the name of neutrality. While +fairness guides everything we do, we know there is a right and a wrong position in +the fight against racism and for reproductive justice. When we report on issues like +the climate crisis, we're not afraid to name who is responsible. And as a global news +organization, we're able to provide a fresh, outsider perspective on US politics - one +so often missing from the insular American media bubble. +Around the world, readers can access the Guardian's paywall-free journalism +because of our unique reader-supported model. That's because of people like you. +Our readers keep us independent, beholden to no outside influence and accessible to +everyone - whether they can afford to pay for news, or not. +If you can, please consider supporting the Guardian today. Thank you. +Betsy +Editor, Guardian US +Single +$5 per month +Monthly +$10 per month +Annual +Other +Continue → +Remind me in July +VISA +MENSES +P PayRol diff --git a/vision-fixhub/court-05/609dcd0e95b88481c4f2f662833fedc555bef9703e386e8fbea828906118ce03.receipt.json b/vision-fixhub/court-05/609dcd0e95b88481c4f2f662833fedc555bef9703e386e8fbea828906118ce03.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fbc50cfd674dce56ee431d7b462b267f356d81a9 --- /dev/null +++ b/vision-fixhub/court-05/609dcd0e95b88481c4f2f662833fedc555bef9703e386e8fbea828906118ce03.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -78, + "dataset": "marble-joined", + "doc_id": "609dcd0e95b88481c4f2f662833fedc555bef9703e386e8fbea828906118ce03", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "f794b57b34b6ddb699b21429482be1a6f086a6f68a2b1e9247fec7b57ffd83ad", + "output_sha256": "40e8a2f934c4cebb3dcfdf40c5a0e263295ea9fa57354efabb863cc47799ab96", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/60a75f57a0357058d954a2319df384f74ae988b0eef925c72b4e425446823978.md b/vision-fixhub/court-05/60a75f57a0357058d954a2319df384f74ae988b0eef925c72b4e425446823978.md new file mode 100644 index 0000000000000000000000000000000000000000..61ff36fde9f8966f7de7290a89e068d36ea5af55 --- /dev/null +++ b/vision-fixhub/court-05/60a75f57a0357058d954a2319df384f74ae988b0eef925c72b4e425446823978.md @@ -0,0 +1,55 @@ +Case 1:22-cv-10904-JSR Document 186-62 Filed 06/14/23 + + + + +Case 1:22-cV-10904-JSR Document 186-62 Filed 06/14/23 Page 2 of 3 +Date: +Subject: +From: +To: +CC: +Thursday, September 1 2011 04:07 PM +Fwd: TWA, LL's tenant approval Middle Bay GA Hangar - ID/badges process assistance +Cecile de Jongh < +@yahoo.com> +Larry Visoski 4 +@aol.com >: +JE ; +Attachments: 2TWA LLCapprovalLetter 1sep2011.pdf; Untitled attachment 48338.htm +With warm regards, +Cecile +Sent from my iPhone +Begin forwarded message: +From: "Walter Challenger" +Date: September 1, 2011 12:04:20 PM EDT +To: "Edred J. Wilkes" +Ce: "Denise Mills" < DMILLS@VIPORT.com >, "Kenn Hobson" < KHOBSON@VIPORT.com > +Subject: TWA, LL's tenant approval Middle Bay GA Hangar - ID/badges process assistance +Good afternoon Chief Wilkes, +Just an FYI: Attached is a copy of an approval letter from VIPA to TWA, LLC for tenancy at the former +Air Center Helicopters' Inc. Middle Bay, General Aviation Hangar, Cyril E. L +Airport. It is selfexplanatory. A proposed lease agreement is in process. The Director of Operations of TWA, LLC, Larry +Visoski, along with other staff of the company (pilots, etc) will visit your office regards badges/ID +process. Please assist accordingly. +The company desires to start to work ASAP on cleaning and refurbishing the hangar bay. +Thank you for your continued assistance and cooperation in this matter. And please call me with any +questions that you may need answered from the Property Management end +Thanks. +Walter + +ESTATE_JPMO16129 + + +Case 1:22-cV-10904-JSR Document 186-62 Filed 06/14/23 Page 3 of 3 +Walter L. Challenger, Jr. +Property Management Officer +Virgin Islands Port Authority +P.O. Box 301707 +St. I +, VI 00803 +tel: (340) 714-6637 +fax: (340) 715-0134 +email: wchallenger@viport.com + +ESTATE_JPMO16130 diff --git a/vision-fixhub/court-05/60a75f57a0357058d954a2319df384f74ae988b0eef925c72b4e425446823978.receipt.json b/vision-fixhub/court-05/60a75f57a0357058d954a2319df384f74ae988b0eef925c72b4e425446823978.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b25e374f775953897074498c65d849168c40863d --- /dev/null +++ b/vision-fixhub/court-05/60a75f57a0357058d954a2319df384f74ae988b0eef925c72b4e425446823978.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -84, + "dataset": "marble-joined", + "doc_id": "60a75f57a0357058d954a2319df384f74ae988b0eef925c72b4e425446823978", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "d7558692c0a4ee1f9861724fe957ace6212402078bf252cf06cb3c26f080e08d", + "output_sha256": "62d3c9b88853a00af8f6f97dd9f584bbbad640caee02cd7f23e300c92e7abcfe", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/60af21cf8fa021a678892ee6d1471b9fc847fbf1ce86539aa6dac9d670bd542d.md b/vision-fixhub/court-05/60af21cf8fa021a678892ee6d1471b9fc847fbf1ce86539aa6dac9d670bd542d.md new file mode 100644 index 0000000000000000000000000000000000000000..d5f9131f1560f6622a2e283a639bc2ee844d8fa3 --- /dev/null +++ b/vision-fixhub/court-05/60af21cf8fa021a678892ee6d1471b9fc847fbf1ce86539aa6dac9d670bd542d.md @@ -0,0 +1,3829 @@ +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 1 of 72 + + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 2 of 72 +1 +2 +3 +4 +5 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE +VIRGIN ISLANDS, +Plaintiff, +v. +JP +No. 22-cv-10904-JSR +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +CHASE BANK, N.A., +Defendant. +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +JAMES EDWARD STALEY, +Third-Party Defendant. +THE ORAL DEPOSITION OF JOHN P. DE JONGH, JR. +was taken on the 30th day of May, 2023 at the Law +Offices of JOEL HOLT, 2132 Company Street, +Christiansted, St. Croix U.S. Virgin Islands, between +the hours of 9:02 a.m. and 4:46 p.m. pursuant to Notice +and Federal Rules of Civil Procedure. +Reported by: +DESIREE D. +Registered Merit Reporter +| Reporting Services +P.O. Box 307501 +st. +1, Virgin Islands +(340) 777-6466 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 3 of 72 +A. Not that I recall, no. +Q. You don't recall a single phone +conversation with Jeffrey Epstein ever? +Q. What about emails? +A. NO. +Q. You don't recall a single email with +Epstein, ever? +From Epstein to me? +Any kind of email contact. +Just the one that I mentioned to you. +early '16. +What year was that? +That would have been late '15 or '16 -- +39 +And what was the substance of that email +communication? +2. +Nothing of substance. Just thank you. +Thank you for what? +He had made an offer to Cecile to lend us +some money after the arrest that took place in order +to settle with the government. +And that's the only email communication +that you've ever had with Epstein? +That I recall, yes. +How long did the First Lady work for + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-CV-10904-JSR Document 267-29 Filed 08/07/23 Page 4 of 72 +Jeffrey Epstein? +A. I think she started in about 2000 and up +until she left like '18 or '19. +So approximately 18 or 19 years? +Yeah - yes. +l. And which specific entities of his did she +work for? +Company. +Financial Trust Company and Southern Trust +40 +In what capacity did she work for him? +Office manager. +What did she do in that role? +MR. TEAGUE: Objection, form. You +can answer if you know. +THE WITNESS: I don't know the +full scale, but just, you know, she +would tell me at times that she was +working on payroll, sending out letters +to government agencies, things -- that's +it. But I don't know the full range of +her responsibilities. +(By Mr. O'Laughlin:) Other than the +in-person meetings that we discussed, the email +communications, the phone calls, have you had any +other means of contact with Jeffrey Epstein? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 5 of 72 +82 +objection. +MR. TEAGUE: It is, because it's a +mischaracterization of his testimony on +the record. Under that objection, you +can answer. +THE WITNESS: Was I aware of -- +(By Mr. O'Laughlin:) Payments made by +Epstein separate and apart from campaign +contributions. +What do you mean - +MR. TEAGUE: Same objection. +THE WITNESS: What do you mean by +"payments"? +(By Mr. O'Laughlin:) What do you understand +the word "payments" to mean? +It can encompass everything. I think I've +mentioned to you that he loaned us 200,000. Is that +what you mean by payment? +What is your understanding of the word +"payments"? +MR. TEAGUE: Same objection, +Counsel. You had asked him at the +beginning of this if he didn't +understand the question to let you know. + + +1 +2 +3 +4 +5 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 6 of 72 +101 +2023, we're on the record. +MR. O'LAUGHLIN: Turn to tab 2 as +the next exhibit. +(Deposition Exhibit No. 5 was +marked for identification.) +(By Mr. O'Laughlin:) So this is a January +24th, 2014 email from ceciledejongh@yahoo.com, and it +says, "Hi, Jeffrey, I have been fundraising for John's +final State of the Territory reception on Monday +night. I have raised $15K of the total $30K budget. +Would you be willing to match that? John and I will +cover the balance." +Did I read that correctly? +You did. +What is a State of the Territory reception? +Annually, the governor is required to give +a state of the territory speech for the previous +year. Usually after the State of the Territory, +there is a reception that's held by the governor and +the staff. +government funds? +And that reception is funded not by +It was not funded by government funds +under our administration. I can't tell you what +others have done. + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 7 of 72 +And you solicited $15,000 from Epstein to +102 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +fund it? +MR. TEAGUE: +Objection, form. You +can answer. +THE WITNESS: +Cecile solicited +15,000. +(By Mr. O'Laughlin:) Did she do this at +your direction? +No. As I mentioned to you earlier, what I +would usually do is sign letters asking for +contributions for various affairs. I probably signed +a letter to him, but I didn't specifically ask her to +go to Mr. Epstein. +2. But you would have signed the letter to +Epstein requesting the funds? +Yes. +MR. TEAGUE: Objection, form. +THE WITNESS: Possibly. Like I +said, I'm not sure who the letters were +sent to, but it wouldn't surprise me if +he wasn't one of them. +(By Mr. O'Laughlin:) If you look at the +top email in this thread, Ms. de Jongh asks, "Do you +want this to go through your personal account or STC?" +Do you see that? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 8 of 72 +A. I do. +Q. Are you aware that money was +routed from +both Epstein and STC. +MS. BOGGS: Objection, form. +Mischaracterizes testimony. +MR. TEAGUE: Same objection. You +can answer if you know. +THE WITNESS: No. +(By Mr. O'Laughlin:) Do you know why the +First Lady was asking Epstein which way to route the +money? +103 +MR. TEAGUE: Objection, calls for +speculation. You can answer. +MS. BOGGS: Same. +THE WITNESS: No. +(By Mr. O'Laughlin:) Are you aware of any +payments from Epstein that were routed through STC? +Are you aware of any payments from Epstein +that were routed through any of his business entities? +MR. O'LAUGHLIN: Turn to tab 4 as +the next exhibit. + + +1 +2 +3 +4 +5 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 9 of 72 +But definitely not this list because highlighted is +Kenneth Mapp. So no. I can't believe she supported +him either. +She says, quote, "I highlighted in yellow +those persons whom we supported." +I'm hoping in this "we " she meant that +the company supported -- Epstein supported. +You don't think that it refers to her? +I find it -- +MS. BOGGS: Objection. +Asked and +answered. +MR. TEAGUE: Objection. +Speculation as well. +THE WITNESS: I find it hard that +she supported Kenneth Mapp, that's all. +(By Mr. O'Laughlin:) Do you have any +reason other than that to know who she meant by "we"? +MR. O'LAUGHLIN: Turn to tab 10 as +the next exhibit. +(Deposition Exhibit No. 11 was +marked for identification.) +(By Mr. O'Laughlin:) This is a +December 24th, 2018 email from the First Lady to +Epstein. She writes, "Happy holidays, Jeffrey. John +127 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 10 of 72 +128 +wanted to know whether you would support Carlton +Dowe's bid to go back to VIPA?" +Who is Carlton Dowe? +Carlton Dowe is a senator during my terms +in office, even before I was governor, and he was a +good supporter, not of just my campaigns but also a +good supporter of my initiatives in government. +What do you mean good supporter? +He supported some of the legislation that +I wanted to put through, and he didn't support some. +He is someone that I could talk to. +What would you talk to him about? +have in process. +that a reference to you? +Whatever legislation or initiative I may +The statement, "John wanted to know, " is +MR. TEAGUE: Objection. Calls for +speculation. You could answer. +THE WITNESS: I'm going to assume +it's me, yes. +(By Mr. O'Laughlin:) Why did you want to +know whether Epstein would support Carlton Dowe's bid +to go back to VIPA? +MR. TEAGUE: Objection, +foundation. You could answer. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 11 of 72 +129 +THE WITNESS: I just wanted to +gain as such support as I could for his +efforts to go back to VIPA, to the +Virgin Islands Port Authority. +(By Mr. O'Laughlin:) Why? +Because I thought he would be very good at +the job. In 2012, when he left as a senator, I +appointed him to be executive director of the Virgin +Islands Port Authority, with the support of the +board, and I thought he did a good job, and I thought +he could do a good job again. +And why did you want to know specifically +whether Epstein would support the bid or not? +MR. TEAGUE: Objection, +foundation. You can answer. +THE WITNESS: Nothing was specific +to Epstein. I was trying -- I was +talking to a number of people and +inquiring as to whether they would +support Carlton's bid to go back to the +Port Authority. +So Cecile saying that to him was nothing +unusual. +(By Mr. O'Laughlin:) What does VIPA do? +The Virgin Islands Port Authority oversees + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 12 of 72 +130 +all the airports and the seaports in the Virgin +Islands. +Q. +So they would have been overseeing the +comings and goings of people entering and exiting the +island? +MS. BOGGS: Objection, form. +MR. TEAGUE: Same objection. +THE WITNESS: No. I think that's +more the federal government. They're in +charge of the facilities, the hard +assets. +(By Mr. O'Laughlin:) Like security? +Within the airport, yes. +So VIPA oversees security within the USVI +airport? +Within the airport. +And is there any sort of Customs check +within the airport? +When you're going through, yes. +Is that overseen by VIPA? +That's overseen by the federal government. +And would security officers employed by - +were they employed by VIPA directly? +MS. BOGGS: Objection, form. +MR. TEAGUE: Same objection. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 13 of 72 +131 +THE WITNESS: That I can't answer. +(By Mr. O'Laughlin:) But they oversaw them? +Yes. +MS. BOGGS: Objection, form. +MR. TEAGUE: Objection, form. +(By Mr. O'Laughlin:) Are you aware of +allegations that Epstein was bringing women in and out +through the USVI airport? +MS. BOGGS: Objection, form. +THE WITNESS: Are we talking in +2014 during my term or are we talking +2018 and '19? +(By Mr. O'Laughlin:) Let's answer both. +What about in 2014? +What about in 2018? +Yes. +So in 2018, you were aware of allegations +that Epstein was bringing women in and out through the +V.I. airport? +MS. BOGGS: Objection, form. +MR. TEAGUE: Same objection. +THE WITNESS: When you say +"airport," I am presuming you mean the +building. Mr. Epstein had a private + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 14 of 72 +138 +whether it was salary or bonus. I wouldn't do that. +I just can't recall that detail. +Q. Were there any benefits in addition to +salary that the First Lady received from Epstein? +Similar to other employees in the office, +we had educational benefits for our children. I +think in the beginning at least, I think it +continued -- I think it was 32 hours of work instead +of 40. So I think those +were the other two benefits. +What do you mean by educational benefits? +Part of the package that she received was +to have our tuition paid for our children if they +went to a private school, which was similar to what +was negotiated for the other employees in the office. +2. +Did that apply to a primary school tuition? +If they went to a private school. +Did it apply to high school tuition? +Yes. +Did it apply to college tuition? +Yes. +How much? +I don't know the dollar amount. +MR. O'LAUGHLIN: Let's enter tabs +12 and 11 as the next exhibit. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 15 of 72 +142 +(Deposition Exhibit No. 13 was +marked for identification.) +(By Mr. O'Laughlin:) This is a +January 10th, 2000 email from Epstein to First Lady +and Richard Kahn, and it has a summary of attachments +that sets out amounts of payment. It has an entry for +at Wake Forest, $19,551; Rene, Skidmore +College, $20,210; +• Elon University, $12,744; +and JP, American University, $17,561." +Did I read notes correctly? +Yes. +Is JP a reference to your son? +MS. BOGGS: Objection. Calls for +speculation. Lack of foundation. +MR. TEAGUE: Same objection. You +can answer. +THE WITNESS: I believe so, yes. +(By Mr. O'Laughlin:) Is Renee a reference +to your daughter? +MS. BOGGS: Same objections. +MR. TEAGUE: Same objections. +She +can answer. +THE WITNESS: Yes. +to Jean +(By Mr. O'Laughlin:) Is +son? +a reference + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 16 of 72 +143 +MS. BOGGS: Same objections? +MR. TEAGUE: Join. +THE WITNESS: I'm going to presume +so, yes. +(By Mr. O'Laughlin:) Is +a +reference to Jean +. BOGGS: Same objections. +MR. TEAGUE: Join that objection. +THE WITNESS: I presume, yes. +(By Mr. O'Laughlin:) So this is a summary +of tuition payments that were being made by Epstein to +pay for the tuition of those four children. +MS. BOGGS: Same objections. +MR. TEAGUE: Objection. Calls for +speculation. You can answer. +THE WITNESS: I presume so, yes. +(By Mr. O'Laughlin:) And Jean +was +the - what was her position with your campaign? +Accountant. +So this is for 2009. So if you sum +together the amount for JP and Renee, you received +$37,771 in the form of tuition payments from Epstein? +MR. TEAGUE: Same objection. +MS. BOGGS: Objection. Calls for +speculation, form, lack of foundation. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 17 of 72 +144 +THE WITNESS: I can't answer that. +I haven't done the math. I haven't. +Q. (By Mr. O'Laughlin:) But if you add the +17,561 here with the 20,210. +Yes. +MS. BOGGS: Same objection. +MR. O'LAUGHLIN: Okay. Let's +enter tab 18 as the next exhibit. +MS. BOGGS: Will this be Exhibit +14? +(Deposition Exhibit No. 14 was +marked for identification.) +(By Mr. O'Laughlin:) So this is an email +thread between the First Lady and Epstein on +September 21, 2010. She writes, "I have not received +an answer or indication from you on this subject, so I +have to assume that it is no. If that is the case, I +will need to negotiate a raise so that I can afford to +pay for my children's tuition at college. John and I +have put money into the campaign based on what we +thought was going to happen with the tuition +payments." Did I read that correctly? +MR. TEAGUE: You were reading from +the second page. He was on the first. +THE WITNESS: I didn't see -- I + + +1 +2 +3 +4 +5 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 18 of 72 +145 +didn't know you did the back and front. +Yes. +(By Mr. O'Laughlin:) How much money did +you put into your campaign based on expectations that +Epstein would pay for your children's tuition? +MR. TEAGUE: objection, +foundation. You can answer. +THE WITNESS: I don't recall off +the top of my head, but it was quite a +bit. +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(By Mr. O'Laughlin:) Was it equal to the +amount of the tuition payments that you were getting? +MS. BOGGS: Objection, form. +MR. TEAGUE: Same objection. +THE WITNESS: It was substantial. +(By Mr. O'Laughlin:) What you mean by +quite a bit? +We paid for various items during the +campaign, t-shirts, some literature, things like +that. +Can you estimate? +I-shirts alone, for example, could be +$7,000; literature could come in anywhere around, you +know, 10 to 6,000. +Was the First Lady taking tuition payments + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 19 of 72 +147 +substance, no. +(By Mr. O'Laughlin:) And she continued +accepting the tuition payments? +MS. BOGGS: Objection. Calls for +speculation, form. +MR. TEAGUE: Objection. +Foundation as well. +THE WITNESS: Make sure I +understand. Did she get a salary +increase and receive tuition payments? +(By Mr. O'Laughlin:) No, I'm just asking, +did she continue to receive tuition payments after +these 2010 emails. +MS. BOGGS: Same objections. +THE WITNESS: That I can't -- I +don't recall. +(By Mr. O'Laughlin:) Weren't you involved +in the finances around paying for your children's +tuition? +I was. But I'm not sure what the numbers +were. +correct? +But you know whether you were paying the +tuition bill or Epstein was the paying tuition bill, +MS. BOGGS: Objection. Objection, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 20 of 72 +148 +argumentative. +THE WITNESS: I still pay tuition +fees and various things for my kids when +they were in college. So I'm not sure +how it worked out. +Q. (By Mr. O'Laughlin:) Were the fees you +were paying room and board? +Some was for room, particularly, with J.P. +Epstein? +So who was paying the tuition, you or +I would think Epstein was, yes. +Was that all the way through his school? +That I don't recall. There was a point +where, I think, we started paying, I believe. +Why did you start paying? +I think Cecile may have renegotiated her +salary or it increased and she didn't want to pass it +on. +Do you know when that change would have +happened? +No, that I don't recall. +So that's for John. What about for Renee? +No. It was for John, JP. +MR. O'LAUGHLIN: Look under tab +14. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 21 of 72 +149 +(Deposition Exhibit No. 15 was +marked for identification.) +(By Mr. O'Laughlin:) This is a +December 2010 email to Epstein from the First Lady +attaching tuition bills for the spring semester of +American University and Skidmore College, and putting +the amounts for each of those tuition bills at 18,090 +and 20,175. +So in 2010, you and the First Lady +received approximately 38,000 from Epstein in the +form of tuition payments, correct? +MS. BOGGS: Objection, calls for +speculation, lack of foundation, form. +MR. TEAGUE: Same objections. You +can answer. +THE WITNESS: Yes, based on the +numbers on the Exhibit 13 I'm looking +at. +(By Mr. O'Laughlin:) And did you declare +that as income in 2010? +MS. BOGGS: Objection, form. +THE WITNESS: Again, I'll have to +look at the taxes, but if we gave it to +the accountant, it was prepared. +(By Mr. O'Laughlin:) You believe it was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 22 of 72 +150 +declared as income? +I believe. +Q. Let's enter tabs 15 and 16 as the next +exhibit. +(Deposition Exhibit No. 16 was +marked for identification.) +Q. +(By Mr. O'Laughlin:) This is an email with +the subject line: "Please approve," sent from the +First Lady to Epstein, and an "Attachment: Skidmore +Fall 2011." +And then the attachment contains a +statement of student account from the Skidmore +Bursar's office listing the amount due as +$24,955.50. +So was this amount paid by Epstein in +2011? +MR. TEAGUE: Objection. Form. +MS. BOGGS: Objection. Lack of +foundation. Form. +THE WITNESS: Again, I'm going by +the email. I assume it was. +(By Mr. O'Laughlin:) And did you declare +that as income in 2011? +MS. BOGGS: Objection. Form. +THE WITNESS: Again, based on my + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 23 of 72 +151 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +taxes. +MR. O'LAUGHLIN: Let's do tab 20 +and 21. +(Deposition Exhibit No. 17 was +marked for identification.) +(By Mr. O'Laughlin:) This is a +December 9th, 2011 email from the First Lady to +Epstein, attaching spring 2012 tuition bills for +Skidmore College in the amount of 20,710, and asking +Epstein, "Please approve this payment so that Rich can +process it." +And so if you take the fall 2011 amount +that we just looked at of 24,000, and then the +spring of 2012 that we looked at and combine them, +it shows that in the 2011 to 2012 school year, your +family received approximately 49,000 in tuition +payments for your children from Epstein, correct? +MS. BOGGS: Objection. Lack of +foundation. Calls for speculation. +Mischaracterization. +MR. TEAGUE: Object. Join those +objections. Also foundation. You can +answer. +THE WITNESS: Based on the numbers +you've provided me. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 24 of 72 +152 +(By Mr. O'Laughlin:) And was that amount +declared as income in your 2011 returns and your 2012 +returns? +Should have been, yeah. +What is the EDA? +What is the -- +EDA? +Virgin Islands Economic Development +Authority. +Actually, before I go there, are you +aware -- beyond the payments we've just looked at, are +you aware of any other tuition payments made by +Epstein to you? +MR. TEAGUE: Objection, vague. +MS. BOGGS: Objection, form. +THE WITNESS: No. +(By Mr. O'Laughlin:) But as far as you +know, he paid the tuition for your children all the +way through college, correct? +MS. BOGGS: Objection, form. +MR. TEAGUE: Objection, form. +Foundation. +THE WITNESS: That I don't recall. +I think there was a point where he did +not directly. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 25 of 72 +154 +How do you know he had ownership interest? +I was told that by Andrew Farkas. +When were you told that? +In 2007. +Is the governor's office involved in +granting EDA benefits? +It's involved -- it affirms the decision +of the EDA board that grants the benefits, yes. +And what is the process surrounding that? +involvement? +The process surrounding the governor's +e. Yeah. +The beneficiary will submit the +application to the Economic Development Authority, +which is then reviewed by their staff. They will go +through the process, according to their rules and +regulations as to whether it fits under the +requirements. +It will then be presented by the staff +to the board of the EDA, either with a recommendation +to approve or disapprove. +The board will then make its +determination as to which way they're going. +If it's approved, it is then sent up to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 26 of 72 +155 +governor's office and sent to legal counsel. Legal +counsel does its review of it, and then at that +point, it will come to the governor for signature. +That was at least the process that we followed. +And so focusing on the portion that +involves the governor's office, what exactly does that +review entail? +MR. TEAGUE: objection, asked and +answered. You can answer it. +THE WITNESS: It involves their +basically reviewing the decision that +the board made to make sure they +complied with the Economic Development +Authority rules and regulations. +(By Mr. O'Laughlin:) And -- so they take +the regulations from the EDA and they look at the +application and they compare the two? +The regulations are codified, our rules +and regs. They would then look at the application, +review the application, and then make a +recommendation. +And the - what is the thing they're +evaluating for? Just compliance with the EDA regs? +And to see how the board approved it, +right. And the type of business activity that would + + +1 +2 +3 +4 +5 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 27 of 72 +157 +to what extent. They may call the EDA +to find out more on the activity. +They'll look at the rules and +regulations. +(By Mr. O'Laughlin:) And is a +recommendation made to you personally? +It's made to me, yes. +Was made to me, +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +yes. +And then you review it? +I review the cover memorandum, usually, of +what was provided to me by my legal counsel. I may +get a little bit more into the activities and +understand the type of business it is. +What do you do to get a little more into +the underlying business? +Just look if -- the overview would provide +the business, the type of activity. I may or may not +look at the application just to understand if it was +an unusual business. +Would you ever reach out to the person who +is applying to ask them questions? +Would you look at the financial projections +that they submitted? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 28 of 72 +158 +Would you do any kind of diligence on the +business itself to see that they were doing what they +claimed to be doing? +MS. BOGGS: Objection, form. +MR. TEAGUE: Same objection. +Foundation as well. You can answer. +THE WITNESS: I presume that by +the time it came to me after the +analysis done by EDA staff and the board +and my legal counsel, that that was less +of an issue. +THE REPORTER: I'm sorry, that +was -- +THE WITNESS: Less of an issue. +(By Mr. O'Laughlin:) So what is +specifically the thing that you are reviewing for? +The legal opinion, making sure it is +consistent with the rules and regulations, looking at +the business activity, looking at the economic +development, diversification that was taking place in +the territory. +activity? +What do you mean by looking at the business +If it was unusual. One year, we had +someone that applied that wanted to do manufacturing. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 29 of 72 +159 +We don't have very many manufacturers in the Virgin +Islands, so I just looked at the application to make +sure I understood. +Some were looking at foreign +destinations to sell their products. +I wanted to +see, you know, what percentage of their business +activity they were looking at. Was it -- did they +consider the U.S. foreign or where are they selling? +So I would look at things like that. +unusual? +What would you do if the business -- the +underlying business activity did strike you as +I would, then, more than likely not call +the individual. I'd probably call my attorney and +ask him to look into it. +And they would go and report back to you? +Correct. +Did you review Financial Trust's +application? +Yes. +application? +Did you review Southern Trust's +Okay. Did you find any of their activity +unusual? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 30 of 72 +160 +A. No. +Q. Did you ask anyone to do any further +investigation into them? +A. No. +Q. Did you consider the character and fitness +of applicants as part of your review? +I went by the recommendation by my legal +counsel, usually. +Do you know if your legal counsel would +look into the character and fitness of applicants? +I don't. +Do you know if they would do a background +check? +Beyond what EDA and the work that they may +have done? I'm not aware. +You're not aware of any background check? +I'm not aware if they did, if they went +further. +Are you aware of any investigation of +public reporting surrounding beneficiaries? +MS. BOGGS: Objection, form. +THE WITNESS: I'm not quite sure I +understand. +(By Mr. O'Laughlin:) Are you aware of any +investigation undertaken by your office into public + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 31 of 72 +161 +reporting surrounding the beneficiaries? +MS. BOGGS : +Same objection. +(By Mr. O'Laughlin:) Did you consider +Epstein's past criminal conviction when you reviewed +the Financial Trust application? +I went sole -- +MS. BOGGS: objection, form. +MR. TEAGUE: Same objection. +Foundation as well. +THE WITNESS: I went solely on the +recommendations of the staff -- of my +legal counsel. +(By Mr. 40'Laughlin:) So you didn't +independently consider his sex offender status? +MS. BOGGS: Objection, form. +MR. TEAGUE: Same objections. +THE WITNESS: No. +(By Mr. O'Laughlin:) And you didn't +independently consider his past criminal convictions? +MS. BOGGS: Objection, form. +THE WITNESS: No. +MR. TEAGUE: Objection, form. +Mischaracterization. +THE REPORTER: Hold on. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 32 of 72 +MR. TEAGUE: Mischaracterization +as well. +Q. (By Mr. O'Laughlin:) And you didn't +162 +independently consider public reporting surrounding +Epstein? +MS. BOGGS: Objection, form. +THE WITNESS: No. +(By Mr. O'Laughlin:) Did you reach out to +the First Lady? +MS. BOGGS: Objection, form. When +you say "First Lady," can you clarify +who you mean? +(By Mr. O'Laughlin:) So throughout this +deposition if I refer to First Lady, do you understand +that I'm referring to First Lady, Cecile de Jongh, +your wife? +Okay. +Okay. Did you perceive any conflict of +interest in approving benefits to Epstein's company —- +MS. BOGGS: Objection. +(By Mr. O'Laughlin:) - companies given +that your wife worked for them? +MS. BOGGS: Objection, form. +THE WITNESS: No. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 33 of 72 +163 +(By Mr. O'Laughlin:) Did you ask your +legal counsel to provide any opinion on any potential +conflict of interest? +MS. BOGGS: Objection, form. Also +privileged to the extent it reveals the +substance of any communications between +Governor de Jongh and his legal counsel. +MR. TEAGUE: Same objection. You +can answer. +THE WITNESS: No. +(By Mr. O'Laughlin:) Did you ask for any +assessment of any kind of any potential conflict of +interest? +MS. BOGGS: Same objections to the +extent we're talking about +communications between your attorney and +you. +MR. TEAGUE: Same objection. +THE WITNESS: No. +(By Mr. O'Laughlin:) Are you aware that +any investigation of any kind was undertaken to assess +any potential conflicts of interest? +MS. BOGGS: Same objections. +MR. TEAGUE: Same. +THE WITNESS: No, I'm not aware of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 34 of 72 +164 +any investigations. +Q. +(By Mr. O'Laughlin:) So you testified that +you didn't approve Southern Trust, correct? +MR. TEAGUE: objection, +mischaracterization. +THE WITNESS: No. I said I did +approve Southern Trust. +Trust. +(By Mr. O'Laughlin:) I thought you said +you did approve Financial Trust but not Southern +I believe I said approved Southern Trust. +MR. TEAGUE: Objection. +Mischaracterization of prior testimony. +(By Mr. O'Laughlin:) Okay. So just to +clarify -- +MR. TEAGUE: You have to let me +finish my objection as well, Counsel. +Go ahead. +(By Mr. O'Laughlin:) So just to clarify, +your belief is that you reviewed and approved both +Financial Trust and Southern Trust? +I approved what the EDA board did, yes. +2. +Okay. With respect to both those entities? +Based on their recommendations, yes. +MR. O'LAUGHLIN: Okay. Let's + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 35 of 72 +167 +analysis would have been stored in the government's +records? +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MS. BOGGS: objection, form. +MR. TEAGUE: Same objection. And +objection to the extent of privilege, +but you can answer. +THE WITNESS: No, I don't have any +knowledge. +(By Mr. O'Laughlin:) So if you go to the +last page of the letter to you -- this letter, by the +way, is sent by Albert Bryan, then chairman of the +EDA. +Who is Albert Bryan? +Chairman of the EDA and he was my +commissioner of Labor. +During what years? +2007 to 2014. +And what does he do now? +He's now the governor of the Virgin +2. +Islands. +So at the time he was chairman of the EDA? +Yes. +And he, in that capacity, signed off on +Epstein's tax benefits? +Based on what you're showing me, yes. + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 36 of 72 +168 +And then he forwarded them to you for your +1 +2 +3 +4 +5 +review? +MR. TEAGUE: Objection, form. +THE WITNESS: EDA forwarded it to +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +me, yes. +(By Mr. O'Laughlin:) And then you signed +off on the tax benefits? +That's correct. +Is that your signature on page 5? +Yes, it is. +With an approval date of May 31st, 2013? +Yes. +So the letter that you signed lays out the +benefits that Epstein was receiving through Southern +Trust under section [ +•. BOGGS: Objection, form. +Mischaracterization. +(By Mr. O'Laughlin:) Sorry. Under +Sections A through G. +MS. BOGGS: Same objections. +MR. TEAGUE: Also object to the +extent that the document speaks for +itself. +e. (By Mr. O'Laughlin:) Do you see that? +Yes. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 37 of 72 +173 +fact as part of your consideration? +No, I don't recall the specifics of what +was provided to me back then. +Nothing stood out to you with respect to +Southern Trust Company in terms of the cost benefit +analysis being un-advantageous to the USVI? +No, nothing stood out. +MS. BOGGS: Objection, form. +Mischaracterization. +MR. TEAGUE: Foundation as well. +(By Mr. O'Laughlin:) So there were no red +flags based on the potential that Epstein was giving +only a few pennies and getting a whole dollar for each +dollar benefit, correct? +MS. BOGGS: Objection, form. +Speculation. Mischaracterization. +MR. TEAGUE: Join. I join the +objection. +THE WITNESS: Dollars and pennies, +and I just have no knowledge of that. +Q. +(By Mr. O'Laughlin:) Okay. Under the +Special Conditions section of the letter, there's an +itemized list of the conditions that Southern Trust +has to comply with as part of receiving benefits. +Do you see that? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 38 of 72 +174 +l. Focusing on number 4, it says, "Southern +Trust will provide its full-time employees and +dependents with one hundred percent employer paid +medical insurance coverage." +Do you see that? +Was an employee of Southern Trust the First +Lady? +She was. +Were you a dependent of the First Lady? +How not? +I was covered under my government +insurance. +Okay. So you didn't receive any benefits +pursuant to this. +MS. BOGGS: Objection, form. +(By Mr. O'Laughlin:) Okay. +No, I did not. +If you look at number 9, it says, "Southern +Trust will provide its employees tuition, +reimbursement, employee training and continuing +professional educational courses for programs related + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 39 of 72 +175 +to an employee's job function and approved by +management. The maximum assistance to be provided to +an eligible employee during calendar year is $5000." +Did you see that? +Is this the provision that provided for the +reimbursement tuition payments? +MS. BOGGS: Objection, foundation, +form, speculation. +MR. TEAGUE: Same objection. +THE WITNESS: I can't answer that. +I don't know -- I don't know what the -- +I don't know. This is in 2013. +Southern Trust, I am not quite sure how +it's being applied. +(By Mr. O'Laughlin:) So you don't know +whether the tuition payments were pursuant to this +particular special condition? +I don't. +MS. BOGGS: objection. +Same +objections. +MR. TEAGUE: Same. +(By Mr. O'Laughlin:) Were the tuition +payments that were made in excess of $5,000? +Based on the list you gave me, yes. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 40 of 72 +176 +MR. O'LAUGHLIN: Let's enter tab +22 as the next exhibit. +(Deposition Exhibit No. 19 was +marked for identification.) +THE WITNESS: Could I just make +one statement? +(By Mr. O'Laughlin:) Sure. +The tuition payments were in 2010 and '11, +not '13. +Were you aware of a previous review of +Financial Trust Company? +I'm sorry, what do you mean by that? +The granting of benefits to Financial Trust +Company? +I believe I approved Financial Trust +Company when it came up for renewal, I believe. +Do you recall whether it would have had +this same or similar special conditions? +foundation, form. +MR. TEAGUE: Right. Real fast +before we go into this next exhibit. I +apologize, I need to take a bathroom +break real fast. +That's on me. +VIDEOGRAPHER: We are going off + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 41 of 72 +188 +to anyone in the Governor's office on behalf of +Epstein regarding this response? +MS. BOGGS: Objection, form. +THE WITNESS: No. +(By Mr. O'Laughlin:) So let's look at the +underlying questions that were asked by the reporter. +In section 1, He asks about the fact that you signed +an approval letter for a five-year extension of EDC +benefits to FTC and notes that the statute requires +the EDC director to examine the character of +applicants. +Do you see that? +Do you know if that character analysis was +done? +Again, like I mentioned to you earlier, I +went on the recommendation of the board, whatever +their analysis was, and I also then went on my legal +counsel's recommendation. So what they did, I'm not +sure. +Did they make a recommendation to you that +Epstein was of the requisite character to receive the +benefits? +They made a recommendation that FTC should +be approved for benefits. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 42 of 72 +189 +And do you know whether that included a +recommendation that his character was -- +I don't recall. +MS. BOGGS: Objection. +Mischaracterizes his testimony. +(By Mr. O'Laughlin:) What is your personal +belief as whether his character merited receiving EDC +benefits? +MR. TEAGUE: Objection, form. +MS. BOGGS: Same objection. +THE WITNESS: 2012, I went on the +recommendation. I didn't give it much +thought beyond that. +(By Mr. O'Laughlin:) So you didn't say, I +don't think that his character is appropriate? +I don't recall, no. +You just went with the recommendation? +I went with the recommendation, yes. +The last question in section 1 from the +reporter is, "Do you believe registered sexual +offender, guilty of such violations, should be +receiving these benefits?" +Do you see that? +What's your answer to that question? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 43 of 72 +190 +MS. BOGGS: Objection, form. Lack +of foundation. +THE WITNESS: Again, I'm not -- +you know, I went on the recommendation +of the board and on the recommendation +of counsel. +Q. (By Mr. O'Laughlin:) But what is your +answer to that question? +MS. BOGGS: Same objection. +MR. TEAGUE: Objection. Asked and +answered. +THE WITNESS: I went on the +recommendation of counsel and the board, +and I approved the benefits. +(By Mr. O'Laughlin:) So you approved the +benefits because you thought he should be receiving +them? +MR. TEAGUE: Objection. +MS. BOGGS: Objection, +mischaracterizes testimony, lack of +foundation, form. +MR. TEAGUE: And asked and +answered. I join in those objections as +well. +THE WITNESS: I approved the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 44 of 72 +212 +terms of someone bringing it to my +attention? +Q. (By Mr. O'Laughlin:) Did the First Lady +ever try to avoid things coming to your desk that +would impact Epstein? +MS. BOGGS: Objection. +MR. TEAGUE: Objection, calls for +speculation, form, lack of foundation. +MS. BOGGS: +Same objection. +THE WITNESS: I don't know for +certain but I'm assuming she did. +MR. O'LAUGHLIN: Let's look at tab +30. +(Deposition Exhibit No. 26 was +marked for identification.) +(By Mr. O'Laughlin:) This is an +August 5th, 2013 email from the First Lady to Epstein +commenting on an apparent dispute, First Resort versus +ISJ, LLC, and she writes, "Additionally, this will end +up on John's desk and he would just as soon avoid +that." +Do you see that? +Do you know what this dispute involved? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 45 of 72 +227 +probationers." Do you see that, the first -- the +second sentence? +The email from Jeffrey Epstein to Cecile? +No. The -- yes, yes. +Right. I'm not copied on that. +Right. But do you see that sentence? +Yes. +So it's about transferring parole -- +MS. BOGGS: Objection. +(By Mr. O'Laughlin) -- given the reference +to probationers? +foundation, calls for speculation. +THE WITNESS: Yes. +(By Mr. O'Laughlin:) Were there +discussions of transferring Epstein's house arrest to +the USVI at any point? +Not with me. +You're not aware of any conversations at +any point regarding transferring Epstein's house +arrest from the USVI -- from Florida to the USVI? +I always recommended that Cecile and her +attorneys talk directly to Vincent. So substantive +-- substance of those discussions, no, I'm not aware +of. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 46 of 72 +228 +So you've testified that you didn't receive +the underlying document, correct? +MS. BOGGS: objection, +mischaracterizes testimony. +THE WITNESS: When you refer to +the "underlying document, " are you +talking about the document that was +corrupted? +(By Mr. O'Laughlin:) Yes. +couldn't open it. +I guess I received the document. I +Okay. On Thursday, April 9th at 9:18 a.m., +which is about 20 minutes after the earlier email +where the First Lady asks for the document to be +resent, she says to Epstein, "Thanks. Sending again +to John." +Do you see that? +Yes. +2. Do you receive -- do you recall receiving +that document in that follow-up transmission? +I don't recall, but if I did, I would have +sent it straight to Vincent. +Q. And she -- in fact, she says, the First +Lady says, "John will email to Vincent," correct? +Correct. + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 47 of 72 +229 +Did you email the document to Vincent +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Frazer? +MR. TEAGUE: objection. +MS. BOGGS: Objection, asked and +answered, lack of foundation. +THE WITNESS: I believe I did, +yes. +(By Mr. O'Laughlin:) And do you know what +was in the document? +So you forwarded a document without knowing +what was in it? +foundation, argumentative. +THE WITNESS: Not very unusual in +terms of the substance of the document. +(By Mr. O'Laughlin:) So it's not unusual +for you to have received a document with a subject +line, "Confidential" from Epstein and forwarded to the +attorney general without looking at it? +foundation, calls for speculation, form. +THE WITNESS: It's not unusual for +me to receive documents that post the +subject line. I may not go into the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 48 of 72 +242 +being sent to you from me and I'm giving +it for his review. There's no substance +to our discussions at all. +l. (By Mr. O'Laughlin:) +sorry, who -- +something is being sent from who to who? +From the attorney -- from myself to the +attorney general, there were no discussions on the +substance of it. +general? +could not open. +What was sent from you to the attorney +What Cecile sent me that you -- that I +l. So just to be clear, there's two different +time periods. In 2009, there was that document that +was sent to you that you couldn't open -- +Eh-hmm. +-- regarding the transfer of parole from +Florida to USVI, correct? +Correct. +e. And then in 2012, three years later, there +was a separate legislation regarding SORNA, correct? +Correct. +MR. TEAGUE: Objection, +foundation. +(By Mr. O'Laughlin:) And so were there -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 49 of 72 +243 +did you have any involvement in the 2011, 2012 period +regarding the SORNA legislation? +MS. BOGGS: objection, lack of +foundation. +THE WITNESS: Not in terms of +substantive discussions with the +attorney general. +(By Mr. O'Laughlin:) What -- when you say +substantive discussions, +what do you mean? +MS. BOGGS: Objection. I'm going +to instruct the witness not to answer if +it involves legal advice or seeking +legal advice or seeking legal advice +from the attorney general. +THE WITNESS: Other than to review +what you're looking at, that's it. The +attorney general and I did not have a +discussion about Mr. Epstein or any +others on the sexual offender list at +all. +(By Mr. O'Laughlin:) So what discussions +were there regarding SORNA? +MS. BOGGS: Objection. Again, I +am going to instruct the witness not to +answer in regard to any legal advice or + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 50 of 72 +244 +seeking legal advice from the attorney +general. +THE WITNESS: Again, I don't +recall anything of substance. Something +along that nature, I would pass on to +the attorney general and be guided by +what came back to me. +(By Mr. O'Laughlin:) +Were you ultimately +the one who signed off on the legislation as the +executive? +must have been. +Once it was approved by the legislature, I +And so what was your involvement in +considering the changes to the legislation? +Any of the recommendations that the AG +1. BOGGS: Objection. Again, I'm +going to instruct the witness not to +reveal any communications with the AG +regarding legal advice or seeking legal +advice. +THE WITNESS: And my policy to +him, have the team 1o0k at. I probably +did sign the legislation -- I'm +presuming I signed it. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 51 of 72 +245 +(By Mr. O'Laughlin:) Do you recall what +the policy team's position was on the legislation? +A. No, but I presume it was to sign it. +Q. Do you recall what the nature of the +amendments was? +No, not at all. +Q. Do you recall what the substance of the +discussions in the legislature were surrounding SORNA? +Did you discuss the bill with the First +Lady? +I did not. +Did you discuss the bill with Epstein? +MS. BOGGS: Objection, form. +THE WITNESS: Of course not. +(By Mr. O'Laughlin:) Did you discuss the +bill with any of Epstein's associates? +MS. BOGGS: Objection, form. +THE WITNESS: Of course not. +(By Mr. O'Laughlin:) Did you advocate for +changes to the legislation? +MS. BOGGS: Objection, form. +THE WITNESS: I did not. +(By Mr. O'Laughlin:) So Epstein had no +input of any kind into your consideration of the SORNA + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 52 of 72 +270 +entirely sure. I think perhaps he finally focused +on the issue at hand and decided that he personally +did not like the language. John is going to speak +to him when he gets back." +Did I read that correctly? +Yes. +Is the John referred to in this email you? +MS. BOGGS: Objection, calls for +speculation, lack of foundation. +THE WITNESS: I'm going to presume +it is. +(By Mr. O'Laughlin:) What was the bad ball +that Vincent started rolling? +foundation, calls for speculation. +THE WITNESS: I have no idea. +(By Mr. O'Laughlin:) When the First Lady +writes that you were going to speak with the AG when +he gets back, what is that referring to? +foundation, calls for speculation, +mischaracterization. +THE WITNESS: I do not recall, but +if - any discussion I would have had +with the AG on this matter, it would + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 53 of 72 +271 +have been the same I had with a lot of +my commissioners, which is -- +MS. BOGGS: Objection to the -- I +instruct you not to answer to the extent +it involves legal information or seeking +legal advice with the attorney general. +MR. TEAGUE: You can answer. +THE WITNESS: Which is you can't +change your mind and say nothing to +someone. +(By Mr. O'Laughlin:) What do you mean by +that? +If you disagree with a position, then tell +them you disagree with the position. You just can't +change your mind and not say a word. So any +discussion I had with Vincent or any one of my +commissioners would not be the substance of the bad +ball rolling. It would be if you don't agree and you +change your mind, then discuss it with them. +What was the change of position that you +discussed with Attorney General Frazer? +I have no idea. +foundation, calls for speculation. +THE WITNESS: I do not recall. + + +1 +2 +3 +4 +5 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 54 of 72 +272 +But clearly he made a decision he felt +comfortable with. I'm not going to try +to get him to change it. I'm going to +tell him, just communicate it. +(By Mr. O'Laughlin:) You're going to tell +him what? +To communicate it. +What do you mean by "to communicate it"? +Well, in the letter, what it says is that +that -- that he basically, he changed his mind and +said nothing. My position would be, you got to say +something. If you disagree with that position, say +you disagree with that position. +So just to be clear, are you testifying +about an actual conversation that you had with the +attorney general? +I believe so. +Okay. And what was that conversation? +Just - +MS. BOGGS: Objection. Again, I +am going to instruct the witness not to +reveal any communications with the +attorney general seeking or obtaining +legal advice. +MR. TEAGUE: You can answer. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 55 of 72 +273 +THE WITNESS: To discuss it with +his attorney, to discuss with them +exactly why you changed your position. +But he did not discuss with me any +substance. +(By Mr. O'Laughlin:) Changed his position +on what? +I have no idea. +I'm going strictly by +this email. +I'm asking if you have a recollection of a +conversation with the attorney general. Do you? +I recall a conversation with the attorney +general where he changed his position and he did not +communicate it to them. I told him to communicate to +them, them, meaning their lawyers, exactly why he +changed his position. +We had no discussion on the substance of +why he changed his position. Just that he needed to +be forthright and tell them the basis on the position +that he took. +But the discussion you had with the +attorney general was about the SORNA legislation? +It was about his -- +MS. BOGGS: Objection, calls for +speculation, lack of foundation. Also, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 56 of 72 +274 +again, I'm going to instruct the witness +not to reveal the content of any +communications with the attorney general +involving legal advice. +THE WITNESS: Strictly based on +the position he took, why did he change +his position. Just conmunicate it to +them. There was no substance on the +discussion. +(By Mr. O'Laughlin:) Was there anyone else +involved in this discussion? +room with me? +Meaning, was there someone else in the +Yes. +Was it an in-person discussion? +Was it over the phone? +I recall, yes. +Were there notes made of this discussion? +What was your reason for reaching out to +the attorney general to have this discussion? +foundation. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 57 of 72 +275 +THE WITNESS: Because if he agreed +on one issue and they thought he was +going to do something, to at least +correct it. +(By Mr. O'Laughlin:) How did you know that +he had changed his position? +It had been mentioned. +By who? +Cecile. +So the First Lady mentioned to you that the +attorney general had changed his position on the SORNA +legislation, and then you followed up with a call to +the attorney general, correct? +MS. BOGGS: Objection, form. +THE WITNESS: +She +mentioned to me +that he had changed his position, +particularly on the issue, which I did +not go into with her. Just that he +changed his position. +And my position always has been if you're +going to change your position on the stance, you +have to notify the individuals you're dealing +with. You just can't change your position. +(By Mr. O'Laughlin:) So the First Lady +came to you with the concern that he changed his + + +1 +2 +3 +4 +5 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 58 of 72 +276 +position, and you followed up by having a conversation +with the attorney general? +MR. TEAGUE: Objection, form. +THE WITNESS: Correct. Correct. +(By Mr. O'Laughlin:) And telling him that +if he was going to change his position on the SORNA +legislation, he should relay that to the First Lady? +I don't know if it was a change on the +SORNA legislation or some aspect, but, yes, that he +should convey it to their counsel, yes. +2. +Do you know if the attorney general in +response to your call did have a follow-up +conversation? +I don't know. +foundation, speculation. +(Discussion off the record.) +(By Mr. O'Laughlin:) What was the attorney +general's response to your message to him that he +should convey any changes in his position? +MS. BOGGS: Objection. Again, I'm +going to instruct the witness not to +reveal any communications with the +attorney general that would involve +local advice. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 59 of 72 +277 +THE WITNESS: I don't recall +specifically what he said. +Q. (By Mr. O'Laughlin:) Do you recall +generally? +MS. BOGGS: Same instruction. +THE WITNESS: It was a very short +conversation. +(By Mr. O'Laughlin:) Did he agree with +you? +MS. BOGGS: Same instruction. +THE WITNESS: I don't recall. +(By Mr. O'Laughlin:) You don't recall +whether he agreed with you or not? +MS. BOGGS: +Same instruction. +THE WITNESS: Well, he did -- +MS. BOGGS: Same instruction. +THE WITNESS: I don't recall +whether he said, Yes, I'll pick the +phone and call them, or that he said, He +would. It was just my telling him what +I thought he needed to do. +(By Mr. O'Laughlin:) And what is it that +you thought he needed to do specifically? +MR. TEAGUE: Objection. Asked and +answered multiple times. You can answer + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 60 of 72 +278 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +again. +THE WITNESS: Be very clear in his +position. +Q. +(By Mr. O'Laughlin:) With who? +With their attorneys. +Their attorneys being Epstein's attorneys? +Yes. +Do you know if the First Lady was unhappy +with the outcome of the SORNA legislation? +MS. BOGGS: Objection, calls for +speculation, lack of foundation. +THE WITNESS: I do not. +(By Mr. O'Laughlin:) Do you know if +Epstein was unhappy with the outcome of the SORNA +legislation? +MS. BOGGS: Objection, calls for +speculation, lack of foundation. +MR. TEAGUE: You can answer. +Go +ahead. +THE WITNESS: I don't. I don't +know what his position was. +(By Mr. O'Laughlin:) Were you involved in +any way with the follow-up by Epstein or his +associates following the sex offender legislation? +MS. BOGGS: Objection. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 61 of 72 +292 +not want to do it via email or phone, " correct? +A. That is correct. +e. Do you have any knowledge as to why she +wouldn't want to put these discussions in email? +MS. BOGGS: Objection, calls for +speculation, lack of foundation. +THE WITNESS: No. +MR. O'LAUGHLIN: What time do you +want to stop? +MR. TEAGUE: Actually, if you're +starting a new topic, this would be a +good time. +MR. O'LAUGHLIN: Yeah. Okay. +VIDEOGRAPHER: Okay. We're going +off the record. The time is 2:16 p.m., +Tuesday, May 30th, 2023. We're off the +record. +(Break taken.) +VIDEOGRAPHER: +We are back on the +record, the time is 2:26 p.m., Tuesday, +May 30th, 2023. We're on the record. +(By Mr. O'Laughlin:) Earlier you testified +that you were arrested in connection with a corruption +case against you, correct? +That is correct. + + +1 +2 +3 +4 +5 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 62 of 72 +293 +What was the nature of the case? +It was an action brought against me by the +government of the V.I. because they thought I +illegally used government funds for security measures +at my house. +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +When I was elected governor in 2006, one +of the last items I had to think about, that I +thought that I did have to think about, was security. +But we made the decision to live in our home because +there's truly no government residence. +And where the previous governors had +lived was not an accommodation to fit my family. I +had three young children, an aunt we were taking care +of. +And to refurbish the place it would have +taken -- we had estimated at three and half -- two +and half to three million. So I thought it would be +better to live at home. +I had an AG's opinion, an acting +attorney general's opinions from Department of +Justice -- +MS. BOGGS: Objection. I'm going +to instruct the witness not to testify +regarding any legal -- sorry -- legal +advice given to you by the attorney + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 63 of 72 +294 +general. +MR. TEAGUE: You can continue. +THE WITNESS: I'll continue, yes. +That it was okay to do it. So I went +through a process where we -- we did +procurement for government contracts +that involved working through the +Department of Property and Procurement, +got their approval, working through the +Department of Justice, and got their +legal sufficiency. +After it was done, after I was out of +office, the then sitting governor decided that +it was illegal. Had me arrested. +(By Mr. O'Laughlin:) Who was the-then +sitting governor? +office? +Kenneth Mapp. +Does he have that authority as the governor +or would it have to go through the attorney general's +Went through the attorney general's +office, an acting attorney general. +l. Was Epstein involved at all in your +response to that lawsuit? +MS. BOGGS: Objection. Objection, + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 64 of 72 +295 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +form. +THE WITNESS: I'm sorry, can you +be a little bit more specific? +Q. +(By Mr. O'Laughlin:) Was Epstein involved +in your defense of the lawsuit? +, in my defense? No. Not at all. +Did he provide advice? +A. No. +Did he provide any financial assistance in +connection with the lawsuit? +With the action itself or -- +Let's answer both. So in regards to the +action, the defense of the action itself, did he +provide assistance? +No, he didn't. +Who paid for the defense of the case? +Cecile and myself. +2. +Personally? +Personally. +And did funds come from any other source? +Came -- it came from my account. +lawsuit? +Okay. And then did he provide any other +type of financial assistance beyond defense of the +Yes, he did. + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 65 of 72 +296 +And what financial assistance did he +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +provide? +In order to settle the case, the +government -- I had paid the government -- we had an +appraisal done on the security enhancements that we +did. +And based on those appraisals, the +government decided without my input, that I needed to +pay them a certain amount, 181,000, which I did. The +government -- I gave them a check. +They then returned the check to me at +7:30 at night, and then the next day held a press +conference saying that I did not meet the obligations +of what I had agreed to do, and then had me arrested +a couple months later. +We then entered into negotiations as to +what it would take to drop the case and essentially +said you have to pay more. +So we came up and agreed on a number. +Once we agreed on that number, Mr. Epstein, +unsolicited by me, spoke to Cecile and said, how can +I help. And that's how he provided $200, 000. +What was the total amount that was paid to +resolve the case? +About 381,000. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 66 of 72 +297 +So the initial amount, the actual cost of +improvements was 181,000? +No. That was the value that the +government said I owed after the depreciated value +over eight years. +Okay. And then the ultimate amount paid +was 381,000. So they added 200,000 on to their +assessment of the value? +That's correct. +Okay. And of the 381,000, Epstein financed +200,000? +He gave us a loan for 200,000. +What were the terms of the loan? +That we had to pay it back -- we asked him +if we could have two years to pay it back. He said, +no, a year. So we paid it back early, mid '16, 2016, +and that was it. +Was there interest accrued on the loan? +Yes, I don't recall the amount, but there +was interest on the loan. +Do you recall what the rate was? +I do not. +How was the rate determined? +negotiated the rate. +I don't know. I don't know how they + + +1 +2 +3 +4 +5 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 67 of 72 +Who negotiated the rate? +A. It would have been between Epstein's +office or Epstein and Cecile. +298 +And were you involved in those negotiations +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +at all? +I was not. +Q. How did Epstein first learn that you might +be in need of that financial assistance? +MS. BOGGS: Objection, foundation, +speculation. +THE WITNESS: I gather that he +kept abreast with Cecile about what was +happening with the case. +(By Mr. O'Laughlin:) So the First Lady +relayed to him what was going on with the case and +then he volunteered to finance $200, 000 worth of the +ultimate amount? +MS. BOGGS: objection, form. +MR. TEAGUE: Objection, +foundation. You can answer. +THE WITNESS: Yes. +(By Mr. O'Laughlin:) Was he involved in +any other way in the case? +A. No. +Did his team review legal filings in the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 68 of 72 +342 +Did you ask the First Lady to relay this +information to Epstein? +A. I must of. +Were you involved in any discussions of a +$50 million loan to the USVI government involving +Epstein? +When you say "discussions," please -- what +do you mean by discussions? +What do you understand the word +"discussions" to mean? +Discussions, but with whom? +Anyone. +I wasn't in any discussions, no. +Did you have - do you have any knowledge +of any $50 million loan to the USVI government? +I was asked some questions, of which I +responded to those questions, yes. +What were the questions you were asked? +Just if the government wanted to borrow, +could they. Was there a revenue stream? Could it be +collateralized? But there was no discussions. There +were just some questions. +Why were those questions coming to you? +MS. BOGGS: Objection, +speculation. Lack of foundation. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 69 of 72 +343 +THE WITNESS: I'm presuming just +based on my knowledge of government. +Q. (By Mr. O'Laughlin:) But this was after +you were out of office, correct? +I believe so. +Okay. Who was asking the questions? +A. I'm not sure if it came from Cecile. I +think it may have come from Cecile. +Okay. On behalf of Epstein? +I presume so. +Okay. Do you know the approximate date of +these questions being asked to you? +No, I don't. +MR. O'LAUGHLIN: Let's enter tab +64. +(Deposition Exhibit No. 50 was +marked for identification.) +(By Mr. O'Laughlin:) Exhibit 50. This is +an email chain that starts February 5, 2017, and +Epstein writes to the First Lady, "The government +needs 40 to 50 million for year. What does John think +would be the most viable collateral"? +Do you see that? +Do you know where the government's need for + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 70 of 72 +344 +40 to $50 million a year was coming from? +I do not. +Did you ask? +I did not. +And you said that you think this request +came to you because you had some particular expertise +in it? +I couldn't imagine any other reason. +What was the expertise you had? +2. +Well, not expertise. Knowledge. +What was the knowledge you had? +Just what -- what could the government +provide as collateral. That's it. +Did you take any steps in response to this +request? +No, I did not. +So on February 6, 2017, the First Lady +writes, "I sent it to John for his response. He did +mention that the government has revenue generating +property in the Subbase area. He has asked a former +Property and Procurement employee for a list of +properties." +Is that right? +Right in terms of what you read or right +in terms of what I did? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 71 of 72 +345 +Right in terms of what I read. +Yes, it is. +Is it right in terms of what you did? +A. No. +MS. BOGGS: Objection. +(By Mr. O'Laughlin:) So the First Lady is +reporting back to Epstein's action that you took that +are not accurate? +MS. BOGGS: Objection, form. +THE WITNESS: No. +Not at all. I +did mention that the government has +revenue generating property, some in the +Subbase area. But I never went to a +former employee to ask because a list of +government properties is located online, +and also is in their budget. So I +didn't have to go to another employee to +ask. +(By Mr. O'Laughlin:) So you never got a +list of government properties from anyone? +MR. TEAGUE: Objection, form. +THE WITNESS: I never got a list +that I shared with anyone, correct. +(By Mr. O'Laughlin:) But did you obtain a + + +Case 1:22-cv-10904-JSR Document 267-29 Filed 08/07/23 Page 72 of 72 +346 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +list? +Q. +share it? +Yes. +You obtained a list and then you didn't +I didn't share it. +Why did you obtain a list if you weren't +planning on sharing it? +Because the amount of time that it took +for me to get the list by going online, which is too +long. So I just never did anything with it, other +than tell them look at properties that the government +owns, which you could find that online. +Did you provide any sort of response to +Epstein about what items +: might be available to secure +a $50 million loan? +When you say "items," you mean properties? +Specific properties? +Yes. +No, I did not. +MR. O'LAUGHLIN: Let's enter tab +65. +(Deposition Exhibit No. 51 was +marked for identification.) +(By Mr. O'Laughlin:) This is a February 6, +2017 email from you where you write, "I don't believe \ No newline at end of file diff --git a/vision-fixhub/court-05/60af21cf8fa021a678892ee6d1471b9fc847fbf1ce86539aa6dac9d670bd542d.receipt.json b/vision-fixhub/court-05/60af21cf8fa021a678892ee6d1471b9fc847fbf1ce86539aa6dac9d670bd542d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..388956752e8e0ac97a7ab3074340ba1d54901926 --- /dev/null +++ b/vision-fixhub/court-05/60af21cf8fa021a678892ee6d1471b9fc847fbf1ce86539aa6dac9d670bd542d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -4376, + "dataset": "marble-joined", + "doc_id": "60af21cf8fa021a678892ee6d1471b9fc847fbf1ce86539aa6dac9d670bd542d", + "engine": "marble-apple-vision", + "event_count": 74, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "3fe627b8cb8cbc5f8453f76d5a52aa2659dc41d3028ff74bb9067645df23e112", + "output_sha256": "d790be00e60566752d3946765c5b8a5d2f289a550adf13b10e805946a03bbbf9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/60d90b58d000a7eb6d83d3c64e11cc3a8b273d96363df83514aebd999e4d9579.md b/vision-fixhub/court-05/60d90b58d000a7eb6d83d3c64e11cc3a8b273d96363df83514aebd999e4d9579.md new file mode 100644 index 0000000000000000000000000000000000000000..3cc8923a3a230039a5e0cc0415be86aefb567db3 --- /dev/null +++ b/vision-fixhub/court-05/60d90b58d000a7eb6d83d3c64e11cc3a8b273d96363df83514aebd999e4d9579.md @@ -0,0 +1,229 @@ +Case 1:22-cv-10904-JSR Document 187-9 | +Filed 06/15/23 Page 1 of 5 + + + +Cape 1:238M10991gISBra Docurent tabit i Filed A6452neyBageryd§ Only +1 +2 +3 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE +UNITED +STATES VIRGIN +ISLANDS, +Plaintiff, +CASE NO. +1:22-CV-10904 +-JSR +V. +JPMORGAN CHASE BANK, +N.A., +Defendant/Third Party +Plaintiff. +JPMORGAN CHASE BANK, +N.A., +Third Party Plaintiff, +V. +JAMES EDWARD STALEY, +: +Third Party Defendant. +CONFIDENTIAL - ATTORNEYS' EYES ONLY +May 3, +2023 +Videotaped deposition +OI WILLIAM D. LANGFORD, taken pursuant to +notice, +was held at the law oftices oi +Boies +Schiller Flexner LUP, 55 Hudson +Yards, New York, New York, +and remotely, +eginning at 9:37 a."'L. Gray, a +on the above +date, before ! +Registered Professional Reporter, +Certified Shorthand Reporter, Certified +Realtime Reporter, and +• Notary Public. +GOLKOW LITIGATION SERVICES +877.370.3377 ph| 917.591.5672 +deps@golkow.com +Golkow +Litigation Services +Page 1 + + +1 +3 +4 +5 +6 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +Cape 1:238M10994g15Bra Docurent tabit i Filed 0645ZneyBagel§ Only +She expresses surprise that +2 there hasn't been a subpoena, correct? +I'm in the first paragraph. +She finds odd -- yeah, she +A. +finds odd. +Okay. And then also notes +• that there had been a subpoena some time +ago to Bear Stearns, correct? +A. +Yes. +And then she answers that +question about why this came up recently. +And she said that his accounted alerted +in Fortent for cash activity, which it +does from time to time. +Correct? +MR. GAIL: Objection. +THE WITNESS: Sorry, repeat +that question. +BY +So I'm asking -- she +responded to your question about why this +came up by explaining that there had been +a Fortent alert for cash activity, +correct? +Page 358 + + +Cape 1:238M10991g15Bra Docurent tabit i Filed A6452neyBaggAe§ Only +1 +Times, Landon [ +reported that +2 Epstein charges a flat fee on the assets +3 entrusted to him, anywhere from +• $25 million to $100 million, but doesn't +5 +collect any portion of the profits. This +6 +is oddly reminiscent of Bernie Madoff's +7 +compensation scheme." +8 +Have I read that correctly? +9 +A. +Yes. +10 +And then finally he says, in +11 the bottom paragraph, "We do know however +12 +that Epstein actually has invested money +13 +with both Citigroup and Bear Stearns" -- +14 +, I'm sorry. Da-da-da. +15 +Turning the page. "On the +16 +other hand, there were no" -- "there are +17 +no SEC filings disclosing Epstein's +18 holding. Not one. It is hard to see how +19 he could be managing billions without +20 +ever tripping a disclosure trigger, +21 +unless he avoids the +market +22 +altogether and only invests in private +23 +deals. This is another red flag." +24 +Have I read that correctly? +Page 388 + + +Cang 1:238M10991g£Bra Document lazit i Filed A6452neyBagege§ Only +1 +A. +Yes. +2 +3 +5 +6 +7 +8 +And he concludes, "We have +no concrete evidence that Epstein is +running a scam. But given the red flags +and the fact that he reportedly controls +billions of dollars, isn't that something +worth looking into?" +Have I read that correctly? +9 +A. +Yes. +10 +Q. +Do you know if, either +11 before or after this article or Maryanne +12 +Ryan's e-mail, JPMorgan ever looked into +13 +Epstein's business activities? +14 +A. +I don't know about +15 +specifically coming from this +16 perspective, no. +17 +And do you -- do you -- are +18 you aware of whether there was ever any +19 investigation by JPMorgan of what Jeffrey +20 +Epstein's business was or who his clients +21 +were? +22 +23 +24 +A. +I don't know. +Q. +Did you ever hear that there +was such an investigation? +Page 389 \ No newline at end of file diff --git a/vision-fixhub/court-05/60d90b58d000a7eb6d83d3c64e11cc3a8b273d96363df83514aebd999e4d9579.receipt.json b/vision-fixhub/court-05/60d90b58d000a7eb6d83d3c64e11cc3a8b273d96363df83514aebd999e4d9579.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..89b236b85fe20924c55a4370e0a007e4f2090386 --- /dev/null +++ b/vision-fixhub/court-05/60d90b58d000a7eb6d83d3c64e11cc3a8b273d96363df83514aebd999e4d9579.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -151, + "dataset": "marble-joined", + "doc_id": "60d90b58d000a7eb6d83d3c64e11cc3a8b273d96363df83514aebd999e4d9579", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "524dffb303fc988312d41f2081446991ab039ba3fe1ce5a8a430cb86d846ed7d", + "output_sha256": "8380fccf6155586b7120ec6c5fe676468ccf9e61c1a38e94be2bccd69f773d6f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/61090d8080ea61a60fee2a8c3c0cf42de9e74788f6e5edc19242571012ac3f5b.md b/vision-fixhub/court-05/61090d8080ea61a60fee2a8c3c0cf42de9e74788f6e5edc19242571012ac3f5b.md new file mode 100644 index 0000000000000000000000000000000000000000..45e3f6077a621934a20ee4d0158e98f498b15803 --- /dev/null +++ b/vision-fixhub/court-05/61090d8080ea61a60fee2a8c3c0cf42de9e74788f6e5edc19242571012ac3f5b.md @@ -0,0 +1,334 @@ +Case 1:22-cv-10904-JSR +Document 187-11 Filed 06/15/23 + + +PART 1 + + +Case 1:22-cv-10904-JSR Document 187-11 +Filed 06/15/23 Page 2 of 8 +SOCIETY MARCH 2003 ISSUE +THE TALENTED MR. EPSTEIN +Lately, Jeffrey Epstein's high-flying style has been drawing oohs and aahs: the bachelor financier lives in New York's largest private +residence, claims to take only billionaires as clients, and flies celebrities including Bill Clinton and Kevin Spacey on his Boeing 727. +But pierce his air of mystery and the picture changes. Vicky explores Epstein's investment career, his ties to retail magnate +Leslie Wexner, and his complicated past. +BY VICKY +MAKC1 1, 2005 +n Manhattan's Upper East Side, home to some of the most expensive real estate on earth, exists the crown jewel of the city's +residential town houses. With its 15-foot-high oak door, huge arched windows, and nine floors, it sits on—or, rather, commands +—the block of 71st Street between Fifth and Madison Avenues. Almost ludicrously out of proportion with its four- and five-story +neighbors, it seems more like an institution than a house. This is perhaps not surprising—until 198g it was the Birch Wathen private +school. Now it is said to be Manhattan's largest private residence. +Inside, amid the flurry of menservants attired in sober black suits and pristine +gloves, you feel you have stumbled into someone's +private Xanadu. This is no mere rich person's home, but a high-walled, eclectic, imperious fantasy that seems to have no boundaries. +THE HIVE NEWSLETTER +Daily updates from Washington, Wall Street, and Silicon Valley. +• Your emal- +Enter your email. +SUBMIT +By signing up you agree to our User Agreement and Privacy Policy & Cookie Statement +The entrance is decorated not with paintings but with row upon row of individually framed eyeballs; these, the owner tells people with +relish, were imported from England, where they were made for injured soldiers. Next comes a marble foyer, which does have a painting, in +the manner of Jean Dubuffet ... but the host coyly refuses to tell visitors who painted it. In any case, guests are like pygmies next to the +nearby twice-life-size sculpture of a naked African warrior. +Despite its eccentricity the house is curiously impersonal, the statement of someone who wants to be known for the scale of his +possessions. Its occupant, financier Jeffrey Epstein, 50, admits to friends that he likes it when people think of him this way. A good-looking +man, resembling Ralph Lauren, with thick grayhair and a weathered face, he usually dresses in jeans, knit shirts, and loafers. He +tells people he bought the house because he knew he "could never live anywhere bigger." He thinks 51,000 square feet is an appropriately +large space for someone like himself, who deals mostly in large concepts-especially large sums of money. + +https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 +1/14 +3/24/23 + + +Case 1:22-cv-10904-JSR Document 187-11 Filed 06/15/23 Page 3 of 8 +Guests are invited to lunch or dinner at the town house-Epstein usually refers to the former as "tea," since he likes to eat bite-size morsels +and drink copious quantities of Earl Grey. (He does not touch alcohol or tobacoo.) Tea is served in the "leather room," so called because of +the cordovan-colored fabric on the walls. The chairs are covered in a leopard print, and on the wall hangs a huge, Oriental fantasy of a +woman holding an opium pipe and caressing a snarling lionskin. Under her gaze, plates of finger sandwiches are delivered to Epstein and +guests by the menservants in +gloves. +Upstairs, to the right of a spiral staircase, is the "office," an enormous gallery spanning the width of the house. Strangely, it holds no +computer. Computers belong in the "computer room" (a smaller room at the back of the house), Epstein has been known to say. The office +features a gilded desk (which Epstein tells people belonged to banker J. P. +), 18th-century black lacquered Portuguese cabinets, and +a nine-foot ebony Steinway "D" grand. On the desk, a paperback copy of the Marquis de Sade's The Misfortunes of Virtue was recently +spotted. Covering the floor, Epstein has explained, "is the largest Persian rug you'll ever see in a private home—so big, it must have come +from a mosque." Amid such splendor, much of which reflects the work of the +i decorator Alberto Pinto, who has worked for Jacques +Chirac and the +families of Jordan and Saudi Arabia, there is one particularly startling oddity: a stuffed black poodle, standing atop +the grand piano. "No decorator would ever tell you to do that," Epstein brags to visitors. "But I want people to think what it means to stuff a +dog." People can't help but feel it's Epstein's way of saying that he always has the last word. +In addition to the town house, Epstein lives in what is reputed to be the largest private dwelling in New Mexico, on an $18 million, 7,500- +acre ranch which he named "Zorro." "It makes the town house look like a shack," Epstein has said. He also owns Little St. James, a 70-acre +island in the U.S. Virgin Islands, where the main house is currently being renovated by Edward Tuttle, a designer of the Amanresorts. +There is also a $6.8 million house in Palm Beach, Florida, and a fleet of aircraft: a Gulfstream IV, a helicopter, and a Boeing 727, replete +with trading room, on which Epstein recently flew President Clinton, actors Chris Tucker and Kevin Spacey, supermarket magnate Ron +Burkle, Lew Wasserman's grandson, +Wasserman, and a few others, on a mission to explore the problems of AIDS and economic +development in Africa. +Epstein is charming, but he doesn't let the charm slip into his eyes. They are steely and calculating, giving some hint at the steady whir of +machinery running behind them. "Let's play chess," he said to me, after refusing to give an interview for this article. "You bel +You get +the first move." It was an appropriate metaphor for a man who seems to feel he can win no matter what the advantage of the other side. His +advantage is that no one really seems to know him or his history completely or what his arsenal actually consists of. He has carefully +engineered it so that he remains one of the few truly baffling mysteries among New York's moneyed world. People know snippets, but few +know the whole. +"He's very enigmatic," says Rosa Monckton, the former C.E.O. of Tiffany & Co. in the U.K. and a close friend since the early 198os. "You +think you know him and then you peel off another ring of the onion skin and there's something else extraordinary underneath. He never +reveals his hand.... He's a classic iceberg. What you see is not what you get." +E +ven acquaintances sense a curious dichotomy: Yes, he lives like a "modern maharaja," as Leah Kleman, one of his art dealers, +, puts it. Yet he is fastidiously, almost obsessively private-he lists himself in the phone book under a pseudonym. He rarely +attends society gatherings or weddings or funerals; he considers eating in restaurants like "eating on the subway"-i.e., +something he'd never do. There are many women in his life, mostly young, but there is no one of them to whom he has been able to +commit. He describes his most public companion of the last decade, Ghislaine Maxwell, 41, the daughter of the late, disgraced media baron +Robert Maxwell, as simply his "best friend." He says she is not on his payroll, but she seems to organize much of his life-recently she was +making telephone inquiries to find a California-based yoga instructor for him. (Epstein is still close to his two other long-term girlfriends, +Paula Heil Fisher, a former associate of his at the brokerage firm Bear Stearns and now an opera producer, and Eva Andersson +doctor and onetime model. He tells people that when a relationship is over the girlfriend "moves up, not down," to friendship status.) +Some of the businessmen who dine with him at his home-they include newspaper publisher Mort Zuckerman, banker Louis Ranieri, +Revion chairman Ronald Perelman, real-estate tycoon +| Black, former Microsoft executive Nathan Myhrvold, Tom Pritzker (of Hyatt +Hotels), and real-estate personality Donald Trump-sometimes seem not all that clear as to what he actually does to earn his millions. +Certainly, you won't find Epstein's transactions written about on Bloomberg or talked about in the trading rooms. "The trading desks don't +seem to know him. It's unusual for animals that big not to leave any footprints in the snow," says a high-level investment manager. +https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 +2/14 + + +Case 1:22-cv-10904-JSR Document 187-11 Filed 06/15/23 Page 4 of 8 +Unlike such fund managers as +Soros and Stanley Druckenmiller, whose client lists and +maneuverings act as their calling +cards, Epstein keeps all his deals and clients secret, bar one client: billionaire Leslie Wexner, the respected chairman of Limited Brands. +Epstein insists that ever since he left Bear Stearns in 1981 he has managed money only for billionaires—who depend on him for discretion. +"I was the only person crazy enough, or arrogant enough, or misplaced enough, to make my limit a billion dollars or more," he tells people +freely. According to him, the flat fees he receives from his clients, combined with his skill at playing the currency markets "with very large +sums of money," have afforded him the lifestyle he enjoys today. +Why do billionaires choose him as their trustee? Because the problems of the mega-rich, he tells people, are different from yours and mine, +and his unique philosophy is central to understanding those problems: "Very few people need any more money when they have a billion +dollars. The key is not to have it do harm more than anything else.... You don't want to lose your money." +e has likened his job to that of an architect-more specifically, one who specializes in remodeling: "I always describe [a +addition, he built a room over the garage ... until you have a house that is usually a mess... It's a large house that has been put +together over time where no one could foretell the financial future and their accompanying needs." +He makes it sound as though his job combines the roles of real-estate agent, accountant, lawyer, money manager, trustee, and confidant. +But, as with Jay Gatsby, myths and rumor swirl around Epstein. +Here are some of the hard facts about Epstein—ones that he doesn't mind people knowing: He grew up middle-class in Brooklyn. His +father worked for the city's +department. His parents viewed education as "the way out" for him and his younger brother, Mark, now +working in real estate. Jeffrey started to play the piano—for which he maintains a passion—at five, and he went to Brooklyn's Lafayette +High School. He was good at mathematics, and in his early 20s he got a job teaching physics and math at Dalton, the elite Manhattan +private school. While there he began tutoring the son of Bear Stearns chairman Ace Greenberg and was friendly with a daughter of +Greenberg's. Soon he went to Bear Stearns, where, under the mentorship of both Greenberg and current Bear Stearns C.E.O. James Cayne, +he did well enough to become a limited partner—a rung beneath full partner. He abruptly departed in 1981 because, he has said, he wanted +to run his own business. +Thereafter the details recede into shadow. A few of the handful of current friends who have known him since the early 198os recall that he +used to tell them he was a "bounty hunter," recovering lost or stolen money for the government or for very rich people. He has a license to +carry a firearm. For the last 15 years, he's been running his business, J. Epstein & Co. +Since Leslie Wexner appeared in his life-Epstein has said this was in 1986; others say it was in 1989, at the earliest—he has gradually, in a +way that has not generally made headlines, come to be accepted by the Establishment. He's a member of various commissions and +councils: he is on the Trilateral Commission, the Council on Foreign Relations, and the Institute of International Education. +His current fan club extends to Cayne, Henry Rosovsky, the former +of Harvard's Faculty of Arts and Sciences, and Larry Summers, +Harvard's current president. Harvard law professor Alan Dershowitz says, "I'm on my 20th book.... The only person outside of my +immediate family that I send drafts to is Jeffrey." Real-estate developer and philanthropist Marshall +. who has worked with Epstein on +projects in New Albany, Ohio, for Wexner, says, "He digests and decodes the information very rapidly, which is to me terrific because we +have shorter meetings." +Also on the list of admirers are former senator +Mitchell and a gaggle of distinguished scientists, most of whom Epstein has helped +fund in recent years. They include Nobel Prize winners Gerald Edelman and +Gelland mathematical biologist +Nowak. When these men describe Epstein, they talk about "energy" and "curiosity," as well as a love for theoretical physics that they don't +ordinarily find in laymen. Gellrather sweetly mentions that "there are always pretty ladies around" when he goes to dinner chez +Epstein, and he's under the impression that Epstein's clients include the Queen of England. Both Nowak and Dershowitz were thrilled to +find themselves shaking the hand of a man named "Andrew" in Epstein's house. "Andrew" turned out to be Prince Andrew, who +subsequently arranged to sit in the back of Dershowitz's law class. +https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 +3/14 + + +Case 1:22-cv-10904-JSR +Document 187-11 Filed 06/15/23 Page 5 of 8 +Epstein gets annoyed when anyone suggests that Wexner "made him." "I had really rich clients before," he has said. Yet he does not deny +that he and Wexner have a special relationship. Epstein sees it as a partnership of equals. "People have said it's like we have one brain +between two of us: each has a side." +"I think we both possess the skill of seeing patterns," says Wexner. "But Jeffrey sees patterns in politics and financial markets, and I see +patterns in lifestyle and fashion trends. My skills are not in investment strategy, and, as everyone who knows Jeffrey knows, his are not in +fashion and design. We frequently discuss world trends as each of us sees them." +y the time Epstein met Wexner, the latter was a retail legend who had built a $3 billion empire-one that now includes Victoria's +the potential to realize his [Jeffrey's] dreams," says someone who has worked closely with both men. "He gave Jeffrey the ball, +and Jeffrey hit it out of the park." +Wexner, through a trust, bought the town house in which Epstein now lives for a reported $13.2 million in 198g. In 1993, Wexner married +Abigail Koppel, a 31-year-old lawyer, and the newlyweds relocated to Ohio; in 1996, Epstein moved into the town house. Public documents +suggest that the house is still owned by the trust that bought it, but Epstein has said that he now owns the house. +Wexner trusts Epstein so completely that he has assigned him the power of fiduciary over all of his private trusts and foundations, says a +source close to Wexner. In 1992, Epstein even persuaded Wexner to put him on the board of the Wexner Foundation in place of Wexner's +ailing mother. Bella Wexner recovered and demanded to be reinstated. Epstein has said they settled by splitting the foundation in two. +Epstein does not care that he comes between family members. In fact, he sees it as his job. He tells people, "I am there to represent my +client, and if my client needs protecting-sometimes even from his own family-then it's often better that people hate me, not the client." +"You've probably heard I'm vicious in my representation of my clients," he tells people proudly; Leah Kleman describes his haggling over +art prices as something like a scene out of the movie Mad Max: Beyond Thunderdome. Even a former mentor says he's seen "the dark side" +of Epstein, and a Bear Stearns source recalls a meeting in which Epstein chewed out a team making a presentation for Wexner as being so +brutal as to be "irresponsible." +One reporter, in fact, received three threats from Epstein while preparing a piece. They were delivered in a jocular tone, but the message +was clear: There will be trouble for your family if I don't like the article. +On the other hand, Epstein is clearly very generous with friends. Joe Pagano, an Aspen-based venture capitalist, who has known Epstein +since before his Bear Stearns days, can't say enough nice things: "I have a boy who's dyslexic, and Jeffrey's gotten close to him over the +years.... Jeffrey got him into music. He bought him his first piano. And then as he got to school he had difficulty ... in studying ... so Jeffrey +got him interested in taking flying lessons." +Rosa Monckton recalls Epstein telling her that her daughter, Domenica, who suffers from Down syndrome, needed the sun, and that Rosa +should feel free to bring her to his house in Palm Beach anytime. +Some friends remember that in the late Bos Epstein would offer to upgrade the airline tickets of good friends by affixing first-class stickers; +the only problem was that the stickers turned out to be unofficial. Sometimes the technique worked, but other times it didn't, and the +unwitting recipients found themselves exiled to coach. (Epstein has claimed that he paid for the upgrades, and had no knowledge of the +stickers.) M +who benefited from Epstein's largesse claim that his generosity comes with no strings attached. "I never felt he +wanted any +e in return," says one old friend, who received a first-class upgrade. +E +n about town as a man who loves women-lots of them, mostly young. Model types have been heard saying they +itude to Epstein for flying them around, and he is a familiar face to many of the Victoria's Secret girls. One young +woman recalls being summoned by Ghislaine Maxwell to a concert at Epstein's town house, where the women seemed to +outnumber the men by far. "These were not women you'd see at Upper East Side dinners," the woman recalls. "Many seemed foreign and +https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 +4/14 + + +Case 1:22-cv-10904-JSR Document 187-11 Filed 06/15/23 Page 6 of 8 +dressed a little bizarrely." This same guest also attended a cocktail party thrown by Maxwell that Prince Andrew attended, which was filled, +she says, with young Russian models. "Some of the guests were horrified," the woman says. +"He's reckless," says a former business associate, "and he's gotten more so. Money does that to you. He's breaking the oath he made to +himself-that he would never do anything that would expose him in the media. Right now, in the wake of the publicity following his trip +with Clinton, he must be in a very difficult place." +ccording to S.E.C. and other legal documents unearthed by VANITY FAIR, Epstein may have good reason to keep his past +before the S.E.C. sued to freeze his assets in 1993, was trying to buy the New York Post. He is currently incarcerated in the +Federal Medical Center in Devens, Massachusetts, serving a 20-year sentence for bilking investors out of more than $450 million in one of +the largest Ponzi schemes in American history. +When Epstein met Hoffenberg in London in the 198os, the latter was the charismatic, audacious head of the Towers Financial Corporation, +a collection agency that was supposed to buy debts that people owed to hospitals, banks, and phone companies. But Hoffenberg began +using company funds to pay off earlier investors and service a lavish lifestyle that included a mansion on Long Island, homes on +Manhattan's Sutton Place and in Florida, and a fleet of cars and planes. +Hoffenberg and Epstein had much in common. Both were smart and obsessed with making money. Both were from Brooklyn. According to +Hoffenberg, the two men were introduced by Douglas Leese, a defense contractor. Epstein has said they were introduced by John Mitchell, +the late attorney general. +Epstein had been running International Assets Group Inc. (I.A.G.), a consulting company, out of his apartment in the +building on East +66th Street in New York. Though he has claimed that he managed money for billionaires only, in a 198g deposition he testified that he +spent 8o percent of his time assisting people recover stolen money from fraudulent brokers and lawyers. He was also not above entering +into risky, tax-sheltered oil and gas deals with much smaller investors. A lawsuit that Michael Stroll, the former head of +Electronics Inc., filed against Epstein shows that in 1982 I.A.G. received an investment from Stroll of $450,000, which Epstein put into oil. +In 1984 Stroll asked for his money back; four years later he had received only $10,000. Stroll lost the suit, after Epstein claimed in court, +among other things, that the check for $10,000 was for a horse he'd bought from Stroll. "My net worth never exceeded four and a half +million dollars," Stroll has said. +Hoffenberg, says a close friend, "really liked Jeffrey.... Jeffrey has a way of getting under your skin, and he was under Hoffenberg's." Also +appealing to Hoffenberg were Epstein's social connections; they included oil mogul Cece Wang (father of the designer Vera) and Mohan +Murjani, whose clothing company grew into Gloria Vanderbilt Jeans. Epstein lived large even then. One friend recalls that when he took +Canadian heiress Wendy Belzberg on a date he hired a Rolls-Royce especially for the occasion. (Epstein has claimed he owned it.) +In 1987, Hoffenberg, according to sources, set Epstein up in the offices he still occupies in the Villard House, on Madison Avenue, across a +courtyard from the restaurant Le Cirque. Hoffenberg hired his new protégé as a consultant at $25,000 a month, and the relationship +flourished. "They traveled everywhere together-on Hoffenberg's plane, all around the world, they were always together," says a source. +Hoffenberg has claimed that Epstein confided in him, saying, for example, that he had left Bear Stearns in 1981 after he was discovered +executing "illegal operations." +Several of Epstein's Bear Stearns contemporaries recall that Epstein left the company very suddenly. Within the company there were +rumors also that he was involved in a technical infringement, and it was thought that the executive committee asked that he resign after his +two supporters, Ace Greenberg and Jimmy Cayne, were outnumbered. Greenberg says he can't recall this; Cayne denies it happened, and +Epstein has denied it as well. "Jeffrey Epstein left Bear Stearns of his own volition," says Cayne. "It was never suggested that he leave by +any member of management, and management never looked into any improprieties by him. Jeffrey said specifically, 'I don't want to work +for anybody else. I want to work for myself.'™ Yet, this is not the story that Epstein told to the S.E.C. in 1981 and to lawyers in a 1989 +deposition involving a civil business case in Philadelphia. +https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 +5/14 + + +Case 1:22-CV-10904-JSR Document 187-11 Filed 06/15/23 Page 7 of 8 +In 1981 the S.E.C.'s Jonathan Harris and Robert Blackburn took Epstein's testimony and that of other Bear Stearns employees in part of +what became a protracted case about insider trading around a tender offer placed on March 11, 1981, by the Seagram Company Ltd. for St. +Joe Minerals Corp. Ultimately several Italian and Swiss investors were found guilty, including Italian financier Giuseppe Tome, who had +used his relationship with Seagram owner Edgar Bronfman Sr. to obtain information about the tender offer. +After the tender offer was announced, the S.E.C. began investigating trades involving St. Joe at Bear Stearns and other firms. Epstein +resigned from Bear Stearns on March 12. The S.E.C. was tipped off that Epstein had information on insider trading at Bear Stearns, and it +was therefore obliged to question him. In his S.E.C. testimony, given on April 1, 1981, Epstein claimed that he had found "offensive" the +way Bear Stearns management had handled a disciplinary action following its discovery that he had committed a possible "Reg D" violation +—evidently he had lent money to his closest friend. (In the 1989 deposition he said that he'd lent approximately $20,000 to| +Eisenstein, to buy +) Such an action could have been considered improper, although Epstein claimed he had not realized this until +afterward. +According to Epstein, Bear Stearns management had questioned him about the loan around March 4. The questioners, Epstein said, were +Michael (Mickey) Tarnopol and Alvin Einbender. In his 1989 deposition Epstein recalled that the partner who had made an "issue" of the +matter was Marvin Davidson. On March 9, Epstein said, he had met with Tarnopol and Einbender again, and the two partners told him +that the executive committee had weighed the offense, together with previous "carelessness" over expenses, and he would be fined $2,500. +"There was discussion whether, in fact, I had ever put in an airline ticket for someone else and not myself and I said that it was possible,.. +since my secretary handles my expenses," Epstein told the S.E.C. In his 1989 testimony he stated that the "Reg D" incident had cost him a +shot at partnership that year. +What the S.E.C. seemed to be especially interested in was whether there was a connection between Epstein's leaving and the alleged insider +trading in St. Joe Minerals by other people at Bear Stearns: +Q: Sir, are you aware that certain rumors may have been circulating around your firm in connection with your reasons for leaving the firm? +A: I'm aware that there were many rumors. +Q: What were the rumors you heard? +A: Nothing to do with St. Joe. +Q: Can you relate what you heard? +A: It was having to do with an illicit affair with a secretary. +Q: Have you heard any other rumors suggesting that you had made a presentation or communication to the Executive Committee +concerning alleged improprieties by other members or employees of Bear Stearns? +A: I, in fact, have heard that rumor, but it's been from Mr. Harris in our conversation last week. +Q: Have you heard it from anyone else? +A: No. +A little later the interview focuses on James Cayne: +Q: Did you ever hear while you were at Bear Stearns that Mr. Cayne may have trader or insider information in connection with St. Joe +Minerals Corporation? +Q: Did Mr. Cayne ever have any conversation with you about St. Joe Minerals? +Q: Did you happen to overhear any conversations between Mr. Cayne and anyone else regarding St. Joe Minerals? +And still later in the questioning comes this exchange: +https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 +6/14 + + +Case 1:22-cv-10904-JSR Document 187-11 +Filed 06/15/23 Page 8 of 8 +Q: Have you had any type of business dealings with Mr. Cayne? +A: There's no relationship with Bear Stearns. +Q: Pardon? +A: Other than Bear Stearns, no. +Q: Have you been a participant in any type of business venture with Mr. Cayne? +Q: Do you have any expectation of participating in any business venture with Mr. Cayne? +Q: Have you had any business participations with Mr. Theram? +A: No; nor do I anticipate any. +Q: Mr. Epstein, did anyone at Bear Stearns tell you in words or substance that you should not divulge anything about St. Joe Minerals to +the staff of the Securities and Exchange Commission? +Q: Has anyone indicated to you in any way, either directly or indirectly, in words or substance, that your compensation for this past year or +any future monies coming to you from Bear Stearns will be contingent upon your not divulging information to the Securities and Exchange +Commission? +A: No. +Despite the circumstances of Epstein's leaving, Bear Stearns agreed to pay him his annual bonus-which he anticipated as being +approximately $100,000. +The S.E.C. never brought any charges against anyone at Bear Stearns for insider trading in St. Joe, but its questioning seems to indicate +that it was skeptical of Epstein's answers. Some sources have wondered why, if he was such a big producer at Bear Stearns, he would have +given it up over a mere $2,500 fine. +Certainly the years after Epstein left the firm were not obviously prosperous ones. His luck didn't seem to change until he met Hoffenbergne of Epstein's first assignments for Hoffenberg was to mastermind doomed bids to take over Pan American World Airways in +1987 and Emery Air Freight Corp. in 1988. Hoffenberg claimed in a 1993 hearing before a grand jury in Illinois that Epstein +came up with the idea of financing these bids through Towers's acquisition of two ailing Illinois insurance companies, +Associated Life and United Fire. "He was hired by us to work on the securities side of the insurance companies and Towers Financial, +supposedly to make a profit for us and for the companies," Hoffenberg reportedly told the grand jury. He also alleged that Epstein was the +"technician," executing the schemes, although, having no broker's license, he had to rely on others to make the trades. Much of +Hoffenberg's subsequent testimony in his criminal case has proven to be false, and Epstein has claimed he was merely asked how the bids +could be accomplished and has said he had nothing to do with the financing of them. Yet Richard the former treasurer of United +Fire, recalls seeing Epstein two or three times at the company. He and another executive say they had direct dealing with Epstein over the +finances. And in his deposition of 1989, Epstein stated that he was the one who executed "all" Hoffenberg's instructions to buy and sell the +- He called it "making the orders." He could not recall whether he had chosen the brokers used. +To win approval from the Illinois insurance regulators for Towers's acquisition of the companies, Hoffenberg promised to inject $3 million +of new capital into them. In fact, in his grand-jury testimony Hoffenberg claimed that he, his chief operating officer, Mitchell Brater, and +Epstein came up with a scheme to steal $3 million of the insurance companies' bonds to buy Pan Am and Emery +-*Jeffrey Epstein and +Mitch Brater arranged the various brokerage accounts for the bonds to be placed with in New York, and I think one in Chicago, Rodman & +Renshaw," Hoffenberg reportedly said. Then, said Hoffenberg, while making it appear as though they were investing the bonds in much +safer financial instruments, they used them as collateral to buy the +_. "Epstein was the person in charge of the transactions, and +Mitchell Brater was assisting him with it in coordination on behalf of the insurance companies" money," Hoffenberg claimed at the time. +https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 +7/14 \ No newline at end of file diff --git a/vision-fixhub/court-05/61090d8080ea61a60fee2a8c3c0cf42de9e74788f6e5edc19242571012ac3f5b.receipt.json b/vision-fixhub/court-05/61090d8080ea61a60fee2a8c3c0cf42de9e74788f6e5edc19242571012ac3f5b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..abf7941a4b8fd1be288277a93db1ce602005e00e --- /dev/null +++ b/vision-fixhub/court-05/61090d8080ea61a60fee2a8c3c0cf42de9e74788f6e5edc19242571012ac3f5b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -525, + "dataset": "marble-joined", + "doc_id": "61090d8080ea61a60fee2a8c3c0cf42de9e74788f6e5edc19242571012ac3f5b", + "engine": "marble-apple-vision", + "event_count": 16, + "fix_ids": 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false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6180d19cfc93ca4f3c5f01a3f0a89054899c70f45dfef305af69740686120b99.md b/vision-fixhub/court-05/6180d19cfc93ca4f3c5f01a3f0a89054899c70f45dfef305af69740686120b99.md new file mode 100644 index 0000000000000000000000000000000000000000..f6dfa8232657b8da7c2c80db49f7634a1c9bacb7 --- /dev/null +++ b/vision-fixhub/court-05/6180d19cfc93ca4f3c5f01a3f0a89054899c70f45dfef305af69740686120b99.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 263-64 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6180d19cfc93ca4f3c5f01a3f0a89054899c70f45dfef305af69740686120b99.receipt.json b/vision-fixhub/court-05/6180d19cfc93ca4f3c5f01a3f0a89054899c70f45dfef305af69740686120b99.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..25a2b61f8f2fe03dd6ceccac5851b11a2212c173 --- /dev/null +++ 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0000000000000000000000000000000000000000..46d010cf660d50ae1fd237d0715bfbc1b6767606 --- /dev/null +++ b/vision-fixhub/court-05/61acbb79dcb861d8b7e21cefc88e838120b7f98ed4998adba9aa04087bd07586.md @@ -0,0 +1,68 @@ +Case 1:22-cv-10904-JSR Document 326-122 Filed 09/08/23 Page 1 of 3 + + + +From: +To: +CC: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-122 Filed 09/08/23 Page 2 of 3 +Jeffrey Epstein +Paul S +Jes Staley +8/24/2010 9.24.027 M +Re: 30yr swaps +yen? „ so far jpm recomendations, are a disater +On Tue, Aug 24, 2010 at 4:19 PM, Jeffrey Epstein wrote: +On Tue, Aug 24, 2010 at 3:44 PM, Paul S +Jeffrey +wrote: +Left you a message. +We should unwind the remainder of our 30yr swap exposure. Between the jobless claims and housing data the risk has +substantially grown for a hard landing which would drive interest rates lower. +We have 1OMM of an outright swap and 1OMM of a receiver swaption (4.35% strike) +Let me know. +Paul +Paul +-, CFA +Managing Director +Global Investment Opportunities Group +JPMorgan Private Bank +40W 57th Street, 33rd Floor, New York, NY 10019 + +JPM-SDNYLIT-00009550 + +Case 1:22-cv-10904-JSR Document 326-122 Filed 09/08/23 Page 3 of 3 +This email is confidential and subject to important disclaimers and conditions including on offers for the purchase +or sale of securities, accuracy and completeness of information, viruses, confidentiality, legal privilege, and legal +entity disclaimers, available at http://www.jpmorgan.com/pages/disclosures/email. +************************************************** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jetfrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. +******** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation @gmail.com, and +destroy this communication and all copies thereof, +including all attachments. +************************** + +JPM-SDNYLIT-00009551 \ No newline at end of file diff --git a/vision-fixhub/court-05/61acbb79dcb861d8b7e21cefc88e838120b7f98ed4998adba9aa04087bd07586.receipt.json b/vision-fixhub/court-05/61acbb79dcb861d8b7e21cefc88e838120b7f98ed4998adba9aa04087bd07586.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..177473b1b11ff7432e70cadeaf53c76279937a5d --- /dev/null +++ b/vision-fixhub/court-05/61acbb79dcb861d8b7e21cefc88e838120b7f98ed4998adba9aa04087bd07586.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "61acbb79dcb861d8b7e21cefc88e838120b7f98ed4998adba9aa04087bd07586", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "37cfc1c5cd28aa3451703ecd60f8de68dde2ffde726a9cc1e8efd4322e0fc50b", + "output_sha256": "812bdec09136d5bfee80ca121f4f63b8bb3d3410fd050c571dbf2efd22470b42", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/61b1e8f31b1edc61722059b08682d3b389313c698bffb00612b0806d8da63bf1.md b/vision-fixhub/court-05/61b1e8f31b1edc61722059b08682d3b389313c698bffb00612b0806d8da63bf1.md new file mode 100644 index 0000000000000000000000000000000000000000..07da261ce80fa9c75c9b561dd46cecf446eb6f0b --- /dev/null +++ b/vision-fixhub/court-05/61b1e8f31b1edc61722059b08682d3b389313c698bffb00612b0806d8da63bf1.md @@ -0,0 +1,925 @@ +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 1 of 41 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-cv-10904 (JSR) +JPMORGAN CHASE BANK, N.A.., +Defendant/Third-Party +Plaintiff. +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +V. +JAMES EDWARD STALEY, +Third-Party Defendant. +DECLARATION OF FELICIA H. ELLSWORTH IN SUPPORT OF JPMORGAN +CHASE BANK, N.A.'S OPPOSITION TO THE GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS' MOTION FOR PARTIAL SUMMARY JUDGMENT +Pursuant to 28 U.S.C. § 1746, I, Felicia H. Ellsworth, declare under penalty of perjury as +follows: +I am a member in good standing of the bar of the Commonwealth of Massachusetts. I +am one of the attorneys representing Defendant JPMorgan Chase Bank, N.A. ("JPMC) +in the above-captioned action and have been admitted to this Court pro hac vice. I am a +Partner with the law firm of Wilmer Cutler Pickering Hale and Dorr LLP, 60 State +Street, Boston, Massachusetts 02109. I am familiar with the facts set forth herein, and +if called as a witness, I could and would competently testify thereto. +1 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 2 of 41 +2. +Attached as Exhibit 54 is a true and correct copy of excerpts of the transcript from the +July 7, 2023 deposition of Bridgette Carr, designated confidential pursuant to the +3. Attached as Exhibit 55 is a true and correct copy of excerpts of the transcript from the +May 26, 2023 deposition of James Dimon, designated confidential pursuant to the +4. +Attached as Exhibit 56 is a true and correct copy of excerpts of JPMC's Responses and +Objections to Third-Party Defendant James E. Staley's Requests for Admission. +5. Attached as Exhibit 57 is a true and correct copy of excerpts of the transcript from the +March 29, 2023 deposition of Francis Pearn. +6. +Attached as Exhibit 58 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00072548, designated confidential pursuant to the +7. +Attached as Exhibit 59 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00139994, designated confidential pursuant to the +8. +Attached as Exhibit 60 is a true and correct copy of excerpts from the June 23, 2023 +Expert Report of Teresa A. Pesce, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +Attached as Exhibit 61 is a true and correct copy of excerpts of the transcript from the +March 15, 2023 deposition of Mary Erdoes, designated confidential pursuant to the +2 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 3 of 41 +10. Attached as Exhibit 62 is a true and correct copy of excerpts of JPMC's Responses and +Objections to USVI's First Requests for Admission. +11. Attached as Exhibit 63 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00149115. +12. Attached as Exhibit 64 is a true and correct copy of the Rubenstein, Who We Are page, +available at https://rubenstein.com/who-we-are/#. +13. Attached as Exhibit 65 is a true and correct copy of excerpts of the transcript from the +June 27, 2023 deposition of Jorge Amador, designated confidential pursuant to the +14. Attached as Exhibit 66 is a true and correct copy of excerpts of the transcript from the +April 7, 2023 deposition of Mary l +15. Attached as Exhibit 67 is a true and correct copy of excerpts of the transcript from the +July 12, 2023 deposition of Marcus Sheridan, designated confidential pursuant to the +16. Attached as Exhibit 68 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00755535. +17. Attached as Exhibit 69 is a true and correct copy of excerpts from JPMC's Responses +and Objections to Doe's First Set of Interrogatories. +18. +Attached as Exhibit 70 is a true and correct copy of excerpts of the transcript from the +June 10, 2023 deposition of James Staley. +19. Attached as Exhibit 71 is a true and correct copy of excerpts of the transcript from the +July 18, 2023 deposition of Catherine Keating, designated confidential pursuant to the +3 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 4 of 41 +20. Attached as Exhibit 72 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00902699, designated confidential pursuant to the +21. Attached as Exhibit 73 is a true and correct copy of excerpts of Third-Party Defendant +James E. Staley's May 23, 2023 Responses and Objections to The United States Virgin +Islands' Requests for Admission. +22. Attached as Exhibit 74 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00153462. +23. +Attached as Exhibit 75 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00136978. +24. Attached as Exhibit 76 is a true and correct copy of excerpts of the transcript from the +April 21, 2023 deposition of Justin Nelson, designated confidential pursuant to the +25. Attached as Exhibit 77 is a true and correct copy of excerpts of the transcript from the +July 13, 2023 deposition of John Duffy, designated confidential pursuant to the +26. Attached as Exhibit 78 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00754968, designated confidential pursuant to the +27. Attached as Exhibit 79 is a true and correct copy of excerpts of the transcript from the +May 24, 2023 deposition of Stephen Cutler. +4 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 5 of 41 +28. Attached as Exhibit 80 is a true and correct copy of excerpts of the transcript from the +July 7, 2023 deposition of Shaun O'Neill, designated confidential pursuant to the +29. Attached as Exhibit 81 is a true and correct copy of excerpts from the June 23, 2023 +Expert Report of Joe Fonseca, designated confidential pursuant to the Protective Order +in this matter and filed under seal. +30. Attached as Exhibit 82 is a true and correct copy of an article titled, +modeling +agent Jean-Luc Brunel found dead in prison cell" dated February 21, 2022 available at +https://www.cnn.com/2022/02/19/europe/jean-luc-brunel-jeffrey-epstein-deathintl/index.html. +31. Attached as Exhibit 83 is a true and correct copy of an article titled "Billionaire Jeffrey +Epstein Arrested for Sec Trafficking" dated July 7, 2019, available at +https://gothamist.com/news/billionaire-jeffrey-epstein-arrested-for-sex-trafficking. +32. Attached as Exhibit 84 is a true and correct copy of Exhibit 19 to the May 26, 2023 +deposition of Inais Borque. +33. Attached as Exhibit 85 is a true and correct copy excerpts of produced by Plaintiff the +Government of the United States Virgin Islands, I +stamped VI-JPM-000012446_U +designated confidential pursuant to the Protective Order in this matter and filed under +34. Attached as Exhibit 86 is a true and correct copy of excerpts of the VIPA Police +Manual. +35. Attached as Exhibit 87 is a true and correct copy of excerpts of produced by Plaintiff +stamped VI-JPM- +5 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 6 of 41 +000006467, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +36. Attached as Exhibit 88 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018027, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +37. Attached as Exhibit 89 is a true and correct copy of a document produced by Plaintiff +the Government of the United States Virgin Islands, | +stamped VI-JPM- +000018041, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +38. Attached as Exhibit 90 is a true and correct copy of excerpts of the June 23, 2023 +Carlyn Irwin Expert Report, designated confidential pursuant to the Protective Order in +this matter and filed under seal. +39. Attached as Exhibit 91 is a true and correct copy of excerpts of the transcript from the +July 6, 2023 deposition of Carlyn Irwin, designated confidential pursuant to the +40. Attached as Exhibit 92 is a true and correct copy of excerpts of the transcript from the +May 10, 2023 deposition of Bonnie +designated confidential pursuant to the +41. Attached as Exhibit 93 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00026008, designated confidential pursuant to the +6 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 7 of 41 +42. Attached as Exhibit 94 is a true and correct copy of excerpts of the transcript from the +July 13, 2023 deposition of Francis Pearn, designated confidential pursuant to the +43. Attached as Exhibit 95 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00127953. +44. Attached as Exhibit 96 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00001893. +45. Attached as Exhibit 97 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00449994. +46. Attached as Exhibit 98 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00127944. +47. Attached as Exhibit 99 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00010814, designated confidential pursuant to the +48. Attached as Exhibit 100 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00157090. +49. Attached as Exhibit 101 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00152748_R. +50. Attached as Exhibit 102 is a true and correct copy of excerpts of the transcript from the +May 24, 2023 deposition of Maryanne Ryan, designated confidential pursuant to the +51. Attached as Exhibit 103 is a true and correct copy of excerpts of the transcript from the +April 28, 2023 deposition of Kevin McCleerey. +7 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 8 of 41 +52. Attached as Exhibit 104 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00119630. +53. Attached as Exhibit 105 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00274774, designated confidential pursuant to the +54. Attached as Exhibit 106 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00127930, designated confidential pursuant to the +55. Attached as Exhibit 107 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00452980. +56. Attached as Exhibit 108 is a true and correct copy of excerpts of the transcript from the +May 3, 2023 deposition of William Langford, designated confidential pursuant to the +57. Attached as Exhibit 109 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00127928. +58. Attached as Exhibit 110 is a true and correct copy of the June 16, 2023 Expert Report +of Jorge Amador, designated confidential pursuant to the Protective Order in this matter +and filed under seal. +59. Attached as Exhibit 111 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00755043. +60. Attached as Exhibit 112 is a true and correct copy of a document produced by third +stamped Estate_006622, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +8 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 9 of 41 +61. Attached as Exhibit 113 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00136519, designated confidential pursuant to the +62. Attached as Exhibit 114 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00231636, designated confidential pursuant to the +63. Attached as Exhibit 115 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00230825, designated confidential pursuant to the +64. Attached as Exhibit 116 is a true and correct copy of excerpts of the transcript from the +May 30, 2023 deposition of Francis Pearn, designated confidential pursuant to the +65. Attached as Exhibit 117 is a true and correct copy of excerpts of the transcript from the +May 18, 2023 deposition of Richard Kahn, designated confidential pursuant to the +66. Attached as Exhibit 118 is a true and correct copy of the May 26, 2023 Declaration of +P. Visoski, Jane Doe 1 v. Deutsche Bank, Case No. 1:22-cv-10018 (JSR). +67. Attached as Exhibit 119 is a true and correct copy of excerpts of the transcript from the +April 20, 2023 deposition of Phillip DeLuca, designated confidential pursuant to the +68. Attached as Exhibit 120 is a true and correct copy of excerpts of the transcript from the +June 30, 2023 deposition of Kimberly Mehlman-Orozco, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +9 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 10 of 41 +69. Attached as Exhibit 121 is a true and correct copy of excerpts of the transcript from the +April 18, 2023 deposition of Paul Morris. +70. Attached as Exhibit 122 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00036580, designated confidential pursuant to the +71. Attached as Exhibit 123 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-W-00025201, designated confidential pursuant to the +72. Attached as Exhibit 124 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00152809, designated confidential pursuant to the +73. Attached as Exhibit 125 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00026008, designated confidential pursuant to the +74. Attached as Exhibit 126 is a true and correct copy of excerpts of the transcript from the +July 10, 2023 deposition of Stephen Cutler, designated confidential pursuant to the +75. Attached as Exhibit 127 is a true and correct copy of excerpts of the transcript from the +July 12, 2023 deposition of Mary Erdoes, designated confidential pursuant to the +76. Attached as Exhibit 128 is a true and correct copy of excerpts of the transcript from the +March 3, 2023 deposition of Jane Doe 1, designated confidential pursuant to the +10 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 11 of 41 +77. Attached as Exhibit 129 is a true and correct copy of excerpts of the transcripts from +the June 11, 2023 deposition of James Staley, designated confidential pursuant to the +78. Attached as Exhibit 130 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00006171. +79. Attached as Exhibit 131 is a true and correct copy of a document produced by third +stamped ESTATE_JPM002773, +designated confidential pursuant to the Protective Order in this matter and filed under +80. Attached as Exhibit 132 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006718. +81. Attached as Exhibit 133 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006716, designated confidential pursuant to the +82. Attached as Exhibit 134 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006791. +83. Attached as Exhibit 135 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006792, designated confidential pursuant to the +84. Attached as Exhibit 136 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00008342. +85. +Attached as Exhibit 137 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00008669. +11 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 12 of 41 +86. Attached as Exhibit 138 is a true and correct copy of' a document produced by JPMC, +stamped JPM-SDNYLIT-00013210, designated confidential pursuant to the +87. Attached as Exhibit 139 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013402. +88. Attached as Exhibit 140 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013463, designated confidential pursuant to the +89. Attached as Exhibit 141 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013475. +90. +Attached as Exhibit 142 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013669. +91. Attached as Exhibit 143 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013762. +92. Attached as Exhibit 144 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00005845, designated confidential pursuant to the +93. Attached as Exhibit 145 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006553, designated confidential pursuant to the +94. Attached as Exhibit 146 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006886, designated confidential pursuant to the + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 13 of 41 +95. Attached as Exhibit 147 is a true and correct copy of' a document produced by JPMC, +stamped JPM-SDNYLIT-00010121, designated confidential pursuant to the +96. Attached as Exhibit 148 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00010989, designated confidential pursuant to the +97. Attached as Exhibit 149 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00012289, designated confidential pursuant to the +98. Attached as Exhibit 150 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00012466, designated confidential pursuant to the +99. Attached as Exhibit 151 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004661. +100. Attached as Exhibit 152 is a true and correct copy of a document produced by third +stamped ESTATE_JPM001758, +designated confidential pursuant to the Protective Order in this matter and filed under +101. Attached as Exhibit 153 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006586. +102. Attached as Exhibit 154 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00006592. +13 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 14 of 41 +103. Attached as Exhibit 155 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006874. +104. Attached as Exhibit 156 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00012494. +105. Attached as Exhibit 157 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004394, designated confidential pursuant to the +106. Attached as Exhibit 158 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004388, designated confidential pursuant to the +107. Attached as Exhibit 159 is a true and correct copy of a document produced by third +stamped ESTATE_JPM002742, +designated confidential pursuant to the Protective Order in this matter and filed under +108. Attached as Exhibit 160 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006704, designated confidential pursuant to the +109. Attached as Exhibit 161 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00010330, designated confidential pursuant to the +110. Attached as Exhibit 162 is a true and correct copy of a document produced by JPMC, +stamped .JPM-SDNYLIT-00010603, designated confidential pursuant to the + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 15 of 41 +111. Attached as Exhibit 163 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004186, designated confidential pursuant to the +112. Attached as Exhibit 164 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00010284, designated confidential pursuant to the +113. Attached as Exhibit 165 is a true and correct copy of a document produced by third +stamped ESTATE_JPM003001, +designated confidential pursuant to the Protective Order in this matter and filed under +114. Attached as Exhibit 166 is a true and correct copy of a document produced by third +stamped ESTATE_JPM002019, +designated confidential pursuant to the Protective Order in this matter and filed under +115. Attached as Exhibit 167 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013770. +116. Attached as Exhibit 168 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00205452. +117. Attached as Exhibit 169 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00269718, designated confidential pursuant to the +15 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 16 of 41 +118. Attached as Exhibit 170 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00269719, designated confidential pursuant to the +119. Attached as Exhibit 171 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-W-00021957, designated confidential pursuant to the +120. Attached as Exhibit 172 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00033761, designated confidential pursuant to the +121. Attached as Exhibit 173 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00021997, designated confidential pursuant to the +122. Attached as Exhibit 174 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-W-00037446, designated confidential pursuant to the +123. Attached as Exhibit 175 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00037463, designated confidential pursuant to the +124. Attached as Exhibit 176 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00022528, designated confidential pursuant to the + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 17 of 41 +125. Attached as Exhibit 177 is a true and correct copy of excerpts of a document produced +by JPMC, +stamped JPM-SDNYLIT-W-00017133, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +126. Attached as Exhibit 178 is a true and correct copy of excerpts of a document produced +by JPMC, +stamped JPM-SDNYLIT-W-00008055, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +127. Attached as Exhibit 179 is a true and correct copy of excerpts of a document produced +by JPMC, +stamped JPM-SDNYLIT-W-00020952, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +128. Attached as Exhibit 180 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00000183, designated confidential pursuant to the +129. Attached as Exhibit 181 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00000001, designated confidential pursuant to the +130. Attached as Exhibit 182 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00000211, designated confidential pursuant to the +131. Attached as Exhibit 183 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00022540, designated confidential pursuant to the +17 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 18 of 41 +132. Attached as Exhibit 184 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00008100, designated confidential pursuant to the +133. Attached as Exhibit 185 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00022549, designated confidential pursuant to the +134. Attached as Exhibit 186 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00008123, designated confidential pursuant to the +135. Attached as Exhibit 187 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00008144, designated confidential pursuant to the +136. Attached as Exhibit 188 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00136910, designated confidential pursuant to the +137. Attached as Exhibit 189 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00136911, designated confidential pursuant to the +138. Attached as Exhibit 190 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00100966. +139. Attached as Exhibit 191 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00150176. + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 19 of 41 +140. Attached as Exhibit 192 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00100998, designated confidential pursuant to the +141. Attached as Exhibit 193 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00030327, designated confidential pursuant to the +142. Attached as Exhibit 194 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00016246, designated confidential pursuant to the +143. Attached as Exhibit 195 is a true and correct copy of excerpts from JPMC's Responses +and Objections to The United States Virgin Islands First Requests for Admissions. +144. Attached as Exhibit 196 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00902715, designated confidential pursuant to the +145. Attached as Exhibit 197 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00373074. +146. Attached as Exhibit 198 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00373254. +147. Attached as Exhibit 199 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015321. +148. Attached as Exhibit 200 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015326, +19 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 20 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +149. Attached as Exhibit 201 is a true and correct copy of Exhibit 7 from the July 20, 2023 +deposition of Denise +150. Attached as Exhibit 202 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016517, +designated confidential pursuant to the Protective Order in this matter and filed under +151. Attached as Exhibit 203 is a true and correct copy of excerpts of the transcript from the +June 6, 2023 deposition of Albert Bryan. +152. Attached as Exhibit 204 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016246, +designated confidential pursuant to the Protective Order in this matter and filed under +153. Attached as Exhibit 205 is a true and correct copy of excerpts of a document produced +by Plaintiff the Government of the United States Virgin Islands, +stamped VI- +JPM-000006066, designated confidential pursuant to the Protective Order in this matter +and filed under seal. +154. Attached as Exhibit 206 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025237, +designated confidential pursuant to the Protective Order in this matter and filed under +20 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 21 of 41 +155. Attached as Exhibit 207 is a true and correct copy of excerpts of the transcript from the +May 29, 2023 deposition of Stacey Plaskett. +156. Attached as Exhibit 208 is a true and correct copy of excerpts of the transcript from the +May 29, 2023 deposition of Cecile de Jongh, designated confidential pursuant to the +157. Attached as Exhibit 209 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015885, +designated confidential pursuant to the Protective Order in this matter and filed under +158. Attached as Exhibit 210 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015674, +designated confidential pursuant to the Protective Order in this matter and filed under +159. Attached as Exhibit 211 is a true and correct copy of a document produced by third +stamped ESTATE_JPM059741, +designated confidential pursuant to the Protective Order in this matter and filed under +160. Attached as Exhibit 212 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016163, +designated confidential pursuant to the Protective Order in this matter and filed under +161. Attached as Exhibit 213 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015950, +21 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 22 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +162. Attached as Exhibit 214 is a true and correct copy of a document produced by third +stamped ESTATE_JPM022478, +designated confidential pursuant to the Protective Order in this matter and filed under +163. Attached as Exhibit 215 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO22479, +designated confidential pursuant to the Protective Order in this matter and filed under +164. Attached as Exhibit 216 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO16210, +designated confidential pursuant to the Protective Order in this matter and filed under +165. Attached as Exhibit 217 is a true and correct copy of a document produced by third +stamped ESTATE_JPM058471, +designated confidential pursuant to the Protective Order in this matter and filed under +166. Attached as Exhibit 218 is a true and correct copy of a document produced by third +stamped ESTATE_JPM060696, +designated confidential pursuant to the Protective Order in this matter and filed under +22 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 23 of 41 +167. Attached as Exhibit 219 is a true and correct copy of a document produced by third +stamped ESTATE_JPM058976, +designated confidential pursuant to the Protective Order in this matter and filed under +168. Attached as Exhibit 220 is a true and correct copy of a document produced by third +stamped ESTATE_JPM023608, +designated confidential pursuant to the Protective Order in this matter and filed under +169. Attached as Exhibit 221 is a true and correct copy of a document produced by third +stamped ESTATE_JPM012505, +designated confidential pursuant to the Protective Order in this matter and filed under +170. Attached as Exhibit 222 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015733, +designated confidential pursuant to the Protective Order in this matter and filed under +171. Attached as Exhibit 223 is a true and correct copy of excerpts of the transcript from the +May 24, 2023 deposition of Kenneth Mapp. +172. Attached as Exhibit 224 is a true and correct copy of excerpts of the transcript from the +May 30, 2023 deposition of John de Jongh. +173. Attached as Exhibit 225 is a true and correct copy of a document produced by third +stamped ESTATE_JPM066053, +23 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 24 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +174. Attached as Exhibit 226 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016303, +designated confidential pursuant to the Protective Order in this matter and filed under +175. Attached as Exhibit 227 is a true and correct copy of a document produced by third +stamped ESTATE _JPM030178, +designated confidential pursuant to the Protective Order in this matter and filed under +176. Attached as Exhibit 228 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024203, +designated confidential pursuant to the Protective Order in this matter and filed under +177. Attached as Exhibit 229 is a true and correct copy of a document produced by third +stamped ESTATE_JPM021286, +designated confidential pursuant to the Protective Order in this matter and filed under +178. Attached as Exhibit 230 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024371, +designated confidential pursuant to the Protective Order in this matter and filed under +24 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 25 of 41 +179. Attached as Exhibit 231 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024370, +designated confidential pursuant to the Protective Order in this matter and filed under +180. Attached as Exhibit 232 is a true and correct copy of a document produced by third +stamped ESTATE_JPM011964, +designated confidential pursuant to the Protective Order in this matter and filed under +181. Attached as Exhibit 233 is a true and correct copy of a document produced by third +stamped ESTATE_JPM064333, +designated confidential pursuant to the Protective Order in this matter and filed under +182. Attached as Exhibit 234 is a true and correct copy of a document produced by third +stamped ESTATE_JPM064334, +designated confidential pursuant to the Protective Order in this matter and filed under +183. Attached as Exhibit 235 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024927, +designated confidential pursuant to the Protective Order in this matter and filed under +184. Attached as Exhibit 236 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO22970, + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 26 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +185. Attached as Exhibit 237 is a true and correct copy of a document produced by third +stamped ESTATE_JPM050241, +designated confidential pursuant to the Protective Order in this matter and filed under +186. Attached as Exhibit 238 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO50265, +designated confidential pursuant to the Protective Order in this matter and filed under +187. Attached as Exhibit 239 is a true and correct copy of a document produced by third +stamped ESTATE_JPM060776, +designated confidential pursuant to the Protective Order in this matter and filed under +188. Attached as Exhibit 240 is a true and correct copy of a document produced by third +stamped ESTATE_JPM061002, +designated confidential pursuant to the Protective Order in this matter and filed under +189. Attached as Exhibit 241 is a true and correct copy of a document produced by third +stamped ESTATE_JPM061003, +designated confidential pursuant to the Protective Order in this matter and filed under +26 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 27 of 41 +190. Attached as Exhibit 242 is a true and correct copy of a document produced by third +stamped ESTATE_JPM055381, +designated confidential pursuant to the Protective Order in this matter and filed under +191. Attached as Exhibit 243 is a true and correct copy of a document produced by third +stamped ESTATE_JPM021989, +designated confidential pursuant to the Protective Order in this matter and filed under +192. Attached as Exhibit 244 is a true and correct copy of a document produced by third +stamped ESTATE_JPM012219, +designated confidential pursuant to the Protective Order in this matter and filed under +193. Attached as Exhibit 245 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000021920, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +194. Attached as Exhibit 246 is a true and correct copy of a document produced by third +stamped ESTATE_JPM061123, +designated confidential pursuant to the Protective Order in this matter and filed under +195. Attached as Exhibit 247 is a true and correct copy of a document produced by third +stamped ESTATE_JPM062263, +27 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 28 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +196. Attached as Exhibit 248 is a true and correct copy of a document produced by third +stamped ESTATE_JPM062254, +designated confidential pursuant to the Protective Order in this matter and filed under +197. Attached as Exhibit 249 is a true and correct copy of a document produced by third +stamped ESTATE_JPM065842, +designated confidential pursuant to the Protective Order in this matter and filed under +198. Attached as Exhibit 250 is a true and correct copy of a document produced by third +stamped ESTATE_JPM060812, +designated confidential pursuant to the Protective Order in this matter and filed under +199. Attached as Exhibit 251 is a true and correct copy of a document produced by third +stamped ESTATE_JPM020484, +designated confidential pursuant to the Protective Order in this matter and filed under +200. Attached as Exhibit 252 is a true and correct copy of Exhibit 20 from the May 29, 2023 +deposition of Cecile de Jongh. +201. Attached as Exhibit 253 is a true and correct copy of excerpts of the transcript from the +May 26, 2023 deposition of Inais Borque. +28 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 29 of 41 +202. Attached as Exhibit 254 is a true and correct copy of Exhibit 5 from the May 26, 2023 +deposition of Inais Borque, designated confidential pursuant to the Protective Order in +this matter and filed under seal. +203. Attached as Exhibit 255 is a true and correct copy of Exhibit 37 from the March 15, +2023 deposition of Mary Erdoes. +204. Attached as Exhibit 256 is a true and correct copy of Exhibit 4 from the July 7, 2023 +deposition of Jean-Pierre Oriol, designated confidential pursuant to the Protective Order +in this matter and filed under seal. +205. Attached as Exhibit 257 is a true and correct copy of Exhibit 5 from the July 7, 2023 +deposition of Jean-Pierre Oriol, designated confidential pursuant to the Protective Order +in this matter and filed under seal. +206. Attached as Exhibit 258 is a true and correct copy of excerpts of the transcript from the +July 7, 2023 deposition of Jean-Pierre Oriol, designated confidential pursuant to the +207. Attached as Exhibit 259 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000061108, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +208. Attached as Exhibit 260 is a true and correct copy of Exhibit 10 from the July 13, 2023 +deposition of Carol +209. Attached as Exhibit 261 is a true and correct copy of excerpt of the transcript from the +July 18, 2023 deposition of Shani Pinney, designated confidential pursuant to the + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 30 of 41 +210. Attached as Exhibit 262 is a true and correct copy of excerpts of the transcript from the +July 20, 2023 deposition of Denise +, designated confidential pursuant to the +211. Attached as Exhibit 263 is a true and correct copy of excerpts of the transcript from the +July 12, 2023 deposition of Carol +, designated confidential pursuant to +the Protective Order in this matter and filed under seal. +212. Attached as Exhibit 264 is a true and correct copy of excerpts of the transcript from the +July 17, 2023 deposition of Denise +, designated confidential pursuant to the +213. Attached as Exhibit 265 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016557, +designated confidential pursuant to the Protective Order in this matter and filed under +214. Attached as Exhibit 266 is a true and correct copy of excerpts of the transcript from the +July 13, 2023 deposition of Vincent Frazer, designated confidential pursuant to the +215. Attached as Exhibit 267 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024492, +designated confidential pursuant to the Protective Order in this matter and filed under +216. Attached as Exhibit 268 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024494, +30 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 31 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +217. Attached as Exhibit 269 is a true and correct copy of a document produced by third +stamped ESTATE_JPM030223, +designated confidential pursuant to the Protective Order in this matter and filed under +218. Attached as Exhibit 270 is a true and correct copy of a document produced by third +stamped ESTATE_JPM030225, +designated confidential pursuant to the Protective Order in this matter and filed under +219. Attached as Exhibit 271 is a true and correct copy of a document produced by third +stamped ESTATE_JPM030228, +designated confidential pursuant to the Protective Order in this matter and filed under +220. Attached as Exhibit 272 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025221, +designated confidential pursuant to the Protective Order in this matter and filed under +221. Attached as Exhibit 273 is a true and correct copy of a document produced by third +stamped ESTATE_JPM030179, +designated confidential pursuant to the Protective Order in this matter and filed under +31 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 32 of 41 +222. Attached as Exhibit 274 is a true and correct copy of Exhibit 1 to the July 18, 2023 +deposition of Shani Pinney. +223. Attached as Exhibit 275 is a true and correct copy of the legacy file copy of the Act No. +7372, Bill No. 29-0239, Twenty-Ninth Legislature of The Virgin Islands, Regular +Session, 2012, available at +https://stthomassource.com/legacy_files/userfiles/file/vetoed%20bills%2071912/Act%2 +0No_%207372%20-%20Bill%20No_%2029-0239.pdf. +224. Attached as Exhibit 276 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025227, +designated confidential pursuant to the Protective Order in this matter and filed under +225. Attached as Exhibit 277 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015021, +designated confidential pursuant to the Protective Order in this matter and filed under +226. Attached as Exhibit 278 is a true and correct copy of Bill 0444, a bill passed in the +United States Virgin Islands in 2012. +227. Attached as Exhibit 279 is a true and correct copy of excerpts of a document produced +by Plaintiff the Government of the United States Virgin Islands, +stamped VI- +JPM-000012237, designated confidential pursuant to the Protective Order in this matter +and filed under seal. +32 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 33 of 41 +228. Attached as Exhibit 280 is a true and correct copy of excerpts of a document produced +by Plaintiff the Government of the United States Virgin Islands, +stamped VI- +JPM-000012328. +229. Attached as Exhibit 281 is a true and correct copy of 14 Virgin Islands Code +§ 1721B(a)(1). +230. Attached as Exhibit 282 is a true and correct copy of produced by Plaintiff the +Government of the United States Virgin Islands, +stamped VI-JPM000012616, +designated confidential pursuant to the Protective Order in this matter and filed under +231. Attached as Exhibit 283 is a true and correct copy of a document produced by Plaintiff +the Government of the United States Virgin Islands, | +stamped VI-JPM- +000087959, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +232. Attached as Exhibit 284 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016129, +designated confidential pursuant to the Protective Order in this matter and filed under +233. Attached as Exhibit 285 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025693, +designated confidential pursuant to the Protective Order in this matter and filed under +234. Attached as Exhibit 286 is a true and correct copy of a document produced by third +stamped ESTATE_JPM044489, +33 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 34 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +235. Attached as Exhibit 287 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016521, +designated confidential pursuant to the Protective Order in this matter and filed under +236. Attached as Exhibit 288 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015782, +designated confidential pursuant to the Protective Order in this matter and filed under +237. Attached as Exhibit 289 is a true and correct copy of excerpts of the June 16, 2023 +Expert Report of Bridgette Carr, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +238. Attached as Exhibit 290 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024879, +designated confidential pursuant to the Protective Order in this matter and filed under +239. Attached as Exhibit 291 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016458, +designated confidential pursuant to the Protective Order in this matter and filed under +240. Attached as Exhibit 292 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016316, +34 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 35 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +241. Attached as Exhibit 293 is a true and correct copy of a document produced by third +stamped ESTATE_JPM025196, +designated confidential pursuant to the Protective Order in this matter and filed under +242. Attached as Exhibit 294 is a true and correct copy of a document produced by third +stamped ESTATE _JPM024114, +designated confidential pursuant to the Protective Order in this matter and filed under +243. Attached as Exhibit 295 is a true and correct copy of a document produced by third +stamped ESTATE_JPM024119, +designated confidential pursuant to the Protective Order in this matter and filed under +244. Attached as Exhibit 296 is a true and correct copy of a document produced by third +stamped ESTATE_JPM020206, +designated confidential pursuant to the Protective Order in this matter and filed under +245. Attached as Exhibit 297 is a true and correct copy of the travel website of the U.S. +Department of State regarding student visas, available at +https://travel.state.gov/content/travel/en/us-visas/study/student-visa.html. +246. Attached as Exhibit 298 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO20983, +35 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 36 of 41 +designated confidential pursuant to the Protective Order in this matter and filed under +247. Attached as Exhibit 299 is a true and correct copy of a document produced by third +stamped ESTATE_JPM064398, +designated confidential pursuant to the Protective Order in this matter and filed under +248. Attached as Exhibit 300 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO22289, +designated confidential pursuant to the Protective Order in this matter and filed under +249. Attached as Exhibit 301 is a true and correct copy of a document produced by third +stamped ESTATE_JPM029515, +designated confidential pursuant to the Protective Order in this matter and filed under +250. Attached as Exhibit 302 is a true and correct copy of a document produced by third +stamped ESTATE_JPM055329, +designated confidential pursuant to the Protective Order in this matter and filed under +251. Attached as Exhibit 303 is a true and correct copy of a document produced by third +stamped ESTATE_JPM059347, +designated confidential pursuant to the Protective Order in this matter and filed under +36 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 37 of 41 +252. Attached as Exhibit 304 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000087870, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +253. Attached as Exhibit 305 is a true and correct copy of a document produced by third +stamped ESTATE_JPM023450, +designated confidential pursuant to the Protective Order in this matter and filed under +254. Attached as Exhibit 306 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015784, +designated confidential pursuant to the Protective Order in this matter and filed under +255. Attached as Exhibit 307 is a true and correct copy of Exhibit 19 from the May 29, 2023 +deposition of Cecile de Jongh, designated confidential pursuant to the Protective Order +in this matter and filed under seal. +256. Attached as Exhibit 308 is a true and correct copy of a document produced by third +stamped ESTATE_JPM021434, +designated confidential pursuant to the Protective Order in this matter and filed under +257. Attached as Exhibit 309 is a true and correct copy of a document produced by third +stamped ESTATE_JPMO15122, +designated confidential pursuant to the Protective Order in this matter and filed under +37 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 38 of 41 +258. Attached as Exhibit 310 is a true and correct copy of Plaintiff the Government of the +United States Virgin Islands' Second Amended Complaint, designated confidential +pursuant to the Protective Order in this matter and filed under seal. +259. Attached as Exhibit 311 is a true and correct copy of excerpts from the transcript of the +May 26, 2023 deposition of Margarita +260. Attached as Exhibit 312 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000017983. +261. Attached as Exhibit 313 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018005. +262. Attached as Exhibit 314 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000019063. +263. Attached as Exhibit 315 is a true and correct copy of a document produced by third +stamped ESTATE_JPM016245, +designated confidential pursuant to the Protective Order in this matter and filed under +264. Attached as Exhibit 316 is a true and correct copy of excerpts of a document produced +by Plaintiff the Government of the United States Virgin Islands, +stamped VI- +JPM-000013479, designated confidential pursuant to the Protective Order in this matter +and filed under seal. +38 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 39 of 41 +265. Attached as Exhibit 317 is a true and correct copy of a document produced by Mark +Paneth, +stamped MP-00001858, designated confidential pursuant to the +266. Attached as Exhibit 318 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000023078. +267. Attached as Exhibit 319 is a true and correct copy of a document produced by Plaintifi +000023091. +stamped VI-JPM- +268. Attached as Exhibit 320 is a true and correct copy of excerpts from the May 17, 2023 +deposition of Sandra Bess. +269. Attached as Exhibit 321 is a true and correct copy of a document produced by third +stamped ESTATE_JPM015014, +designated confidential pursuant to the Protective Order in this matter and filed under +270. Attached as Exhibit 322 is a true and correct copy of a document produced by third +stamped ESTATE_JPM018432, +designated confidential pursuant to the Protective Order in this matter and filed under +271. Attached as Exhibit 323 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000022897. +39 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 40 of 41 +272. Attached as Exhibit 324 is a true and correct copy of a document produced by third +stamped ESTATE_JPM055884, +designated confidential pursuant to the Protective Order in this matter and filed under +273. Attached as Exhibit 325 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000016206. +274. Attached as Exhibit 326 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018885, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +275. Attached as Exhibit 327 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000016200, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +276. Attached as Exhibit 328 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018918, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +277. Attached as Exhibit 329 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018934, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +40 + + +Case 1:22-cv-10904-JSR Document 263 Filed 08/07/23 Page 41 of 41 +278. Attached as Exhibit 330 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000018551, designated confidential pursuant to the Protective Order in this matter and +filed under seal. +279. Attached as Exhibit 331 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000017233. +280. Attached as Exhibit 332 is a true and correct copy of Exhibit 37 from the May 26, 2023 +deposition of Margarita +281. Attached as Exhibit 333 is a true and correct copy of a document produced by Plaintiff +stamped VI-JPM- +000016492. +282. Attached as Exhibit 334 is a true and correct copy of Exhibit 14 from the May 29, 2023 +deposition of Cecile de Jongh. +283. Attached as Exhibit 335 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-W-00008805, designated confidential pursuant to the +Dated: August 7, 2023 +1s/ Felicia Ellsworth +Felicia H. Ellsworth +41 \ No newline at end of file diff --git a/vision-fixhub/court-05/61b1e8f31b1edc61722059b08682d3b389313c698bffb00612b0806d8da63bf1.receipt.json b/vision-fixhub/court-05/61b1e8f31b1edc61722059b08682d3b389313c698bffb00612b0806d8da63bf1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a8ddad24bbaea2f7d3c355e7eb88a258f5e3d3fd --- /dev/null +++ b/vision-fixhub/court-05/61b1e8f31b1edc61722059b08682d3b389313c698bffb00612b0806d8da63bf1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -10021, + "dataset": "marble-joined", + "doc_id": "61b1e8f31b1edc61722059b08682d3b389313c698bffb00612b0806d8da63bf1", + "engine": "marble-apple-vision", + "event_count": 43, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "fa2e93bce3cfb7d52c554d5104d7ae80dd2d1ae1b8a6531f0b0583bf55baa2a4", + "output_sha256": 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0000000000000000000000000000000000000000..bf3024fe498072537416841bf5c3e3b629723670 --- /dev/null +++ b/vision-fixhub/court-05/61e97d3ffedd4428391249a0565b3f7a25bd3a0f125516cfb45502339638d973.md @@ -0,0 +1,24 @@ +Case 1:19-cr-00830-AT Document 45 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA +-against- +TOVA NOEL and MICHAEL +Filed 02/25/21 Page 1 of 1 +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC#: +DATE FILED: 2/25/2021 +19 Cr. 830 (AT) +ORDER +ANALISA +Defendants. +District Judge: +The status conference scheduled for March 17, 2021, at 1:00 p.m. is ADJOURNED to +March 17, 2021, at 3:00 p.m. +SO ORDERED. +Dated: February 25, 2021 +New York, New York +ANALISA +United States District Judge diff --git a/vision-fixhub/court-05/61e97d3ffedd4428391249a0565b3f7a25bd3a0f125516cfb45502339638d973.receipt.json b/vision-fixhub/court-05/61e97d3ffedd4428391249a0565b3f7a25bd3a0f125516cfb45502339638d973.receipt.json new file mode 100644 index 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0000000000000000000000000000000000000000..f6c3c70ddebc31258df7e74ad7bc25be26616904 --- /dev/null +++ b/vision-fixhub/court-05/61f46919166b3592e39249708edffa681deeefa9199bc77e70d430c953c11e89.md @@ -0,0 +1,66 @@ +Case 1:22-cV-10904-JSR Document 244-15 Filed 07/25/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 244-15 Filed 07/25/23 Page 2 of 3 +From: +Sent: +To: +CC: +Subject: +Jonathan [/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=V293453] +3/29/2011 9:15:35 PM +Shenker, Nina O [nina.o.shenker@jpmorgan.com] +Langford, William D [william.d.langford@jpmchase.com] +FW: fyi +Nina, +Just called your office with William to talk to you about the email below and follow-up discussion I've had with Jes and +Steve. Understand you're on the West Coast. Would you be available to speak with us sometime this evening (up +until 1030pm NY) or tomorrow before you catch your 9am (NY-time) flight? If tomorrow morning, best to try to chat for +at 830 or 845am (NY time) your time since William and I both have meetings at 8am east coast. +Thanks, +Jon +From: Staley, Jes +Sent: Monday, Math 28, 2011 5:15 PM +Jonathan +Subject: FW: fyi +Privileged - let's discuss +Jes Staley | Chief Executive Officer| Investment. Bank | J.P. Morgan | 383 Madison Avenue, 7th Floor | T: +1 212 270 2375 | +jes.staley@jpmorgan.com +From: Jeffrey Epstein [mailto:jeevacation@gmail.com] +Sent: Monday, March 28, 2011 10:52 AM +To: Staley, Jes +Subject: fyi +fowwarded " +Jeffrey, It should now be apparent to both you and Glenn's own counsel +that there is a serious problem. In today's email it states that Glenn now +admits to knowing about the Zwirn plane in Sept or Oct of 06.- both before +is in a box. We know that Schulte Roth was called in in May 06 , so that is +really when he first found out. The moncy for the plane was taken from the +Highbridge managed acet. Highbridge was owned my JPM at that time. This is +ugly. +**************************** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for + +Д ПЕХНІВІТ 30 +Deponenfutker +Datda+2B Rptram +WWW.DEPOBOOKPRODUCTS.COM +JPM-SDNYLIT-00731610 + + +Case 1:22-cV-10904-JSR Document 244-15 Filed 07/25/23 Page 3 of 3 +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved + +JPM-SDNYLIT-00731611 diff --git a/vision-fixhub/court-05/61f46919166b3592e39249708edffa681deeefa9199bc77e70d430c953c11e89.receipt.json b/vision-fixhub/court-05/61f46919166b3592e39249708edffa681deeefa9199bc77e70d430c953c11e89.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6b90ae405256824c83431f733c2278a2ed4b4c4f --- /dev/null +++ b/vision-fixhub/court-05/61f46919166b3592e39249708edffa681deeefa9199bc77e70d430c953c11e89.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -71, + "dataset": "marble-joined", + "doc_id": "61f46919166b3592e39249708edffa681deeefa9199bc77e70d430c953c11e89", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "7d4fedec7d41820d116612f6a7febf90d4dacaf050451c6e92987fd29a0b3373", + "output_sha256": "49b2d293eac0708ff1761f79ba5e44989f401ced6acc1c3296a02241733f2f6b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6230a63b5d1cea72c898a82ae238afbd99d914432ad6a829e2b3234b790e400c.md b/vision-fixhub/court-05/6230a63b5d1cea72c898a82ae238afbd99d914432ad6a829e2b3234b790e400c.md new file mode 100644 index 0000000000000000000000000000000000000000..d57c1460151bdb22220f3b205c5978fa70b78ec8 --- /dev/null +++ b/vision-fixhub/court-05/6230a63b5d1cea72c898a82ae238afbd99d914432ad6a829e2b3234b790e400c.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 243-25 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/6230a63b5d1cea72c898a82ae238afbd99d914432ad6a829e2b3234b790e400c.receipt.json b/vision-fixhub/court-05/6230a63b5d1cea72c898a82ae238afbd99d914432ad6a829e2b3234b790e400c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..77d9fc94653b8f0a2433bc50c40c39e2ef82af99 --- /dev/null +++ b/vision-fixhub/court-05/6230a63b5d1cea72c898a82ae238afbd99d914432ad6a829e2b3234b790e400c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "6230a63b5d1cea72c898a82ae238afbd99d914432ad6a829e2b3234b790e400c", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "9972c92031220d829bef21da26851a8ea277aa8d14cb3426189dc4d6528c9fd9", + "output_sha256": "e6776a436a6b9ab7d57c8db23df2677758751821123bdc20a739cc17146953a8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/623f26972bcc99fa1e4ee4a52a5de45d94e6bd62be663a93ea15de06eb676c6f.md b/vision-fixhub/court-05/623f26972bcc99fa1e4ee4a52a5de45d94e6bd62be663a93ea15de06eb676c6f.md new file mode 100644 index 0000000000000000000000000000000000000000..7f7ed8779d52eb0bbbc03c90ae51d94dbe01de1c --- /dev/null +++ b/vision-fixhub/court-05/623f26972bcc99fa1e4ee4a52a5de45d94e6bd62be663a93ea15de06eb676c6f.md @@ -0,0 +1,975 @@ +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 1 of 17 + + + +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 2 of 17 +FORMER GOV KENNETH E. MAPP_Confidential +Gov of the US Virgin Islands vs JP +Chase +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +CASE NO. 22-cv-10904 +May 24, 2023 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +V. +JP +CHASE BANK, N.A., +Defendant. +*CONFIDENTIAL* +VIDEO DEPOSITION OF +FORMER GOV. KENNETH E. MAPP +Wednesday, May 24, 2023 +9:48 a.m. - 5:03 p.m. +Conducted at +Losey, PLLC +1420 Edgewater Drive +Orlando, +Florida 32804 +Reported by: +Janet +Job No.: +RPR, CRC, +FPR +J9718146 +AUSTIN REDCAY, Videographer +LOUWHAN WELCH, Exhibit +Technician (via Zoom) +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 3 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +24, 2023 +40 +l. Gov. Mapp, we were, just before we broke, +talking about the lunch that you had on Mr. Epstein's +island. And, again, that was at some point between +2015 and 2019. Correct? +A. Yeah. Yes. It may -- maybe sometime in +2016. +Q. What was the purpose of that lunch? +A. Well, he -- I believe at that time we were +attempting to do, float municipal bonds. And he had +been trying to assist me. I actually asked for his +help; as an investment person and a person that I +believed to, you know, be very connected to the +market. +We were having tremendous difficulty with +the issuance of the bonds. Because at that time on +the national stage Congress was really involved in the +debt crisis in Puerto Rico. So there was a bill that +was constructed, generally known as PROMESA, which +stands for some long label of words. But it was +dealing with what would happen, how it would sort of +protect the bondholders, the persons holding notes in +Puerto Rico, and how Puerto Rico would have to manage +what was expected to be a default on its debt. +MR. DUNN: Excuse me. Sorry to interrupt, +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 4 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +41 +but the witness is muted. We can't hear +anything on the Zoom. +VIDEOGRAPHER: I apologize. I must have +muted that. +MS. ELLSWORTH: Sorry. +Sorry, Jonathan. You're unmuted now. +A. +And while the PROMESA conversations were +taking place between the House and the US Senate, it +was driving a lot of consternation in the market about +the debt of the territories. And so we were trying to +keep territories out of the PROMESA language and keep +the PROMESA discussion and language specifically +directed to Puerto Rico and Puerto Rico's financial +issues. +And there was literally a collaboration +that all of the territories should be -- PROMESA +shouldn't be Puerto Rico specific. It should be all +of the territories. +And so the territories, we were concerned +about that. But more specifically I was concerned. +Because I'm now going into the market trying to get, I +believe, $200-something-million for varying financial +needs. And so we were dealing with that and trying to +see how we would structure this bond deal. And one of +the options that were on the table was that, if a +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 5 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +42 +natural issuance of bonds were going to run into -- +was going to be hampered by the PROMESA debate and +activity, what opportunities would we have for what is +known as a private placement of the bonds? Because at +the end of the day, the amount was $200-somethingmillion. And, again, the interest earnings on +Virgin Islands debt is about 90% tax exempt, if not +all exempt. +We didn't believe we had a problem +establishing our ability to pay the debt. Because +we've never had any issue in paying Virgin Islands +debt, given the structure that we use. +And so I think in that collaboration, I +asked for Jeffrey Epstein -- I was seeking +Jeffrey Epstein's advice. I was seeking +Mosler's advice, another EDC entity who does +investment banking. And I believe Dave +from +capital markets. Who also do financial management. I +was seeking their input and advice in terms of how to +get -- how to be successful in issuing what was some +really critically-needed bonds for financing some +critical financing needs of the territory. +Q. +(By Ms. Ellsworth) And at the lunch meeting +that you had with Mr. Epstein, was the subject of +discussion focused on this bond issuance issue? +A. It was focused on that. But Mr. Epstein +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 6 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +61 +A. What -- +Q. What interactions did you have with +Ms. Kellahar when she was acting on behalf of +Mr. Epstein or his entities while you were governor, +from 2015 to 2019? +A. She was involved in the meeting and +conversations having to do with the DPNR issues. +Q. Anything other than the DPNR issues that +you recall discussing with Ms. Kellahar when she was +acting on behalf of Mr. Epstein or his entities? +A. Not that I recall. +Q. And what about William Blum? Who is +William Blum? +A. +Wel1, I know William Blum well. +William Blum was the chief counselor to, counsel to +Gov. Juan Luis. When he served, I -- I served as +Gov. Juan Luis' security as a young guy and ended up +serving in his cabinet by the end of his term. So +Bill Blum was Gov. Luis' chief counsel. +Now the issue -- well, how I came to know +Bill Blum. +The EDC program in the Virgin Islands has a +unique twist. And that unique twist is that the +revenue benefits that -- the revenues that receive the +tax exempt benefits in the Virgin Islands by the major +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 7 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +62 +companies, the varying companies, are subject to being +domesticated or remaining sort of in the +Virgin Islands. So that if you -- if an entity has an +operation going in the Virgin Islands and is based and +has, as I say, a parent entity on the US mainland, and +there's a level of revenues that receive a tax break, +if I'm describing this accurately. And I'm subject to +being corrected. If you repatriate those dollars for +which you receive the tax benefits on, then they're +subject to additional taxation once the dollars hit +the US mainland. +I don't want to say sort of like if you're +a US entity operating in a foreign jurisdiction and +you get whatever tax structure you have in that +jurisdiction, those dollars may not be sort of subject +to US taxations, depending on how you do your income +tax. But if you seek to repatriate the dollars back +home to the US, then they become subject to some level +of tax obligation. +And so under the EDC program of the +Virgin Islands, when you receive your tax exemption +and you remember now in order to get the benefit you +have to sort of -- the entity has to be a resident, +and generally the owner of the entity is a resident in +the Virgin Islands. If you repatriate the money, then +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 8 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +63 +you sort of lose the tax benefit. And then you owe +the obligation to the IRS on the repatriation. +We wanted to find an avenue to make the +Virgin Islands EDC program more lucrative and to drive +in more companies and more owners of companies to take +residence in the territory. And I already in our +earlier conversation described what those benefits +were to the Virgin Islands. +We wanted to see if we could fashion +language which would have to ultimately be sanctioned +by the US Congress. Because the Virgin Islands +government has no jurisdiction outside the +Virgin Islands. We wanted to try to fashion language +that would allow repatriation either at some level, or +repatriation after the dollars remained in the +Virgin Islands for a specific period of time. So +that the -- we knew that Congress would not -- it +wouldn't be representative of any state's interest to +allow immediate repatriation of the dollars. Because +then why would you pay state taxes if you could just, +you know, operate in the Virgin Islands and then just +next year send the money to your corporate entity in +whatever state you were in? +So we were really trying to find a nexus, a +link that we could resist the political opposition. +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 9 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +64 +And it could be seen as favorable to the expansion of +the Virgin Islands' economy, and make the program more +attractive if the repatriation of the dollars after it +had a certain life in the Virgin Islands could occur. +And if it could occur with some level of percentage +being repatriated after some specific time. +And I know part of our discussions, the +conversation between Jeffrey Epstein and myself, I +would -- you know. I asked. How would that -- how +could that benefit, say, his particular business? And +I believe I asked Mr. L +, capital markets, the +same question. +And so I believe -- Epstein, I guess, knew +Will Blum. Because I was surprised when he mentioned +his name. Because I knew who Will Blum was. And he, +I guess on his own, got in touch with Mr. Blum. And +then -- Bill knew who I was and called. And so he was +helping us on seeing what kind of construct of +language could be put together that could begin the +process of that discussion and hopefully try to make +that happen. +Q. And did Mr. Blum provide some draft +language or a draft piece of legislation to you? +A. He may have. +He may have. +Q. And was it your understanding, when +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 10 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +65 +Mr. Blum provided a draft piece of legislation to you +related to this repatriation that he was being paid by +Mr. Epstein in connection with that work? +A. +Well, he would have, had to be. Because +Mr. Epstein brought him to the table. +I had my own counsel in Washington that -- +whatever legislations or drafts or whatever anybody +presented to me would ultimately end up in my local +counsel, my chief counsel in Government House. But we +would generally send those things off to our counsels +in DC. Because -- you know. Obviously, they were +hired and always did our political advocacy. And then +the draft of languages with varying staff at the +Congress in terms of what we thought we could get +through and what absolutely wasn't going to get +through. +So, you know, Bill would -- obviously was +put in contact with them. And, you know, this is not +pejorative at all: Lawyers will do what lawyers will +do. +Did you have a conversation with Mr. Blum +and Mr. Epstein about this repatriation legislation? +A. +Questions. Yes. Obviously. +e. And what do you recall about that +conversation? +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 11 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +A. Yes. +May 24, 2023 +101 +Q. Do you know what "Seb" refers to in this +email? +MR. ACKERMAN: Object to form. +A. Sebastiano Paiewonsky Cassinelli? +Q. (By Ms. Ellsworth) I'm asking you if you +have -- +A. That's all I can think it is. +Q. okay. Do you recall ever discussing with +Ms. de Jongh your campaign either attacking or not +attacking former Gov. de Jongh? +A. NO. +l. And do you recall with Mr. Epstein your +campaign either attacking or not attacking +Gov. de Jongh? +A. +No. +MR. ACKERMAN: Object to form. +MS. ELLSWORTH: Tab 14, please. Thank you. +I've marked as Exhibit 5 a document +-labeled ESTATE_JPM015733. +(Exhibit 5 marked for identification.) +MS. ELLSWORTH: Take a look and let me know +when you've had a chance to do so. +THE WITNESS: Okay. +Q. +(By Ms. Ellsworth) This is an email from -- +& ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 12 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +102 +at the top at least -- from Ms. de Jongh to +Mr. Epstein dated December 18, 2014? +A. Uh-hum. +Q. And it is entitled "Inaugural Committee." +You testified earlier that you believed +Mr. Epstein had testified to your inaugural committee. +Correct? +MR. ACKERMAN: Object to form. +A. That he had -- +Q. (By Ms. Ellsworth) -- contributed to your +inaugural committee? +A. Yes. +Q. Does this refresh your recollection as to +the amount that Mr. Epstein donated? +MR. ACKERMAN: Object to form. +This is the first time I am seeing an +A. +amount. +Q. +(By Ms. Ellsworth) And my question is: +Does this refresh your recollection that +Jeffrey Epstein donated $10, 000 to your Inaugural +Committee? +MR. ACKERMAN: Objection. +A. I had no knowledge of how much he donated, +but I believed he did donate to the Inaugural +Committee. +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 13 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +103 +Q. (By Ms. Ellsworth) Okay. Do you have any +reason to doubt that he donated $10, 000? +A. I have none. +Q. The bottom of this email chain begins with +an email from Sebastiano Paiewonsky Cassinelli. +Correct? +A. That's what it says. +Q. Is that different than Filippo Cassinelli? +A. That would be his brother. +Q. Okay. And did Sebastiano Cassinelli work +for your campaign? +A. He supported the campaign. +l. Okay. Was he involved in planning your +inaugural event? +A. +No. I don't know -- other than the folks +that I have designated as the head of the inaugural +committee, I don't know who all was involved. But I +know many businesses and folks got involved in the +inaugural event. +Q. Do you recall who was the -- who were the +designated heads of your inaugural committee? +A. +Former First Lady Barbara Schneider and +Former First Lady Luz Luis. +Do you recall -- did you throw an inaugural +event? +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 14 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +119 +A. No. +Q. The beginning of this email -- I'm sorry -- +in that second paragraph, beginning with "Mapp would +like." +A. Yes. +Q. Ms. de Jongh references previous +discussions she has +had with you with regards to +eCommerce? +A. +Uh-hum. +e. +When do you recall first discussing +eCommerce issues with Mr. Epstein? +A. It may have come up when I met with him as +part of my spiel in terms of what are some of the +priorities if I am successful at becoming Governor. +Because I -- that was one of the big issues for me. +Q. Do you have any more specific recollection +about discussing eCommerce issues with Mr. Epstein? +MR. ACKERMAN: Object to form. +A. As I said, during the course of some of my +meetings. Any ability he had from clientele and folks +in particularly in the investment market. The money +market area. The money industry. That it became a +selling point for financial managers in the +Virgin Islands. Because here we had a redundant +platform that was tied in by fiber-optic and undersea +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 15 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +120 +cables directly into Florida and into New York. That +could benefit such a business. +So to the extent of making that well-known +and looking for recommendations and spreading the word +that the Virgin Islands had this unique attribute that +it was pushing for business investment, that would be +the extent of the conversations. +Q. +(By Ms. Ellsworth) Is it fair to say that +one of your campaign platforms when you ran for +governor was to increase business investment in the +Virgin Islands? +A. Significantly. +l. And one of your key platforms as governor +was to increase business investment in the +Virgin Islands? +A. +Yes. +Q. And you did discuss those platforms with +Mr. Epstein as a business owner on the Virgin Islands. +Correct? +A. +Yes. +Q. +Did you discuss Mr. Epstein's advice about +increasing government -- excuse me -- business +investment in the US Virgin Islands? +A. +Mr. Epstein. Members of the Chamber of +Commerce. Other members of the EDC Community. Local +→ ESQUIRE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 16 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +121 +businesses. Members of Congress. Members of the +Senate. +Any advice, any way that folks felt the +Virgin Islands lacked in its approach to its messages +about the Virgin Islands being open for business and +how to help facilitate business investment. And even, +you know, a number of folks had a lot of +recommendations about some of the failures within the +Virgin Islands's public system in terms of +facilitating business growth and development in terms +of how we handle registering businesses, licensing +businesses. Just the time involved and the +bureaucratic -- the bureaucracy, and how it impacted +and delayed and frustrated people. +You know. I was just open to all of that. +e. +And so the answer is yes, you did seek +Mr. Epstein's advice about how to increase business +investment in the Virgin Islands? +A. +Yes. +Yes. +MR. ACKERMAN: Object to form. +e. +(By Ms. Ellsworth) What advice do you +recall receiving from Mr. Epstein about how to +increase business investment in the Virgin Islands? +A. +Some of the bureaucracy issues. Some of +the limitations that EDC businesses faced. And I +→ ESQUIRE + + +2 +3 +4 +5 +6 +7 +8 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cv-10904-JSR Document 267-28 Filed 08/07/23 Page 17 of 17 +FORMER GOV KENNETH E. MAPP Confidential +Gov of the US Virgin Islands vs JP +Chase +May 24, 2023 +122 +think we exhausted quite a bit of time talking about +the repatriation issues. Certainly the limitation on +travel, as it affected everyone in the Virgin Islands. +But particularly members of the EDC community across +the board. A number of EDC companies raised that +issue with me, with the regulation of Treasury. +Things of that nature. +l. Atter you became Governor -- well, +withdrawn. +You had a separate campaign fund as a part +of your campaign in 2014. +Correct? +A. +Well, when you say "separate campaign +fund" -- +Let me start the question again. +You had a campaign fund as a part of your +2014 campaign? +A. +Yes. Yes. +l. Okay. Did you use that same fund in the +2018 campaign? +A. +I believe we did. Yes. +Q. Okay. Did you also have a political action +committee or PAC that was associated with your +campaign? +A. +Well, there were -- there were PACs out +there of people who were supporting the campaign and +→ ESQUIRE \ No newline at end of file diff --git a/vision-fixhub/court-05/623f26972bcc99fa1e4ee4a52a5de45d94e6bd62be663a93ea15de06eb676c6f.receipt.json b/vision-fixhub/court-05/623f26972bcc99fa1e4ee4a52a5de45d94e6bd62be663a93ea15de06eb676c6f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e099f309697b98f207c9844fefad475ab99f6750 --- /dev/null +++ b/vision-fixhub/court-05/623f26972bcc99fa1e4ee4a52a5de45d94e6bd62be663a93ea15de06eb676c6f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1211, + "dataset": "marble-joined", + "doc_id": "623f26972bcc99fa1e4ee4a52a5de45d94e6bd62be663a93ea15de06eb676c6f", + "engine": "marble-apple-vision", + "event_count": 20, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "6c115c097212c2b910bd7474ffdb10acee0299cdd8c6b546be2e3aad42d58568", + "output_sha256": "e524c9a0e0b9ee7418ce7d44c4a6cdd002d3e0bb83ca2e3ec4f077c4035109d1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6240cdf457878e3cfbf49a8f28ef2a6b6c4d844fb5a894a7dc09c4fc9edff9f0.md b/vision-fixhub/court-05/6240cdf457878e3cfbf49a8f28ef2a6b6c4d844fb5a894a7dc09c4fc9edff9f0.md new file mode 100644 index 0000000000000000000000000000000000000000..0075a0f4e15c7e46381ee6f53df025fbd8d03597 --- /dev/null +++ b/vision-fixhub/court-05/6240cdf457878e3cfbf49a8f28ef2a6b6c4d844fb5a894a7dc09c4fc9edff9f0.md @@ -0,0 +1,192 @@ +Case 1:22-cv-10904-JSR Document 238-4 Filed 07/25/23 Page 1 of 9 +FILED UNDER SEAL + + + +Case 1:22-cv-10904-JSR Document 238-4 Filed 07125/23 Page 2 or 9 +Know Your Customer (KYC) +A fundamental concept that leads the fight against +Anti-Money Laundering, Fraud and Reputational Risk +• KYC is a due diligence process that ensures we "know" +the clients we deal with, and understand how and why they +use our products and services. +• Without KYC, we become vulnerable. Unknowing to us, +our clients could easily use PCS as a vehicle to perpetrate +illegal activities. +• Potential loss and government sanctions aside, reputational +risk is a major concern. Any adverse media about illegal +activities - whether accurate or not - can cause a loss of' +integrity and market confidence for JPMC. + + +2 +3/29/23 +JPM-SDNTCI-00T28026 + + +Case 1:22-cv-10904-JSR Document 238-4 Filed 07125/23 Page 3 of 9 +Know Your Customer +Regulations and JPMC Policies Assist in Adhering to KYC +KYC Component +Practice Description +Associated Regulation/Policy +Customer Acceptance +Determining, at inception and on a ongoing basis, whether the client or prospect complies with +relevant legal/regulatory policies and meets our firm's client standards +JPMC Sponsorship +Policy +Client Identification +Obtaining satisfactory evidence of the true identity of any prospect, client or intermediary +acting on behalf of a person/entity. +Understanding the true relationship by identifying all material beneficial owners. +• Identifying those client types that are likely to pose higher than average risk to the bank and +performing enhanced due diligence to assess our risk +Retaining pertinent, up-to-date, and relevant client records to document all risk assessments +Product Use Rationale +Obtain appropriate information regarding the nature of the client's business/personal activities +to execute a reasonableness test. +Understanding of what is considered normal financial transactions and account balances for +our client. Knowledge of significant cash flow rationales and why domestic/international wire +transfers are transacted. +JPMC KYC Policy +Ongoing Monitoring +well as identity nervinoof rins. +Ongoing scrutiny of financial transactions to continually validate existing risk assessments, as +Bank Secrecy Act and +JPMC KYC Policy + +JPM-SDNYLIT-00128027 + + +Case 1:22-cv-10904-JSR Document 238-4 Filed 07125/23 Page 4 of 9 +JPMC Sponsorship Policy +• New Policy to be introduced 3rd Quarter 2005 +• Sponsorship is defined as the relationship +manager's responsibility for: +- Determining whether an existing or prospective +relationship complies with relevant legal and regulatory +based policies. +- Taking appropriate action to identity, communicate and +resolve any issues that may arise in the course of such +determinations. +• More to come later in the year. + +JPM-SDNYLIT-00128028 + + +Case 1:22-cv-10904-JSR Document 238-4 Filed 07125/23 Page 5 org +All new accounts in PCS are required to be opened in compliance with PCS's AML/KYC Policy and Guidelines, and encompasses +all deposit, loan, personal trust, custody, trust agency and investment agency accounts. The PCS associate responsible for the +client relationship, in concert with middle office associates, is responsible for obtaining and recording CIP information as +outlined in the following seven steps: +Step 1: Determine if customer is new or existing +•If customer is an existing client of PCS, associates are to use specific business unit standards to establish and document +"reasonable belief" of the customer's identity. +•If customer is new to PCS (including referrals from other JPMC Lines of Businesses), the associate is to establish the +customer's identity by obtaining and verifying the customer's ID. +Step 2: Disclosure to customers +We are required by law to disclose to our clients that we verify their identification. A standard PCS AML disclosure statement is +to be provided to customers who open new accounts as part of their account opening documentation. +Step 3: Gather customer "core 4" information: +•Name (individual or business entity) +•Residential or business location address +•Social Security number or tax ID +•Date of birth (for individuals only) +Step 4: Obtain customer identification +•Individuals - Two pieces of identification. One must be primary and both must be issued from different sources. +•Non-individuals - State/Government certified documents, such as Articles of Incorporation, Partnership Agreement, etc. +Step 5: Verify customer identity +Unless the verification is a systematic part of the new account process, use an independent third-party source, like ChexSystems to +validate the client's identity. + +JPM-SDNYLIT-00128029 + + +Case 1:22-cv-10904-JSR Document 238-4 Filed 07125/23 Page 6 of 9 +Step 6: Determine if your client falls into a "high risk" category. If the client does, perform "enhanced due diligence." +Certain clients are considered high risk due to their probability of engaging in money laundering, their account size and complexity, +or as defined by the government. The following "enhanced due diligence" efforts may be required for new and existing clients. +1. Background screening +•Required for all clients opening an account for $1 million or more, and/or those who JPMC policy defines as high risk. +•Corporate Security will provide background-screening alerts to PCS Risk Management for its review. Depending on the level +of the alert received, PCS Risk Management will contact the front office associate for appropriate approvals. A business case +will be created and provided to the Managing Director, Regional Director and PCS National Director. +2. Non-U.S. citizens +• The International Private Client Services process and forms must be used when opening any account for a non-US citizen +or foreign entity. +•The IPCS Risk Manager is to approve all new non-U.S. citizens outside of IPCS's financial and geographic targets. +•Additionally, the Market Regional Director and the Head of PCS is required to approve all new senior political officials, also +known as politically exposed persons (PEPs). +3. A PCS Enhanced Due Diligence form with appropriate PCS management sign-off must be completed when: +• The ultimate source of funds for the new account cannot readily be established, or +•When JPMC policy defines the new or existing client as High Risk. +Step 7: Record and retain identification/ verification information +The Patriot Act Data System (PADS), Customer Assist, Trust/Custody/Agency checklists, General Release of Credit Form, and/or +eChecklist is used to record core pieces of client identification and verification information for PCS accounts. +In addition, PCS business units is to retain supporting documentation, including enhanced due diligence documentation in front +office files, imaging systems or processing systems to comply with the retention requirements of the Act. All identifying information +obtained pursuant to the Customer Identification Program (CIP), as well as records of the methods used and results received during +the verification process, is required to be retained for 5 years after the account is closed. + +JPM-SDNYLIT-00128030 + + +Case 1:22-cv-10904-JSR Document 238-4 Flled 07125/23 Page 7 of 9 +High Risk Designations - Consumers +• Non-US citizens +• Owners of high risk businesses +What you need to do: +- Complete either the IPCS non-US or PCS Enhanced Due Diligence +forms, as appropriate. Obtain management sign-off prior to +opening account. +- If appropriate, initial a client/prospect background screen. + +JPM-SDNYLIT-00128031 + + +case 1:22-cv-10904-JSR Document 238-4 Filed 07/25/23 Page 8 of 9 +High Risk Designations - Business Entities +ATM Vendors/providers, Auctioneers of luxury good, Bank note +traders, Brokers/Dealers, Car/plane/boat dealerships/operators, +Cash intensive business, Charities and Foundations, Coupon +redemption business, Deposit brokers, Foreign corporations +(including Off Shore Companies and Private Investment/Holding +Companies), Hedge funds, Investment advisors/brokers, +Import/export companies, Jewel and precious metal +dealers/stores, Loan and credit agents, Pawn brokers, Phone card +companies, Private equity/Investment firms, Professional +services - lawyers, accountants and company services, Salvage +businesses, Ship and bus operators, Special purpose vehicles, +Societies and clubs, Telemarketers, Travel agents +What you need to do: +-Complete an PCS Enhanced Due Diligence Form (or IPCS forms +for foreign businesses) and obtain management sign-off +-If appropriate, initial a client/prospect background screen. + +JPM-SDNYLIT-00128032 + + +Case 1.22-cv-10904-JSR Document 238-4 Filed 07125/23 Page 9 of 9 +High Risk Designations - Geographic Restrictions +High Risk - Afghanistan, Algeria, Angola, Azerbaijan, Bahamas, Bhutan, Bolivia, Brazil, Burkina +Faso, Burma, Burundi, Cameroon, Central African Republic, China, Colombia, Comoros, +Congo, +Islands, Cuba, Dominican Republic, East Timor, Ecuador, Equatorial Guinea, +Eritrea, Ethiopia, Gabon, Guatemala, Guinea, Haiti, India, Indonesia, Iran, Iraq, Jamaica, +Kazakhstan, Kiribati, Korea, Kosovo, Kyrgyzstan, Laos, Latvia, Lesotho, Liberia, Libya, +Madagascar, Malawi, Maldives, Mali, Martinique, Mauritania, Mexico, Mongolia, Nauru, Nepal, +Niger, Nigeria, Pakistan, Palestine, Panama. Papua New Guinea, Paraguay, Peru, Philippines, +Russia, Rwanda, Sao Tome, Sierra Leone, +Islands, Somalia, Sudan, Syria, Tajikistan, +Thailand, Turkmenistan, Tuvalu, Uganda, Venezuela, Vietnam and Zimbabwe (Red = PCS +Target Market) +Medium Risk - Armenia, Bangladesh, Benin, Brunei Darussalam, Cambodia, Chad, Cote +D'lvoire, Djibouti, Fiji, Gambia, Georgia, Ghana, Guyana, Honduras, Kenya, Macau, Micronesia, +Moldova, Montserrat, Morocco, Mozambique, Namibia, Nicaragua, Niue, Palau, Samoa, San +Marino, Senegal, Seychelles, Sri Lanka, St. Lucia, Suriname, Swaziland, Tanzania, Togo, Tonga, +Tunisia, Turks & Calicos, Uzbekistan, Western Sahara, Yemen, Yugoslavia (Serbia) and Zambia +• What you need to do: +-Complete IPCS Client Profile/Applications forms with management signoff. +—Perform World Check and OFAC screens + +JPM-SDNYLIT-00128033 \ No newline at end of file diff --git a/vision-fixhub/court-05/6240cdf457878e3cfbf49a8f28ef2a6b6c4d844fb5a894a7dc09c4fc9edff9f0.receipt.json b/vision-fixhub/court-05/6240cdf457878e3cfbf49a8f28ef2a6b6c4d844fb5a894a7dc09c4fc9edff9f0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..33ce43231ea146b569cde7e1048ab29f222063ab --- /dev/null +++ b/vision-fixhub/court-05/6240cdf457878e3cfbf49a8f28ef2a6b6c4d844fb5a894a7dc09c4fc9edff9f0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -548, + "dataset": "marble-joined", + "doc_id": "6240cdf457878e3cfbf49a8f28ef2a6b6c4d844fb5a894a7dc09c4fc9edff9f0", + "engine": "marble-apple-vision", + "event_count": 20, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "fd80749f27033fe110436fbcabdb7fe765c3645cc45488f1dbe304443c7f1a18", + "output_sha256": "a72b7920a9ac88c17474f766096427dad6d1fac982ea84f92b0c6b2bf2781d91", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/62719491dbfb63ef8f1bcd5a22bf57f9eef2b412da5f42d8dea8340b5323e7d9.md b/vision-fixhub/court-05/62719491dbfb63ef8f1bcd5a22bf57f9eef2b412da5f42d8dea8340b5323e7d9.md new file mode 100644 index 0000000000000000000000000000000000000000..b68af6343c71d07776f8e6d563fc0decf557fc00 --- /dev/null +++ b/vision-fixhub/court-05/62719491dbfb63ef8f1bcd5a22bf57f9eef2b412da5f42d8dea8340b5323e7d9.md @@ -0,0 +1,42 @@ +Case 1:22-cv-10904-JSR Document 239-1 Filed 07/25/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 239-1 Filed 07/25/23 Page 2 of 2 +Rapid Response Team +October 17, 2006 +Existing Client - Jeffrey Epstein +Private Banker - Mary 4|||| - GDP 464-0374 +Nature of Existing Relationship +The Epstein relationship, which includes accounts for his personal investment company - +Financial Trust Company, consists of banking, asset and credit accounts with balances totaling +approximately $32 million. +Cash withdrawals are routinely made in amounts for $40,000 to S80,000 several times a month, +which total over $750,000 year to date. +Source of Wealth +Jeffrey Epstein is a money manager for wealthy individuals. Press articles indicate that he owns +what is said to be the Manhattan's largest private house and runs his business from a 100 acre +private island in St. +Derogatory Information reported by Security Services +The following derogatory information was identified by Security Services within related entity +DDRs for Jeffrey Epstein - YHS, LLC, Ranch Lake II, Ine and Ranch Lake III, Inc - all opened +with a temporary waiver +• Several newspaper articles were found that detail the indictment of Jeffrey Epstein in +Florida on felony charges of soliciting underage prostitutes. +Banker Recommendation from DDR +After internal discussions with Jes Staley, Mary Erdoes, Catherine Keating, John Duffy and +Mary L +!. it was decided that we will keep Mr. Epstein solely as a banking client and on a +'reactive', client service basis. We will not proactively solicit new investment business from him. +Team Meeting +Conclusion +After internal discussions with Jes Staley, Mary Erdocs, Catherine Keating, John Duffy and +Mary I +1, it was decided that we will keep Mr. Epstein solely as a banking client and on a +'reactive', client service basis. We will not proactively solicit new investment business from him. + +Erdoes - 3 +3/15/23 +CONFIDENTIAL - ATTORNEY CLIENT PRIVALEDGE + +JPM-SDNYLIT-00127953 diff --git a/vision-fixhub/court-05/62719491dbfb63ef8f1bcd5a22bf57f9eef2b412da5f42d8dea8340b5323e7d9.receipt.json b/vision-fixhub/court-05/62719491dbfb63ef8f1bcd5a22bf57f9eef2b412da5f42d8dea8340b5323e7d9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6a2fa418e05e87851937db877bed477725e3a0db --- /dev/null +++ b/vision-fixhub/court-05/62719491dbfb63ef8f1bcd5a22bf57f9eef2b412da5f42d8dea8340b5323e7d9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -53, + "dataset": "marble-joined", + "doc_id": "62719491dbfb63ef8f1bcd5a22bf57f9eef2b412da5f42d8dea8340b5323e7d9", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "670cc8bdc8ac38e4bf48bd4dc72617c4005aff4084b257174684717caac34c6a", + "output_sha256": "4aa33bafd42aa4591b377a81cceb8787d1b8b8f2b77ba436648becb502686f4c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/62790f7417c07dad89d1316bb2a87673458267d9bf3679e9493a9bb6173f003e.md b/vision-fixhub/court-05/62790f7417c07dad89d1316bb2a87673458267d9bf3679e9493a9bb6173f003e.md new file mode 100644 index 0000000000000000000000000000000000000000..b5b52996f2c4f38c95df358ff50f979252a9f433 --- /dev/null +++ b/vision-fixhub/court-05/62790f7417c07dad89d1316bb2a87673458267d9bf3679e9493a9bb6173f003e.md @@ -0,0 +1,163 @@ +Case 1:22-cV-10904-JSR Document 263-70 Filed 08/07/23 Page 1 of 4 + +FILED UNDER SEAL + + +Case 1:22-cv-10904-JSR Document 263-70 Filed 08/07/23 Page 2 of 4 +From: +Sent: +To: +Subject: +Ryan, Maryanne X [/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MARYANNE.X.RYAN] +1/10/20115:09:25 PM +Langford, William D [william.d.langford@jpmchase.com]; DeLuca, Phillip A [phillip.a.deluca@jpmchase.com]; +Nichols, Nina A [nina.a.nichols@jpmchase.com] +RE: Jeffrey Epstein +• will dig more on the modeling agency and his personal accounts for potentially interesting activity 1r +Seems JPMC never was served a subpoena, +which I find odd since we were +15 *1 bank and actuall +Bear got one in 07. +Rich is getting me the AUSA correspondence and we will compare their ask of Bear +(something about $1000 and $100,000 transactions were of interest to them) +How it came up again was his account alerted in Fortent for cash activity which it does for time to time +and we went to Jim and he again said PB is comfortable with him and that Steve cutler +I spoke to Phil and given the H project thought that steve Cutler may feel differently about +Epstein, given the exposure the bank has received on the HT project +I circled back with PB and that was +he reason for the RR meeting on Friday. Seems PB was not so thrilled with retaining him, ft was all due +digging will take a few days, I'1l get back to you when I am done. The guy likes cash so the paper trail +could be hard. +Regards, +Maryanne Ryan, +Department| | 194 +Vice Presidnue south Fratra, Isen, IsepMn, . A V V:132.452d00mpliance +Avenue South, Floor 4, Iselin, NJ +--Original Message-- +From: Langford, william D +Sent: Monday, January 10, +2011 11:55 AM +To: Deluca, Phillip A; Nichols, Nina A +Cc: Ryan, Maryanne X +Subject: RE: Jeffrey Epstein +noted below that he +whaed below that he has the forde modesing agency, stethat really teals us 1 and bad activity? You +nas ties to the modeling agency, +Also, how again did this come up recently? Was it the negative media this summer? +- W +-----Original Message----- +From: Deluca, Phillip A +Sent: +Monday, January 10, 2011 11:29 AM +To: Nichols, Nina A; Langford, William D +Cc: Ryan, Maryanne X +Subject: FW: Jeffrey Epstein +Phil +•--Original Message- +From: Ryan, Maryanne X +sus PC. Re. Defrey 210, 21021 22:03 An +lere is the RR memo which includes I think everything you would want, or W would want. Let me know afte +rou read it if there is more vou would like to see. +Regards, +Maryanne Ryan, +Department| | 194 +---Original Message- +From: Deluca, Phillip A +Sent: Monday, January 10, 2011 10:42 AM +To: Ryan, Maryanne X + +JPM-SDNYLIT-W-00025201 + + +Case 1:22-cv-10904-JSR Document 263-70 Filed 08/07/23 Page 3 of 4 +Subject: FW: Jeffrey Epstein +Maryanne, +Can you please begin to gather his info? +Thanks, +Phil +--Original Message-- +From: Langford, William D +ok. Can you all assemble prior email on the facts and include any relevant press reports so we can get +all the facts asap in advance is any meeting with Jes? +Thanks. +W +Sent with Good (www.good.com) +--=--Original Message----- +From: +DeLuca, Phillip A +Sent: Nichols, Ninary 10, 2011 07:50 AM Eastern Standard Time +subject: +Langford, william D +FW: Jeffrey Epstein +Nina, +Welcome! +he'1l provide some color around this matter. +Please see below. I can also fill you in with additional details when we speak. In essence: +JPMC maintains the Private Banking (PB) relationship for this individual, Jeffrey Epstein. +He is alleged to be involved in the human trafficking of young girls and law enforcement is +also allegedly investigating his involvement in this activity. +He is also an alleged personal associate of the CEO of the Investment Bank (Jes Staley) +relationship. +AML Operations went to a PB risk meeting late last week requesting that we exit this +he CEO of PB US (Catherine Keating) and PB General Counsel (Anne Verdon) suggest that Willia +nd PB management meet with Jes Staley to review our recent HT initiative with hir +I'm copying william as we have discussed this individual in the past and you may not have email set up +yet. Maryanne Ryan's email below discusses the request as well as additional detail related to Epstein. +Please let me know when you have a few moments to discuss. +Thanks, +Phi1 +-----original Message----- +Confidentiall +JPM-SDNYLIT-W-00025202 + + +Case 1:22-cV-10904-JSR Document 263-70 Filed 08/07/23 Page 4 of 4 +From: Ryan, Maryanne X +Sent: Friday, +January 07, 2011 7:33 PM +To: Deluca, Phillip A +Cc: Middlemiss, Arthur +Subject: Jeffrey Epstein +Phil- +This email +is a summary of the Rapid Response meeting regarding Jeffrey Epstein. It involves an ask of +William so I am sending to you first. +The RR +meeting +Bonnie +attended by Catherine Keating, Ann Verdon, the current and former banker, Kevin, Jim and +from Risk and Art and I. +Jeffrey Epstein is a friend of Jes 5 and Catherine feels that PB along with william should meet with him +to explain the HT project and explain the banks recognition on the project and whether Epstein if further +exposed could have a potential serious impact. +Epstein was released in July from house arrest and the Palm Beach Post carried two articles saying DOJ +be investigating +for child trafficking via a modeling agency he is part owner in. +melieves that after the briefing on HT that Jes would need to point blank ask Jeffrey the status of any +criminal investigations. +Catherine made sure we knew that no one on today +etained him as a client. Seems it all is due to Jes's personal relationship. Note he has about 212 mil +in the bank and some in JPMS (old Bear PCS) +compared to countless stories related to his escapades. +palm beach and in st +I (his places of residence). +Lots of salon, lingerie shops, drug stores ny +Plus lots of video like girls gone +and some +other shops not fit for my good catholic upbringing! +The transactions are old 05 to 08. Besides frequent +frequent spa like charges it has died down . Surprised +she was never subpoened. +The one new concerning +thing is the one article about the DOJ investigation is saying they brought under +agency M2 that +age girls to the US via a model oan in relation to this modeling agency. +is owned by a guy named Brunel. Turns out the banker +today we extended Epstein a +It appears to be a legit +modeling agency. If girls were expolited via their contract or arrangement it would be hard for us to +Bottom line we need w to meet with Jes to explain HT and then Jes could decide the next steps. +Typed on my bb so sorry for typos. I do have a PB rapid response memo I can forward as well. + +JPM-SDNYLIT-W-00025203 diff --git a/vision-fixhub/court-05/62790f7417c07dad89d1316bb2a87673458267d9bf3679e9493a9bb6173f003e.receipt.json b/vision-fixhub/court-05/62790f7417c07dad89d1316bb2a87673458267d9bf3679e9493a9bb6173f003e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b55d2c95babfbfd45f8d79d90ae08e0597152f57 --- /dev/null +++ b/vision-fixhub/court-05/62790f7417c07dad89d1316bb2a87673458267d9bf3679e9493a9bb6173f003e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -83, + "dataset": "marble-joined", + "doc_id": "62790f7417c07dad89d1316bb2a87673458267d9bf3679e9493a9bb6173f003e", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "30b75b34b7470bcb91403bf2a89aa95cf720d8716bb6c54e3ce041ba31a73f06", + "output_sha256": "90ae6accf25e71613d12f0306e483521f605207d8e3ca2657091590a7bfe6318", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/62806f8f5ef20a29469d95ff866248a283e14c01221505a816042c03f522e2df.md b/vision-fixhub/court-05/62806f8f5ef20a29469d95ff866248a283e14c01221505a816042c03f522e2df.md new file mode 100644 index 0000000000000000000000000000000000000000..8006f5a0660453733953988c5b3a9b30fd100658 --- /dev/null +++ b/vision-fixhub/court-05/62806f8f5ef20a29469d95ff866248a283e14c01221505a816042c03f522e2df.md @@ -0,0 +1,136 @@ +Case 1:22-cv-10904-JSR Document 284-25 Filed 08/14/23 + + +FILED UNDER SEAL + + +Case 1:22-CV-10904-JSR Docueft 574-25 Filed 08/14/23 Page 2 of 5 +Cecile +2009 +Proposed increases/bonuses +2010 +2011 +2012 +2013 +2014 +Salary +Salary - Increase +Bonus +Health Insurance +Simple IRA +Payroll taxes +Antilles tuition +College tuition +15,300 +74,799 +14,900 +38,176 +15,300 +79,735 +16,230 +21,569 +16,230 +22,027 +Jeanne +2009 +2010 +2011 +2012 +2013 +2014 +Salary +Salary - Increase +Bonus +Health Insurance +Simple IRA +Payroll taxes +Antilles tuition +College tuition + +ESTATE_JPM064334 + + +Case 1:22-CV-10904-JSR Docueft 574-25 Filed 08/14/23 Page 3 of 5 +Anna +2009 +2010 +2011 +2012 +2013 +2014 +Salary +Bonus +Health Insurance +Simple IRA +Payroll taxes +Local tuition +JEE personal +LSJE - as of 11.30.2013 +LSJE - as of December +Daphne +2009 +2010 +2011 +2012 +2013 +2014 +Salary +Salary - Increase +Bonus +Health Insurance +Simple IRA +Payroll taxes +JEE personal + +ESTATE_JPM064335 + + +Case 1:22-CV-10904-JSR Doculeft 55425 Filed 08/14/23 Page 4 of 5 +Una +2009 +2010 +2011 +2012 +2013 +2014 +Salary +Salary - Increase +Bonus +Health Insurance +Simple IRA +Payroll taxes +Local tuition +Loan given +payments made to date +Jermaine +2009 +2010 +2011 +2012 +2013 +2014 +Salary +Salary - Increase +Bonus +Health Insurance +Simple IRA +Payroll taxes +Local tuition +JEE personal +Loan given +payments made to date + +ESTATE_JPM064336 + + +Case 1:22-CV-10904-JSR Docueft 574-25 Filed 08/14/23 Page 5 of 5 +Year +Total - for current employees +2009 +2010 +2011 +2012 +2013 +2014 + +ESTATE_JPM064337 \ No newline at end of file diff --git a/vision-fixhub/court-05/62806f8f5ef20a29469d95ff866248a283e14c01221505a816042c03f522e2df.receipt.json b/vision-fixhub/court-05/62806f8f5ef20a29469d95ff866248a283e14c01221505a816042c03f522e2df.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bb05b25a2a4b3543e31aec2d5e8d56a020c352e4 --- /dev/null +++ b/vision-fixhub/court-05/62806f8f5ef20a29469d95ff866248a283e14c01221505a816042c03f522e2df.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -287, + "dataset": "marble-joined", + "doc_id": "62806f8f5ef20a29469d95ff866248a283e14c01221505a816042c03f522e2df", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "1af5f4ac32e87e823552860174770d892278bfc2a943350bb2541e1c00f3794a", + "output_sha256": "b92e4581c2756c92fe389d8537065ced627bdf06ea942b0ae0cada675ec08403", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/62970e4de10ea2f18786a7ff5d8d7235ec5ee45c7e6adf6b13797bbfa1efb2eb.md b/vision-fixhub/court-05/62970e4de10ea2f18786a7ff5d8d7235ec5ee45c7e6adf6b13797bbfa1efb2eb.md new file mode 100644 index 0000000000000000000000000000000000000000..2696a345dbe2ea1199d0878863a20c21720bc717 --- /dev/null +++ b/vision-fixhub/court-05/62970e4de10ea2f18786a7ff5d8d7235ec5ee45c7e6adf6b13797bbfa1efb2eb.md @@ -0,0 +1,59 @@ +Case 1:22-cv-10904-JSR Document 270-3 Filed 08/07/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 270-3 Filed 08/07/23 Page 2 of 3 +Bank Secrecy Act / +Anti-Money Laundering +Examination Manual +Federal Financial Institutions Examination Council: +Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, +National Credit Union Administration, Office of the Comptroller of the Currency, +and Office of Thrift Supervision +2006 + +Langford +Date: 5/3/23 +MLG, CSR, RPR, CAR + + +Case 1:22-cv-10904-JSR Document 270-3 Filed 08/07/23 Page 3 of 3 +Suspicious Activity Reporting — Overview +Suspicious Activity Reporting — Overview +Objective. Assess the bank's policies, procedures, and processes, and overall +compliance with statutory and regulatory requirements for monitoring, detecting, and +reporting suspicious activities. +Suspicious activity reporting forms the cornerstone of the BSA reporting system. It is +critical to the United States' ability to utilize financial information to combat terrorism, +terrorist financing, money laundering, and other financial crimes. Within this system, +FinCEN and the federal banking agencies recognize that, as a practical matter, it is not +possible for a bank to detect and report all potentially illicit transactions that flow through +the bank. Examiners should focus on evaluating a bank's policies, procedures, and +processes to identify and research suspicious activity. However, as part of the +examination process, examiners should review individual Suspicious Activity Report +(SAR) filing decisions to determine the effectiveness of the suspicious activity +monitoring and reporting process. Above all, examiners and banks should recognize that +the quality of SAR data is paramount to the effective implementation of the suspicious +activity reporting system. +Banks, bank holding companies, and their subsidiaries are required by federal +regulations to file a SAR with respect to: +• Criminal violations involving insider abuse in any amount. +• Criminal violations aggregating $5,000 or more when a suspect can be identified. +• Criminal violations aggregating $25,000 or more regardless of a potential suspect. +• Transactions conducted or attempted by, at, or through the bank (or an affiliate) and +aggregating $5,000 or more, if the bank or affiliate knows, suspects, or has reason to +suspect that the transaction: +• May involve potential money laundering or other illegal activity (e.g., terrorism +financing). +• Is designed to evade the BSA or its implementing regulations." +• Has no business or apparent lawful purpose or is not the type of transaction that +the particular customer would normally be expected to engage in, and the bank +* See 12 CFR 208.62, 211.5(k), 211.24(f), and 225.4(f (Board of Governors of the Federal Reserve +System); 12 CFR 353 (Federal Deposit Insurance Corporation); 12 CFR 748 (National Credit Union +Administration); 12 CFR 21.11 (Office of the Comptroller of the Currency; 12 CFR 563.180 (Office of +Thrift Supervision) (does not apply to Savings and Loan Holding Companies); and 31 CFR 103.18 +(FinCEN). +' Refer to Appendix G ("Structuring") for additional guidance. +FFIEC BSA/AML Examination Manual +60 +7/28/2006 diff --git a/vision-fixhub/court-05/62970e4de10ea2f18786a7ff5d8d7235ec5ee45c7e6adf6b13797bbfa1efb2eb.receipt.json b/vision-fixhub/court-05/62970e4de10ea2f18786a7ff5d8d7235ec5ee45c7e6adf6b13797bbfa1efb2eb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..767d75cd62e9f052daa241bae5a1f27b40d839ab --- /dev/null +++ b/vision-fixhub/court-05/62970e4de10ea2f18786a7ff5d8d7235ec5ee45c7e6adf6b13797bbfa1efb2eb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -52, + "dataset": "marble-joined", + "doc_id": "62970e4de10ea2f18786a7ff5d8d7235ec5ee45c7e6adf6b13797bbfa1efb2eb", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "b7c30cf2337db4838e052b79532e62f93cbbda62eb88e219bbc61f38402cbc87", + "output_sha256": "115d114a9aea502f58b3398e56fea6b49318dfc98b0ab4ab0180e05ebe7872dd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/62aa014c8ded57ddbde5cef0a28f6f9c1463f4bfdbe59add739fca8b6a4e3162.md b/vision-fixhub/court-05/62aa014c8ded57ddbde5cef0a28f6f9c1463f4bfdbe59add739fca8b6a4e3162.md new file mode 100644 index 0000000000000000000000000000000000000000..6ef19a6e81e13d956682395d881fb2318db457be --- /dev/null +++ b/vision-fixhub/court-05/62aa014c8ded57ddbde5cef0a28f6f9c1463f4bfdbe59add739fca8b6a4e3162.md @@ -0,0 +1,56 @@ +Case 1:22-cV-10904-JSR Document 285-64 Filed 08/15/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 285-64 Filed 08/15/23 Page 2 of 3 +From: +Sent: +To: +Subject: +mahmoud.difrawy@jpmorgan.com [mahmoud.difrawy@jpmorgan.com] +2/15/2006 10:16:05 AM +jes.staley@jpmorgan.com +Re: J.Epstein +Hi Jes, +We would certainly like to meet with Sultan privately and it would be nice if he could organise meetings with 2 of his +colleagues...1)Mohammed Al Gergawi, Chairman Dubai Holding;2)Muhammad Al Abbar, Chairman Emaar. +Sultan,Muhammad and Mohammed are the 3 lieutenants to HH Sheikh Mohammed bin Rashid Al Maktoum, the ruler of +Dubai. They are the three that executed his vision about the development of Dubai to rival Singapore and Hong Kong as +an offshore business and tourist destination. +We will fix other meetings around them. +Mahmoud Difrawy +JPMorgan Private Bank +Tel. +44 (0)207 777 4995 +Fax. +44 (0)207 777 0854 +Jes Staley +Jes Staley To: Mahmoud Difrawy/JPMCHASE@JPMCHASE +14/02/2006/cc: +20:45 +Subject: Re: J.Epstein {doclink : document = '53587C3ADAEFB6388525710F0071052E' view = +(5E502A1BAAAF40CA85256197006C1A32' database = 4225608F0033B810° } +Mahmoud: What should I say to the Sultan? +Thanks, +Jes + +JPM-SDNYLIT-00449037 + + +Case 1:22-cV-10904-JSR Document 285-64 Filed 08/15/23 Page 3 of 3 +To: jes.staley@jpmorgan.com +02/08/2006 03:33 PM +Please respond to +CC: +Subject: J.Epstein +Hi Jes.. It's +Jeffrey Epstein's assistant. Jeffrey had me email the Sultan of +Dubai +and +ask if he could meet with +you while you are in Dubai. He said March 16th would +work for him and asked if you could email him directly. Here is his email: +HEs E011 name 1s: Sultan Ahmed Bin Sulayen. +His titles are Chairman of Dubai Ports and Free Zone Corporation, or Chairman +Corporate Office or Chairman of Nakheel +We just call him Sultan... +Please let me know if you need any more info. and could you please confirm you received +this email as I've been having some trouble with some of my emails going through. Thanks! diff --git a/vision-fixhub/court-05/62aa014c8ded57ddbde5cef0a28f6f9c1463f4bfdbe59add739fca8b6a4e3162.receipt.json b/vision-fixhub/court-05/62aa014c8ded57ddbde5cef0a28f6f9c1463f4bfdbe59add739fca8b6a4e3162.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..032b7d9951cb6e0591f437a166d67c91254b31e5 --- /dev/null +++ b/vision-fixhub/court-05/62aa014c8ded57ddbde5cef0a28f6f9c1463f4bfdbe59add739fca8b6a4e3162.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -59, + "dataset": "marble-joined", + "doc_id": "62aa014c8ded57ddbde5cef0a28f6f9c1463f4bfdbe59add739fca8b6a4e3162", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "31a7ec1a7099f33c81a1d69192d87820cc7a6635bb55faa6f10ba2b296f9e278", + "output_sha256": "26be978482dd3990eaf9a67ad271ccc4390c9ccc5dd52a3eafaec11232d421ec", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/62b49db511c92999afac95703a50266458642c1c9c7463022553d2bef15749a6.md b/vision-fixhub/court-05/62b49db511c92999afac95703a50266458642c1c9c7463022553d2bef15749a6.md new file mode 100644 index 0000000000000000000000000000000000000000..20497a7707379f08704927c6fbc6c51c9dcdd862 --- /dev/null +++ b/vision-fixhub/court-05/62b49db511c92999afac95703a50266458642c1c9c7463022553d2bef15749a6.md @@ -0,0 +1,346 @@ +Case 1:22-cv-10904-JSR Document 284-7 Filed 08/14/23 Page 1 of 6 + +FILED UNDER SEAL + + +Case 1:22-cv-10904-JSR Document 284-7 Filed 08/14/23 Page 2 of 6 +Page 1 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-------- - - - +- +JANE DOE 1, individually and on +behalf of all others similarly +situated, +09:09:27 +- X +Plaintiff, +Case No. +1:22-cv-10019-JSR +-against- +JPMORGAN Chase BANK NA, +Defendants. +--- +- +--- +- - X + +Videotaped oral deposition of +Richard Kahn taken pursuant to notice, +was held REMOTELY, commencing May 18, +2023, 9:21 a.m., on the above date, +before Leslie Fagin, a Court Reporter +and Notary Public in the State of New +York. +MAGNA LEGAL SERVICES +(866) +624-6221 +www.Magnals.com + + +Case 1:22-CV-10904-JSR Document 284-7 Filed 08/14/23 Page 3 of 6 +Page 75 +1 +R. Kahn +2 +accounts at JPMorgan? +3 +A. I was not that involved in the cash +4 +withdrawal process. I believe it was +5 +that was requesting it; potentially Harry was +going to get it from the bank. +7 +But I do recall there was a certain +8 +period of time when I first started that +9 there were large withdrawals of cash, and +10 +that was because the pilots were requesting +11 +cash because they were able to negotiate +12 favorable rates from the fuel provider when +13 +they would take long trips, they would get a +14 +better rate if they paid with cash. +15 +So there were larger withdrawals +16 +because I think at that time jet fuel was 6- +17 +or $7 per gallon, and the plane could hold 6- +18 to 8,000 gallons, you know, it was a large +19 +20 +21 +22 +amount that was being paid for fuel. +Q. Which pilots were requesting cash? +A. I don't recall which ones, but I +believe the pilots at the time were Larry +23 +24 +25 +Visoski, Dave Rogers, and Bill Hammond. +Q. And you think it was Visoski, +Rogers, or Hammond that were requesting cash? +10:46:23 +10:46:25 +10:46:30 +10:46:33 +10:46:37 +10:46:41 +10:46:44 +10:46:48 +10:46:54 +10:46:59 +10:47:04 +10:47:08 +10:47:11 +10:47:14 +10:47:17 +10:47:22 +10:47:26 +10:47:29 +10:47:30 +10:47:34 +10:47:37 +10:47:40 +10:47:46 +10:47:49 + + +Case 1:22-CV-10904-JSR Document 284-7 Filed 08/14/23 Page 4 of 6 +Page 105 +1 +R. Kahn +2 +to that entity. +3 +O. What was the plane entity, +4 +Hyperion, Inc.? +5 +A. +Hyperion was one of the plane +6 +entities, and I believe JEGE, Inc. was the +7 +other. +8 +Q. And when we are talking about cash +9 that is paid for fuel, are you saying cash +10 being wire transferred to a fuel company, or +11 +are you saying cash being -- somebody goes to +12 the teller, withdraws cash money -- +13 +A. Correct. +14 +-- and then hands that for fuel? +15 +MS. ELLSWORTH: Object to form. +16 +17 +18 +19 +A. +Correct. +MS. ELLSWORTH: I'm not sure what +cash you are using in this context. +MR. +I'm having the same +20 +21 +22 +problem. +e. So what do you mean by cash? +A. +My understanding of cash is +23 +bills. +24 +Okay. +25 +A. +Not a wire or a check or not a +11:27:01 +11:27:02 +11:27:06 +11:27:06 +11:27:08 +11:27:12 +11:27:12 +11:27:14 +11:27:20 +11:27:24 +11:27:28 +11:27:28 +11:27:30 +11:27:32 +11:27:33 +11:27:34 +11:27:37 +11:27:39 +11:27:40 +11:27:40 +11:27:41 +11:27:44 +11:27:46 +11:27:46 + + +Case 1:22-cv-10904-JSR Document 284-7 Filed 08/14/23 Page 5 of 6 +Page 109 +1 +R. Kahn +2 +money by wire to them, why would it make any 11:32:00 +3 +difference whether this is in +bills or +11:32:03 +4 +-- they're still receiving the money? +11:32:08 +5 +A. +To answer your question, I think +11:32:10 +6 +what you are asking why in some circumstances +11:32:12 +7 +did we pay credit card, cash, or wire, and my 11:32:14 +8 +answer for that is kind of something that we +11:32:18 +9 applied with all vendors, not just fuel. We +11:32:20 +10 +were always trying to get the best prices, +11:32:23 +11 +whether it was fuel, +whether it was an +11:32:25 +12 architect, purchasing pretty much whatever it| +11:32:27 +13 +was. So we would normally go where the best +11:32:30 +14 +deal was. +11:32:33 +15 +So in the circumstance where +11:32:34 +16 Mr. Epstein used +bills cash, I believe +11:32:37 +17 that was a New York vendor, and I believe it +11:32:40 +18 was JFK Airport, but I'm not 100 percent +11:32:42 +19 +20 +21 +22 +sure. +11:32:47 +In this example here, on the +11:32:47 +exhibit, Exhibit 4, the last page, we were +11:32:48 +able to get the best pricing by prepaying and +11:32:51 +23 buying the fuel in bulk. +11:32:54 +24 +25 +So we didn't discriminate against +using cash, credit card, or wire. We were +11:32:56 +11:32:58 + + +Case 1:22-CV-10904-JSR Document 284-7 Filed 08/14/23 Page 6 of 6 +Page 110 +1 +R. Kahn +2 +seeking the best pricing. +3 +l. But by this point in time that we +4 +are looking at, 2012, that's long after the +5 +time period where you were using +bills +6 +to pay for case -- I mean to pay for fuel? +7 +A. +I only remember a short window of +8 +time that we paid cash +for fuel. +9 +e. And that short window being before +10 +the time period Jeffrey Epstein went to jail +11 +in Florida; meaning, early in your +12 relationship? +13 +A. Correct. +14 +l. And during that period of time +15 +where you would have used cash, would that +16 +money have come from the -- from your office, +17 / +picked up by Larry Visoski, and taken to +18 whoever the vendor was for fuel? +19 +MS. ELLSWORTH: Object to form. +20 +21 +22 +A. +Yes. At the time New York Strategy +Group would have been the office that larry +came to and collected the cash, correct. +23 +24 +25 +Q. And would you have had receipts for +that fuel? +A. We wouldn't have them at the time +11:33:00 +11:33:01 +11:33:04 +11:33:06 +11:33:08 +11:33:11 +11:33:14 +11:33:16 +11:33:17 +11:33:19 +11:33:22 +11:33:23 +11:33:24 +11:33:26 +11:33:30 +11:33:35 +11:33:38 +11:33:41 +11:33:43 +11:33:48 +11:33:51 +11:33:53 +11:33:55 +11:33:57 \ No newline at end of file diff --git a/vision-fixhub/court-05/62b49db511c92999afac95703a50266458642c1c9c7463022553d2bef15749a6.receipt.json b/vision-fixhub/court-05/62b49db511c92999afac95703a50266458642c1c9c7463022553d2bef15749a6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e25c92b41dfb123303649df38d21668f8a4ff393 --- /dev/null +++ b/vision-fixhub/court-05/62b49db511c92999afac95703a50266458642c1c9c7463022553d2bef15749a6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -207, + "dataset": "marble-joined", + "doc_id": "62b49db511c92999afac95703a50266458642c1c9c7463022553d2bef15749a6", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "8ed7cad0f20f13b812dc19f7a70c1159814cb48edb9eed928356eaab5a688150", + "output_sha256": "4b63eeec05544783d5e0d52e6691f38154310e36009065301b2d3bf27a8417ce", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/62bb20664c8d81ef76643e1b7034f55954ad79e57b1f0d41bf4bc43224835a73.md b/vision-fixhub/court-05/62bb20664c8d81ef76643e1b7034f55954ad79e57b1f0d41bf4bc43224835a73.md new file mode 100644 index 0000000000000000000000000000000000000000..a59db13ba540626044c1670cc0107a122dc0c8a5 --- /dev/null +++ b/vision-fixhub/court-05/62bb20664c8d81ef76643e1b7034f55954ad79e57b1f0d41bf4bc43224835a73.md @@ -0,0 +1,29 @@ +Case 1:22-cv-10904-JSR Document 284-13 Filed 08/14/23 + + +FILED UNDER SEAL + + +Case 1:22-cV-10904-JSR Document 284-13 Filed 08/14/23 Page 2 of 2 +Date : 6/23/2014 4:16:52 PM +From: "Cecile de Jongh" +To : "Erika Kellerhals" +Subject : Re: help!! +I asked him already. +With warm regards, +Cecile +Sent from my iPhone and misspellings courtesy of iPhone. +On Jun 23, 2014, at 504 PM, Enka Kellerhal - +I need to raise S20K by Wednesday for Stacey. Think I can ask JEE? Anyone eke you can think of? +Erika A. Kellerhals +Member +Kellerhals Ferguson Kroblin PLLC +Tel: +Fax: +email: +Nocice: This communication may contain proleged or other condolencial information. If you are noe the intended socipient, or believe that you have seccived this communiion in enor, please do not print, copy, re-transmit, +disseminate, or otherw be use this informator. Abo, please incheate bo the serader that you hine roodved this e-mall in enor, a delete the copy you rocched. Thank you. +Cular 230; To ensure complonce with the requirements imposed by the IRS, we infom you that any tas advice contained in our communication Oncluding any attaches) was not intended or writtes to be used, and +cannot be used, for the purpose of 0 ankling any tax penalty ce (g) promoring, marketing or neermerling to another party any transaction or matter acknessed herin + +ESTATE_JPM059741 diff --git a/vision-fixhub/court-05/62bb20664c8d81ef76643e1b7034f55954ad79e57b1f0d41bf4bc43224835a73.receipt.json b/vision-fixhub/court-05/62bb20664c8d81ef76643e1b7034f55954ad79e57b1f0d41bf4bc43224835a73.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a8b981c6fb01aa25c0e8133d50d886503bb29e74 --- /dev/null +++ b/vision-fixhub/court-05/62bb20664c8d81ef76643e1b7034f55954ad79e57b1f0d41bf4bc43224835a73.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -58, + "dataset": "marble-joined", + "doc_id": "62bb20664c8d81ef76643e1b7034f55954ad79e57b1f0d41bf4bc43224835a73", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "873c59198c4d241866f63063dde82d323101691b7feeec511c44b97f2882ce10", + "output_sha256": "86a3113e3cad06be3cb76bb27c20d9a68fc097b80a5cfeaaa469632b45662745", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/62f593b5d72c527ae5b8c9174971f1448c7c84fbcfe38709446d2f21687c68ae.md b/vision-fixhub/court-05/62f593b5d72c527ae5b8c9174971f1448c7c84fbcfe38709446d2f21687c68ae.md new file mode 100644 index 0000000000000000000000000000000000000000..59c355c82f5f00514f2f82939d6d2429638ef43f --- /dev/null +++ b/vision-fixhub/court-05/62f593b5d72c527ae5b8c9174971f1448c7c84fbcfe38709446d2f21687c68ae.md @@ -0,0 +1,34 @@ +Case 1:22-cv-10904-JSR Document 132-3 Filed 05/04/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 132-3 Filed 05/04/23 Page 2 of 3 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +Case No. 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A., +Defendant. +DECLARATION OF MIMI LIU, ESQ. IN SUPPORT OF +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +MOTION FOR ORDER AUTHORIZING ALTERNATIVE SERVICE +OF SUBPOENA FOR THIRD PARTY LARRY PAGE +I, Mimi Liu, declare in support of Plaintiff, the Government of the United States Virgin +Islands' ("the Government"), Motion for Order Authorizing Alternative Service of Subpoena for +Third Party Larry Page as follows: +I am an attorney with Motley Rice LLC, counsel for the Government, and am +admitted to practice in the above-captioned matter. +Motley Rice hired the investigative firm Gryphon Strategies to search public +records databases for an address for Larry Page. +Motley Rice's process server attempted service at two addresses that Gryphon +Strategies identified, but they were not valid addresses for Mr. Page. +I declare under penalty of perjury under the laws of the United States that the foregoing is +true and correct. + + +Case 1:22-cv-10904-JSR Document 132-3 Filed 05/04/23 Page 3 of 3 +Executed this 4th day of May 2023 at Washington, D.C. +2 diff --git a/vision-fixhub/court-05/62f593b5d72c527ae5b8c9174971f1448c7c84fbcfe38709446d2f21687c68ae.receipt.json b/vision-fixhub/court-05/62f593b5d72c527ae5b8c9174971f1448c7c84fbcfe38709446d2f21687c68ae.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..93e3e70235796bd162b1bbbab22bbe3a653a058d --- /dev/null +++ b/vision-fixhub/court-05/62f593b5d72c527ae5b8c9174971f1448c7c84fbcfe38709446d2f21687c68ae.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -45, + "dataset": "marble-joined", + "doc_id": "62f593b5d72c527ae5b8c9174971f1448c7c84fbcfe38709446d2f21687c68ae", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "2d1d7e3ca78e0708d4e0024110a1b589a90111ae69dc300e158b35b1ea2dc5d0", + "output_sha256": "a29dfcbb8b237566b0c843f04211160082f05a8127ba1f227e37f198ea10ae07", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6308a6e1ae99a468ac9a660a67ade3510b7d353d237d13b984897706902e7b79.md b/vision-fixhub/court-05/6308a6e1ae99a468ac9a660a67ade3510b7d353d237d13b984897706902e7b79.md new file mode 100644 index 0000000000000000000000000000000000000000..56c996e436e42ee0b9ee6a5de59a3782058bdd7c --- /dev/null +++ b/vision-fixhub/court-05/6308a6e1ae99a468ac9a660a67ade3510b7d353d237d13b984897706902e7b79.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 158-70 Filed 05/23/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6308a6e1ae99a468ac9a660a67ade3510b7d353d237d13b984897706902e7b79.receipt.json b/vision-fixhub/court-05/6308a6e1ae99a468ac9a660a67ade3510b7d353d237d13b984897706902e7b79.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..40332a80d36350cad7144ba848b7cc85a8f48e4f --- /dev/null +++ b/vision-fixhub/court-05/6308a6e1ae99a468ac9a660a67ade3510b7d353d237d13b984897706902e7b79.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "6308a6e1ae99a468ac9a660a67ade3510b7d353d237d13b984897706902e7b79", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "12448e6ac7a5d1b61a4ff85b07d77e0f383ca2a1dab2a4b8f4fc019815ea31d1", + "output_sha256": "6e23d83d085bc959e50ffe9efcfc068c3cf7f09f3db7e65c912519b6058e64b7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/63152a8a391dab720bae66f28e25075f1c2cd0ee92000c0e63cb4c141f2161d3.md b/vision-fixhub/court-05/63152a8a391dab720bae66f28e25075f1c2cd0ee92000c0e63cb4c141f2161d3.md new file mode 100644 index 0000000000000000000000000000000000000000..899869a4bcc1e8a8476d5bcad707b8457e3c7bbf --- /dev/null +++ b/vision-fixhub/court-05/63152a8a391dab720bae66f28e25075f1c2cd0ee92000c0e63cb4c141f2161d3.md @@ -0,0 +1,82 @@ +Case 1:22-cv-10904-JSR Document 290 Filed 08/18/23 Page 1 of 3 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +V. +Case Number: 1:22-cv-10904-JSR +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +V. +JAMES EDWARD STALEY +Third-Party Defendant. +DECLARATION OF DAVID I. ACKERMAN IN SUPPORT OF THE +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +MOTION TO EXCLUDE EXPERT OPINIONS OF KIMBERLY +MEHLMAN-OROZCO, +FONSECA, AND CARLYN IRWIN +Pursuant to 28 U.S.C. § 1746, I, David I. Ackerman, declare under penalty of perjury as +follows: +I am a member in good standing of the bars of the State of New York, the State of +New Jersey, and the District of Columbia, and am admitted to practice before this Court. I am one +of the attorneys representing the Government of the United States Virgin Islands in the abovecaptioned action. I am a Member of the law firm of Motley Rice LLC, and my office is located at +401 9th Street NW, Suite 630, Washington, DC 20004. I am familiar with the facts set forth herein + + +Case 1:22-cv-10904-JSR Document 290 Filed 08/18/23 Page 2 of 3 +and if called as a witness, I could and would competently testify thereto. I submit this Declaration +and the attached Exhibits in support of United States Virgin Islands' Motion to Exclude Defendant +JPMorgan Chase's Expert Opinions of Kimberly Mehlman-Orozco, [ +Fonseca, and Carlyn +Irwin. +Attached hereto are true and correct copies of the following: + +Number + +Description + + + + + +Copy of the Expert Report of Dr. Kimberly Mehlman-Orozco, submitted on +June 23, 2023, in this action. [portions designated confidential are redacted and +filed under seal] +Excerpts from the transcript of the Deposition of Dr. Kimberly Mehlman- +Orozco, taken on June 30, 2023, in this action. [portions designated confidential +are redacted and filed under seal] +Screenshots from the Wayback Machine Archive reflecting the following web +pages as they are asserted to have appeared on May 12, 2015: +http://justitiainstitute.org/about/products; http://justitiainstitute.org/work; +and http://justitiainstitute.org/media/in-the-news. +Copy of the Expert Report of +Fonseca, submitted on June 23, 2023, in +this action. [portions designated confidential are redacted and filed under seal] +Excerpts from the transcript of the Deposition of | +Fonseca, taken July 6, +2023, in this action. +Copy of the Curriculum Vitae of Carlyn Irwin, submitted on July 6, 2023, In +this action. + + +Copy of the Expert Report of Carlyn Irwin, submitted on June 23, 2023, in +this action. +Excerpts from the transcript of the Deposition of Carlyn Irwin, taken on July +6, 2023, in this action. +The screenshots collected as Exhibit 3 were created using the Wayback Machine, +an "online digital archive of web pages—'a digital library of Internet sites' —run by the Internet +Archive, a nonprofit library in San Francisco." Thorne v. Square, Inc., 2022 WL 542383, at *1 n.2 +(E.D.N.Y. Feb. 23, 2022) (taking judicial notice of materials taken from the Wayback Machine +and collecting cases). +2 + + +Case 1:22-cv-10904-JSR Document 290 Filed 08/18/23 Page 3 of 3 +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true +and correct. +Dated: August 18, 2023 +David I. Ackerman +3 diff --git a/vision-fixhub/court-05/63152a8a391dab720bae66f28e25075f1c2cd0ee92000c0e63cb4c141f2161d3.receipt.json b/vision-fixhub/court-05/63152a8a391dab720bae66f28e25075f1c2cd0ee92000c0e63cb4c141f2161d3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6b164835d6b62da7dab7a0238cee8a64483db47a --- /dev/null +++ b/vision-fixhub/court-05/63152a8a391dab720bae66f28e25075f1c2cd0ee92000c0e63cb4c141f2161d3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -117, + "dataset": "marble-joined", + "doc_id": "63152a8a391dab720bae66f28e25075f1c2cd0ee92000c0e63cb4c141f2161d3", + "engine": "marble-apple-vision", + "event_count": 13, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "8f3a432dfc2da40c0dc99d26931b85cf78672084bd693251c37a9d58cb0bb310", + "output_sha256": "895c23320aca89d6bbf6c7fd370195f5823df6b5387576698d9dd445d4c32e18", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/633e4f8811a52a586ce66ec31c2cb834ae6d7f251492f9d7e147b096d2c8bd34.md b/vision-fixhub/court-05/633e4f8811a52a586ce66ec31c2cb834ae6d7f251492f9d7e147b096d2c8bd34.md new file mode 100644 index 0000000000000000000000000000000000000000..e2ed0744835de2031065468de7f0abf1bd1689a5 --- /dev/null +++ b/vision-fixhub/court-05/633e4f8811a52a586ce66ec31c2cb834ae6d7f251492f9d7e147b096d2c8bd34.md @@ -0,0 +1,30 @@ +Case 1:22-cv-10904-JSR Document 42 Filed 02/03/23 Page 1 of 1 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiffs, +Case No. 22-cv-10904-JSR +MOTION FOR ADMISSION +PRO HAC VICE +JPMORGAN CHASE BANK, N.A., +Defendant. +Pursuant to Rule 1.3(c) of the Local Rules of the United States District Courts for the +Southern and Eastern Districts of New York, 1, Rachel S. Morse, hereby move this Court for an +Order for admission to practice Pro Hac Vice to appear as counsel for Defendant JPMorgan Chase +Bank, N.A. in the above-captioned action. +I am in good standing with the bar of Illinois and there are no disciplinary proceedings +against me in any state or federal court. I have never been convicted of a felony. I have never +been censured, suspended, disbarred or denied admission or readmission by any court. I have +attached the affidavit pursuant to Local Rule 1.3. +Dated: February 3, 2023 +Respectfully submitted, +/s/ Rachel S. Morse +Rachel S. Morse +MASSEY & GAIL LLP +50 East Washington Street, Suite 400 +Chicago, IL 60602 +Tel.: (312) 283-1590 +rmorse@masseygail.com +Attorney for Defendant JPMorgan +Chase Bank, N.A. diff --git a/vision-fixhub/court-05/633e4f8811a52a586ce66ec31c2cb834ae6d7f251492f9d7e147b096d2c8bd34.receipt.json b/vision-fixhub/court-05/633e4f8811a52a586ce66ec31c2cb834ae6d7f251492f9d7e147b096d2c8bd34.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7a133be7ab66a447c1fe6ed7847069c2a0b11de8 --- /dev/null +++ b/vision-fixhub/court-05/633e4f8811a52a586ce66ec31c2cb834ae6d7f251492f9d7e147b096d2c8bd34.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "633e4f8811a52a586ce66ec31c2cb834ae6d7f251492f9d7e147b096d2c8bd34", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "fb89cf9e3630a4deaf8b8911c4031756f8702ee0347b6f39ac184dc68a9cafb8", + "output_sha256": "ba0402bb5be11aa7e25fbd297634d7f3f6eeee78a095ce4e04610a731efe4bb1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/634fc919355dd9eaf701c3e3de06c1dd4721c186751293637b1ad1667440c84b.md b/vision-fixhub/court-05/634fc919355dd9eaf701c3e3de06c1dd4721c186751293637b1ad1667440c84b.md new file mode 100644 index 0000000000000000000000000000000000000000..f9bfb82738a56c00c4d8bbad187c10d02397f1e7 --- /dev/null +++ b/vision-fixhub/court-05/634fc919355dd9eaf701c3e3de06c1dd4721c186751293637b1ad1667440c84b.md @@ -0,0 +1,37 @@ +Casse1122201D9904155R Document 11153 FfleeD02103223 Faagel0622 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiffs, +Case No. 22-cv-10904-JSR +[PROPOSED| ORDER FOR +ADMISSION PRO HAC VICE +V. +JPMORGAN CHASE BANK, N.A., +Defendant. +The motion of Leonard A. Gail for admission to practice pro hac vice in the abovecaptioned action is granted. +Applicant has declared that he is a member in good standing of the bar of the state of +Illinois, and that his contact information is as follows: +Massey & Gail LLP +50 East Washington Street, Suite 400 +Chicago, IL 60602 +Tel.: (312) 283-1590 +lgail@masseygail.com +Applicant having requested admission pro hac vice to appear for all purposes as counsel +for Defendant JPMorgan Chase Bank, N.A. in the above-captioned action, +IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the +above-captioned case in the United States District Court for the Southern District of New +York. + + +Casse1122201D9904155R Documeet 1153 FreekD02103233 Fagge220622 +All attorneys appearing before this Court are subject to the Local Rules of this Court, +including the Rules governing discipline of attorneys. +Dated: February 10 +-, 2023 +New York, NY +Jed S. Rakoff +The Honorabde Jed S. Rakoff +United States District Judge +2 diff --git a/vision-fixhub/court-05/634fc919355dd9eaf701c3e3de06c1dd4721c186751293637b1ad1667440c84b.receipt.json b/vision-fixhub/court-05/634fc919355dd9eaf701c3e3de06c1dd4721c186751293637b1ad1667440c84b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a3a3d3ae31780a5ec26ca5799bffc0ebd58b6178 --- /dev/null +++ b/vision-fixhub/court-05/634fc919355dd9eaf701c3e3de06c1dd4721c186751293637b1ad1667440c84b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "634fc919355dd9eaf701c3e3de06c1dd4721c186751293637b1ad1667440c84b", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "1086704e5f8a3b23179605db4ddd38306a146ac2240a07def64004e22b2c6eac", + "output_sha256": "0f97e248abbebb3f2c7db113b48e12d8ef394529cc09d0e0648973efaef154d0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/636da4a68967e8e58e396140b6b2ffd7792d62faf7ab704983f82664bc8eb8e3.md b/vision-fixhub/court-05/636da4a68967e8e58e396140b6b2ffd7792d62faf7ab704983f82664bc8eb8e3.md new file mode 100644 index 0000000000000000000000000000000000000000..ac5bee313df6b646850dd1281434d5f10da53d7b --- /dev/null +++ b/vision-fixhub/court-05/636da4a68967e8e58e396140b6b2ffd7792d62faf7ab704983f82664bc8eb8e3.md @@ -0,0 +1,96 @@ +Case 1:22-cv-10904-JSR Document 28 Filed 01/20/23 Page 1 of 3 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +MOTION FOR ISSUANCE OF LETTER OF REQUEST (LETTER ROGATORY) +NOW COMES, the Plaintiff, in the above referenced action, and moves for the Issuance of +a Letter of Request (Letter Rogatory) pursuant to F.R.C.P. 28 requesting an order requiring Miles +Alexander, located at 7 Harmonie Crescent, Paradise Beach, Jeffreys Bay 6330, South Africa, to +do the following: +(a) Appear to have his remote deposition taken on a date to be agreed within 30 days of service +of the subpoena at a mutually convenient location in or near Jeffreys Bay; and +(b) Produce all Documents, Communications, and agreements related to his employment by +Jeffrey Epstein, including: +1. Employment and | +agreements, +2. Non-disclosure agreements, +3. All payments, in any form, received from or on behalf of Jeffrey Epstein, and +4. Along tiner. Letty Forcin Chilaine Maxwell. Bella Kien. Daphne +Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. +1 + + +Case 1:22-cv-10904-JSR Document 28 Filed 01/20/23 Page 2 of 3 +As grounds for this Motion, the Plaintiff states the following: +1. The above captioned case is currently pending in the United States District Court for +the Southern District of New York. +2. Plaintiff alleges decedent Jeffrey E. Epstein ("Epstein") engaged in a criminal sexual +trafficking enterprise in the United States Virgin Islands, wherein he used his vast +wealth and property holdings and a deliberately opaque web of corporations and +companies to transport young women and girls to his privately owned islands where +they were held captive and subject to severe and extensive sexual abuse. Plaintiff +further alleges that Defendant JPMorgan Chase Bank, N.A. and its affiliates had actual +or constructive knowledge of Epstein's misconduct but nevertheless violated their +statutory duties to report suspicious transactions from accounts held by them. +3. Upon information and belief, Miles Alexander was employed by decedent Epstein as +the house manager for his residence on Little St. James from approximately 1999 to +2007, and, as such, would have first-hand knowledge of Epstein's conduct and visitors +at Little St. James. +4. In order to prepare the case for trial, Plaintiff needs to the take the deposition of Miles +Alexander. +WHEREFORE Plaintiff respectfully requests that this Honorable Court allow this Motion +and issue a Letter of Request (Letter Rogatory). A proposed Letter of Request (Letter Rogatory) +is attached to this Motion as Exhibit 1. +Dated: January 20, 2023 +CAROL +1, ESQ. +ACTING ATTORNEY GENERAL +Is/Linda +LINDA +2 +(NYS Bar #2473403) + + +Case 1:22-cv-10904-JSR Document 28 Filed 01/20/23 Page 3 of 3 +Admitted Pro Hac Vice +Motley Rice LLC +401 gth Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Isinger@motleyrice.com +CAROL +(NYS Bar #2941300) +Admitted Pro Hac Vice +Acting Attorney General of the United States +Virgin Islands +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +St. +_. U.S. Virgin Islands 00802 +Tel.: (340) 774-5666 ext. 10101 +DAVID I. ACKERMAN (NYS Bar #4110839) +Motley Rice LLC +401 9* Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 849-4962 +dackerman@motleyrice.com +PAIGE BOGGS +Molley die Hac Vice +401 9* Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 386-9629 +pboggs@motleyrice.com +CERTIFICATE OF SERVICE +I hereby certify that on January 20, 2023, the foregoing Plaintiff's Motion for Issuance of +Letter of Request (Letter Rogatory) was filed with the Clerk's Office using the CM/ECF system. +Notice of this filing will be sent to all parties of record by operation of, and parties may access this +filing through, the Court's CM/ECF system. +/s/Linda +Linda +3 diff --git a/vision-fixhub/court-05/636da4a68967e8e58e396140b6b2ffd7792d62faf7ab704983f82664bc8eb8e3.receipt.json b/vision-fixhub/court-05/636da4a68967e8e58e396140b6b2ffd7792d62faf7ab704983f82664bc8eb8e3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ba6129a2b2a4cbc49149e7a4161e485f9b37fa7a --- /dev/null +++ b/vision-fixhub/court-05/636da4a68967e8e58e396140b6b2ffd7792d62faf7ab704983f82664bc8eb8e3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "636da4a68967e8e58e396140b6b2ffd7792d62faf7ab704983f82664bc8eb8e3", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "9b2a53015095aa696caae6e1fd91e87646a0c2df45b24ac8f83ba7810f72aa00", + "output_sha256": "4d2dc15ccbfc2db72a80568b1973da03d97da75bc416dfac6fabad287d2fe097", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/63da8657b934a96b58b2492f3f589b2e6850c25e84626e5092983571f3540ae6.md b/vision-fixhub/court-05/63da8657b934a96b58b2492f3f589b2e6850c25e84626e5092983571f3540ae6.md new file mode 100644 index 0000000000000000000000000000000000000000..a3d2c52efc88446e25d8993ecaf912f5d5119fba --- /dev/null +++ b/vision-fixhub/court-05/63da8657b934a96b58b2492f3f589b2e6850c25e84626e5092983571f3540ae6.md @@ -0,0 +1,42 @@ +Case 1:22-cV-10904-JSR Document 242-13 Filed 07/25/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 242-13 Filed 07/25/23 Page 2 of 2 +From: +To: +Sent: +Subject: +Attachments: +jes.staley@ipmorgan.com +rosa.m.dasilva@jpmorgan.com +1/23/20086:09:28 PM +Re: Jeffrey Epstein +pic14867.gif +Go through Jamie's office. +Rosa M da Silva +-- Original Message ---- +From: Rosa M da Silva +Sent: 01/23/2008 12:53 FM EST +To: Jes Staley +Subject: Fw: Jeffrey Epstein +Jes: Is it OK for me to contact Ehud Barak directly to arrange a mtg with Jamie? Thanks, Rosa +--- Forwarded by Rosa M da Silva/JPMCHASE on 01/23/2008 12:51 PM -••• +"Lesley Groff" +To +01/23/2008 12:44 PM +SubjectJeffrey Epstein +Hello Rosa..1 think +talking to me on the phone and to +us was to actually email you!) +might have already emailed you, but wanted to follow up just in case (Jeffrey was +who was standing with him at the same time... so not sure which one of +Jeffrey requested that we give you the contact email for Ehud Barak so that you can organize the meeting with +Jamie Diamond and Barak on your end for simplification. Nili handles Mr. Barak's itinerary. (She is his life +partner'-I'm guessing like a wife, but not married??!) Her email address is: +Thanks Rosa, +LEsley + + +113 +JPM-SDNYLIT-00002152 diff --git a/vision-fixhub/court-05/63da8657b934a96b58b2492f3f589b2e6850c25e84626e5092983571f3540ae6.receipt.json b/vision-fixhub/court-05/63da8657b934a96b58b2492f3f589b2e6850c25e84626e5092983571f3540ae6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..970b29ac13cec25542fb67662ca9aa047bad7787 --- /dev/null +++ b/vision-fixhub/court-05/63da8657b934a96b58b2492f3f589b2e6850c25e84626e5092983571f3540ae6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -54, + "dataset": "marble-joined", + "doc_id": "63da8657b934a96b58b2492f3f589b2e6850c25e84626e5092983571f3540ae6", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "40f73d28d22983c8613d81a62ee2d43fbdda86ab3353e1c949fa9efe558d41ea", + "output_sha256": "e621495b5d0ef220139f87aa82943c817d886b5f64d2eac1228c97b8ecc27c8a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/63e179d0463c2608c7a8b82e9fc21cc7aab49a19b24ea77ab1483300d9318f1d.md b/vision-fixhub/court-05/63e179d0463c2608c7a8b82e9fc21cc7aab49a19b24ea77ab1483300d9318f1d.md new file mode 100644 index 0000000000000000000000000000000000000000..f580797cbf2b8d1968e0942294d7ce54b9322841 --- /dev/null +++ b/vision-fixhub/court-05/63e179d0463c2608c7a8b82e9fc21cc7aab49a19b24ea77ab1483300d9318f1d.md @@ -0,0 +1,31 @@ +Case 1:20-cr-00330-PAE | +Document 750 +Filed 08/10/22 Page 1 of 1 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AM +USA / Plaintiffs) +Case No.: 20-cr-330 +GHISLAINE MAXWELL, +Defendant(s) +) +NOTICE OF FILING OF OFFICIAL TRANSCRIPT +INFERENC +Notice is hereby given that an official transcript of a +held on +has been filed by the court reporter/transcriber in the above-captioned matter. +12/3/21 +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting +the transcript is a judge or a member of the public or media. +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court +any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also +be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically +available to the public without redaction after ninety (90) calendar days. +This process may only be used to redact the following personal data identifiers: Social Security +numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure +5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information +may proceed by motion. +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. +speer +Court Reporter/Transcriber +Date diff --git a/vision-fixhub/court-05/63e179d0463c2608c7a8b82e9fc21cc7aab49a19b24ea77ab1483300d9318f1d.receipt.json b/vision-fixhub/court-05/63e179d0463c2608c7a8b82e9fc21cc7aab49a19b24ea77ab1483300d9318f1d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a7979ab0a7882681c7553206e8f11fd54b83826e --- /dev/null +++ b/vision-fixhub/court-05/63e179d0463c2608c7a8b82e9fc21cc7aab49a19b24ea77ab1483300d9318f1d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -14, + "dataset": "marble-joined", + "doc_id": "63e179d0463c2608c7a8b82e9fc21cc7aab49a19b24ea77ab1483300d9318f1d", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "95065f1f5e9e0a39fbbc3edd590ca35ad6cc7573411ac5c7762f8a1460bf068c", + "output_sha256": "b29f595053ea0a5106a8dd5147e10ab16506674fed31ba31ea484ba28e8ec9c6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/640265b7c8788836e60e269fd25b94387e0d9ce03cb15c9e08e3ad81f78f7fdc.md b/vision-fixhub/court-05/640265b7c8788836e60e269fd25b94387e0d9ce03cb15c9e08e3ad81f78f7fdc.md new file mode 100644 index 0000000000000000000000000000000000000000..ff7c5f4080caa48448e4336a1c4e08c00eaf6e87 --- /dev/null +++ b/vision-fixhub/court-05/640265b7c8788836e60e269fd25b94387e0d9ce03cb15c9e08e3ad81f78f7fdc.md @@ -0,0 +1,396 @@ +Case 1:22-cv-10904-JSR Document 237-20 Filed 07/25/23 Page 1 of 13 + + + +• +Case 9:09 ase80836-KA090DdSR1eDbturEeter237020FUS @0223/03/0m/2909 oPage 1 of 27 +JANE DOE No. 102, +Plaintiff, +VS. +JEFFREY EPSTEIN, +Defendant. +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF FLORIDA +09-80656 +Civil Action No. +CIV-RYSKAMP +MAGISTRATE JUDGE +VITUNAC +FILED by. 05D.C +INTAKE +MAY - 1 2009 +TEVEN M. LARIMOR +LERK US. DIST. C +S.D. OF FLA. MIAMI +COMPLAINT AND +DEMAND FOR JURY TRIAL +/ +COMPLAINT AND DEMAND FOR JURY TRIAL +Plaintiff, Jane Doe No. 102, brings this Complaint against Defendant, Jeffrey Epstein, +and states as follows: +PARTIES, JURISDICTION, AND VENUE +At all times material to this cause of action, Plaintiff, Jane Doe No. 102, was a +resident of Palm Beach County, Florida. +2. +This Complaint is brought under a fictitious name to protect the identity of +Plaintiff, Jane Doe No. 102, because this Complaint makes sensitive allegations of sexual assault +and abuse of a then minor. +3. +At all times material to this cause of action, Defendant, Jeffrey Epstein, had a +residence located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida. +4. +Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is +currently incarcerated in the Palm Beach County Stockade. +5. +At all times material to this cause of action, Defendant, Jeffrey Epstein, was an +adult male born in 1953. +25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 + + +Case 9:09ase80886KADĐOĐJSRneĐbâurEeter287e20FUS@ 02k23/@3/0R/20Đ9 oPage 2 of 27 +6. +This Court has jurisdiction over this action and the claims set forth herein +pursuant to 18 U.S.C. § 2255. +7. +This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a +substantial part of the events giving rise to the claim occurred in this District. +STATEMENT OF FACTS +8. +At all relevant times, Defendant, Jeffrey Epstein, was an adult male, spanning the +ages of 45 and 55 years old. Epstein is known as a billionaire financier and money manager with +a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, +and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a +Boeing 727, as well as a fleet of motor vehicles. Until his incarceration, he maintained his +principal place of residence in the largest home in Manhattan, a 51,000-square-foot eight-story +mansion on the Upper East Side. Upon information and belief, he also owns a $6.8 million +mansion in Palm Beach, Florida, a $30 million 7,500-acre ranch in New Mexico he named +"Zorro," a 70-acre private island known as Little St. James in St. +U.S. Virgin Islands, a +mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris. +The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous +other locations both nationally and internationally. +9. +Upon information and belief, Defendant has a sexual preference for underage +minor girls. He engaged in a plan, scheme, or enterprise in which he gained access to countless +vulnerable and relatively economically disadvantaged minor girls, and sexually assaulted, +molested, and/or exploited these girls, and then gave them money. +10. +Beginning in or around 1998 through in or around September 2007, Defendant +used his resources and his influence over vulnerable minor girls to engage in a systematic pattern +of sexually exploitative behavior. +2 +25 West Flagler Street, Suite 800, Miami, FL. 33130, Miari 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 + + +Case 9:09ase80886KADĐODdSRneĐbđurEeter237e20FU5l@D02ł23/03/0R/20Đ9 oPage 3 of 27 +11. +Defendant's plan and scheme reflected a particular pattern and method. +Defendant coerced and enticed impressionable, vulnerable, and relatively economically less +fortunate minor girls to participate in various acts of sexual misconduct that he committed upon +them. Defendant's scheme involved the use of underage girls, as well as other individuals, to +recruit other underage girls. Upon information and belief, Defendant and/or an authorized agent +would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach +residence. His assistants would call economically disadvantaged and underage girls from West +Palm Beach and surrounding areas who would be enticed by the money being offered and who +Defendant and/or his assistants perceived as less likely to complain to authorities or have +credibility issues if allegations of improper conduct were made. The then minor Plaintiff and +other minor girls, some as young as 12 years old, were transported to Defendant's Palm Beach +mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with +"massages." +12. Many of the instances of illegal sexual conduct committed by Defendant were +perpetrated with the assistance, support, and facilitation of at least three assistants who helped +him orchestrate this child exploitation enterprise. These assistants would often arrange times for +underage girls to come to Defendant's residence, transport or cause the transportation of +underage girls to Defendant's residence, escort the underage girls to the massage room where +Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove +their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the +conclusion of each "massage appointment," and, upon information and belief, take nude +photographs and/or videos of the underage girls for Defendant with and/or without their +knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars. +3 +25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 + + +Case 9:09ase80886KADĐODdSRneĐbđurEeter@37e20FUS@d02ł23/03/0R/2gĐ5 oPage 4 of 27 +13. +Epstein designed this scheme to secure a private place in Defendant's Palm Beach +mansion where only persons employed and invited by Epstein would be present, so as to reduce +the chance of detection of Defendant's sexual abuse and prostitution as well as to make it more +difficult for the minor girls to flee the premises and/or to credibly report his actions to law +enforcement or other authorities. The girls were usually transported by his employees, agents, +and/or assistants or by a taxicab paid for by Defendant in order to make it dificult for the girls to +flee his mansion. +14. +Upon arrival at Defendant's Palm Beach mansion, each underage victim would +generally be introduced to one of Defendant's assistants, who would gather the girl's personal +contact information. The minor girl would then be led up a flight of stairs to a room that +contained a massage table and a large shower. The staircase leading to the room was plastered +with nude photographs of young girls, including some photographs depicting two or more young +girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such +photographs in each of his six homes and/or on his computers. +15. +At times, if it was the girl's first "massage" appointment, another female would +be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant +would start his massage wearing only a small towel, which eventually would be removed +Defendant and/or the other female would direct the girl to massage him, giving the minor girl +specific instructions as to where and how he wanted to be touched, and then direct her to remove +her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including +masturbation, fondling the minor's breasts and/or sexual organs, touching the minor's vulva, +vagina, and/or anus with a vibrator and/or back massager and/or his finger(s) and/or his penis, +digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or +coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution and/or +4 +N 1udFlauluu Glumel Coulae Drul diaml Et 93130 dfiu S0C 700 n0/ D... 305 9C0 7707 PundT ... d +«d.t- nea dem anar +ËFTA02810472 + +Case 9:09ase80886KADĐODdSR1eĐbđurEeter23720FUS @02123/03/0P/200S oPage 5 of 27 +enticing the then minor girl to engage in sexual acts with another female in Defendant's +presence. The exact degree of molestation and frequency with which the sexual exploitations +took place varied and is not yet completely known; however, Defendant committed such acts +regularly on a daily basis and, in most instances, several times a day. In order to facilitate the +daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily +available. +16. +Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of +luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to +contact these minor girls for the purpose of coercing them into acts of prostitution and to enable +himself to commit sexual battery against them and/or acts of lewdness in their presence, and he +conspired with others, including assistants and/or his drivers) and/or pilots), and his socialite +friend/partner, Ghislaine Maxwell, to further these acts and to avoid police detection. +Defendant's systematic pattern of sexually exploitative behavior referred to in paragraph 10 and +described in paragraphs 11 through the present paragraph occurred in all of Defendant's +domestic and international residences and/or places of lodging and/or modes of transportation. +17. +Consistent with the foregoing plan and scheme, Defendant used his money, +wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. +A vulnerable young girl, Plaintiff was working as a changing room assistant at The Mar-A-Lago +Club in Palm Beach making approximately $9 an hour when she was first lured into Defendant's +sexually exploitative world. In or about the summer of 1998, when Plaintiff was merely fifteen +years old while attending to her duties at Mar-A-Lago, Plaintiff was recruited by Ghislaine +Maxwell, who lived, traveled, socialized, and worked with Defendant. Ms. Maxwell asked +Plaintiff if she was interested in learning massage therapy and earning a great deal of money +while learning the profession. Plaintiff's father, who was a maintenance manager at The Mar-A- +5 +25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 + + +Case 9:09ase80886KADĐODdSRneĐbđurEeter@37e20FUS@0zł23/Ø3/0R/agĐ9 oPage 6 of 27 +Lago Club, was not apprehensive because he felt comforted that an older woman had approached +Plaintiff with this opportunity. As a result, Plaintiff's father dropped off Plaintiff at Defendant's +mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm +Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would +provide transportation home for his teenaged daughter. Ghislaine Maxwell led Plaintiff up a +flight of stairs to a spa room with a shower and a massage table. Defendant was lying naked on +the massage table. Plaintiff was shocked, but, with no experience with massages, thought this +could be massage therapy protocol. Ms. Maxwell then took off her own shirt and left on her +underwear and started rubbing her breasts across Defendant's body, impliedly showing Plaintiff +what she was expected to do. Ms. Maxwell then told Plaintiff to take off her clothes. The minor +girl was apprehensive about doing this, but, in fear, proceeded to follow Ms. Maxwell by +removing everything but her underwear. She was then ordered to remove her underwear and to +straddle Defendant. +The encounter escalated, with Defendant and Ms. Maxwell sexually +assaulting, battering, exploiting, and abusing Plaintiff in various ways and in various locations, +including the steam room and shower. At the end of this sexually exploitive abuse, Defendant +and Ms. Maxwell giddily told Plaintiff to return the following day and told her she had "lots of +potential." Defendant paid Plaintiff hundreds of dollars, told her it was for two hours of work, +and directed one of his employees to drive her home. +18. +Defendant and/or his procurers thereafter lured the then minor Plaintiff to his +Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of +sexual exploitation. Defendant and/or his procurers arranged at the end of each incident the +transportation and scheduling for the following day's appointment. Additionally, Defendant +telephoned the minor Plaintiff himself and/or had Ms. Maxwell telephone Plaintiff to make +arrangements. Plaintiff was often times driven to and from Epstein's mansion by Epstein +6 +7 Wrent Elsale Chorut Coito 0 Mimi ET 22130 Mismi 205 150 7000 Es ANE 250 7307 Ensl adandala 051 463 1246 + + +Case 9:09ase80886KADĐODdSR1eĐbđurEeter237e20FUS @D@2123/03/0P/2008 oPage 7 of 27 +himself or his driver. Alternatively, Defendant or Ms. Maxwell would arrange and pay for +Plaintiff's transportation home by taxicab. +19. +During Plaintiff's second incident of being sexually exploited and assaulted by +Defendant at Defendant's Palm Beach mansion, Defendant asked Plaintiff to quit her job at The +Mar-A-Lago Club and travel with him to earn much more money while learning the massage +profession. Thus, Plaintiff, an impressionable and vulnerable young girl of modest means, quit +her job as a changing room assistant, was lured by Defendant, and continued to be victimized by +Defendant, who immersed the minor Plaintiff into Defendant's lewd and abusive lifestyle. +Under Defendant's dominion and control, Defendant continuously "groomed" the minor +adolescent. +Defendant's daily routine required the minor Plaintiff to perform sexually on +Defendant multiple times per day and to provide Defendant massages multiple times per day. +Plaintiff had absolutely no say as to when, how many times, or what was done during each +sexual encounter. Often, Plaintiff was joined by Ms. Maxwell, Ms. Maxwell's assistant, and/or a +countless array of young women who would be brought to one of Defendant's homes for the +sexual trysts and then be sexually exploited by Defendant. +20. +The first time that Defendant transported Plaintiff to another state in order to +engage in sexual acts with her occurred when she was merely fifteen years old and after only two +weeks of daily sexually abusive encounters with Defendant. Defendant used his private jet to +transport the minor Plaintiff to Manhattan, where he provided her with spending money and +accommodations with him at his mansion. +From the time that Plaintiff was 15 years old, +Defendant abused her to serve his every sexual whim, obtaining and purchasing passports and +whatever was needed for her to travel with him and/or for him. Defendant transported Plaintiff +in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles, +San Francisco, St. Louis, and numerous other domestic destinations, as well as international +7 +25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 + + +Case 9:09ase80886KADĐODdSR1eĐbđurEeter237e20FUS @D02123/03/0P/2009 oPage 8 of 27 +destinations, including Europe, the Caribbean, and Africa. He provided accommodations with +him in order to have her available to him at all times wherever he went, including while +transporting the minor Plaintiff on his private jet. Each time they would travel to one of these +destinations, the same pattern of sexual abuse would occur, often with a vast array of aspiring +models, actresses, celebrities, and/or other females, including minors, from all over the world +Upon information and belief, Defendant transported minor girls from Turkey, the Czech +Republic, Asia, and numerous other countries, many of whom spoke no English. To Plaintiff's +knowledge, the only females specifically excluded from Defendant's sexual escapades were +African-Americans. +21. +In addition to being continually exploited to satisfy Defendant's every sexual +whim, Plaintiff was also required to be sexually exploited by Defendant's adult male peers, +including royalty, politicians, academicians, businessmen, and/or other professional and personal +acquaintances. +Whenever Defendant transported Plaintiff with him in his private jet to any +destination, Defendant would pay Plaintiff a flat rate per day while he and/or his abovementioned associates would sexually exploit and abuse minor Plaintiff. +22. +Most of these acts of abuse occurred during a time when Defendant knew that +Plaintiff was approximately 15, 16, and 17 years old, and, after years of daily sexual exploitation, +continued into her adulthood. Despite Defendant's stating shortly before Plaintiff's sixteenth +birthday that he soon would have to trade her in because she was getting too old, Defendant +continued to sexually exploit Plaintiff until she fled at age 19. Defendant's predilection for +young girls was well known to those who regularly procured them for him and to his circle of +friends. On one of Defendant's birthdays, a friend of Defendant sent him three 12-year-old girls +from France who spoke no English for Defendant to sexually exploit and abuse. After doing so, +they were sent back to France the next day. +8 +25 West flagler Stret, Suite 800, Miami, FL 3130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 9544634346 1 + + +23. +Any assertions by Defendant that he was unaware of the age of the then minor +Plaintiff are belied by his own actions, and are rendered irrelevant by the provision of applicable +federal statutes concerning the sexual exploitation and abuse of a minor child. Defendant, +Jeffrey Epstein, at all times material to this cause of action, knew and should have known of +Plaintiff's age of minority. Defendant and Ms. Maxwell acknowledged and celebrated Plaintiff's +16" birthday. Defendant's preference for underage girls was well-known to those who regularly +procured them for him. +24. +As previously stated in paragraph 14, Defendant displayed nude photographs of +underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. +Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of +Defendant's homes, including a photograph of herself naked at Defendant's home in Palm +Beach. When she asked Defendant about it, he stated dismissively that he had naked photographs +of her in all of his homes. +25. Upon information and belief, some of the photographs in Defendant's possession +were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, +police found two hidden cameras and photographs of underage girls on a computer in +Defendant's home. Upon information and belief, Defendant may have taken lewd photographs +of Plaintiff, Jane Doe No. 102, with his hidden cameras and may have transported lewd +photographs of Plaintiff (among many other victims) to his other residences and elsewhere using +a facility or means of interstate and/or foreign commerce. In addition, while Plaintiff was a +minor teenager and upon Ms. Maxwell's insistence after Ms. Maxwell rejected as inappropriate +photographs that Plaintiff presented of herself fully clothed, Ms. Maxwell photographed Plaintiff +naked in different sexually explicit positions. +Ms. Maxwell then presented these nude +photographs of Plaintiff to Defendant as a birthday present for Defendant from Ms. Maxwell. +9 +25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 + + +Case 9:09ase80886 KA090D0SR1eDbturEete 28720FUS@D02123/03/0Ra0091 Bag8 10 of 27 +Upon information and belief, one or more nude photographs of Plaintiff that were taken when +she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a +search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information +and belief, those photographs are still in the custody of law enforcement. +26. +It is virtually impossible to calculate the exact number of times that Defendant +sexually exploited and abused Plaintiff. From the age of 15, Plaintiff was sexually exploited and +abused by Defendant on a daily basis and, most often, multiple times each day. While some of +the precise dates these acts occurred are unknown to Plaintiff, these dates are known to +Defendant, as he is reported to have kept a written log of each instance in which he engaged in +these lewd acts with then minor Plaintiff and others. Upon information and belief, these logs are +also in the custody of law enforcement. +27. +In or around September 2002, Defendant purchased a commercial round-trip +airline ticket, and provided a passport, U.S. currency, and accommodations for Plaintiff to fly to +Thailand. While thousands of miles away from Defendant on this extended trip alone for the +first time in more than four years, Plaintiff met, fell in love, and married a young man. She +escaped from Defendant's abuse with the help and insistence of her new husband and, instead of +returning to Defendant, boarded a plane to Australia with one suitcase. +28. +Since November 2002, Plaintiff has lived a modest life in Australia, while +maintaining lines of communication with her family and without contact with Defendant or any +of the people in his entourage. However, suddenly, in 2008, Plaintiff received numerous phone +calls from one of Defendant's agents. During these phone calls to Plaintiff, he repeatedly asked +whether she knew anything about the civil cases against Defendant, whether she knew any of the +females who were proceeding with the civil suits, whether she was planning on filing suit, +whether she was communicating and/or cooperating with anyone against Defendant, and whether +10 +25 Wast Flaolar Street SuitoR Miami FT. Miami Miami 305258 9RN0 av 305 258 7387 • FretT anandala 054 463 4246 + + +Case 9:09ase80886 KA090D0SR1eDbturEete 28720FUS@D02123/03/0P20092 Bag₴ 11 of 27 +she would return to the United States to testify. Terrified by Defendant's demonstrated ability to +track her down on her changed cell phone number halfway across the world, Plaintiff attempted +to reassure Defendant's agent that she would remain quiet. During the course of one of these +phone calls from Defendant's agents, Defendant himself spoke on the phone, continued to +question her intentions, and, upon being reassured by Plaintiff, thanked her for not getting +involved. +29. +Around January 2009, Plaintiff received a letter from the United States Attorney's +Office for the Southern District of Florida, informing her of her potential civil claims against +Defendant under 18 U.S.C. § 2255. Plaintiff contacted undersigned counsel within days and +diligently and repeatedly pursued a good faith viable settlement of her claims against Defendant. +Unable to reach a settlement, this lawsuit followed. +30. As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 102, has in +the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, +emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, +confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, +invasion of her privacy, separation from her family, and other damages associated with +Defendant's controlling and manipulating her on a daily basis for years into a perverse and +unhealthy way of life. +31. Defendant, Jeffrey Epstein, committed the above-referenced acts upon Plaintiff in +violation of federal statutes condemning the coercion and enticement of a minor to engage in +prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex +trafficking of children, sexual exploitation of minor children, transport of visual depictions of a +minor engaging in sexually explicit conduct, transport of child pornography, child exploitation +enterprises, and other crimes, specifically including, but not limited to, those crimes designated +11 +25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 + + +Case 9:09ase80886 KA090D0SR1eDbturEete 28720FUS@D02123/03/0R20093 Bag₴ 12 of 27 +in 18 U.S.C. § 2421, § 2422(a), § 2422(b), § 2423(a), § 2423(b), § 2423(e), § 2251, § 2252, § +2252A(a)(1), and § 2252A(g)(1) +32. +In June 2008, after investigations by the Palm Beach Police Department, the Palm +Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States +Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas +of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and +the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in +Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had +been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must +admit liability unto Plaintiff, Jane Doe No. 102. Plaintiff hereby exclusively seeks civil remedies +pursuant to 18 U.S.C. § 2255. +COUNT ONE +(Cause of Action for Coercion and Enticement of Minor to Engage in Prostitution or +Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2422(b)) +33. +Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by +reference the allegations contained in paragraphs 1 through 32 above. +34. +Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign +commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 102, when she was +under the age of 18 years, to engage in prostitution and/or sexual activity for which any person +can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in +violation of 18 U.S.C. § 2422(b). +35. +Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in +18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, +pursuant to this Section of the United States Code. +12 +25 West Flagler Strect, Suite 800, Miami, FL. 3130, Miami 305.358.2800 Fax 305.358.2382 • For Lauderdale 9544634346 \ No newline at end of file diff --git a/vision-fixhub/court-05/640265b7c8788836e60e269fd25b94387e0d9ce03cb15c9e08e3ad81f78f7fdc.receipt.json b/vision-fixhub/court-05/640265b7c8788836e60e269fd25b94387e0d9ce03cb15c9e08e3ad81f78f7fdc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dec253f8dcf0a27fd6807fd23b63f60f6c5a91b8 --- /dev/null +++ b/vision-fixhub/court-05/640265b7c8788836e60e269fd25b94387e0d9ce03cb15c9e08e3ad81f78f7fdc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -574, + "dataset": "marble-joined", + "doc_id": "640265b7c8788836e60e269fd25b94387e0d9ce03cb15c9e08e3ad81f78f7fdc", + "engine": "marble-apple-vision", + "event_count": 15, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "6fb69701b14521e8db4b7c19d92b38248f3c6491785fb3f5d94fc791182a403b", + "output_sha256": "48737abd431a50f7af288ce57b7989495d7ef5f70de6c0e6dcafe75877c2ff28", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/64303a5f2a169e2e0a613505c3def5a84b83a97f6b95194a9f000dfbfa7469fc.md b/vision-fixhub/court-05/64303a5f2a169e2e0a613505c3def5a84b83a97f6b95194a9f000dfbfa7469fc.md new file mode 100644 index 0000000000000000000000000000000000000000..2144f11ca09607a54d9158df69f11c9538587eb3 --- /dev/null +++ b/vision-fixhub/court-05/64303a5f2a169e2e0a613505c3def5a84b83a97f6b95194a9f000dfbfa7469fc.md @@ -0,0 +1,106 @@ +Case 1:22-cv-10904-JSR Document 241-4 Filed 07/25/23 Page 1 of 4 + + + +Case 1:22-cv-10904-JSRileyDoqoregаp24 1v4h0Flech7/25/2BBriRage 2 of 4 +Home > Entertainment & Pop Culture > Actors +Arts & Culture +Miley Cyrus +American actress and +Also known as: Destiny Hope Cyrus, Miley Ray Cyrus +Written by John M. Cunningham +Fact-checked by The Editors of Encyclopaedia Britannica +Last Updated: May 15, 2023 • Article History +: Actions += Table of Contents +Listen to article +5 minutes +ЛАХІМ +JIM BEAM +GHOST +WHISKEY +SONY +eleve +XIM +HOT +100 +SONY +make beleve +MAXIM +HOT +100 +M +JIM BEAR +GHOST +JIM BEAM +GHOST +WHITE +SC +make. +JMBCAN +X +Miley Cyrus +Category: Arts & Culture +Born: November 23, 1992 (age 30) » Franklin • Tennessee +You have reached Britannica's public website. +Click here for ad-free access to your Britannica School or Library +account. +https://www.britannica.com/biography/Miley-Cyrus +See all media +Get Started +Everyday Rewards+ Cred +1/13 + + +Case 1:22-cv-10904-JSRileyDqоы/велар2 Iv4hoflech7/25/2BBriRage 3 of 4 +Miley Cyrus, in full Miley Ray Cyrus, original name Destiny Hope Cyrus, (born November 23, 1992, Eranklin, Tennessee, U.S.), +American +and actress whose performance on the television show Hannah Montana (2006-11) and its related soundtrack +albums catapulted her into stardom. +Cyrus was born to country +and actor Billy Ray Cyrus and his wife, Tish, and grew up on her family's farm outside Nashville. Her +sunny disposition as a child earned her the nickname "Smiley Miley." (She had her name legally changed to Miley Ray Cyrus in 2008). +Though her father was initially reluctant to let her follow in his show business footsteps, at the age of nine she landed a role in an +episode of his TV series Doc. Another role, in the film Big Fish (2003), followed. +Britannica Quiz +Pop Culture Quiz +In 2005 Cyrus auditioned for the lead role in Hannah Montana, a Disney Channel series about a girl who leads a double life as a +normal middle-school student and, with the help of a blonde wig, as a glamorous pop +.. Though initially deemed by executives to +be too small and young for the character, she persisted and won the part. The show debuted the following year (featuring Billy Ray as +her TV dad) and became an immediate sensation, scoring record ratings for cable television and turning the 13-year-old into a bona +fide star. Aiming to capitalize on the show's obvious youth-market appeal, a soundtrack album featuring the music of Hannah +Montana was released in 2006 and eventually sold more than three million copies. It was followed by the equally successful Hannah +Montana 2: Meet Miley Cyrus (2007), which was packaged as a double CD, with half of the material under Cyrus's own name. +In late 2007 Cyrus embarked on a national tour called Best of Both Worlds in support of her latest album. Two concerts from the tour +were filmed and presented as a 3-D movie; it made more than $30 million in its opening weekend despite having been released only to +select theatres. Although already well known to the preteen demographic, she gained wider exposure in early 2008 as her song "See +You Again" crossed over to the pop charts. Later that year she released the album Breakout and voiced one of the leading roles in the +animated film Bolt. For the latter, Cyrus cowrote the single "I Thought I Lost You," which was nominated for a Golden Globe Award. +X +You have reached Britannica's public website. +Click here for ad-free access to your Britannica School or Library +account. +https://www.britannica.com/biography/Miley-Cyrus +2/13 + + +Miley and Billy Ray Cyrus +Though her celebrity status had increased, Cyrus continued to perform as Hannah Montana in various media. In early 2009 she +starred in Hannah Montana: The Movie and sang on its soundtrack, and she later issued two additional soundtrack albums (2009, +2010) for the TV show before its final episode aired in 2011. Meanwhile, Cyrus continued to record under her own name for the EP The +Time of Our Lives (2009), which featured the hit "Party in the U.S.A.," and the full-length album Can't Be Tamed (2010). In addition, +she took starring movie roles in the romantic drama The Last Song (2010) and the low-budget coming-of-age tale LOL (2012). +In 2013 Cyrus released the album Bangerz, which departed from her earlier work in its embrace of hip-hop influences and its +frequently adult-themed lyrics. Her new style was epitomized by the single "We Can't Stop," a bouncy ode to hedonism that she +notably performed, in controversially risqué fashion, at the MTV Video Music Awards. The ballad "Wrecking Ball," meanwhile, became +Cyrus's first song to top the Billboard singles chart. She then veered away from the mainstream with Miley Cyrus & Her Dead Petz +(2015), a collection of loosely psychedelic songs recorded in large part with the rock band the Flaming Lips and made available for free +on the Internet. Younger Now (2017) featured a number of ballads and country-infused songs, one of which was a duet with Dolly +Parton. Cyrus's seventh studio album, the rock-infused Plastic Hearts (2020), further highlighted her versatility. +X +You have reached Britannica's public website. +Click here for ad-free access to your Britannica School or Library +account. +https://www.britannica.com/biography/Miley-Cyrus +3/13 \ No newline at end of file diff --git a/vision-fixhub/court-05/64303a5f2a169e2e0a613505c3def5a84b83a97f6b95194a9f000dfbfa7469fc.receipt.json b/vision-fixhub/court-05/64303a5f2a169e2e0a613505c3def5a84b83a97f6b95194a9f000dfbfa7469fc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0742da9cf159e416298a99a807cc85fc2cbb43c3 --- /dev/null +++ b/vision-fixhub/court-05/64303a5f2a169e2e0a613505c3def5a84b83a97f6b95194a9f000dfbfa7469fc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -111, + "dataset": "marble-joined", + "doc_id": "64303a5f2a169e2e0a613505c3def5a84b83a97f6b95194a9f000dfbfa7469fc", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "249d40621d2563aeb38f5b3de580ed3a1f1555c82e77a74c16da2a2cdbbaf622", + "output_sha256": "236f43bd80f19b25e756ef2e2f84b5b70417acbdc616c012c0776d654f857e95", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/643fc4f7da6f2fe6a8e360e5aff7408d7e9b3c1e71a05a81d0f05f0d45b3c8bc.md b/vision-fixhub/court-05/643fc4f7da6f2fe6a8e360e5aff7408d7e9b3c1e71a05a81d0f05f0d45b3c8bc.md new file mode 100644 index 0000000000000000000000000000000000000000..ecefe4ce57cdd6e63ac8dd763438bfbd2a54c0af --- /dev/null +++ b/vision-fixhub/court-05/643fc4f7da6f2fe6a8e360e5aff7408d7e9b3c1e71a05a81d0f05f0d45b3c8bc.md @@ -0,0 +1,104 @@ +Case 1:22-cv-10904-JSR Document 244-3 Filed 07/25/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 244-3 Filed 07/25/23 Page 2 of 3 +The Wayback Machine -https://web.archive.org/web/20120426055706/https://careers.jpmorganchase.com/cm.. +J.P. +Home +PURCHASE OF HIGHBRIDGE CAPITAL MANAGEMENT +Jun 11, 2009 +• J.P. +Asset Management will complete its purchase of Highbridge, effective July 1, 2009. +New York, June, 11, 2009 -- Highbridge Capital Management announced today that J.P. +Asset +Management will complete its purchase of Highbridge, effective July 1, 2009. J.P. +Asset Management +entered into a strategic partnership with Highbridge in December 2004 and has increased its ownership stake +over the last five years, creating one of the largest and most significant strategic alliances in the hedge fund +industry. +Following the purchase, co-founder Glenn +will continue in his role as the CEO of Highbridge. Co- +founder Henry Swieca plans to assist in the transition through late 2009 and seek new opportunities in the +finance industry. +Since December 2004, Highbridge has tripled its assets under management to approximately $21 billion and +evolved into a global, diversified investment management platform offering investment products across its hedge +fund, traditional investment management and private investment businesses. In the wake of last year's global +market crisis and industry consolidation, Highbridge is exceptionally well positioned, given its depth of +investment talent and institutional quality operating platform. +"When Glenn and I founded Highbridge 17 years ago, we wanted to build an alternative investment management +business that would endure long after us," Mr. Swieca said. "I am proud to say that we've succeeded beyond our +dreams." +Mr. +added, "Over the last five years, with J.P. +Asset Management as our strategic partner, +Highbridge has continued to evolve into a global, diversified alternative investment management firm. In this +next era, I look forward to leading Highbridge in an environment that has its clear challenges, but offers +unprecedented opportunities." +"Since day one of the partnership between J.P. +Asset Management and Highbridge, our goal was to +create an institutionalized hedge fund business with the ability to deliver strong risk-adjusted returns," said Jes +Staley, CEO of J.P. +Asset Management. "Under the leadership of Glenn and Henry, we've not only +accomplished this, but have uniquely positioned the J.P. +/Highbridge partnership to deliver best-in-class +investment opportunities to our broad range of clients going forward." +About Highbridge Capital Management +Highbridge Capital Management, LLC is a global alternative investment management firm founded in 1992 by +Glenn +and Henry Swieca. Since its inception, the company has developed a world-class, diversified +investment platform that includes hedge funds, traditional investment management products and private equity. +With over 310 employees, including over 100 investment professionals, Highbridge manages approximately $21 +billion of capital for some of the world's most prominent institutional investors, public and corporate pension +funds, endowments, foundations and family offices. The firm is based in New York with offices in London, +Hong Kong and Tokyo. + +WIT: _ +DATE: +17 +Staley +6/10/23 +RDA CAR CSR #13921 + + +Case 1:22-cv-10904-JSR Document 244-3 Filed 07/25/23 Page 3 of 3 +In December 2004, J.P. +Asset Management purchased a majority interest in Highbridge creating one of +the largest and most significant strategic alliances in the hedge fund industry. Highbridge's sale to J.P. +Asset Management remains at the vanguard of the institutionalization of the hedge fund industry and is widely +viewed as a model of success. +About J.P. +Asset Management +J.P. +Asset Management, with assets under supervision of S1.5 trillion, is a global leader in investment +and wealth management. J.P. +Asset Management's clients include institutions, retail investors and highnet worth individuals in every major market throughout the world. J.P. +Asset Management offers global +investment management in equities, fixed income, real estate, hedge funds, private equity and liquidity. J.P. +Asset Management provides trust and estate, banking and brokerage services to high-net-worth clients +and retirement services for corporations and individuals. +About JPMorgan Chase & Co. +JPMorgan Chase & Co. (NYSE: JPM), the parent company of J.P. +Asset Management, is a leading +global financial services firm with assets of $2.1 trillion and operations in more than 60 countries. The firm is a +leader in investment banking, financial services for consumers, small business and commercial banking +financial transaction processing, asset management, and private equity. A component of the Dow +Industrial Average, JPMorgan Chase & Co. serves millions of consumers in the United States and many of the +world's most prominent corporate, institutional and government clients under its J.P +, Chase, and WaMu +brands. Information about JPMorgan Chase & Co. is available at www.jpmorganchase.com. + +Contact: +Highbridge Capital Management +Lisa Steele +(212) 287-4277 +lisa.steele@highbridge.com +J.P. +Mary Sedarat +(212) 648-1796 +mary.sedarat@jpmorgan.com +Powerscourt Media +Victoria Palmer-Moore ++44 (0)20 7250 1446 +Victoria.palmer-moore@powerscourtmedia.com +Copyright © 2012 JPMorgan Chase & Co. All rights reserved. diff --git a/vision-fixhub/court-05/643fc4f7da6f2fe6a8e360e5aff7408d7e9b3c1e71a05a81d0f05f0d45b3c8bc.receipt.json b/vision-fixhub/court-05/643fc4f7da6f2fe6a8e360e5aff7408d7e9b3c1e71a05a81d0f05f0d45b3c8bc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..73fefcfa058c4e8a345dd3f5fcdc45a8d69a55ea --- /dev/null +++ b/vision-fixhub/court-05/643fc4f7da6f2fe6a8e360e5aff7408d7e9b3c1e71a05a81d0f05f0d45b3c8bc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -59, + "dataset": "marble-joined", + "doc_id": "643fc4f7da6f2fe6a8e360e5aff7408d7e9b3c1e71a05a81d0f05f0d45b3c8bc", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.bare-h3\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "da0ba6fa3d1e4d9305890f1802d785d3da2d17b09d0a8f16ce6bc4858e188f32", + "output_sha256": "1c69937277786a5d2b141589590c7ed8e8a02a5b998cef9810e993f965db0da7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/644d052b423d14411470b5082aaf4253944c05cee7957e95baef5acac43d595c.md b/vision-fixhub/court-05/644d052b423d14411470b5082aaf4253944c05cee7957e95baef5acac43d595c.md new file mode 100644 index 0000000000000000000000000000000000000000..42055a6a60e8b4b787d6c3db70bf6a4a73dda23b --- /dev/null +++ b/vision-fixhub/court-05/644d052b423d14411470b5082aaf4253944c05cee7957e95baef5acac43d595c.md @@ -0,0 +1,43 @@ +Case 1:22-cv-10904-JSR Document 162 Filed 05/23/23 Page 1 of 2 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES VIRGIN +ISLANDS, +Plaintiff, +22-cv-10904 (JSR) +ORDER +-V- +JPMORGAN CHASE BANK, N.A., +Defendant/Third-Party Plaintiff, +-V- +JAMES EDWARD STALEY, +Third-Party Defendant. +JED S. RAKOFF, U.S.D.J.: +On May 17, 2023, defendant JPMorgan Chase Bank, N.A. ("JP +") +moved to compel production of two categories of documents from thirdparty the Estate of Jeffrey Epstein ("the Estate"): +1. All email correspondence in the possession, custody, or control +of the Estate containing Cecile De Jongh in the to/from/co line; +2. All documents in the possession, custody or control of the Estate +that hit on the search terms "Cecile," "CDJ, " or "De Jongh" that +are not already captured by Category 1 or prior productions of +the Estate. See ECF No. 154. +After full consideration of letter briefing submitted by JP +and the Estate, the Court finds that the requested documents are +1 + + +Case 1:22-cv-10904-JSR Document 162 Filed 05/23/23 Page 2 of 2 +relevant and that the burden of producing them is not +excessive. +Accordingly, it hereby grants JP +motion. +The Clerk is respectfully directed to close entry number 154 on +the docket of this case. +SO ORDERED. +New York, +NY +May 23. +2023 +(OFF, U.s.D.J. +2 diff --git a/vision-fixhub/court-05/644d052b423d14411470b5082aaf4253944c05cee7957e95baef5acac43d595c.receipt.json b/vision-fixhub/court-05/644d052b423d14411470b5082aaf4253944c05cee7957e95baef5acac43d595c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6d4747f2f5a1c49c5d94ca5b4ad1dbeffd9faeac --- /dev/null +++ b/vision-fixhub/court-05/644d052b423d14411470b5082aaf4253944c05cee7957e95baef5acac43d595c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "644d052b423d14411470b5082aaf4253944c05cee7957e95baef5acac43d595c", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "6eeac1bf4065ebe5e84e421720fa449aad512b93383a0002b1e16394970b0919", + "output_sha256": "41975e2f82e0cae6070f573d2d458068c74a93d2c884fc2612b229888b804fb2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/646402e2321850be0c9c5e6f1eca54e536700390b72c6b08042f5e3614ba495a.md b/vision-fixhub/court-05/646402e2321850be0c9c5e6f1eca54e536700390b72c6b08042f5e3614ba495a.md new file mode 100644 index 0000000000000000000000000000000000000000..69f9c73f6687b050e25f37612b6e49af7c3c18af --- /dev/null +++ b/vision-fixhub/court-05/646402e2321850be0c9c5e6f1eca54e536700390b72c6b08042f5e3614ba495a.md @@ -0,0 +1,62 @@ +Case 1:22-cv-10904-JSR Document 186-7 Filed 06/14/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 186-7 Filed 06/14/23 Page 2 of 3 +From: +Sent: +To: +Subject: +Lesley Groff L +@gmail.com] +7/12/20183:32:46 PM +Jeffrey Epstein [jeevacation@gmail.com] +Re: Bloomberg Invite for Plaskett for Congress fundraiser +Importance: High +Sure thanks Lesley +The short answer is that because there will be a primary and a general clection for the congressional race our +campaign can receive $5,400 from each individual contributor. The FEC states that a candidate may receive +$2,700 for each race - and because there will be a primary and a general election a contributor may write one +check for $5,400 and designate on the note line $2.7k for primary; $2.7k for general. +On Jul 12, 2018, at 1057 AM, jeffrey E. wrote: +get maximum ampounts allowed +On Thu, Jul 12, 2018 at 10:57 AM, Lesley Groff < +@gmail.com> wrote: +Begin forwarded message: +From: Stacey Plaskett < +@gmail.com> +Subject: Bloomberg Invite for Plaskett for Congress fundraiser +Date: July 12, 2018 at 10:55:05 AM EDT +To: +@gmail.com, Erika Kellerhals ‹ +Cc: +@kellfer.com> +@detailsconsultingllc.com +Good morning Lesley, +If you would share this invitation with Jeffiey I'd be much appreciative. I would be grateful for his support and +the support of those that he may direct to assist me. +I'll be in New York City the Thursday of the event through the weekend. +Again thanks +Stacey +Begin forwarded message: +From: Yolonda Addison < +Date: July 11, 2018 at 3:15:09 PM EDT +To: LeRoy Daughter +Cc: Jerome +Subject: Bloomberg Invite +@ detailsconsultingllc.com> +@gmail.com>, Stacey Plaskett < +@gi.com +@gmail.com> + +ESTATE_JPM012219 + + +Case 1:22-cv-10904-JSR Document 186-7 Filed 06/14/23 Page 3 of 3 +Here it is! Please let me know if you would like me to send it to anyone :) +Yolonda Addison +Managing Director +Details Consulting. LC +Fice +www.detailsconsultinellc.com +-- diff --git a/vision-fixhub/court-05/646402e2321850be0c9c5e6f1eca54e536700390b72c6b08042f5e3614ba495a.receipt.json b/vision-fixhub/court-05/646402e2321850be0c9c5e6f1eca54e536700390b72c6b08042f5e3614ba495a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f0dabdda712edce55fbc9a60cdaac940c77789e0 --- /dev/null +++ b/vision-fixhub/court-05/646402e2321850be0c9c5e6f1eca54e536700390b72c6b08042f5e3614ba495a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -685, + "dataset": "marble-joined", + "doc_id": "646402e2321850be0c9c5e6f1eca54e536700390b72c6b08042f5e3614ba495a", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "4b3111fb46cd8b6d20676f0874bfe727aa7001d5a864191b2670760cfd0b8a77", + "output_sha256": "b7fff9aceb2b503a69c3968738acaf8843914e71f7419621e311da8f28b25a70", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/64780f6b86e53f32a6166161cd69983d8c9a34aea292245786f3b982a6118a9f.md b/vision-fixhub/court-05/64780f6b86e53f32a6166161cd69983d8c9a34aea292245786f3b982a6118a9f.md new file mode 100644 index 0000000000000000000000000000000000000000..9286608fdd14dce2dfbd676c7fac1740dc5991eb --- /dev/null +++ b/vision-fixhub/court-05/64780f6b86e53f32a6166161cd69983d8c9a34aea292245786f3b982a6118a9f.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 242-15 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/64780f6b86e53f32a6166161cd69983d8c9a34aea292245786f3b982a6118a9f.receipt.json b/vision-fixhub/court-05/64780f6b86e53f32a6166161cd69983d8c9a34aea292245786f3b982a6118a9f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..71dfe1ae0b90324f874781401fe9e922152fb6d3 --- /dev/null +++ b/vision-fixhub/court-05/64780f6b86e53f32a6166161cd69983d8c9a34aea292245786f3b982a6118a9f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "64780f6b86e53f32a6166161cd69983d8c9a34aea292245786f3b982a6118a9f", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "fbbd893e14f7b72d6309a8403573c25e9f10b14f4dd784cffadf023829026818", + "output_sha256": "6257d524dfe6678bc17b35658c9a90b932effc227e5390ba3876f44e50a185d8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/648397f04a3ff11637457f1dcaaa3c3e2b1a42056c716a27a84747de4862c226.md b/vision-fixhub/court-05/648397f04a3ff11637457f1dcaaa3c3e2b1a42056c716a27a84747de4862c226.md new file mode 100644 index 0000000000000000000000000000000000000000..2a56fa58472409c575fc05497f813a04b4bcf293 --- /dev/null +++ b/vision-fixhub/court-05/648397f04a3ff11637457f1dcaaa3c3e2b1a42056c716a27a84747de4862c226.md @@ -0,0 +1,59 @@ +Case 1:22-cv-10904-JSR Document 106 Filed 04/03/23 Page 1 of 2 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +Case Number: 1:22-cv-10904-JSR +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +JAMES EDWARD STALEY +Third-Party Defendant. +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +NOTICE OF MOTION FOR LEAVE TO AMEND +TO ADD 18 U.S.C. $ 1591(d) OBSTRUCTION COUNT +Pursuant to Rule 15(a) and/or 16(b) of the Federal Rules of Civil Procedure, Plaintiff, the +Government of the United States Virgin Islands ("Government"), respectfully moves for an Order +granting the Government leave to amend its First Amended Complaint to add a count for violation +of 18 U.S.C. § 1591(d), obstruction or attempted obstruction of enforcement of the Trafficking +Victims Protection Act. The reasons in support of the Government's motion are set forth in the +Memorandum of Law filed herewith. As directed by the Court during the parties' March 31, 2023 +telephone call with the Court, the Government's motion and supporting Memorandum of Law are +hereby submitted before 5:00 PM on April 3, 2023. Pursuant to further direction provided by the + + +Case 1:22-cv-10904-JSR Document 106 Filed 04/03/23 Page 2 of 2 +Court during the same call, Defendant JPMorgan Chase Bank, N.A.'s opposition is due by 5:00 +PM on April 4, 2023, and there will be no reply and no oral argument. +Dated: April 3, 2023 +CAROL +I ESQ. +ACTING ATTORNEY GENERAL +/s/ Linda +Linda +(pro hac vice) +Mimi Liu (pro hac vice) +David I. Ackerman +Paige Boggs (pro hac vice) +MOTLEY RICE LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 / Fax: (202) 232-5513 +Isinger@motleyrice.com +mliu@motleyrice.com +dackerman@motleyrice.com +pboggs@motleyrice.com +Carol +(pro hac vice) +Acting Attorney General of the +United States Virgin Islands +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +St. +1. U.S. Virgin Islands 00802 +Tel: (340) 774-5666 ext. 10101 +Attorneys for Plaintiff Government of the +United States Virgin Islands +2 diff --git a/vision-fixhub/court-05/648397f04a3ff11637457f1dcaaa3c3e2b1a42056c716a27a84747de4862c226.receipt.json b/vision-fixhub/court-05/648397f04a3ff11637457f1dcaaa3c3e2b1a42056c716a27a84747de4862c226.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..83b03f2f17e7941402bc30d522f074be387d458f --- /dev/null +++ b/vision-fixhub/court-05/648397f04a3ff11637457f1dcaaa3c3e2b1a42056c716a27a84747de4862c226.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "648397f04a3ff11637457f1dcaaa3c3e2b1a42056c716a27a84747de4862c226", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "662b56b847766c17126d00c548b4aaa6781a5e1f82061fc583c8ea1c2ad1a90a", + "output_sha256": "1d0849c930364c9839c5904edd71d40d56c5226254f644844aca0b6497082336", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/64896a6cc71b8bcdcf4b2aaea24274b605f49868336b38dbf84fb4e6812b5ae6.md b/vision-fixhub/court-05/64896a6cc71b8bcdcf4b2aaea24274b605f49868336b38dbf84fb4e6812b5ae6.md new file mode 100644 index 0000000000000000000000000000000000000000..7bdacb0be2ba699866e8441d0f5201f044b877f4 --- /dev/null +++ b/vision-fixhub/court-05/64896a6cc71b8bcdcf4b2aaea24274b605f49868336b38dbf84fb4e6812b5ae6.md @@ -0,0 +1,135 @@ +Case 1:22-cv-10904-JSR Document 265-39 Filed 08/07/23 + + +FILED UNDER SEAL + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 265-39 Filed 08/07/23 Page 2 of 4 +Jeffery + +jes.staley@jpmorgan.com +9/27/2008 7:02:02 PM +Re: +The word is THROWING,, but at your level +there is no need to spell +on 9/27/08 11:47 AM, "jes.staley@jpmorgan.com" +wrote: +> I miss you. What a deal Jamie did. +> I'm spending a lot of time with Treasury. The Private Bank has brought in $44 +> billion dollars in the last two weeks. Unreal. +> +> +> +Thanks for the note. +> +> +Jes +- Original Message ----- +> +> +> +> From: Jeffery +> Sent: 09/27/2008 10:13 AM AST +> To: Jes Staley +> Subject: Re: +[jeevacation@gmail.com] +> Ou'll have plent of time. Enjoy this, its a once in a lifetime opportunity, +> make friends. Keep your eyes open for opportunity +> On 9/26/08 9:43 PM, "jes.staley@jpmorgan.com" + +JPM-SDNYLIT-00004186 + + +> +> wrote: +Case 1:22-cV-10904-JSR Document 265-39 Filed 08/07/23 Page 3 of 4 +>> Wamu is an unbelievable deal. But thus is still going out of control. I +>> need a break. +>> +>> Generally, this communication is for informational purposes only +>> and it is not intended as an offer or solicitation for the purchase +>> or sale of any financial instrument or as an official confirmation +> +>> of any transaction. In the event you are receiving the offering +>> materials attached below related to your interest in hedge funds or +> +» private equity, this communication may be intended as an offer or +> +»> solicitation for the purchase or sale of such fund(s). All market +> +>> prices, data and other information +are not warranted as to +> +>> completeness or accuracy and are subject to change without notice. +> +>> Any comments or statements made herein do not necessarily reflect +> +›> those of JPMorgan Chase +& Co., its subsidiaries and affiliates. +>> +>> This transmission may contain information that is privileged, +»> confidential, legally privileged, and/or exempt from disclosure +>> under applicable law. If you are not the intended recipient, you +>› are hereby notified that any disclosure, copying, distribution, or +>> use of the information contained herein (including any reliance +> +›> thereon) is STRICTLY PROHIBITED. Although this transmission and any +>> +attachments are believed to be free of any virus or other defect +>> that might affect any computer system into which it is received and +> +>> opened, it is the responsibility of the recipient to ensure that it +> +>> is virus free and no responsibility is accepted by JPMorgan Chase & +>> co., +its subsidiaries and affiliates, as applicable, for any loss +>> or damage arising in any way from its use. If you received this +>> transmission in error, please immediately contact the sender and +›> destroy the material in its entirety, whether in electronic or hard +> + +JPM-SDNYLIT-00004187 + + +»> copy forma Ca§hali22-GY:10904-JSR Document 265-39 Filed 08/07/23 Page 4 of 4 +>> Please refer to http://www.jpmorgan.com/pages/disclosures for +»> disclosures relating to UK legal entities. +> Generally, this conmunication is for informational purposes only +> and it is not intended as an offer or solicitation for the purchase +> or sale of any financial instrument or as an official confirmation +> of any transaction. In the event you are receiving the offering +> materials attached below related to your interest in hedge funds or +> private equity, this communication may be intended as an offer or +> solicitation for the purchase or sale of such fund(s). All market +> prices, data and other information are not warranted as to +• are not maranted a 1 ta. +> completeness or accuracy and are subject to change without notice. +> Any comments or statements made herein do not necessarily reflect +> those of JPMorgan Chase +& Co., +its +subsidiaries and affiliates. +> This transmission may contain information that is privileged, +> confidential, legally privileged, and/or exempt from disclosure +> under applicable law. If you are not the intended recipient, you +› are hereby notified that any disclosure, copying, distribution, or +> use of the information contained herein (including any reliance +> thereon) is STRICTLY PROHIBITED. Although this transmission and any +> attachments are believed to be free of any virus or other defect +› that might affect any computer system into which it is received and +> opened, it +is the responsibility of the recipient to ensure that it +> is virus free and no responsibility is accepted by JPMorgan Chase & +> Co., its subsidiaries and affiliates, as applicable, for any loss +> or damage +arising in any way from its use. If you received this +> transmission +in error, please immediately contact the sender and +> destroy the material in its entirety, whether in electronic or hard +> copy format. Thank you. +> Please refer to http://www.jpmorgan.com/pages/disclosures for +› disclosures relating to UK legal entities. diff --git a/vision-fixhub/court-05/64896a6cc71b8bcdcf4b2aaea24274b605f49868336b38dbf84fb4e6812b5ae6.receipt.json b/vision-fixhub/court-05/64896a6cc71b8bcdcf4b2aaea24274b605f49868336b38dbf84fb4e6812b5ae6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..18b0a3911b10f92ec96065f330a55d8e3264bfe0 --- /dev/null +++ b/vision-fixhub/court-05/64896a6cc71b8bcdcf4b2aaea24274b605f49868336b38dbf84fb4e6812b5ae6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -94, + "dataset": "marble-joined", + "doc_id": "64896a6cc71b8bcdcf4b2aaea24274b605f49868336b38dbf84fb4e6812b5ae6", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "ec8ba161ee57f03552c1d8791ce0b64620e7ae3ac145d2951ce50bda3afceb39", + "output_sha256": "8b984fbcacc2984bdff0df8cd4ef222307dddef8a074d3c1ccc870e02e1d50e2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/64934c71660b60b7687cbf6cb05fab152b0d4ed7c200766d922932ce951137af.md b/vision-fixhub/court-05/64934c71660b60b7687cbf6cb05fab152b0d4ed7c200766d922932ce951137af.md new file mode 100644 index 0000000000000000000000000000000000000000..39e20d93898b0d1d33398dced28b90765cfc8be1 --- /dev/null +++ b/vision-fixhub/court-05/64934c71660b60b7687cbf6cb05fab152b0d4ed7c200766d922932ce951137af.md @@ -0,0 +1,1315 @@ +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 1 of 45 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +Case Number: 1:22-cv-10904-JSR +JAMES EDWARD STALEY +Third-Party Defendant. +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +MEMORANDUM OF LAW IN SUPPORT OF +MOTION FOR PARTIAL SUMMARY JUDGMENT + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 2 of 45 +TABLE OF CONTENTS +INTRODUCTION +LEGAL STANDARD.. +ARGUMENT... +1 +3 +4 +I. JPMORGAN PARTICIPATED IN EPSTEIN'S SEX-TRAFFICKING VENTURE IN +VIOLATION OF TVPA 18 U.S.C. § 1591(a)(2). +A. Epstein Engaged in a Sex-Trafficking Venture. +B. JPMorgan Knew or Recklessly Disregarded that Epstein Ran a Sex-Trafficking Venture 5 +i. In 2006, JPMorgan Knew Epstein Was Engaged in Sex-Trafficking • +a. Epstein Admitted the Conduct (but Not the "Ages") to Staley +4 +4 +.. 5 +6 +b. JPMorgan's Own Diligence Gave It Reason to Suspect Epstein and Ghislaine +Maxwell Early On.. +7 +c. JPMorgan Had Corroborating Information on +and +7 +9 +d. JPMorgan Had Information about Epstein's Cash Withdrawals. +ii. After July 2006, JPMorgan Learned More Information that Fed Its Knowledge of +Epstein's Sex-Trafficking, including that Epstein's High-Powered Lawyers Helped +Him Avoid Federal Sex-Trafficking Charges +10 +ili. JPMorgan Knew Epstein Was Connected to the MC2 Modeling Agency He Was +Accused of Using to Traffic and Abuse "Underage Models" +11 +iv. JPMorgan Knew of Reports that Epstein Settled Dozens of Civil Lawsuits Alleging +Child Sex-Trafficking. +v. JPMorgan Knew Epstein's 2008 Conviction Covered Sex-Trafficking Conduct. +vi. Based on Its Own Human Trafficking Work, JPMorgan Knew Epstein Was Engaged +Human Trafficking.. +, 12 +... 13 +13 +vii. In 2008, JPMorgan Knew the Feds Were Connecting Certain Transactions to +Epstein's Sex-Trafficking.......... +vili. JPMorgan Employees Had Personal Knowledge of Epstein's Sex-Trafficking... 15 +C. JPMorgan Participated in Epstein's Sex-Trafficking Venture +D. JPMorgan Benefited from Participation in Epstein's Sex-Trafficking Venture. +14 +16 +21 +II. JPMORGAN OBSTRUCTED ENFORCEMENT OF THE TVPA IN VIOLATION OF +18 U.S.C. § 1591(d). +II. THE USVI'S REQUESTED RELIEF FOR VIOLATIONS OF THE TVPA +IV. JPMORGAN'S EQUITABLE AND FAULT-SHIFTING DEFENSES DO NOT APPLY +TO THE GOVERNMENT'S TVPA PARENS PATRIAE CLAIMS +24 +....27 +27 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 3 of 45 +A. JPMorgan's Defenses are Barred as Applied to Sex Offender Registry Issues +30 +i. The Government's Investigations or Monitoring of Epstein Cannot Form the Basis of +Viable Affirmative Defenses ...... +ii. The Discretionary Act of Granting a Waiver of Notification Periods for Overseas +Travel is Not Grounds to Shift Fault to the Government +33 +B. JPMorgan's Defenses are Barred as Applied to the Economic Development +Commission's Grant of Tax Benefits to Epstein's Companies +C. JPMorgan Has No Viable Defenses Based on Activity of Cecile De Jongh +CONCLUSION. +35 +38 +39 +ii + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 4 of 45 +TABLE OF AUTHORITIES +Cases +Alfred L. Snapp v. Puerto Rico, +458 U.S. 592 (1982) +City of New York v. FedEx Ground Package System, Inc., +314 F.R.D. 348 (S.D.N.Y. 2016). +Coffey v. C.I.R., +663 F.3d 947 (8th Cir. 2011). +Donovan v. Fed. Clearing Die Casting Co., +655 F.2d 793 (7th Cir. 1981). +FTC v. Crescent Publ. Grp., Inc., +129 F. Supp. 2d 311 (S.D.N.Y. 2001) +Groh v. Ramirez, +540 U.S. 551 (2004) +Harlow v. Fitzgerald, +457 U.S. 800 (1982) +HH v. G6 Hospitality, Inc., +No 2:19-cv-755, 2019 WL 6682152 (S.D. Ohio Dec 6, 2019) +Maldonado by and through Ochoa v. City of Sibley, +58 F.4th 1017 (8th Cir. 2023).. +McGaughey v. District of Columbia, +684 F.3d 1355 (D.C. Cir. 2012) .. +Olin Corp. v. Lamorak Ins. Co., +332 F. Supp. 3d 818, 839 (S.D.N.Y. 2018) (Rakoff, J.).. +v. Gov't of the Virgin Islands, +847 F.2d 104 (3d Cir. 1988). +State of New York v. UPS, Inc., +160 F. Supp. 3d 629 (S.D.N.Y. 2016).. +U.S. v. One +Crystal Covered Bat Tour Glove & Other Michael +2013 WL 12196595 (C.D. Cal. Aug. 19, 2013) +United States v. Angell, +292 F.3d 333 (2d Cir. 2002) +United States v. Philip Morris Inc., +300 F. Supp. 2d 61 (D.D.C. 2004) +United States v. Vineland Chem. Co., Inc., +692 F. Supp. 415 (D.N.J. 1988) +27 +27, 29, 30, 34 +35 +31 +29 +31 +35 +21 +34 +34,37 +.. 4 +34,36 +30 +Memorabilia, +32 +29 +29 +30 +ili + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 5 of 45 +Statutes +14 V.I.C. § 1724 +14 V.I.C. § 1724(b)(4) +14 V.I.C. § 1728(a) ... +18 U.S.C. § 1591(a)(1) +18 U.S.C. § 1591(a)(2). +18 U.S.C. § 1591(c) .. +18 U.S.C. § 1591(d).. +18 U.S.C. § 1595(d).. +26 U.S.C. § 934(b)(1) . +29 V.I.C. § 701(a). +29 V.I.C. § 701(c) +29 V.I.C. § 705(a) +29 V.I.C. § 708. +29 V.I.C. § 722(4). +29 V.I.C. § 1101(a) +29 V.I.C. § 1101(b) +Rules +Fed. R. Civ. P. 56(c). +Regulations +12 C.F.R. § 21.11(c)(2) +12 C.F.R. § 21.11(d). +31 +33 +... 33 +4, 7 +.. 3,4,27 +...7 +3,24,27 +29,30 +.. 35 +35 +37 +36 +37 +37 +35 +35 +3 +20 +20 +iv + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 6 of 45 +INTRODUCTION +In July 2006, after his arrest for felony sex crimes and extensive news coverage detailing +unlawful sex acts with underage girls, Jeffrey Epstein admitted to James (Jes) Staley (then CEO +Asset and Wealth Management ("A WM")), who reported it to Mary Erdoes (then CEO Global +Private Bank ("PB")), that he had engaged in sex with multiple young women for money, only +denying the girls' "ages." At that time, JPMorgan could have immediately exited Epstein-but the +Bank knew, from Douglas (Sandy) Warner, when he was head of JPMorgan, Epstein is "one of +the most connected people I know in New York." In 2003, Epstein was, by double, the top revenue +generator in the Private Bank, and the source of Google co-founder Sergey +(*one of the largest +[relationships] in the Private Bank, of +$4BN*"), Glenn +(billionaire founder of Highbridge), +and many other ultra-wealthy clients and connections, which would come to include Bill Gates, +Black, Larry Summers, the Sultan of Dubai, Prince Andrew, Ehud Barak, +Pritzker, +Lord Peter Mandelson, and Prime Minister Netanyahu. In 2004, Epstein—together with Jamie +Dimon (then CEO-in-waiting) +—was an integral part of JPMorgan's game-changing acquisition of +Highbridge. The next year, +Epstein was too big to fail. +So, JPMorgan did not exit Epstein in 2006. Or 2007. Or 2008. Or 2009. Or 2010. Or 2011. +Or 2012. Or the first half of 2013, +SUF $386.' +And, even after his exit right up until his arrest in 2019, JPMorgan continued to work with Epstein. +Only months before his arrest in July 2019, +1 "SUF" references are to the Statement of Material Facts as to which Government of the United +States Virgin Islands Contends there is No Genuine Dispute (filed concurrently). + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 7 of 45 +Rather than exit Epstein in 2006, JPMorgan handled millions of dollars in payments to +Epstein's other "rock star" lawyers who the Bank knew were working to discredit Epstein's +victims and help Epstein avoid federal sex-trafficking charges. +JPMorgan banked all the girls and women publicly alleged in 2006 to be recruiters, +accomplices, or victims, including +, and Ghislaine +Maxwell. JPMorgan knew that +-who Epstein was reported to have referred to as his +"Yugoslavian sex slave"—in fact came from Yugoslavia as a teenager in 2004 supposedly to work +as a "model" and was sponsored by Epstein. For years, JPMorgan handled Epstein business with +MC2 Model Management knowing Epstein was accused of using the supposed modeling agency +to traffic and abuse underage girls. +At the same time, and for the next seven years, JPMorgan—self-described as Epstein's "#1 +bank" at the time, SUF 9[174 continued to participate in Epstein's sex-trafficking venture. It +"really never stopped" handling his excessive cash withdrawals despite tying them to his felony +sex crimes; did not question his cash-for-fuel to travel to foreign countries explanation, even when +he was in jail and on house arrest; made millions of dollars more in payments to co-conspirators, +including Maxwell, recruiters and victims, including many girls and women with Eastern +European surnames or located in Eastern Europe, from where JPMorgan knew Epstein was +reported to have trafficked girls; and continued to extend the loan to MC2, which, for all it knew, +2 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 8 of 45 +was a "payment for services as a procurer." Even when JPMorgan knew that federal prosecutors +had subpoenaed Bear Stearns (which it acquired in 2008) for account and specific transaction +information tied to Epstein, JPMorgan +and +went right on handling many more. The entire time, the cynical jokes within the company also +never stopped-from +asking if Epstein was at a party with "Miley Cyrus," to +David Brigstocke (then CFO AWM) comparing another client's house to Epstein's: "Reminded +me of JE's house, except it was more tasteful, and fewer nymphettes." SUF 99181-82, 190, see +also SUF 19179-180, 183-89. Only in August 2019—after Epstein's arrest and death and when +there were no more referrals or other benefits to be had +-even though it had all the information +in real-time, not "[h]indsight" as Dimon (CEO) misrepresented to CNN. SUF 9[418. Accordingly, +the Government is entitled to judgment as a matter of law for JPMorgan's participation in Epstein's +sex-trafficking venture and obstruction of federal prosecutors' enforcement of the law in violation +of the Trafficking Victims Protection Act ("TVPA"), 18 U.S.C. §§ 1591(a)(2) and (d). +The Government also is entitled to judgment as a matter of law on JPMorgan's equitable +and fault-shifting affirmative defenses (Defenses 5 to 8). The legal deficiencies that left the Court +"skeptical" that the defenses would survive summary judgment persist and no facts have been +developed during discovery that would revive these deficient defenses. +LEGAL STANDARD +Summary judgment is appropriate "if the pleadings, the discovery and disclosure materials +on file, and any affidavits show that there is no genuine issue as to any material fact and that the +movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(c). "Where the moving party +3 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 9 of 45 +has documented particular facts in the record, the burden shifts to the opposing party to adduce +contrary record evidence sufficient to create a genuine dispute of material fact." Olin Corp. v. +Lamorak Ins. Co., 332 F. Supp. 3d 818, 839 (S.D.N.Y. 2018) (Rakoff, J.). "To do so, the opposing +party cannot merely make conclusory assertions to the contraryl.J" Id. +ARGUMENT +JPMORGAN PARTICIPATED IN EPSTEIN'S SEX-TRAFFICKING VENTURE +IN VIOLATION OF TVPA 18 U.S.C. § 1591(a)(2) +A. Epstein Engaged in a Sex-Trafficking Venture +JPMorgan does not dispute Epstein was engaged in sex-trafficking: "Epstein was engaged +in horrendous criminal activity, including sex trafficking. That's not something being contested at +all by JPMorgan." SUF 91. "Epstein's behavior was monstrous ... the survivors ... suffered +unimaginable abuse at the hands of this man ...[who] commit[ted] heinous crimes." SUF 92. +JPMorgan acknowledged +in its own due diligence, respectively, +that Epstein +and ran a "sex-trafficking ring." SUF 9913-5. +Epstein was arrested on July 6, 2019 on federal charges of sex-trafficking of minors and on August +10, 2019 died in prison. SUF 99I6-7. Ghislaine Maxwell was convicted in 2022 for conspiring with +Epstein to engage in sex-trafficking. SUF 98. In 2008, Epstein was convicted for solicitation of an +underage girl for prostitution, SUF 19, a covered act under the TVPA. 18 U.S.C. § 1591(a)(1). In +upholding his Level 3 sex offender status imposed with that conviction, a New York appeals court +found "clear and convincing" evidence Epstein had "committed multiple offenses against a series +of underage girls." SUF 9910-11. Over the years, many victims have come forward and described +being sex-trafficked by Epstein, including in the U.S. Virgin Islands ("USVI"). +4 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 10 of 45 +SUF 9912-31. JPMorgan also +handled millions of dollars in payments from Epstein to known co-conspirators, recruiters, victims, +girls and women until 2019, including payments to women in years that coincided with their trips +to the USVI. SUF 432 and infra Part I.C. +B. +JPMorgan Knew or Recklessly Disregarded that Epstein Ran a Sex- +Trafficking Venture +JPMorgan had "knowledge of Epstein's sex-trafficking venture, either directly or by +recklessly disregarding what was plainly to be seen." Op. and Order, May 1, 2023 (Dkt. 130) at +28 ("Order"). The Government uses "knew" or "knowledge" herein to mean direct knowledge or +reckless disregard. +In 2006, JPMorgan Knew Epstein Was Engaged in Sex-Trafficking +In July 2006, Epstein was indicted for felony solicitation of prostitution and arrested. +Numerous JPMorgan senior executives (including Staley, Erdoes, Catherine Keating (then CEO +US PB)) knew of Epstein's arrest and related news coverage, including a Palm Beach Post article +which stated: "Epstein paid to have underage girls and young women brought to his home, where +he received massages and sometimes sex" and "police thought there was probable cause to charge +Epstein with unlawful sex acts with a minor and lewd and lascivious molestation." SUF 9933, 41- +46. JPMorgan's own due diligence process required that it monitor news reports about customers. +SUF 19134-40. The Palm Beach Post article detailed evidence from police documents, including: +• A college student gave Epstein a naked massage and then "brought him six girls, ages 14 to +16, for massage and sex-tinged sessions" at Epstein's home. +• Police obtained statements from five alleged victims and 17 witnesses. Police contend Epstein +"had sex with the girls" on three occasions. +met Epstein at age 17 and was recruited to massage him. Epstein told her he +would "pay her to bring him more girls—the younger the better." She stated she once brought +5 + + +Case 1:22-cV-10904-JSR Document 220 Filed 07/24/23 Page 11 of 45 +a 23-year-old woman to him and "Epstein said she was too old...." She brought six girls to +Epstein and said the girls were paid $200 for each session. +told police, "I'm like a Heidi Fleiss." +• A 27-year-old Epstein employee, +massage table. +would arrange the sessions and prepare the +• One 14-year-old victim recounted the details of her encounter in February 2005 including +being paid $300 for a massage in her bra and panties. For bringing this child to Epstein, +received $200. +• Police scoured the trash from Epstein's house and found notes with names and phone numbers, +sex toys and female hygiene products. Notes stated that one girl could not "come over at 7 p.m. +because of soccer. Another said a girl had to work Sunday—'Monday after school?' Another +said a girl leaves school at 11:30 a.m. and would come over the next day[.J" +SUF 9943-46. Another July 2006 news report said the police submitted arrest warrant requests for +and +The same report stated a girl told police she was paid by Epstein +to have sex with +as Epstein watched, and "Epstein bragged he brought +[into the United States to be his Yugoslavian sex slave." SUF 99|48-49; see also SUF +950 (August news report). JPMorgan knew from its own work on human trafficking that "Sexual +Slavery" means "the coercion of the unwilling into various sexual practices." SUF 951. News +around the time of Epstein's arrest also reported that "It]wo of Epstein's former employees told +investigators that young-looking girls showed up to perform massages two or three times a day +when Epstein was in town." SUF 952. The news explained that Epstein paid $200 or $300 cash to +the girls and $200 cash to +a. +for recruiting the girls. SUF 1943, 45. +Epstein Admitted the Conduct (but Not the "Ages") to Staley +On July 25, 2006, Staley met with Epstein in person, and Epstein admitted to the alleged +conduct of engaging in sex for money with young women-only denying the "ages." SUF 953. +Staley communicated the exchange to Erdoes the next day: "I went and saw him last night. I've +never seen him so shaken. He also adamantly denies the ages." SUF 9|54. Solicitation of a minor +6 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 12 of 45 +for prostitution is a covered act under the TVPA, and Epstein "had a reasonable opportunity to +observe [the victim]," so it need not be proved "the defendant knew, or recklessly disregarded the +fact, that the person had not attained the age of 18 years." 18 U.S.C. $§ 1591(a)(1) and (c). Staley +also spoke to Dimon about the "very public" indictment of the Bank's client, Epstein. SUF 955. +JPMorgan's Own Diligence Gave It Reason to Suspect Epstein +and Ghislaine Maxwell Early On +By 2006, JPMorgan already had reason to suspect Epstein's sex-trafficking—and +Maxwell's involvement. In 2003, as part of the Bank's due diligence for an Epstein account, +JPMorgan reviewed the Vanity Fair profile "The Talented Mr. Epstein," which reported Epstein's +penchant for "young." "foreign," "model types," and his "best friend" Maxwell "summon[ing]" a +young woman for him and throwing a party attended by Prince Andrew and "filled" with "young +Russian models." SUF 99|56-59. In 2003, JPMorgan also knew that Maxwell was involved with +Epstein in structuring cash withdrawals, SUF 9960-62, a red flag for trafficking, SUF 9963-64. +Yet, the Private Bank opened an account for Maxwell in 2003, on Epstein's referral, noting +Maxwell was a "companion/long-time friend of Jeffrey Epstein." SUF 165. By Epstein's arrest, +JPMorgan knew it had made over $25 million in payments to Maxwell from Epstein. SUF 967. +News reports related to Epstein's 2006 arrest again described Epstein's relationship with Maxwell. +SUF 9|52. JPMorgan continued to handle payments from Epstein to Maxwell, including $7 million +for the purchase of a helicopter. SUF 9|223. Later reports again alleged Maxwell "solicited young +girls for Epstein"—identified as a "human rights" issue by JPMorgan. SUF 966. +c. +JPMorgan Had Corroborating Information on +and +JPMorgan had significant corroborating evidence of Epstein's sex crimes by July 2006 +and knowledge of ongoing conduct after July 2006. JPMorgan knew that alleged accomplice +7 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 13 of 45 +worked for Epstein and had—just months prior to his arrest +SUF 968. +was +also a customer of the Bank. SUF 9[69-70. JPMorgan, in 2005, made two separate $25,000 +payments from Epstein's accounts to +SUF 171. After police reports identified her as a +recruiter in 2006, JPMorgan continued to handle payments to +totaling over $675,000 from +Epstein's accounts. SUF 9|72. +JPMorgan also had information related to trafficking victim and accomplice +also a customer of the Bank. SUF 973. In 2004, sponsored by Epstein, JPMorgan opened accounts +and credit cards for two teenagers, +another victim, SUF 9|23, and +"models in NYC and friends of Jeffrey Epstein." SUF 99|74, 75, 77. JPMorgan's Due Diligence +Report ("DDR") on +was approved by the Private Bank even though the report had no +birthdate, confirmed SSN, or a Passport or Driver's License Number. SUF 176. Epstein's Banker +at the time (Mary (Rieth) +never met +as JPMorgan's process contemplated +even after news reports that Epstein referred to her as his "Yugoslavian sex slave." SUF 976. +JPMorgan knew that Epstein said +came to the US from Yugoslavia and lived at a +building owned by Epstein's brother. SUF 177, 79. Further, JPMorgan knew it had made more +than $36,000, $67,000, and $82,000 in payments from Epstein's account to +in 2004, +2005, and 2006, respectively, even though Epstein represented her net worth was $100,000 from +supposed "modeling assignments." SUF T180, 78. JPMorgan also knew +'s "debit +transactions" at the time—which AML compliance only reviewed more than four years later— +were "enlighting [sic] as compared to countless stories related to [Epstein's] escapades. Lots of +salon, lingerie shops, drug stores ny palm beach and in st +(his places of residence). Plus +lots of video like girls gone +and some other shops not fit for my good catholic upbringing!" +8 + + +Case 1:22-cV-10904-JSR Document 220 Filed 07/24/23 Page 14 of 45 +SUF 181. JPMorgan's own Human Trafficking +paper discussed "upscale" sex-trafficking +operations "incurring] expenses such as jewelry, lingerie, cosmetics, [and] sex toys." SUF 982. +Even after she was identified in 2006, JPMorgan continued to handle payments to +totaling over $600,000 from Epstein's JPMorgan accounts. SUF 983. JPMorgan +." SUF +for +99184-85. JPMorgan also knew that Epstein sponsored credit cards for +and +"travel| ] through Paris, Europe and US Virgin Islands and US monthly." SUF 86. +JPMorgan Had Information about Epstein's Cash Withdrawals +On October 17, 2006, in light of the derogatory information related to Epstein's "felony +charges of soliciting underage prostitutes," JPMorgan Private Bank held a "Rapid Response" +meeting, which were "escalations of derogatory information to management." Private Bank +identified Epstein's frequent cash withdrawals as worthy of note in conjunction with his "felony +charges of soliciting underage prostitutes." "Cash withdrawals are routinely made in amounts for +$40,000 to $80,000 several times a month, which total over $750,000 year to date." SUF 9990-93. +JPMorgan compliance staff acknowledged Epstein was "known to pay cash for his massages" and +"minors are the issue." SUF 994. Three "massages" a day with girls paid $200-$300 cash and +recruiters paid $200 cash—as JPMorgan knew was reported—is about $40,000 cash per month. +JPMorgan knew that in the time period of the incidents investigated by the Palm Beach police, and +prior to Epstein's plea, it had handled nearly $1.75 million in cash withdrawals for Epstein. SUF +995. +I SUF 1196-97. +9 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 15 of 45 +The large cash withdrawals "really never stopped"—and were ultimately the claimed +reason for JPMorgan's parting with Epstein in 2013 when "combined with his personal history." +SUF 9998-99. Epstein's 2011 explanation that the cash was for jet fuel for his foreign travel was +and not supported by any receipts +or other documentation. +Further, JPMorgan knew Epstein was in jail and on house arrest from July 2008 through +July 2010 and thus not traveling overseas. SUF 91100-106. In any event, JPMorgan's diligence +cited reports that Epstein traveled to foreign countries to traffic young women, SUF 9|107, so +whether to pay for that travel, or to pay victims and recruiters, or both, JPMorgan knew the cash +was connected to Epstein's sex-trafficking. +ii. +After July 2006, JPMorgan Learned More Information that Fed Its +Knowledge of Epstein's Sex-Trafficking, including that Epstein's High- +Powered Lawyers Helped Him Avoid Federal Sex-Trafficking Charges +JPMorgan also knew that Epstein's wealth and "high-powered" lawyers allowed him to +escape more serious charges including federal sex-trafficking charges. In 2006, JPMorgan's +diligence included multiple news reports that Epstein "assembled a team of star lawyers"- +including Alan Dershowitz, Gerald Lefcourt, Roy Black, and Jack Goldberger—"to undermine the +credibility of the 14- to 17-year-old girls" and challenge the "distorted" view of the case "presented +by the Palm Beach Police." SUF TIl 108, 110. Reports said Epstein used Black to hire private +investigators to "pos[e] as police officers" and to review with witnesses what to say to actual police +officers. SUF 9|110. In 2006 and 2007, JPMorgan reviewed reports that federal prosecutors were +looking to bring child sex-trafficking charges against Epstein and that his lawyers were +"negotiating a deal" to avoid those charges. SUF 9[112, see also SUF 150 (FBI considering +investigating for federal child sex crimes). JPMorgan later acknowledged reports that Epstein +10 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 16 of 45 +"supposedly bought his way to a lesser sentencing" and "paid a whole series of girls to stay quiet." +SUF 113. JPMorgan was handling millions of dollars in payments to those lawyers at that timeincluding numerous +$100,000 payments—and continued to handle tens of millions in +payments to lawyers. SUF 99L 127. +On September 24, 2007, Epstein agreed to plead guilty to two prostitution charges in state +court, including the solicitation of a minor to engage in prostitution, in exchange for a federal nonprosecution agreement (NPA") providing him with immunity from federal child sex-trafficking +charges. Under the NPA, Epstein also waived his right to contest liability and damages in civil +lawsuits by minor girls identified by the NPA. The NPA identified +, and Lesley +Groff as Epstein's co-conspirators in soliciting underage girls for commercial sex. SUF 99114, +118-21. JPMorgan knew of reports of the plea deal beginning in 2007. SUF 99115; see also SUF +99116-17 (2008). The NPA later became public, and JPMorgan was aware of it. SUF 99122-24. +In October 2007, Anne Verdon (then General Counsel PB) received requested information +about Epstein, his transactions, and the news coverage. This research connected the dots between +Epstein's financial transactions at the Bank—his large, frequent cash withdrawals, credit cards for +and +and transfers to +and his illegal conduct. The diligence showed +, who had talked to police ('T'm like a Heidi Fleiss"), had a "revoked" credit card, while +, who did not talk to police, still had an "active" credit card under Epstein. SUF 99l 125-27, +43. JPMorgan continued with business as usual. +ili. +JPMorgan Knew Epstein Was Connected to the MC2 Modeling Agency +He Was Accused of Using to Traffic and Abuse "Underage Models" +A news report surfaced in 2007 of "industry speculation that massage maven Jeffrey +Epstein is a secret financial backer of the agency being run by scandal-scarred Jean-Luc Brunel, +who was once accused of taking advantage of underage models." "Epstein reportedly gave millions +11 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 17 of 45 +to start MC2, which opened in October 2005." "[Epstein's] a desperate old man that fantasizes and +takes advantage of young girls.'" Epstein's rep, Howard Rubenstein, said, "He has no business +relationship with [Brunel and MC2]." SUF 9|128. But JPMorgan knew at the time of the report that +Rubenstein was covering up for Epstein. In 2005, JPMorgan had extended a $1 million Stand By +Letter of Credit ("SBLC") for Epstein to backstop a loan to MC2. SUF 9129. +Only two weeks after the news about Epstein's ties to Brunel and MC2, +, among +others, discussed the MC2 SBLC, which the Bank renewed through March 2011. SUF 99 130-32. +Even though Epstein was set to plead guilty to felony sex crimes, JPMorgan did not determineand as late as 2011 still did not know—if the $1 million was a "payment for services as a procurer." +SUF 419138-39. JPMorgan would review multiple reports about child sex-trafficking by Epstein, +Brunel, and MC2—"Brunel, owner of MC2 and Jeffrey Epstein engaged in racketeering that +involved luring in minor children for sexual play for money"—all the while continuing to extend +the $1 million SBLC. SUF 99 130-31, 134-39. +-who JPMorgan was supposed to but +did not meet with- +SUF 9140, +iv. +JPMorgan Knew of Reports that Epstein Settled Dozens of Civil +Lawsuits Alleging Child Sex-Trafficking +Then came the reports of the civil lawsuits—another category of information that was +supposed to be part of JPMorgan's due diligence. SUF 914. In 2007, Epstein was "bracing for a +slew of lawsuits from as many as 40 young women[.J" SUF 9[142. By early 2008, Erdoes and Lisa +Waters (then a Managing Director AWM), among others, knew of multiple news outlets reporting +the first lawsuit "against JE- sexual abuse of minor etc. etc." Then the next: "the teen ... says she +was lured to Epstein's Palm Beach mansion and then sexually assaulted in his massage room." +SUF 99[143-45. In 2010, JPMorgan knew of reports that "Epstein had settled more than two dozen +12 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 18 of 45 +lawsuits and claims against him by teen-agers who say they were lured to his Palm Beach mansion +to give him sexually charged massages and/or sex in exchange for money." "These same civil +complaints allege that young girls from South America, Europe, and the former Soviet republics +... were recruited for Epstein's sexual pleasure." SUF 99137-38. +V. +JPMorgan Knew Epstein's 2008 Conviction Covered Sex-Trafficking +Conduct +On June 30, 2008, Epstein pled guilty to felony solicitation of prostitution and procurement +of a 14-year-old minor to engage in prostitution and was "sentenced to 18 months in jail" and +"required to register as a sex offender." SUF 9146-47. +las described above, +SUF 9913-4, 148. In 2011, William Langford (then Global Head of Compliance) +communicated to Steve Cutler (then General Counsel) "concern about retaining Epstein as a +client. Cutler testified: "Those concerns are heightened, if you will, by the human trafficking +initiative that we're doing, given that he was convicted of these crimes." SUF 9149. +vi. +Based on Its Own Human Trafficking Work, JPMorgan Knew Epstein +Was Engaged Human Trafficking +Around the time of Epstein's conviction in 2008, JPMorgan's AML (Anti-Money +Laundering) compliance group (under Langford) created a "Human Trafficking Overview." The +overview reported that "nearly two-thirds of the women trafficked for prostitution worldwide come +from Eastern Europe" and "former Eastern bloc countries such as Albania, Moldova, Romania, +Bulgaria, Russia, Belarus and Ukraine have been identified as major trafficking source countries +for women and children." SUF 9151. JPMorgan knew and had assembled evidence that Epstein +had made at least tens of thousands of dollars of payments to +and was reported to refer +13 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 19 of 45 +to her as his "Yugoslavian sex slave." SUF 9148-50, 125-26. JPMorgan also knew it had made +more than $1.2 million in payments to girls or women, many with Eastern European surnames, +from Epstein's accounts from 2003 to 2008. SUF 91225. +SUF +991227, 229. Beginning in 2008, several payments were sent to high-risk locations, such as Belarus, +Lithuania, and Russia. SUF 9|230. +AML compliance—JPMorgan's in-house human trafficking experts—wanted Epstein +gone from the Bank. SUF 99|162-66. In 2010, when additional "news stories ... connected] Jeffrey +Epstein to human trafficking, " SUF 99152-53, AML compliance was concerned about continuing +to bank a human trafficker while trumpeting the Bank's efforts to rein in human trafficking through +the bank. "My fear is will all our touting of good will on the [Human Trafficking] work, if anyone +should ever say yet we bank Epstein, a known child sleaze." SUF II154-55, 159-60. "I sent you +an e-mail yesterday on that scum Epstein .... I reminded McCleerey [then Head of PB Risk +Management] that he listened to 2 days of [Human Trafficking] at the forum and this account could +be problematic in several ways." SUF 9157. AML compliance requested the Bank "responsor this +client in light of the new allegations of human trafficking which the firm has been actively assisting +law enforcement in uncovering others engaged in this practice." SUF 9|158. Langford, the public +face of JPMorgan's human trafficking initiative and the Global Head of Compliance, believed +JPMorgan "should exit Jeffrey Epstein as a client." SUF 9164. But business—including Erdoes +(then CEO AWM)-decided otherwise. SUF 19[167-68, 260, 262-63. +vii. +In 2008, JPMorgan Knew the Feds Were Connecting Certain +Transactions to Epstein's Sex-Trafficking +JPMorgan also knew that it made many payments from Epstein's accounts that federal +prosecutors believed could be evidence of sex trafficking. In 2008, JPMorgan acquired Bear +14 + + +Case 1:22-CV-10904-JSR Document 220 Filed 07/24/23 Page 20 of 45 +Stearns, where it knew Epstein conducted his brokerage business. SUF 99[169-70. Around the time +of Epstein's guilty plea, Arthur Middlemiss, formerly a compliance officer at Bear Stearns, +assumed a similar role at JPMorgan and worked on Epstein investigations. SUF 99171-72. +SUF 99173, 175. +SUF 9I 176-77. +SUF 1236, +SUF 9191235, 178. +SUF 991235-36. +vili. +JPMorgan Employees Had Personal Knowledge of Epstein's Sex- +Trafficking +Many e-mails over JPMorgan e-mail between Staley and Epstein demonstrate that Staley +had personal knowledge of Epstein's sex-trafficking. SUF I9 195, 197-203. Staley met Epstein's +co-conspirators at Epstein's townhouse. SUF 4Il 204-06. +SUF 9207. JPMorgan handled more than $210,000 in payments to +from Epstein. SUF 9231. +JPMorgan admits Staley was "the senior person at JPMorgan with a business relationship with +Epstein," SUF 99|191-92, 208-13; thus, Staley's knowledge is imputed to JPMorgan. Order at 29. +Brigstocke (CFO of AWM) wrote Erdoes comparing a client's house to Epstein's: "Reminded me +of JE's house, except it was more tasteful, and fewer nymphettes." SUF 9190. +15 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 21 of 45 +C. JPMorgan Participated in Epstein's Sex-Trafficking Venture +Even if participation requires active engagement, Order at 24, there is no genuine dispute +that JPMorgan actively participated in Epstein's sex-trafficking venture from 2006 until 2019. The +Court found allegations that the Bank allowed Epstein to use its accounts to send dozens of +payments to then-known co-conspirators; +; provided excessive and unusual amounts of cash to Epstein; and structured +cash withdrawals so that those withdrawals would not appear suspicious "went well beyond merely +providing their usual [banking] services to Jeffrey Epstein and his affiliated entities" and were +sufficient to allege active engagement. Order at 25-26. The New York State Department of +Financial Services ("NYSDFS") entered into a Consent Order and issued a $150 million penalty +to Deutsche Bank for its "inexcusable fail[ure] to detect or prevent millions of dollars of suspicious +transactions" related to Epstein, including: payments to publicly alleged co-conspirators; +settlement payments and dozens of payments to law firms for legal expenses of Epstein and coconspirators; payments to Russian models, including for school tuition and hotel and rent expenses, +and to numerous women with +Eastern European surnames; and periodic suspicious cash +withdrawals totaling more than $800,000 over four years. SUF 4214. +Payments to Co-Conspirators +and +: From August 2006 +through 2013, JPMorgan handled $678,741.57 and $607,804.30 in payments, respectively, from +Epstein's JPMorgan accounts to +and +Epstein's co-conspirators, +recruiters, and/or victim +D. SUF 19216, 218. Even after it decided to terminate +Epstein's accounts in July 2013, JPMorgan still handled a payment of $15,000 from Epstein's +JPMorgan accounts to +SUF 9217. +16 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 22 of 45 +| SUF 99220, 84. In addition to payments from Epstein, JPMorgan also opened credit +cards for +and +"through NES, LLC c/o Jeffrey Epstein" only months after +Epstein was indicted. NES, LLC is an Epstein entity for which JPMorgan had not conducted the +required due diligence, and +SUF 99186, 88-89, 60-61. +Payments to Co-Conspirator Ghislaine Maxwell: After August 2006, JPMorgan +continued to handle payments to Maxwell, who, by July 2006, it had reason to suspect was +involved with Epstein in the alleged sex crimes. See supra Part I(B)(i)(b). JPMorgan's payments +to Maxwell included more than $7 million to purchase a helicopter. SUF 99222-23. +Millions of Dollars in Payments to Girls and Women, Many with Eastern European +Surnames and/or Located in Eastern Europ +1. SUF 9226, +SUF 99107, 151, 153, 48-50, 125-26. JPMorgan sent several of the +payments by foreign wire to girls or women to locations in Eastern Europe including Belarus, +Lithuania, and Russia. SUF 9230. JPMorgan also handled payments to women for school tuition +and rent expenses. SUF 191232, 234. +SUF 9228. +SUF 91229. + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 23 of 45 +$1000 and Smaller Dollar Payments to Girls or Women and $100,000 Payments: +SUF 99|235-36. As explained +above, JPMorgan knew from the federal prosecutors' subpoena to Bear Stearns that law +enforcement considered these payments suspicious and evidence of Epstein's federal sex crimes. +SUF 49L 176-177. +MC2 Modeling Agency SBLC: As described above, from 2005 to March 2011, JPMorgan +extended an SBLC to Brunel and MC2 despite reports it supported "payment for services as a +procurer." By 2007, there were reports that Epstein was engaged in sexual abuse of minors through +MC2, yet JPMorgan continued to extend the SBLC. +SUF 9237, who it knew was covering up Epstein's +involvement with MC2. See supra Part I(B)(iii). +Payments to "High-Powered" Lawyers Covering Up Epstein's Sex Crimes: Following +Epstein's arrest for felony sex crimes and confession to Staley and prior to the NPA, +SUF 991238-39. After the NPA through 2013, +Excessive and Unusual Cash Withdrawals: The NYSDFS found inexcusable Deutsche +Bank's failure to monitor "suspicious cash withdrawals [of] more than $800,000 over four years." +SUF 9214. Between September 2003 and November 2013, or approximately ten years, JPMorgan +handled more than $5 million in outgoing cash transactions for Epstein, SUF 9242—ignoring its +18 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 24 of 45 +own policy discouraging large cash withdrawals, SUF |241. From August 2006 to 2013, JPMorgan +facilitated nearly $2.5 million in cash withdrawals for Epstein, SUF 1247, even though it was +widely publicized that Epstein paid for sexual encounters with minors in cash and +| See supra Part I(B)(i)(d). +SUF 4249. +JPMorgan did not seek an explanation for Epstein's excessive +cash withdrawals until 2011, again in violation of its own policy. SUF 9|241. | +SUF 9101; see also supra Part I(B)(i)(d). L +JPMorgan +must file SARs to report suspicious financial transactions "[w]henever the national bank detects +... a transaction or transactions conducted through the bank and involving or aggregating $5,000 +or more in funds or other assets where the bank believes... that it was used to facilitate a criminal +19 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 25 of 45 +transaction, and the bank has a substantial basis for identifying a possible suspect." 12 C.F.R. § +21.11(c)(2). JPMorgan must file a SAR "no later than 30 calendar days after the date of the initial +detection of facts that may constitute a basis for filing a SAR. 12 C.F.R. § 21.11(d). +From 2003 to 2013, JPMorgan helped Epstein withdraw over $5 million in cash, make +millions of dollars in payments to co-conspirators and accomplices, send more than $3 million in +wires to women and girls, and +At the 2006 Rapid Response meeting following Epstein's indictment on "felony charges +of soliciting underage prostitutes," JPMorgan explicitly noted "[c] ash withdrawals ... made in +amounts for $40,000 to $80,000 several times a month" +See supra Part I(B)(i)(d) and (ii). +SUF 9197. +20 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 26 of 45 +D. JPMorgan Benefited from Participation in Epstein's Sex-Trafficking Venture +JPMorgan argued the Government must allege that it received revenue from Epstein in +exchange for the Bank's furtherance of Epstein's sex-trafficking venture. The Court "is not +convinced that the benefit element should be read in this way," Order at 31, and, indeed, "the +statutory language imposes no such [causal relationship] requirement." HH v. G6 Hospitality, Inc., +No 2:19-cv-755, 2019 WL 6682152, at *2 (S.D. Ohio Dec 6, 2019). JPMorgan admits it received +fees and other revenue from providing services to Epstein and his affiliated entities. Order at 31; +SUF 991252-53. In any event, from at least 2006 to Epstein's arrest in 2019, JPMorgan knowingly +benefited from furthering Epstein's sex-trafficking venture. +In or about the 2000 time period, Sandy Warner, then head of JPMorgan, told Staley (then +head PB), "[YJou should meet Epstein. He's one of the most connected people I know of in New +York." SUF 9275. Warner was right. By 2003, Epstein introduced Staley and Google's founders, +Sergey Brin and Larry Page, and helped source billionaire hedge fund (Highbridge) owner Glenn +SUF 911280-81, 311, 314-16. By then, Epstein was also bringing in over $8 million in +revenues to the Private Bank +—the top revenue and nearly double the amount of the next highest +client. In 2003, "Epstein, through the trading of his accounts and that of Leslie Wexner, generates +one of the largest annual revenue flows of private clients in the private bank." SUF 991254-58. +The following year, Epstein facilitated JPMorgan's acquisition of Highbridge, a gamechanging acquisition for JPMorgan. Highbridge, a hedge fund with $7 billion in assets under +21 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 27 of 45 +management, was co-founded by Epstein's close friend +and Epstein was a founding +investor. Epstein advised both JPMorgan and Highbridge on the acquisition and worked with +Dimon, then CEO-in-waiting, Bill +, then CEO, and other "JPMorgan Chase Executive +Management" on the acquisition. Epstein was paid a $15 million consulting fee for his work on +the acquisition. SUF 19|370-381. Epstein also continued to facilitate introductions to the Bank, +including a meeting between Staley and the Sultan of Dubai. SUF 49333-35. +This sets the stage for 2006, after Epstein was arrested for felony sex crimes and confessed +his conduct to Staley, when JPMorgan could have exited Epstein but did not. Instead, at the Rapid +Response meeting, the Private Bank imposed a condition on his accounts supposedly to "mitigate +the risk" —he could remain a "banking" but not an investment client. SUF 99382-84. But, when it +later benefited the Bank, the restrictions were ignored, and by 2011, Epstein was the Private Bank's +investment arm's "biggest revenue producer." SUF 99|385, 267-72. The Rapid Response meeting +was a fiction in other respects. Though JPMorgan was supposedly considering terminating its +relationship with Epstein, at precisely the same time, the Bank was actively trying to find a New +York home for Epstein's accounts "as the advisor to the Google founders"—a relationship that +would become "one of the largest in the Private Bank, of +$4BN." SUF 991322, 314-327, 331-32. +The Bank was also actively growing the Epstein relationship-between post-indictment +and post-conviction Rapid Response meetings, Epstein's assets under management increased fourfold from $32 million to over $120 million. SUF 9I 259, 264. By September 3, 2008, when +Epstein's Private Banker +) thought his assets were a "probable outflow (pending Dimon +review)," Epstein's accounts were worth more than $156 million—and, needless to say, were not +"outflow[ed]." SUF TIl 265-66. Within months of public reports that Epstein was engaged in sexual +abuse of girls potentially tied to MC2, JPMorgan moved forward with renewing Epstein's loan to +22 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 28 of 45 +MC2. The Bank's only concern: "Are we comfortable taking on additional credit exposure just +ahead of his pending plea arrangement?" SUF 9133. +JPMorgan also kept banking Epstein, despite its knowledge of his sex-trafficking, because +it was trying to settle lawsuits he had against the bank—one related to his investments at Bear +Stearns and another in +In 2011, as JPMorgan had near-settled Epstein's +claims against Bear Stearns, Cutler wrote to Erdoes "I would like to put it and HIM behind us. Not +a person we should do business with - period." But—as Shenker (then General Counsel AWM), +explained to Erdoes—"[Cutler] at conclusion of JE approval [of Bear Stearns settlement], asked +when we are offboarding JE. I reminded him that we have the other matter outstanding." At the +time, the Bank was still trying to settle +SUF 9191387-98. +In 2008, Bear Stearns, now part of JPMorgan, had made it known that it wanted to keep +Epstein as a brokerage client despite his felony conviction. Alan "Ace" Greenberg, former +Chairman of Bear Stearns (and now with JPMorgan), also "wanted to continue to do business with +Epstein" and sought an "exception to the felon policy," which, on paper, required that the GC +(Cutler) approve retaining Epstein. SUF 99399-403. In addition, throughout spring and summer +2011, Epstein helped Erdoes and Staley—who JPMorgan admits were involved in the decision to +maintain Epstein at the Bank—put together a proposal for a $100 billion Donor Advised Fund for +the Gates Foundation, which Erdoes and Staley presented to the Gates Foundation on August 31, +2011. Erdoes communicated frequently and familiarly with Epstein +during the DAF development and pitch process. SUF 91404-12. +Throughout, Epstein continued to connect JPMorgan with the world's dignitaries and +wealthiest people, including, among others, Gates, Boris Nikolic (advisor to Gates), Summers, the +Sultan of Dubai, Prince Andrew, Barak, Netanyahu, David Gergen (former advisor to Nixon, +23 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 29 of 45 +Reagan, and Clinton), Pritzker, and Mandelson. SUF 91276-313. Epstein also continued to bring +in significant revenues to the Bank. SUF 99267-74. +Epstein was also a personal resource to Staley and Erdoes, two business executives who +JPMorgan does not dispute were involved in the decision to maintain Epstein at the Bank. Epstein +helped Staley with +In 2005, Erdoes personally +sought Epstein's help in resolving a $600 million tax issue for +In December 2008, after Bernie Madoff's investment scandal was uncovered, +Erdoes wrote Staley: "glenn and I have been going back and forth all night. We have HUNDREDS +of clients ….. Can you call JE to get the scoop from down there?" SUF T9413-17. +Post-exit, JPMorgan continued to benefit from Epstein until months before his 2019 arrest. +Duffy (then CEO US PB) gave Epstein's former JPMorgan Banker (Justin Nelson) permission to +continue a relationship with Epstein as "a potential source of referrals." Nelson met with Epstein +8-10 times, twice as many times as +who had been his main Banker for a decade prior to his +exit, including about business with +Black, CEO of private equity behemoth Apollo Global +Management. SUF 99353-65, 369. In 2019, a few months before Epstein was arrested, JPMorgan +was still taking referrals from Epstein. +SUF 141366-68. +All the while, JPMorgan continued to +IL. +JPMORGAN OBSTRUCTED ENFORCEMENT OF THE TVPA IN VIOLATION +OF 18 U.S.C. § 1591(d) +By 2007, JPMorgan knew of "an effort to enforce the TVPA" and "intentionally +obstruct|ed] or attempt[ed] to obstruct that enforcement effort." Order at 33. Though Epstein +24 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 30 of 45 +confessed the conduct (except the "ages"), JPMorgan +and, instead, actively handled payments to Epstein's lawyers who it knew were +discrediting the victims, hiring private investigators to target witnesses, and negotiating a deal +where federal prosecutors would (and did) defer prosecution of TVPA charges. Supra Part I(B)(ii). +Further, +Supra Part I. +JPMorgan +the payments to +and Maxwell; the credit cards to +and +, including for monthly travel "through +Paris, Europe and US Virgin Islands and US;" the revoked credit card to +who had talked +to police; the DDR information Epstein provided for +(or any of the other girls Epstein +referred to the Bank); the payments to the girls and women, including with Eastern European +names, or their names and location, which it also had. JPMorgan +that it helped Epstein financially back Brunel and MC2 since 2005. Supra Part I. In +2019, Brunel was charged with rape of minors and under investigation for trafficking tied to +Epstein and was widely known, including by JPMorgan, years earlier as "among the sleaziest +people in the fashion industry ... a conveyor belt, not a casting +" SUF 91421-22. +25 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 31 of 45 +Even when it knew that the feds had subpoenaed Bear Stearns for Epstein's account and +transaction information related to its investigation, +Supra Part I. In 2010, JPMorgan learned of new federal investigations of +Epstein for child sex-trafficking, but +Supra Part I. +JPMorgan's own due diligence on Epstein shows it knew that "names and contact +information of material witnesses and additional victims" would have been "extremely useful in +investigations and prosecuting the [federal] case." SUF 9|420. JPMorgan had the names and +information for dozens of accomplices, victims, and other material witnesses—including, for +example, his pilots, SUF 87, his assistants, and his accountant, who JPMorgan later +acknowledged "controlled the movement of Epstein funds that potentially assisted in facilitating +the sex trafficking ring," SUF 15, as well as the long list of dignitaries and ultra-wealthy men +Epstein referred or connected to the Bank- +Supra Part I. By Epstein's arrest in 2006, there should have been "a constant stream of +information from JPMC to the FBI about Epstein's ongoing +.... Human +trafficking is an ongoing crime, with harm incurred every day that the crime continues." +26 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 32 of 45 +there is no genuine +dispute Epstein would have been federally charged with sex-trafficking much earlier. SUF 9419. +III. THE USVI'S REQUESTED RELIEF FOR VIOLATIONS OF THE TVPA +Declaratory Judgment and Injunction: The Government requests that the Court declare +JPMorgan violated TVPA §§ 1591(a)(2) and (d) by participating in Epstein's sex-trafficking +venture and obstructing federal law enforcement efforts to enforce the TVPA against Epstein from +2006 to 2019. The Government seeks an injunction to prevent JPMorgan from participating in +trafficking ventures in the future and obstructing efforts to stop such ventures in violation of the +TVPA. See Alfred L. Snapp v. Puerto Rico, 458 U.S. 592, 598-99 (1982). +Civil Penalties: The Government has proven even greater participation by JPMorgan in +Epstein's sex-trafficking than the NYSDFS found against Deutsche Bank and seeks at least $150 +million in civil penalties. +Other Remedies: The Government defers its request for disgorgement, compensatory and +punitive damages, and other appropriate relief for JPMorgan's TVPA violations until trial. +IV. JPMORGAN'S EQUITABLE AND FAULT-SHIFTING DEFENSES DO NOT +APPLY TO THE GOVERNMENT'S TVPA PARENS PATRIAE CLAIMS +This is an action by the Government of the Virgin Islands to vindicate public rights. While +JPMorgan seeks to shift focus away from its own failings and point blame on the Government, +such equitable or fault-shifting defenses are legally barred. See, e.g., City of New York v. FedEx +Ground Package System, Inc., 314 F.R.D. 348, 357 (S.D.N.Y. 2016) (***[W Jhen acting in a capacity +to enforce public rights in the public interest ... government entities are not subject to all equitable +defenses +-such as laches or estoppel—that could ordinarily be invoked against a private actor."") +(quoting State of New York v. UPS, Inc., 160 F. Supp. 3d 629, 640 (S.D.N.Y. 2016)); id. at 359 +27 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 33 of 45 +(contention that government plaintiffs were "negligent in their discretionary tax enforcement ... +is impermissible where the government seeks to vindicate the public interest via enforcement of a +public statutory right"). The Court therefore should grant summary judgment for the Government +on JPMorgan's Affirmative Defenses No. 5 ("in pari delicto"), 6 ("unclean hands"), 7 ("laches"), +and 8 ("comparative and contributory negligence or fault"). Answer and Affirmative Defenses +(Dkt. 124) at 26, because they seek to do precisely what the law prohibits—shift fault to a +government plaintiff bringing suit to vindicate public rights.? +JPMorgan's attempts to distract from its violations of the TVPA described above by +claiming that the Government should have done more are particularly galling. The Government +must comply with constitutional and legal principles that protect all individuals by ensuring that +investigations cannot proceed without concrete evidence. JPMorgan had that evidence-in +spades +- in its own files; the Government did not. JPMorgan knowingly handled virtually every +financial transaction Epstein needed to operate his sex-trafficking venture, from the millions in +cash withdrawals and payments to co-conspirators, recruiters, and victims, to the millions in +payments to lawyers and publicists for the ongoing cover-up. JPMorgan had virtually every +financial detail of Epstein's venture—from payments to young women in Lithuania and Russia, to +transfers for the purchase of a helicopter by Maxwell, to a "revoked" credit card for an alleged +recruiter who talked to the police—in real-time and kept virtually all of it, and thus its own outsized +role, under wraps until Epstein was dead and gone. Supra Part I. +2 The Government previously moved to strike these same defenses. See Dkt. 138, 139, 168, 205. +"he Court denied the motion to strike without prejudice to the USVI's right to move for summar +udgment on these defenses. Order (Dkt. 215) at 1 ("Although the Court is skeptical that some o +all of the defenses will survive summary judgment (let alone prevail at trial), the Court is satisfied +they should not be stricken as a matter of pleading."). +28 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 34 of 45 +The Government's causes of action against JPMorgan arise under the TVPA's parens +patriae provision for state attorneys' general, which provides that where: +[T]he attorney general of a State has reason to believe that an interest of the +residents of that State has been or is threatened or adversely affected by any person +who violates section 1591, the attorney general of the state, as parens patriae, may +bring a civil action against such person on behalf of the residents of the State in an +appropriate district court of the United States to obtain appropriate relief. +18 U.S.C. § 1595(d). The TVPA makes clear that a State Attorney General plaintiff brings suit not +as a private litigant on behalf of itself, but "as parens patriae" (i.e., the sovereign) "on behalf of +the residents of the State" to "obtain appropriate relief" for "an interest of [those] residents" that +"has been or is threatened or adversely affected" by JPMorgan's prohibited conduct. +In denying JPMorgan's motion to dismiss, the Court confirmed this plain reading of the +TVPA. The Court found that the Government satisfies the elements of parens patriae standing, +including that it "allege[s] an injury to a quasi-sovereign interest that affects a sufficiently +substantial segment of its population[.J" Order at 17 (citing Snapp, 458 U.S. at 607). The Court +explained that the Government's asserted interest in protecting residents "from the harmful effects +of criminal sex-trafficking enterprises flourishing in the Islands ... directly parallels the interest +that Puerto Rico successfully asserted in Snappl.J" Id. at 18 (cleaned up). Having found that the +Government alleges a quasi-sovereign interest and is vindicating public rights, the Court now +should hold that JPMorgan's equitable and fault-shifting defenses do not apply as a matter of law.? +3 See, e.g., United States v. Angell, 292 F.3d 333, 338 (2d Cir. 2002) ("[LJaches is not available +against the federal government when it undertakes to enforce a public right or protect the public +interest."); FedEr, 314 F.R.D. at 358 (striking laches, unclean hands, and in pari delicto defenses +as to Contraband Cigarette Trafficking Act ("CCTA"), 18 U.S.C. § 2346, public enforcement +claims); UPS, 160 F. Supp. 3d at 647 (same); United States v. Philip Morris Inc., 300 F. Supp. 2d +61, 75-77 (D.D.C. 2004) (granting government plaintiff partial summary judgment on equitable +defenses of, inter alia, laches, unclean hands, and in pari delicto); FTC v. Crescent Publ. Grp., +Inc., 129 F. Supp. 2d 311, 324 (S.D.N.Y. 2001) (**As a general rule ... neglect of duty on the part +of officers of the Government is no defense to a suit by it to enforce a public right or protect a +29 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 35 of 45 +The Government's TVPA claim under section 1595(d) is one exclusively pursued by state +governments, and not by private parties, just as under the CCTA in FedEx and UPS. The TVPA +makes this clear by predicating a state's claim upon its showing that "an interest of the residents +of that State has been or is threatened or adversely affected by any person who violates section +1591[.J"* 18 U.S.C. § 1595(d). The dismissal opinion makes it clearer still that the Government is +acting in a public enforcement capacity by holding that the Government "allege[s] an injury to a +quasi-sovereign interest" and "seek[s] relief to the territory's injury that would be unavailable to +individual plaintiffs." Order at 18. Since the Government is enforcing the TVPA in its capacity as +sovereign, not as a privately-interested litigant, JPMorgan's equitable and fault-shifting defenses +are barred as a matter of law and discovery has not shown otherwise. +JPMorgan has generally cited three issues forming the basis of its fault-shifting affirmative +defenses: (1) Epstein's registration as a sex offender; (2) the Virgin Islands Economic +Development Commission's ("EDC's") provision of tax benefits to Epstein's companies under a +federally-authorized tax benefit program; and (3) actions taken by Cecile de Jongh, whom Epstein +employed. As explained below, JPMorgan's claims of a Government-wide conspiracy to protect +Epstein are both legally unsound and factually unsupported. The defenses based on these +allegations cannot survive summary judgment. +A. JPMorgan's Defenses are Barred as Applied to Sex Offender Registry Issues +JPMorgan argues that the Government's purportedly improper enforcement of sexoffender registry requirements with respect to Epstein supports its equitable and/or fault-shifting +public interest."") (quoting Nevada v. U.S., 463 U.S. 110, 141 (1983)); United States v. Vineland +Chem. Co., Inc., 692 F. Supp. 415, 423 (D.N.J. 1988) (*[T]he equitable doctrine of unclean hands +may not be asserted against the United States when it acts in its sovereign capacity to protect the +public welfare."). +30 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 36 of 45 +defenses. See Opp'n Mot. Strike (Dkt. 157) ("MTS Opposition") at 8-11. This argument is without +basis. +i. +The Government's Investigations or Monitoring of Epstein Cannot +Form the Basis of Viable Affirmative Defenses +JPMorgan essentially argues that the Government should have more aggressively +investigated Epstein or monitored his whereabouts. But that argument suffers from a fatal flaw. +Even as a convicted sex offender, Epstein possessed constitutional rights that the Government was +required to respect. (Nothing, however, granted Epstein a constitutional right to conduct business +with JPMorgan or to be free from JPMorgan's scrutiny.) JPMorgan's attempts to equate its own +compliance failures with the Government's actions have no legal basis and thus amount to little +more than a brazen attempt to distract from its own regulatory failings. The officials within the +Virgin Islands Government responsible for sex offender registration and monitoring are not +responsible for Epstein's crimes. SUF 9|424. The laws required Epstein to register—which he did— +and to provide notification of travel overseas. 14 V.I.C. § 1724. But the Government could not +enter his island or conduct searches without concrete evidence that crimes were being committed. +All witnesses confirmed that the Government never received such evidence. SUF 99I429-30. +JPMorgan has attempted to point to news articles or complaints filed by anonymous victims +in other states as "evidence" that the Virgin Islands Government failed to pursue. But those +documents do not and cannot underpin a government investigation. The Government could not +search Epstein's property without a warrant, which can only issue upon probable cause. See, e.g., +Groh v. Ramirez, 540 U.S. 551, 557 (2004). Newspaper reports or anonymous statements do not +constitute sufficient basis for probable cause because "[m]ere journalistic prose is not the kind of +underlying factual data upon which a magistrate can exercise [appropriate] judgment." Donovan +v. Fed. Clearing Die Casting Co., 655 F.2d 793, 797 (7th Cir. 1981) ("We need not belabor the +31 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 37 of 45 +point that all newspaper reports are not of sufficient reliability to form the basis of Fourth +Amendment probable cause determination"); see also U.S. v. One +Crystal Covered Bat Tour +Glove & Other Michael +_ Memorabilia, 2013 WL 12196595, at *4 (C.D. Cal. Aug. 19, +2013). These cases are consistent with the undisputed witness testimony confirming that the +Department of Justice could not initiate investigations or pursue warrants based upon these types +of hearsay statements. SUF 9|426-27. As witnesses confirmed, absent an actual complaint from a +victim or eyewitness evidence brought to the Department of Justice's attention, the Department +could not initiate investigations. SUF 9428. +JPMorgan's complaints concerning the adequacy of address verification checks fare no +better. No provision in the law requires the Virgin Islands to perform such checks, which are done +to confirm that the registrant resides at the address provided to the Government. The checks were +performed roughly annually in conjunction with U.S. Marshalls and other federal partners. SUF +9431. The applicable law required address checks to verify that an offender is living where +reported. They do not, however, authorize entry onto private property or dispense with the +requirements of the Fourth Amendment. Government officials may not enter a sex offender's +property or conduct a search absent consent or a warrant based on probable cause. SUF 9|432. +That protection is the reason that, in certain years, the U.S. Marshalls and Virgin Islands +officials did not proceed beyond Epstein's dock. If an offender refused entry, the government +officials performing the check did not possess authorization to enter. SUF 9433. One Virgin Islands +witness testified that she conferred with the federal government concerning this practice and was +told that it was similar to a situation where a landowner has placed a gate at the border to his +property. The officials were not permitted to proceed beyond that gate without a warrant. SUF +32 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 38 of 45 +9434. Nor was it improper or unusual for the Government to confirm addresses at a sex offender's +place of employment, as was done one year with Epstein. SUF 9435. +ii. +The Discretionary Act of Granting a Waiver of Notification Periods for +Overseas Travel is Not Grounds to Shift Fault to the Government +Following his conviction in Florida, Epstein was required to register as a sex offender with +the Virgin Islands Department of Justice. In 2012, the Legislature amended its sex offender laws, +in part to obtain federal funding for its sex offender unit. SUF 9436. The U.S. Government +approved the changes to the law in advance. SUF 9437. JPMorgan has sought to make of the +fact that Epstein's attorneys consulted with lawmakers concerning the proposed changes. But those +arguments prove nothing. The Legislature rejected Epstein's proposed changes. SUF 9|438. +The amended statute required that "[a]ll sex offenders required to register in this +jurisdiction shall appear in person at the Department of Justice at least twenty one (21) calendar +days prior to any intended travel outside of the United States and provide information about their +intended travel as provided in [14 V.I.C.] section 1726[.J" 14 V.I.C. § 1724(b)(4) (emphasis +added). The same provision then states that "that Attorney General may at his discretion reduce +this twenty-one (21) day notice requirement if a sex offender requests such a reduction and +provides information in support of his request." Id. (emphasis added). Other statutory provisions +confirm that "InJothing under this chapter shall be construed as a waiver of sovereign immunity +for the United States Virgin Islands, its departments and agencies." 14 V.I.C. § 1728(a). +Epstein applied for and received a discretionary waiver of his travel notification +requirements pursuant to these statutory provisions. SUF 9439. But this waiver does not constitute +misconduct or otherwise form the basis of a valid affirmative defense. The provision of streamlined +travel notice requirements upon satisfactory proof is statutorily mandated and/or vested in the +Attorney General's discretion. Caselaw is clear that such discretionary actions do not support +33 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 39 of 45 +shifting fault to the Government. See, e.g., City of New York v. FedEx, 314 F.R.D. at 359; see also +v. Gov't of the Virgin Islands, 847 F.2d 104, 107 (3d Cir. 1988) (Virgin Islands law +recognizes the "public duty doctrine," which "preclud[es] suit for governmental negligence based +only on the Government's failure to comply with a duty owed to the public in general[.I").* +The defense fails as a factual matter as well. The statutory waiver of which JPMorgan +complains applied only to international travel. 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 +federally-approved Virgin Islands statute required such notification. SUF 9442. Nor did the +provision of such a waiver somehow enable Epstein's crimes. Testimony is clear that Epstein never +failed to register as a sex offender and there is no evidence that he failed to notify of travel. SUF +9425. There is no evidence that permitting Epstein to email his international travel notifications 24 +hours in advance instead of appearing in person 21 days in advance somehow enabled him more +latitude to commit his crimes. Notifications are not authorizations or requests; the Government has +no ability to restrict his travel. SUF 9443. Moreover, entry into the Territory from overseas is +controlled by federal authorities, not the Virgin Islands Governments. SUF 9|444. +Any attacks on the granting of the waiver itself are meritless. Then-Attorney General +Frazer testified that he relied on representations of Epstein's counsel in forming his decision, and +that those "representations" were "satisfactory to conclude that there was not an undue risk to the +community" that would arise from the waiver. SUF 9440. Epstein's lawyers represented to Mr. +* See also Maldonado by and through Ochoa v. City of Sibley, 58 F.4th 1017, 1022 (8th Cir. 2023) +(IT]he public-duty doctrine generally applies when the government fails to adequately enforce +criminal or regulatory laws for the benefit of the general public or ... protect the general public +from somebody else's instrumentality.") (cleaned up); McGaughey v. District of Columbia, 684 +F.3d 1355, 1358 (D.C. Cir. 2012) (public duty doctrine barred claims against government for +failure to investigate rape allegation: "Courts and juries are ill-equipped to review legislative and +executive decisions about how to allocate limited municipal resources to best protect the public."). +34 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 40 of 45 +Frazer that other states permitted Epstein to provide email notification of his travels and affirmed +that "there is no public safety necessity in requiring Epstein to notify the Department in person +each time he travels to or from the jurisdiction." SUF 9441. JPMorgan's defense thus rests not on +whether the decision was authorized under law—it most certainly was—but on whether the +Attorney General in 2012 exercised sufficient discretion in granting the waiver. This is precisely +what the caselaw cited above precludes. Cf. Harlow v. Fitzgerald, 457 U.S. 800, 817-818 (1982) +("[G]overnment officials performing discretionary functions generally are shielded from liability +for civil damages insofar as their conduct does not violate clearly established statutory or +constitutional rights of which a reasonable person would have known"). +B. +JPMorgan's Defenses are Barred as Applied to the Economic Development +Commission's Grant of Tax Benefits to Epstein's Companies +The EDC operates under the umbrella of the USVI Economic Development Authority +("EDA"), which is a "semi-autonomous instrumentality of the Government" and is governed by a +board of individuals appointed by the Governor. 29 V.I.C. § 1101(a). The EDA "is a public +corporation having legal existence and personality separate and apart from the Government of the +Virgin Islands and the officers controlling it." 29 V.I.C. § 1101(b). Thus, to the extent JPMorgan +conflates entities and treats EDC actions as attributable to the Government, see MTS Opp'n at 2, +its arguments find no support in Virgin Islands law. +The tax benefits are authorized by a federal statute (26 U.S.C. § 934(b)(1)), pursuant to +which, the EDC administers "a unique economic development program for the USVI," allowing +residents of the Territory to exempt certain income if it is "connected with the conduct of a trade +or business within the Virgin Islands."" Coffey v. C.I.R., 663 F.3d 947, 949 (8th Cir. 2011) (quoting +26 U.S.C. § 934(b)(1)). The substance and procedures for the EDC's provision of tax benefits are +set by statute and regulation. See, e.g., 29 V.I.C. § 701(a) ("I)t is the policy and determination of +35 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 41 of 45 +the Government of the Virgin Islands that certain industrial development benefits should be made +available for development and expansion of such industrial or business activities as are determined, +pursuant to this subchapter, to be in the public interest by advancing the growth, development +and/or diversification of the economy of the Territory of the Virgin Islands."); 29 V.I.C. § 705(a) +("The Commission shall[.J [b]ased upon the investigation and recommendations of the Director, +review all applications for economic development benefits, hold public hearings thereon as +provided in section 717 of this chapter, and (1) grant certificates for same, or (2) deny such +certificate, subject to reconsideration in accordance with section 717."). The provision, +continuation, and/or revocation of economic development-related tax benefits thus is statutorily +mandated and/or vested in the EDC's discretion, not evidence of government misconduet or +grounds for fault-shifting. See +847 F.2d at 107.5 +The factual record bears this out. The EDC granted tax incentives to two of Epstein's +companies: Financial Trust Company and Southern Trust Company. SUF 9445. The first grant of +benefits to an Epstein-owned company occurred in 1999 to Financial Trust. SUF 9446. In 2009, +Financial Trust applied for and received an extension of benefits. SUF 9[447. Epstein formed a new +company—Southern Trust—which applied for and received tax benefits in 2012. SUF 9[448. In +each of those cases, the grant of benefits was performed in compliance with all statutory and +regulatory procedures and requirements. The companies submitted applications for the benefits. +SUF 9449. EDC held public hearings during which the benefits were discussed and the applicants +were provided the opportunity to present their case and answer questions. SUF 9450. The EDC +then held decision meetings where the board considered the applications and rendered decisions. +S The EDC's grant of economic development-related tax benefits to Epstein also is irrelevant. The +Government has abandoned claims for damages based on lost revenues from the grant of tax +benefits. See USVI Letter-Brief (Dkt. 205) at 1; USVI Opp'n Mot. Sanctions (Dkt. 200) at 2. +36 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 42 of 45 +SUF 9451. To the extent JPMorgan questions the reasoning behind those decisions, that is +precisely the type of second-guessing the law precludes. See McGaughey, supra, 684 F.3d at 1358 +("Courts and juries are ill-equipped to review legislative and executive decisions about how to +allocate limited municipal resources to best protect the public."). +Once benefits are granted, Virgin Islands law limits the EDC's ability to modify them. +"The Commission may not require an applicant to meet qualifications or requirements in excess +of those representations made by the applicant to the Commission during the application process +as a condition of granting an initial certificate." 29 V.I.C. § 708. Indeed, the law specifies that +benefits granted are "consider[ed] ... as being in the nature of a contract between [the] government +and the beneficiary." 29 V.I.C. § 701(c). +The EDC could not revoke, suspend or modify the benefits based upon a felony conviction +unless it concerned conduct "connected with the operation of the beneficiary's business or +industry." 29 V.I.C. § 722(4). Thus, Epstein's Florida conviction was not grounds for revocation +at that time because no evidence was available to the EDC that Epstein's solicitation of a minor +for prostitution in Florida was "connected with the operation" of his USVI businesses. SUF 9452. +Unlike JPMorgan, the EDC did not have access to Epstein's companies' daily financial +transactions, and was not aware of any connection between his conduct and the operations of his +business. SUF 9|453. Indeed, the EDC reached out to Epstein's attorney in January 2015 to inquire +whether media reporting regarding allegations of misconduct had any connection to the business +of Epstein's Southern Trust Company. His attorney responded to confirm "[w]e do not believe that +these media discussions will have any impact on the business activities of STC." SUF 9[454. +JPMorgan has pointed to a "cost-benefit" ratio that purportedly shows in many years that +the Territory (not the Government) received less in benefits than it gave up in tax revenue. Fact +37 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 43 of 45 +witness testimony, however, shows this analysis to be irrelevant because it uses an artificial +baseline. A long-tenured EDC employee who was personally involved in the granting of benefits +testified that the ratio "doesn't give the full picture" and "can be misleading" because, unless the +business already operated in the Territory, the Government would not receive the tax revenue in +the first place and has not "lost" anything. SUF 991455-56. This analysis applies to both the initial +grants of benefits to both companies and to Financial Trust's extension request. During a March +2009 public hearing, Epstein's attorney explained that a denial of an extension would likely cause +"a responsible business person ... to seriously consider relocating the business" if another territory +offered similar benefits. SUF 9|458. Thus, the EDC could not assume that it would collect Epstein's +tax revenue if the benefits were not extended. SUF 9459. The ratio further ignores ancillary +benefits that accrue to the Territory from the presence of high-net-worth individuals, who engage +in economic activity unrelated to their businesses that benefits the territory. SUF |457.° +C. JPMorgan Has No Viable Defenses Based on Activity of Cecile De Jongh +JPMorgan also argues that the activity of Cecile de Jongh, former First Lady of the U.S. +Virgin Islands and Office Manager for Epstein, supports its defenses. MTS Opp'n at 20. Not so. +As First Lady, Ms. de Jongh had no statutory or regulatory authority. Ms. de Jongh +confirmed that "there's 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. SUF 9[461. Moreover, the factual record shows that during the time her husband was +Governor, Ms. de Jongh was widely known and recognized to be employed by Epstein's +businesses and acting on their behalf. SUF 9|462. Unlike the information that JPMorgan +6 To the extent JPMorgan may allege that EDC gave Epstein favorable treatment compared to other +applicants, the record evidence shows otherwise. SUF 9460. +38 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 44 of 45 +de Jongh's employment with Epstein was widely reported and numerous witnesses +confirmed their familiarity with her employment. SUF 9|463. +Most importantly, Ms. de Jongh had no responsibility for governmental decisions that form +the basis of JPMorgan's flawed affirmative defenses. She had no contact with Department of +Justice personnel responsible for sex offender registration and monitoring. SUF 9|464. Decisions +concerning tax benefits were made by the EDC's board members. SUF 9|465. Although the law at +the time required the Governor (her husband) to sign tax benefit certificates, that process was a +formality and could not happen without the EDC's recommendation in the first place. SUF 9[465. +Ms. de Jongh vehemently denied knowing about or facilitating Epstein's crimes in the +Virgin Islands. SUF 9467. Although JPMorgan has pointed to emails about arranging an ESL class +for women in the Virgin Islands, Ms. de Jongh testified that she was not aware these individuals +were potential trafficking victims, and documents make clear that the University merely agreed to +offer an existing class for them. SUF 91468-69. Although Ms. de Jongh's emails may have +provided salacious fodder for JPMorgan, she ultimately was not responsible for any government +decisions. +CONCLUSION +For the foregoing reasons, the Court should grant the Government's motion for partial +summary judgment. +39 + + +Case 1:22-cv-10904-JSR Document 220 Filed 07/24/23 Page 45 of 45 +Dated: July 24, 2023 +ARIEL +1. ESQ. +ATTORNEY GENERAL +Is/ Mimi Liu +MIMI LIU +Admitted Pro Hac Vice +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +mliu@motleyrice.com +VENETIA VELAZQUEZ +Admitted Pro Hac Vice +Acting Chief, Civil Division +Virgin Islands Department of Justice +Office of the Attorney General +213 Estate La Reine, RR1 Box 6151 +Kingshill, St. Croix +U.S. Virgin Islands 00850 +Tel: (340) 773-0295 ext. 202481 +venetia.velazquez@ doj.vi.gov +LINDA +(Admitted Pro Hac Vice) +DAVID I. ACKERMAN +PAIGE BOGGS (Admitted Pro Hac Vice) +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Isinger@motleyrice.com +dackerman@motleyrice.com +pboggs@motleyrice.com +Attorneys for Plaintiff Government of the +United States Virgin Islands +40 diff --git a/vision-fixhub/court-05/64934c71660b60b7687cbf6cb05fab152b0d4ed7c200766d922932ce951137af.receipt.json b/vision-fixhub/court-05/64934c71660b60b7687cbf6cb05fab152b0d4ed7c200766d922932ce951137af.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..037861b5bb303f8cdd29305d0f8e81ae8aabd9ca --- /dev/null +++ b/vision-fixhub/court-05/64934c71660b60b7687cbf6cb05fab152b0d4ed7c200766d922932ce951137af.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -554, + "dataset": "marble-joined", + "doc_id": "64934c71660b60b7687cbf6cb05fab152b0d4ed7c200766d922932ce951137af", + "engine": "marble-apple-vision", + "event_count": 52, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "9d054b20487075f697130e32a740bbbb5fcfc5285a247c30b0bbfbda742f8fb3", + "output_sha256": "eb60a541404d0f7651302dce60ccc4355e118ad5a2b1c0a21593658e50780912", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/64ad942e92eeaa1ec8d13e5a74d32e648d94c66c8e45903a0e7984c69f5945a4.md b/vision-fixhub/court-05/64ad942e92eeaa1ec8d13e5a74d32e648d94c66c8e45903a0e7984c69f5945a4.md new file mode 100644 index 0000000000000000000000000000000000000000..6d8b76c281dbbef2b947d394ff2de74bd5878fa0 --- /dev/null +++ b/vision-fixhub/court-05/64ad942e92eeaa1ec8d13e5a74d32e648d94c66c8e45903a0e7984c69f5945a4.md @@ -0,0 +1,59 @@ +Case 1:22-cV-10904-JSR Document 284-46 Filed 08/14/23 Page 1 of 3 + + + +Case 1:22-cV-10904-JSR Document 284-46 Filed 08/14/23 Page 2 of 3 +Bill 29-0239 +Proposed amendments: +Section 6, (amending Section 1724 of Title 14 of the VI Code), +Section 6, Sub-section (b)(4) (revision to 1724(b) by deletion and replacement) +(4). All sex offenders required to register in this jurisdiction shall notify the Department of +Justice at least twenty-one (21) calendar days prior to any intended travel outside the United +States for seven (7) days or more, and provide information about their intended travelas +provided in Section 1726; provided, however, that a sex offender who provides reasonable and +reliable proof to the Department of Justice that he travels outsidethe United States frequently +for work or other legitimate purposes, and a sex offender who travels outside the United States +for emergency situations, shall notify the Department of Justice in writing at least twenty-four +(24) hours before traveling outside of the United States for seven (7) days or more, and, in any +such case, shall notify the Department of Justice in writing upon the sex offender's return to this +jurisdiction. +Section 6, Sub-section 9(16) and (19) (revision to 1726 by deletion and replacement): +(16) Within twenty-one (21) days priorto travel away from the Virgin Islands for 7 days or more, +the sex offender shall provide the information set forth below to the Department of Justice, +provided, however, that a sex offender who provides reasonable and reliable proof to the +Department of Justice that he travels frequently forwork or other legitimate purposes, and a +sex offender who travels foremergency situations, shall provide such information within at least +twenty-four (24) hours before traveling away from the Virgin Islands for 7 days or more: +(i) identifying information of the temporary lodging locations, including addresses and +names, or, in the case of a sex offender who provides reasonable and reliable proof to the +Department of Justice that he travels frequently for work or otherlegitimate purposes, reliable +information regarding general travel locations and areas of work in lieu of specificaddresses, +and contact telephone information at which the sex offender can be contacted without +unreasonable delay at all times whiletraveling away from the Virgin Islands, and +(ii) the dates the sex offender will be staying at each temporary lodging location, orin +such general locations and areas of work. +(19) Within twenty-one (21) days prior to traveling outside of the United States for seven (7) +days or more, except when a different time for notification is prescribed underSection +1724(b)(4), the sex offender shall provide the following information: +(i) Destination; +(ii) Dates/Places of arrival and departure; +1 + +ESTATE_JPM030225 + + +Case 1:22-cv-10904-JSR Document 284-46 Filed 08/14/23 Page 3 of 3 +(iii) Itinerary details or, in the case of a sex offender who provides reasonable and reliable proof +to the Department of Justice that he travels frequently for work or other legitimate purposes, +and a sex offender who travels for emergency situations, reliable information regarding general +travel locations and areas of work in lieu of specificitinerary information; +(iv) Address or, in lieu of address, contact telephone information at which the sex offender can +be contacted without unreasonable delay at all times while in the destination country; +(v) Purpose of Travel; +(vi) Any other information as may be required by the Attorney General; and +(vii) In addition to any otherinformation sharing requirements of this chapter, any information +regarding a sex offender's intended or actual travel outside of the United States will be +immediately forwarded by the Department of Justice to the United States Marshals Service. +2 + +ESTATE_JPM030226 diff --git a/vision-fixhub/court-05/64ad942e92eeaa1ec8d13e5a74d32e648d94c66c8e45903a0e7984c69f5945a4.receipt.json b/vision-fixhub/court-05/64ad942e92eeaa1ec8d13e5a74d32e648d94c66c8e45903a0e7984c69f5945a4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9953eb4a56917ae93278c0610c218c327fdb6845 --- /dev/null +++ b/vision-fixhub/court-05/64ad942e92eeaa1ec8d13e5a74d32e648d94c66c8e45903a0e7984c69f5945a4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -71, + "dataset": "marble-joined", + "doc_id": "64ad942e92eeaa1ec8d13e5a74d32e648d94c66c8e45903a0e7984c69f5945a4", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "2f7e714914b3efa50e07606ef5a8de4ee07f2e957445494d68135b5bd47f4a81", + "output_sha256": "8399e3a23764e74c22e7907b42f4ffceb3ab987e7188280d7dc1a55dee3d8b22", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/64cdffe3262874de0e8be9f63a151dc951021fa99e586c75d85030bc0da449e6.md b/vision-fixhub/court-05/64cdffe3262874de0e8be9f63a151dc951021fa99e586c75d85030bc0da449e6.md new file mode 100644 index 0000000000000000000000000000000000000000..434c9c263f9ebc31fe46379272146174e9b764b7 --- /dev/null +++ b/vision-fixhub/court-05/64cdffe3262874de0e8be9f63a151dc951021fa99e586c75d85030bc0da449e6.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 226-34 Filed 07/24/23 + + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/64cdffe3262874de0e8be9f63a151dc951021fa99e586c75d85030bc0da449e6.receipt.json b/vision-fixhub/court-05/64cdffe3262874de0e8be9f63a151dc951021fa99e586c75d85030bc0da449e6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..255d5b8ecba53de273010f698936d85a068520a7 --- /dev/null +++ b/vision-fixhub/court-05/64cdffe3262874de0e8be9f63a151dc951021fa99e586c75d85030bc0da449e6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "64cdffe3262874de0e8be9f63a151dc951021fa99e586c75d85030bc0da449e6", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "52d17106f8d18d161ebcb17a7e166d0d8e8c836661d4003eff8858788c8fb133", + "output_sha256": "b0fc085cbc2e4665756229ada5bced25aeb5f1fd84cacd8ad70294ccd26d3d57", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/64cf1cc764be28db0deaf0dfec38e486e6b4c06744b97a1e93b516329ab8cf8c.md b/vision-fixhub/court-05/64cf1cc764be28db0deaf0dfec38e486e6b4c06744b97a1e93b516329ab8cf8c.md new file mode 100644 index 0000000000000000000000000000000000000000..d46fa1c7e9b0b06d7df42e6c02d1fcfd7381e0ad --- /dev/null +++ b/vision-fixhub/court-05/64cf1cc764be28db0deaf0dfec38e486e6b4c06744b97a1e93b516329ab8cf8c.md @@ -0,0 +1,70 @@ +Case 1:22-cv-10904-JSR Document 284-54 Filed 08/14/23 + + +FILED UNDER SEAL + + +Case 1:22-cV-10904-JSR Document 284-54 Filed 08/14/23 Page 2 of 3 +Date: +Tuesday. February 10201505:54 PM +Subject: Forml-20 UVI +From: +Cecile de Jongh +To: +JEE : +Application for Undergraduate Admission, Readmission and Transfer +University of the Virgin Islands +NEW AND TRANSFER STUDENTS: Applicants seeking admission to the University must submit the +completed application form, a non-refundable $25.00 application fee of $25.00 The fee must be +submitted in U.S. dollars by certified check or money order (payable to the University of the Virgin +Islands). +All documents must be received in the Admissions Office by April 30 for the Fall semester and +October 30 for the Spring semester. "Official" documents should be mailed directly to the Admissions +Office from the sending institution. Every effort should be made to submit required documents in a +complete package, when possible. Admitted students will be required to submit a $100.00 nonrefundable enrollment deposit fee to confirm their intent to enroll. +To apply to the St. +Bay St. +campus - forward the application to Admissions Office, #2 John +VI 00802-9990 +INTERNATIONAL STUDENTS: Students are urged to apply 4-6 weeks in advance of stated +deadlines in order to facilitate timely Admissions and U.S. Dept. of Justice, Immigration and +Naturalization Service (INS) processing. International students must submit: +Official certified copies of General Certificate of Education (GCE), Caribbean Examination Council +(CXC) or Caribbean Advanced Proficiency Examination (CAPE) results directly to the Admissions +Office. Passes in five (5) "O" level GCE or CXC (General I and Il), or a combination of both (including +English Language) is acceptable for admission. The CXC (General III) will also be accepted if based +on the six-point scale. Transfer credit is granted for CXC A-level work. The British Virgin Islands +Grade I certificate is required from the BVI High School. +Scholastic Aptitude Test - SAT (UVI code 0879) or the American College Testing Assessment- +ACT (UVI code - 5288). Students should check with the Ministry of Education in their home country +for test dates. Careful planning is required to ensure official results are forwarded to the Admissions +Office prior to the admission deadline. +Test of English as a Foreign Language (TOEFL) is required of applicants from countries where +English is not the official language. For information about TOEFL write to: Educational Testing +Service Box 899, Princeton, NJ 08540 USA. +The Certificate of Finances form Documentation of financial support must be submitted along with +the Certificate of Finance form to verify the availability of funds for at least the first year of study; and +projected support for the remainder of the program. Documentation should include an official +statement from the bank, or lending institution, to confirm the availability of funds. These must reflect +the availability of funds for tuition, fees, and living expenses while attending the University of the +Virgin Islands. +Please note: The I-20 Immigration Form will not be issued until the applicant has been accepted for +admission and submitted evidence of their ability to pay tuition, fees and miscellaneous expenses. + +ESTATE_JPM022289 + + +Case 1:22-cV-10904-JSR Document 284-54 Filed 08/14/23 Page 3 of 3 +There is a charge of $100.00 US for the I-901 processing fee (pay on-line at +www.ice.gov/graphics/sevis/i901/faq4.html or print and mail the form from www.ice.gov/sevis/i901) or +you will not be able to get an appointment for the interview at the Embassy. The I-20 is then taken to +the nearest embassy, where students may be issued approval to pursue academic study in the U.S. +INS regulations governing non-immigrant "F-1" students require that all persons in this status must +pursue a full-time course of study, the equivalent of 12 undergraduate credits per semester. Failure to +do so will render the student in violation of their "F-1"visa status. You may not attend the University +full-time on a B-2 visa. +https://www.applyweb.com/uviu/UV| under_grad_app_instructions.pdf +With warm regards, +Cecile + +ESTATE_JPMO22290 diff --git a/vision-fixhub/court-05/64cf1cc764be28db0deaf0dfec38e486e6b4c06744b97a1e93b516329ab8cf8c.receipt.json b/vision-fixhub/court-05/64cf1cc764be28db0deaf0dfec38e486e6b4c06744b97a1e93b516329ab8cf8c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8a596d0cedbdc1f0295884dad27ecb233bdc7e1d --- /dev/null +++ b/vision-fixhub/court-05/64cf1cc764be28db0deaf0dfec38e486e6b4c06744b97a1e93b516329ab8cf8c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -84, + "dataset": "marble-joined", + "doc_id": "64cf1cc764be28db0deaf0dfec38e486e6b4c06744b97a1e93b516329ab8cf8c", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "3bbcf2bb2dec7efb94728c33517c1ebeed683b16a227f50e3e0a437c0ce6cf1d", + "output_sha256": "c0ae2603400d59c4023ce140a968a471edd5ef9803771f739d08354478a52da2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/64d40e39d2c78389f44501f5fd884b6d4c862fd21dad6f00b047ad0703a7a5f0.md b/vision-fixhub/court-05/64d40e39d2c78389f44501f5fd884b6d4c862fd21dad6f00b047ad0703a7a5f0.md new file mode 100644 index 0000000000000000000000000000000000000000..7abbc767826cfe32df960738380175b1116fee81 --- /dev/null +++ b/vision-fixhub/court-05/64d40e39d2c78389f44501f5fd884b6d4c862fd21dad6f00b047ad0703a7a5f0.md @@ -0,0 +1,62 @@ +Case 1:20-cr-00330-PAE +Document 806 +Filed 08/06/25 + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +-V- +GHISLAINE MAXWELL, +20 Cr. 330 (PAE) +ORDER +Defendant. +PAUL A. ENGELMAYER, District Judge: +This Order publicly dockets one additional letter, submitted to the Government this +afternoon on behalf of a victim in this case, regarding the Government's request to unseal +defendant Maxwell's grand jury materials. This letter, which is attached, supplements the five +letters submitted yesterday, which the Court previously docketed. See Dkt. 804. The Court +understands that no redactions to this letter are needed to protect victims' privacy interests. +SO ORDERED. +aul N. Engeline +AUL A. ENGELMAYEF +United States District Judge +Dated: August 6, 2025 +New York, New York + + +Case 1:20-cr-00330-PAE Document 806 Filed 08/06/25 Page 2 of 3 +August 6, 2025 Victim Letter + + +Case 1:20-cr-00330-PAE +Document 806 +Filed 08/06/25 Page 3 of 3 +PANISH +SHEA +RAVIPUDI ULP +11111 Santa Monica Boulevard +Suite 700 +Los Angeles, CA 90025 +Phone 310.477.1700 +Fax 310.477.1699 +panish.law +August 6, 2025 +VIA E-MAIL +SDNY Victim and Witness Coordinator +United States Attorney's Office +26 Federal Plaza, 37th Floor +New York, New York 10278 +Email: USANYS.EpsteinMaxwellVictims@usdoj.gov +Re: +Unsealing of Grand Jury Transcripts in U.S. v. Epstein, 19-cr-490 (RMB) +and U.S. v. Maxwell, 20-er-330 (PAE) +Dear SDNY Victim and Witness Coordinator: +I represented a victim identified as Jane Doe in U.S. v. Maxwell, 20-cr-330. Please be +dvised I am hereby joining in the letter submitted to you previously on August 5, 2025 o +behalf of victim +by her attorney Sigrid McCawley +With that said, I am strongly opposed to any portions of the grand jury transcripts being +released that would in any way identify the victims. If any materials are released, the victims' +names and other identifying information should be redacted. +Very truly yours, +Robert S. Glassman diff --git a/vision-fixhub/court-05/64d40e39d2c78389f44501f5fd884b6d4c862fd21dad6f00b047ad0703a7a5f0.receipt.json b/vision-fixhub/court-05/64d40e39d2c78389f44501f5fd884b6d4c862fd21dad6f00b047ad0703a7a5f0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..29e0d6bbda256a41009992757b108c6f0ddaecec --- /dev/null +++ b/vision-fixhub/court-05/64d40e39d2c78389f44501f5fd884b6d4c862fd21dad6f00b047ad0703a7a5f0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "64d40e39d2c78389f44501f5fd884b6d4c862fd21dad6f00b047ad0703a7a5f0", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "b5de5d65b4a07a2f6b374562edafc845b5e2ba9da10155212a1d17412e1e0139", + "output_sha256": "6d6c8364c264804fb2af036d1609766f4abba5b084362bb1f1bcbb8c6aca3416", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6525974e09e354fa5ee88109a809b564544cbb662bde957e5a4cc0d925570b9e.md b/vision-fixhub/court-05/6525974e09e354fa5ee88109a809b564544cbb662bde957e5a4cc0d925570b9e.md new file mode 100644 index 0000000000000000000000000000000000000000..bcffbdcd77dc912f88967a214fd7293efacb9836 --- /dev/null +++ b/vision-fixhub/court-05/6525974e09e354fa5ee88109a809b564544cbb662bde957e5a4cc0d925570b9e.md @@ -0,0 +1,92 @@ +Case 1:20-cr-00330-PAE +Document 795 +Filed 07/25/25 + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +-V- +GHISLAINE MAXWELL, +20-CR-330 (PAE) +ORDER +Defendant. +PAUL A. ENGELMAYER, District Judge: +The Court has received the attached letter from MSW Media, Inc., styled as a motion to +intervene, which addresses the scope of appropriate redactions of grand jury transcripts to the +extent, if any, that the Court may authorize the disclosure of these. The Court denies the motion +to intervene but will take into consideration the views expressed in MSW Media's letter. +SO ORDERED. +Pant A Englayer +PAUL A. ENGEL +United States District Judge +Dated: July 25, 2025 +New York, New York + + +Case 1:20-cr-00330-PAE Document 795 Filed 07/25/25 Page 2 of 4 +ATTACHMENT 1 + + +Case 1:20-cr-00330-PAE Document 795 Filed 07/25/25 Page 3 of 4 +NATIONAL SECURITY COUNSELORS +1451 ROCKVILLE PIKE, SUITE 250 +ROCKVILLE, MD 20852 +TELEPHONE: (501) 301-4NSC (4672) +FACSIMILE: (240) 681-2189 +KEL MCCLANAHAN, ESQ., EXECUTIVE DIRECTOR (admitted in DC, NY, WA) +EMAIL: KEL@NATIONALSECURITYLAW ORG +ESQ., DEPUTY EXECUTIVE DIRECTOR (admitted in DC, IL) +25 July 2025 +Hon. Paul A. Engelmayer +United States District Court for the Southern District of New York +Thurgood Marshall Courthouse +40 Foley Square +New York, NY 10007 +Re: United States v. Maxwell, Case No. 20-Cr-330 +Dear Judge Engelmayer: +On behalf of MSW Media, Inc. ("MSW Media"), I respectfully submit this letter motion +to intervene in the above-captioned case for the purposes of partially supporting and partially +opposing the Government's motion to unseal the transcripts of grand jury testimony in this case, +filed as Docket No. 785. +MSW Media (https://mswmedia.com/) operates numerous podcasts and blogs about +federal government operations, including Mueller She Wrote, SpyTalk, Daily Beans, and Jack. It +clearly qualifies as a representative of the news media. +MSW Media has standing to intervene in this case for the following reason. On 17 July +2025, after President Donald Trump publicly instructed Attorney General Pam Bondi to seek the +Court's permission to release "any and all pertinent Grand Jury testimony, we filed a Freedom of +Information Act ("FOIA") request with the Department of Justice ("DOJ") for transcripts of all +grand jury testimony from this case and United States v. Epstein, No. 19-490 (S.D.N.Y.). We are +concerned with the modifier "pertinent" in President Trump's instruction, and that concern +seemed vindicated when the Government advised this Court that it intended to "make +appropriate redactions of victim-related information and other personal identifying information +prior to releasing the transcripts." (Dkt. #785 at 2 (emphasis added).) +To be clear, we have no interest in victim-related information, and this Motion does not +pertain to that information. However, we do have concerns that the Government seems to be +implicitly seeking this Court's permission to withhold other personally identifiable information, +such as information about Defendant's partners in crime or clients. Accordingly, while we join +the Government in requesting that these transcripts be released, we accordingly make this narrow +independent request to the Court: Please do not weigh in on the appropriateness of withholding +personally identifiable information unrelated to victims. We intend to litigate this FOIA request +if necessary, and the question of whether such information may be properly withheld is a + + +Case 1:20-cr-00330-PAE Document 795 Filed 07/25/25 Page 4 of 4 +question best left to the court adjudicating that future case. We are concerned that, if this Court +explicitly or implicitly blesses the Government's proposed redactions of non-victim-related +personally identifiable information (even in passing), that opinion will be treated as a proverbial +thumb on the scale in our FOIA case without materially affecting the Court's decision in this +case. +In other words, if this Court mentions in its decision that it was swayed at all by the +Government's promise to redact personally identifiable information, we are concerned that the +Government will then argue in its FOIA case that "Judge Englemayer agreed that this +information should not be publicly disclosed." Therefore, we respectfully request that this Court +not take the Government's statements regarding non-victim-related personally identifiable +information into account when reaching its decision regarding the Government's motion, and we +further request that the Court specify that it is not opining on that question, should it grant the +Government's motion. +The Government takes no position on the intervention of MSW Media. I attempted +twice—Wednesday and Thursday—to reach Defendant's counsel and have not received a +response, so 1 am filing this as an opposed motion due to the fast-moving nature of this case. +Sincerely, +el McClanahan +Counsel for Proposed Intervenor diff --git a/vision-fixhub/court-05/6525974e09e354fa5ee88109a809b564544cbb662bde957e5a4cc0d925570b9e.receipt.json b/vision-fixhub/court-05/6525974e09e354fa5ee88109a809b564544cbb662bde957e5a4cc0d925570b9e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..afee8d4907a713c12747458342c9f5ade31787fe --- /dev/null +++ b/vision-fixhub/court-05/6525974e09e354fa5ee88109a809b564544cbb662bde957e5a4cc0d925570b9e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -59, + "dataset": "marble-joined", + "doc_id": "6525974e09e354fa5ee88109a809b564544cbb662bde957e5a4cc0d925570b9e", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "40b69b59b413abfc2480eaf9d72811d43b718077a30ea26be4c05fa2aba16988", + "output_sha256": "c6b3b2ebc0046e78b10aa1bee38892c90762e84c39eb15beeea012e632dcfae5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6538fba2ba61b8282874376887073fcadfadc3bc387ae59c5537307d1212dcb1.md b/vision-fixhub/court-05/6538fba2ba61b8282874376887073fcadfadc3bc387ae59c5537307d1212dcb1.md new file mode 100644 index 0000000000000000000000000000000000000000..93a16351fa692a68d615a95a38f7354714162622 --- /dev/null +++ b/vision-fixhub/court-05/6538fba2ba61b8282874376887073fcadfadc3bc387ae59c5537307d1212dcb1.md @@ -0,0 +1,45 @@ +Casse11222ewv1099043S5R Doocumeet2D094 FfeeldD07106283 Faggel10022 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-cv-10904-JSR +[PROPOSED| ORDER +GRANTING MOTION FOR +ADMISSION PRO HAC VICE +JPMORGAN CHASE BANK, N.A., +Defendant / +Third-Party Plaintiff +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +JAMES EDWARD STALEY, +Third-Party Defendant. +The motion of Kees D. Thompson for admission to practice pro hac vice in the abovecaptioned action is GRANTED. Applicant has declared that he is a member in good standing of +the bars of the District of Columbia and New York and that his contact information is as follows: +Applicant's Name: Kees D. Thompson +Firm Name: +& Connolly LLP +Address: +680 Maine Avenue, S.W. +City/State/Zip: +Telephone/Fax: +Email: +Washington, D.C. 20024 +(202) 434-5779 / (202) 434-5029 +keesthompson@wc.com + + +Casse1122260/1D9904155R Doccuneet 2D094 FreeD07106283 Fagge220022 +Applicant having requested admission pro hac vice to appear for all purposes as counsel +for Third-Party Defendant James Edward Staley in the above-captioned action; +IT IS HEREBY ORDERED that Applicant Kees D. Thompson is admitted to practice +pro hac vice in the above-captioned action in the United States District Court for the Southern +District of New York. All attorneys appearing before this Court are subject to the Local Rules of +this Court, including the Rules governing discipline of attorneys. +Dated:_ +7/17/2023 +Jed S. Rakoff, U.S.D.g +Honorable Jed S. Rakoff +United States District Judge diff --git a/vision-fixhub/court-05/6538fba2ba61b8282874376887073fcadfadc3bc387ae59c5537307d1212dcb1.receipt.json b/vision-fixhub/court-05/6538fba2ba61b8282874376887073fcadfadc3bc387ae59c5537307d1212dcb1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8f03738bdde572412f9f575f89c2794690cc3730 --- /dev/null +++ b/vision-fixhub/court-05/6538fba2ba61b8282874376887073fcadfadc3bc387ae59c5537307d1212dcb1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "6538fba2ba61b8282874376887073fcadfadc3bc387ae59c5537307d1212dcb1", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "c70addc5e54ff5414bd76b41d8f85152ba5584e21784557dd791eb72898eef35", + "output_sha256": "91eaa9f1aa5f24504206ff23aecda95fe5b11a5f312861c9fc53abbd4a91a67d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/654c94c072789971e0c82c816a4b3d48d01fe6ededd80b5f20d7e701da2f773f.md b/vision-fixhub/court-05/654c94c072789971e0c82c816a4b3d48d01fe6ededd80b5f20d7e701da2f773f.md new file mode 100644 index 0000000000000000000000000000000000000000..af741a8a6174797a0a75777c3a4a860c8aa89dfa --- /dev/null +++ b/vision-fixhub/court-05/654c94c072789971e0c82c816a4b3d48d01fe6ededd80b5f20d7e701da2f773f.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 226-44 Filed 07/24/23 + + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/654c94c072789971e0c82c816a4b3d48d01fe6ededd80b5f20d7e701da2f773f.receipt.json b/vision-fixhub/court-05/654c94c072789971e0c82c816a4b3d48d01fe6ededd80b5f20d7e701da2f773f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5d65e0a396fc729e75e9a5c968cd1c6c7ed002c0 --- /dev/null +++ b/vision-fixhub/court-05/654c94c072789971e0c82c816a4b3d48d01fe6ededd80b5f20d7e701da2f773f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "654c94c072789971e0c82c816a4b3d48d01fe6ededd80b5f20d7e701da2f773f", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "26550f506561ceac2c6c0f742fe5733e595215fcce974e7bcd9a07e5a45a77f7", + "output_sha256": "eb5ab9a96c6960f68f439cc9bb1973ab3dc17d698f4db6619b29fe76ad61f0ac", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/655432c67d5ceec9b8606a4cd6c74c7d552bfdeb125a5ed30834374ae7ada3bc.md b/vision-fixhub/court-05/655432c67d5ceec9b8606a4cd6c74c7d552bfdeb125a5ed30834374ae7ada3bc.md new file mode 100644 index 0000000000000000000000000000000000000000..7f8d49f55ad1442de475645221aba0f7f6f1b437 --- /dev/null +++ b/vision-fixhub/court-05/655432c67d5ceec9b8606a4cd6c74c7d552bfdeb125a5ed30834374ae7ada3bc.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 242-14 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/655432c67d5ceec9b8606a4cd6c74c7d552bfdeb125a5ed30834374ae7ada3bc.receipt.json b/vision-fixhub/court-05/655432c67d5ceec9b8606a4cd6c74c7d552bfdeb125a5ed30834374ae7ada3bc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7b83906803856930c5aed9a117db5a87c59d369f --- /dev/null +++ b/vision-fixhub/court-05/655432c67d5ceec9b8606a4cd6c74c7d552bfdeb125a5ed30834374ae7ada3bc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "655432c67d5ceec9b8606a4cd6c74c7d552bfdeb125a5ed30834374ae7ada3bc", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "ef363c234d9a99488207ef59291e82386c422dd9eb803bf1491dd14c56ebcf84", + "output_sha256": "82f76e6b48f23bef96b9602b2ef21a781e915e554a2e2f810dc8adc4edc43623", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6578bd18d53a30ec5c3de60333458efa915cf7ecea3ae20d166d33d47343385d.md b/vision-fixhub/court-05/6578bd18d53a30ec5c3de60333458efa915cf7ecea3ae20d166d33d47343385d.md new file mode 100644 index 0000000000000000000000000000000000000000..2c273f08b3913e02c3d73a3fc57777e1400a14e6 --- /dev/null +++ b/vision-fixhub/court-05/6578bd18d53a30ec5c3de60333458efa915cf7ecea3ae20d166d33d47343385d.md @@ -0,0 +1,1612 @@ +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 1 of 34 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +Case Number: 1:22-cv-10904-JSR +JAMES EDWARD STALEY +Third-Party Defendant. +DECLARATION OF MIMI LIU IN SUPPORT OF +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +MOTION FOR PARTIAL SUMMARY JUDGMENT +Pursuant to 28 U.S.C. § 1746, I, Mimi Liu, declare under penalty of perjury as follows: +1. +I am a member in good standing of the bars of the State of New York and the +District of Columbia. I am one of the attorneys representing the Government of the United States +Virgin Islands in the above-captioned action and have been admitted to this Court pro hac vice. I +am a Member of the law firm of Motley Rice LLC, 401 9th Street NW, Suite 630, Washington, +DC 20004. I am familiar with the facts set forth herein and if called as a witness, I could and would +competently testify thereto. I submit this declaration and the attached Exhibits in support of the +United States Virgin Islands' Motion for Partial Summary Judgment. + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 2 of 34 + +Number + + + + + + + + + +Attached hereto are true and correct copies of the following: +Description +Article by Kevin Breuninger, et al., JPMorgan Prepared to Pay $290 Million in +Settlement with Jeffrey Epstein Victims, CNBC (June 12, 2023), +https://www.cnbc.com/2023/06/12/jpmorgan-reaches-settlement-with-epsteinvictim-in-lawsuit.html. +JPM-SDNYLIT-W-00018180-00018196 produced by +JPMorgan in this Action and marked as Cutler Exhibit 38 at deposition. +Designated Confidential by JPMorgan pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +JPM-SDNYLIT-W-00002185-00002196 produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +JPM-SDNYLIT-00184442-00184461, JPM-SDNYLIT- +00184460-00184461 (excerpts) produced by JPMorgan in this Action, +designated Confidential by JPMorgan pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +August 10, 2019, email, | +JPM-SDNYLIT-00154364 produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Article by William K. Rashbaum, +Weiser, & Michael Gold, Jeffrey +Epstein Dead in Suicide at Jail, Spurring Inquiries, N.Y. Times (Aug. 10, 2019) +https://www.nytimes.com/2019/08/10/nyregion/jeffrey-epstein-suicide.html. +Document, "Risk Level & Designation Determination," New York State +Division of Criminal Justice Services, +https://www.criminaljustice.ny.gov/nsot/risk_levels.htm#f:~:text=Level7o20372 +0(high%20risk%20of,threat%20to%20public%20safety%20exists). +EVCP00000006 produced by nonparty Epstein Victims +Commensation Program ("EVCP») in this Action, designated Confidential by +the EVCP pursuant to the Protective Order in this matter and filed under seal. +(Sealed] +Excerpt of Expert Report of Bridgette Carr, June 16, 2023. Designated +Confidential pursuant to the Protective Order in this matter and filed under seal. +2 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 3 of 34 + + + + + + + + + + + + + +LN_000001-000024 produced by a nonparty in this Action, +designated Confidential pursuant to the Protective Order in this matter and filed +under seal. [Sealed] +Document at JDoe_DBAG_010034-010044 produced by a nonparty in this +Action, designated Confidential pursuant to the Protective Order in this matter +and filed under seal. [Sealed] +Document at JDoe_DBAG_010023-010032 produced by a nonparty in thi +Iction, designated Confidential pursuant to the Protective Order in this matte +and filed under seal. (Sealed] +Document at JDoe_JPMC_007438-007448 produced by Plaintif Doe in +this Action, designated Confidential pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +JDoe_JPMC_007449-007464 produced by Plaintiff Doe in +this Action, designated Confidential pursuant to the Protective Order in this +matter and filed under seal. (Sealed] +Document at! +MIC 000456-000476 produced by a nonparty in this Action, +designated Confidential pursuant to the Protective Order in this matter and filed +under seal. [Sealed] +Creditor's Claim on behalf of Jane Doe 981: In the Matter of the Estate of +Jeffrey Epstein, Superior Court of the Virgin Islands, March 12, 2020. +Creditor's Claim on behalf of 1 +In the Matter of the Estate of Jeffrey +Epstein, Superior Court of the Virgin Islands, November 26, 2019. +Complaint, Jane Doe No. 2 v. Epstein, No. 08-cv-80119 (S.D. Fla. Feb. 6, +2008). +Excerpt of Complaint, +|v. Epstein, No. 10-cv-81111 (S.D. Fl. Sept. 17, +2010). +Complaint and Demand for Jury Trial, Jane Doe No. 102 v. Epstein, No. 09-Cv- +80656 (S.D. Fla. May 4, 2009). +First Amended Complaint, Jane Doe 43 v. Epstein, No. 17-cv-616 (S.D.N.Y. +June 5, 2017). +ESTATE_000454, ESTATE_000464, +ESTATE 000466, ESTATE_000474, ESTATE_000500, ESTATE_000536 +produced by nonparty The Estate of Jeffrey E. Epstein in this Action, designated +Confidential pursuant to the Protective Order in this matter and filed under seal. +(Sealed] +3 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 4 of 34 + + + + + + + + + +Estate of efies E. Epstein in this Action, designated Conte by prant to +the Protective Order in this matter and filed under seal. (Sealed] +800256-00257 produces nonparty Yarry Visosk in this Action, designated +Confidential pursuant to the Protective Order in this matter and filed under seal. +[Sealed] +LV_000339-000340, LV_000362-00363, +LV_000381-000382, LV_000391-000392, LV_000401-000402 produced by +nonparty Larry Visoski in this Action, designated Confidential pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Flight manifests at?? +LV_000423-000424, LV_000429-000430, +LV_000473-000474, LV_000491-000492 produced by nonparty Larry visos +in this Action, designated Confidential pursuant to the Protective Order in thi +natter and filed under seal. Sealed +MJPM-SDNYLIT-W-00038289, JPM-SDNYLIT-W- +00038401-00038408 produced by JPMorgan in this Action, designated +confidential by JPMorgan pursuant to the Protective Order in this matter and +filed under seal. [Sealed] +Excerpts of JPMorgan Chase Bank, N.A.'s Responses and Objections to Third- +Party Defendant's (Staley) First Request for Admissions, No. 22-cv-10019-JSR, +dated May 22, 2023. +Document at JPM-SDNYLIT-00128026-00128033 produced by +JPMorgan in this Action, and previously marked as Pearn Exhibit 2 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +| JPM-SDNYL.IT-00131915-00131916 produced by +Potorian indis Action, designated Confidential by SMor +designated Confidential by JPMorgan pursuant to th +Due Diligence Report approved on April 14, 2011, || JPM-SDNYLI- +00036570-00036578 produced by JPMorgan in this Action, and previously +4 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 5 of 34 + + + + + + + + +Transcript excerpts of the Deposition of Mary | taken April 7, 2023, in +this Action. JPMorgan has withdrawn its initial designation of Confidential for +the testimony contained in these excerpts. +Transcript excerpts of the 30(b)(6) Deposition of Senior Advisor, Risk and +Compliance, Francis Pearn, taken on March 29, 2023, in this Action. +JPMorgan has withdrawn its initial designation of Confidential for the +testimony contained in these excerpts. +Transcript excerpts of the Deposition of Vice Chairman and Banker, Private +Bank, William Marcus Sheridan, taken on July 12, 2023, in this Action. +Designated Confidential by JPMorgan pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +Transcript excerpts of Deposition of Private Bank Risk Manager, Kevin +McCleerey, taken on April 28, 2023, in this Action. JPMorgan has withdrawn +its designation of Confidential for the testimony contained in these excerpts. +Transcript excerpts of Deposition of former AML Compliance Manager, +Maryanne Ryan, taken May 24, 2023, in this Action, designated Contidential +in part by JPMorgan pursuant to the Protective Order in this matter and filed +under seal in part. [Sealed in part] +Due Diligence Report from Aug.-Sept. 2006, +JPM-SDNYLIT- +00037183-00037205, produced by JPMorgan in this Action, and previously +marked as +| Exhibit 17 at deposition. JPMorgan initially designated this +document Confidential pursuant to the Protective Order in this matter but has +withdrawn the designation in part and the document is filed under seal in part. +[Sealed in part] +Excerpt of Due Diligence Report requested February 22, 2011, L +JPM- +SDNYLIT-00013546, JPM-SDNYLIT-00013551, produced by JPMorgan in +this Action, and previously marked as Langford Exhibit 49 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +Excerpts of JPMorgan Chase Bank, N.A.'s Responses and Objections to +Plaintiff Government of the United States Virgin Island's First Request for +Admissions, No. 1:22-cv-10904 (JSR) (S.D.N.Y.), dated May 17, 2023. +JPMorgan initially designated this document as Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +5 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 6 of 34 + + + + + + +Article, Afier long probe, billionaire faces solicitation charge, The Palm Beach +Post (July 26, 2006), previously marked as Erdoes Exhibit 9 at deposition in this +Action. +Probable Cause Affidavit, Palm Beach Police Department, dated May 1, 2006, +and previously marked as Langford Exhibit 15 at deposition in this Action. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +July 28, 2006, article from ABC News: The Blotter, Warrants Were Prepared to +Arrest Others in Millionaire Sex Scandal, | JPM-SDNYLIT-00269657- +00269658, produced by JPMorgan in the Action, designated Confidential by +JPMorgan pursuant the Protective Order in this matter and filed under seal. +[Sealed] +August 14, 2006, email, +JPM-SDNYLIT-00105859, produced by +JPMorgan in this Action, and a New York Post article by Dan Mangan, Mystery +Mogul's Teen-Sex Secret Bared in Probe, dated August 14, 2006, +http://www.nypost.com/news/regionalnews/mystery_moguls_teen_sex_secret_b +ared_in probe_regionalnews_dan mangan.htm, accessed April 4. 2023, +together previously marked as +[Exhibit 11 at deposition. JPMorgan +initially designated this document Confidential pursuant to the Protective Order +in this matter but has withdrawn the designation in part and the document 1s +filed under seal in part. [Sealed in part] +AML Operations Human Trafficking Overview, _ +| JPM-SDNYLIT- +00174047-00174061, dated August 5, 2008, produced by JPMorgan in this +Action, and is an excerpt of a document previously marked as Langford Exhibit +14 at deposition. JPMorgan initially designated this document Confidential +pursuant to the Protective Order in this matter but has withdrawn the +designation for this portion of Langford Exhibit 14. +September 22, 2006, email and attachment, +JPM-SDNYLIT-00269393- +00269403, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant the Protective Order in this matter and filed under seal. +[Sealed] + + +July 26, 2006, email, ||| JPM-SDNYLIT-00099334, produced by JPMorgan +in this Action, and previously marked as Erdoes Exhibit 8 at deposition. +6 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 7 of 34 + + +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +Excerpts of Third-Party Defendant James E. Staley's Reponses and Objections +to United States Virgin Islands' First Set of Request for Admissions, dated May +22,2023. +May 21,2003, email, JPM-SDNYLIT-00137281, produced by +JPMorgan in this Action, and an article by Vicky l +IL, The Talented Mr. +Epstein, Vanity Fair (March 1, 2003), https://www.vanity +fair.com/news/2003/03/jeffrey-epstein-200303 (accessed March 31, 2023), +Exhibit 4 at deposition. JPM-SDNYLIT- + + + + +I JPM-SDNYLIT-W-00025790 - 00025790_003, produced +by JPMorgan in this Action, and previously marked as Dimon Exhibit 125 at +deposition. Designated Confidential by JPMorgan pursuant the Protective Order +JPM-SDNYLIT-W-00025792 - 00025792_003, produced +by JPMorgan in this Action, and previously marked as Dimon Exhibit 126 at +deposition. Designated Confidential by JPMorgan pursuant the Protective Order +Document at JPM-SDNYLIT-W-00025791 - 00025791 +_003, produced by +JPMorgan in this Action, and previously marked as Dimon Exhibit 127 a +deposition. Designated Confidential by JPMorgan pursuant the Protective Order +in this matter and filed under seal. Sealed] +Presentation, "Human Trafficking,"||| JPM-SDNYLIT-00151917- + + +the designation. +Document at JPM-SDNYLIT-00174386-00174391, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant the +Protective Order in this matter and filed under seal. [Sealed] +Document at | JPM-SDNYLIT-W-00037475-00037476, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant the +Protective Order in this matter and filed under seal. (Sealed] +7 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 8 of 34 + + + + + + +Expert Report of Jorge Amador, June 16, 2023. Designated Confidential +pursuant to the Protective Order in this matter and filed under seal. +Index of account statements for Epstein's JPMorgan account ending in 0438, +produced by JPMorgan in this Action." +Index of account statements for Epstein's JPMorgan account ending in 1001, +produced by JPMorgan in this Action." +Index of account statements for Financial Trust's JPMorgan account ending in +0001, produced by JPMorgan in this Action." +Index of account statements for Financial Trust's JPMorgan account ending in +5001, produced by JPMorgan in this Action." +JPM-SDNYLIT-00449033, produced by + + + + +Excerpts of JPMorgan Chase Bank, N.A.'s Responses and Objections to +Plaintiff Doe's First Request for Admissions, Case No. 1:22-cv-10019, dated +March 23, 2023. +Oct. 19-23, 2007, email thread with multiple attachments, +LJPM- +SDNYLIT-00269651-00269660, produced by JPMorgan in this Action, and +previously marked as Cutler Exhibit 8 at deposition. JPMorgan initially +esignated this document Confidential pursuant to the Protective Order in thi +natter but has withdrawn the designation in part and the document is filed unde +seal in part. [Sealed in part] +Account summary for account ending in 2810, +00091213, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +(Sealed] +Document at | JPM-SDNYLIT-00104316-00104317, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +"For all account statements, the Government is producing an index rather than attaching these +ocuments because they are voluminous (thousands of pages). The Government's SUF include +ables summarizing relevant information from the account statements. The Government wi +provide these documents to the Court at its request. +8 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 9 of 34 + + + + + + + + +January 14, 2011, email and attachment, | JPM-SDNYLIT-00152804- +00152806, produced by JPMorgan, and previously marked as Ryan Exhibit 34 +at deposition. JPMorgan initially designated this document Confidential +desigant to the Protective Order in this matter but has withdrawn the +JPM-SDNYLIT-00149696-00149700, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +February 9, 2004, Due Diligence Report, | JPM-SDNYLIT-00036564- +0036569, produced by JPMorgan in this Action, and previously marked a +Erdoes Exhibit 6 at deposition. JPMorgan initially designated this documen +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation in part and the document is filed under seal in part. [Sealed in +Document at | SDNYLIT-W-00041545-00041550, produced by JPMorgan +in this Action, designated Confidential by JPMorgan pursuant to the Protective +Order in this matter and filed under seal. [Sealed] +January 10, 2011, email, 1 +JPM-SDNYLIT-00152748_R, produced by +PMorgan in this Action, and previously marked as Cutler Exhibit 28 a +leposition. JPMorgan initially designated this document Confidential pursuan +to the Protective Order in this matter but has withdrawn the designation. +Document entitled, "Human Trafficking Finance: Nature, Scope and Control +Project, " November 2010. _ +JPM-SDNYLIT-00173973-00173992, +roduced by JPMorgan in this Action, and previously marked + +8 at deposition. JPMorgan initially designated this document Confidenti +pursuant to the Protective Order in this matter but has withdrawn th +lesienation in part and the document is filed under seal in part. [Sealed in +John Carney; Meet. +— Star Girl of the Raunchiest Part of +Epstein Scandal, Dealbreaker (July 28, 2006), +https://dealbreaker.com/2006/07/meet-| +-star-girl-of-theraunchiest-part-of-epstein-scandal, accessed July 1, 2023. +March 8, 2007, email and attachment, || JPM-SDNYL.IT-00001494- +00001496, produced by JPMorgan in this Action and previously marked as +Exhibit 15. JPMorgan initially designated this document Confidential +ursuant to the Protective Order in this matter but has withdrawn th +esignation in part and the document is filed under seal in part. [Sealed i +9 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 10 of 34 + + + + + + + + + +JPM-SDNYLIT-00008237-00008240, produced by +Morgan in this action, and previously marked as | Exhibit 35 a +leposition. JPMorgan initially designated this document Confidential pursuan +to the Protective Order in this matter but has withdrawn the designation while +retaining its original redactions to the document. +Document at 1| JPM-SDNYLIT-00026318, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Oct. 17, 2006 Rapid Response Team memorandum, - +JPM-SDNYLIT- +00127953, produced by JPMorgan in this Action, and previously marked as +Erdoes Exhibit 3 at deposition. JPMorgan initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation. +Transcript excerpts of the Deposition of Risk Manager, Bonnie +I taken +May 10, 2023, in this Action, designated Confidential in part by JPMorgan +pursuant to the Protective Order in this matter and filed under seal in part. +JPM-SDNYLIT-W-00021995-00021996, produced by +JPMorgan in this Action, and previously marked as DeLuca Exhibit 29 at +deposition. Designated Confidential pursuant to the Protective Order in this +Currency Transaction Reports, produced by third-party the Financial Crimes +Enforcement Network ("FinCEN) in this Action. +July 16, 2008, email and attachment, JPM-SDNYLIT-00269718- +00269719, produced by JPMorgan in this Action, designated Confidential +pursuant to the Protective Order in this matter and filed under seal. [Sealed] +Document at || JPM-SDNYLIT-W-00021932-00021937, produced by +JPMorgan in this Action, and previously marked as McClecrey Exhibit 13 at +deposition. Designated Confidential pursuant to the Protective Order in this +matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-W-00021965-0021966, produced by +JPMorgan in this Action, and previously marked as Ryan Exhibit 23 at +Deposition. JPMorgan initially designated this document Confidential pursuant +**The Government is producing an index rather than attaching the currency transaction reports +because they are voluminous (nearly 700 pages). The Government's SUF includes tables +summarizing relevant information from the currency transaction reports. The Government will +provide these documents to the Court at its request. +10 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 11 of 34 + + +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +July 19,2013, email, +JPM-SDNYLIT-00100966, produced by JPMorgan +in this Action, and previously marked as Erdoes Exhibit 30 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +January 7, 2011, Rapid Response Team memo, | | JPM-SDNYLIT- +00127930-00127932, produced by JPMorgan in this Action, and previously + + + + + + +Document at | JPM-SDNYLIT-00230825-00230830, produced by +JPMorgan in this Action, designated Confidential pursuant to the Protective +Order in this matter and filed under seal. [Sealed] +Docunient at || JPM-SDNYLIT-00036884-00036890, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +JPM-SDNYLIT-W-00019086-00019096, produced by +Order in this matter and filed under seal. [Sealed] +Transcript excerpts of Deposition of former CEO of Private Bank John +uffy, taken July 13, 2023, in this Action. Designated Confidential b +PMorgan pursuant to the Protective Order in this matter and filed under sea +[Sealed] +Document at JPM-SDNYLIT-00006049-00006050, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +November 9, 2010, email, | JPM-SDNYLIT-00010814-0001080815, +produced by JPMorgan in this Action, and previously marked as I +| Exhibit +7 at deposition. JPMorgan initially designated this document Confidentia +ursuant to the Protective Order in this matter but has withdrawn th +designation in part and the document is filed under seal in part. [Sealed in +11 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 12 of 34 + + + + + +July 26,2006, email, +JPM-SDNYLIT-00099335, produced by JPMorgan +in this Action, and Palm Beach Post article by Larry | +After long probe, +Palm Beach billionaire faces solicitation charge, published July 26, 2006, at +http://www.palmbeachpost.com/pbccentral/content/local_new/epaper/2006/07/2 +6/slb_EPSTEIN_0726.html, accessed March 15, 2023 through +https://web.archive.org/web/20060929041447, together previously marked as +1H Exhibit 5 at deposition. JPMorgan initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation in part and the document is filed under seal in part. [Sealed in +September 20, 2007, emails, +JPM-SDNYLIT-000099500, JPM- +SDNYLIT-000099501, JPM-SDNYLIT-00390951, JPM-SDNYLIT- +00390952, produced by JPMorgan in this Action, and previously marked as +Staley Exhibit 14. JPMorgan initially designated these documents Confidential +designation pet and the out is an i be as i apart iscated in +June 17, 2013, email and attachment, +JPM-SDNYLIT-00194342- +00194344, produced by JPMorgan in this Action, and previously marked as +DeLuca Exhibit 23 at deposition. JPMorgan initially designated this document +the desiration in pat and the document is fried tunder seat bupat. Vitalen +Jeffrey Epstein's 2007 Non-Prosecution Agreement, +JDoe_JPMC_003010-003023, produced by Plaintiff Jane Doe in this Action, +and previously marked as Erdoes Exhibit 39 in deposition. +JPM-SDNYLIT-00099526- +00099528, produced by JPMorgan in this Action, and previously marked as + + +July 1, 2008, email and attachment,|| JPM-SDNYLIT-00002952- +00002955, produced by JPMorgan in this Action, and previously marked as +Erdoes Exhibit 17 at deposition. JPMorgan initially designated this document +C'onfidential pursuant to the Protective Order in this matter but has withdrawr +the designation. +July 15, 2008, email and multiple attachments, JPM-SDNYLIT- +00003026-00003035, produced by JPMorgan in this Action, and previously +12 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 13 of 34 + + + + + + + + + +marked as +Exhibit 27 at deposition. JPMorgan initially designated this +document Confidential pursuant to the Protective Order in this matter but has +withdrawn the designation in part and the document is filed under seal in part. +[Sealed in part] +Sept. 9, 2010, email, +| JPM-SDNYLIT-00229703, produced by JPMorgan +in this Action, and previously marked as Cutler Exhibit 9 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +Transcript excerpts of the Deposition of former General Counsel Stephen +Cutler, taken May 24, 2023, in this Action. Designated Confidential in part by +JPMorgan pursuant to the Protective Order in this matter and filed under seal in +part. (Sealed in part] +March 16, 2011, email, | JPM-SDNYLIT-00274527-00274531, produced +by JPMorgan in this Action, and previously marked as Cutler Exhibit 29 at +deposition. JPMorgan initially designated this document Contidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +Oct. 6,2007, article, L +JPM-SDNYLIT-00036593, produced by JPMorgan +in this Action, and previously marked as +Exhibit 24 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +Oct. 26, 2007, email, +JPM-SDNYLIT-00001962-00001965, produced by +JPMorgan in this Action, and previously marked as + +leposition. JPMorgan initially designated this document Confidential pursuan +to the Protective Order in this matter but has withdrawn the designation. +Document at JPM-SDNYLIT-00002155, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant the Protective Order i +his matter and filed under seal. Sealed +July 31, 2010, email, L +JPM-SDNYLIT-00100251, produced by JPMorgan +in this Action, and previously marked as Erdoes Exhibit 23 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +Document at JPM-SDNYLIT-00011902, produced by JPMorgan in this +Action, designated confidential by JPMorgan pursuant to the Protective Order in +this matter and filed under seal. [Sealed] +August 4, 2010, article, [ +JPM-SDNYLIT-00036596-00036598, produced +by JPMorgan in this Action, and previously marked as + +deposition. JPMorgan initially designated this document Confidential pursuant +13 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 14 of 34 + + + + + + + + + +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. (Sealed in part] +March 7, 2011, email and attachment, JPM-SDNYLIT-00013499- +00013500, produced by JPMorgan in this Action, and previously marked as +Erdoes Exhibit 26 at deposition. JPMorgan initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation. +Document at JPM-SDNYLIT-00751685, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at ] +JPM-SDNYLIT-00751686, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Article by Dareh Gregorian, Second Girl Sues Mogul, New York Post (February +7,2008), https://nypost.com/2008/02/07/second -girl-sues-mogul/ (accessed +July 11, 2023). +Intentionally left blank. +Due Diligence Report, I +JPM-SDNYLIT-00036258-00036263, produced +by JPMorgan in this Action, and previously marked as Pearn Exhibit 17 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +October 22 - December 21, 2010, email thread, | JPM-SDNYLIT- +00194018-00194021, produced by JPMorgan in this Action, and previously +marked as DeLuca Exhibit 7 at deposition. JPMorgan initially designated this +locument Confidential pursuant to the Protective Order in this matter but has +withdrawn the designation +December 22, 2010, email, +| JPM-SDNYLIT-00152738-00152742, +produced by JPMorgan, and previously marked as DeLuca Exhibit 8 at +deposition. JPMorgan initially designated this document Contidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +December 23, 2010, email, L +JPM-SDNYLIT-00204777, produced by +JPMorgan in this Action, and previously marked as DeLuca Exhibit 10 at +deposition. JPMorgan initially designated this document Contidential pursuant +to the Protective Order in this matter but has withdrawn the designation while +retaining its original redactions to the document. +14 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 15 of 34 + + + + + + + +January 4, 2011, email, +JPM-SDNYLIT-00011967-00011968, produced +by JPMorgan in this Action, and previously marked as Exhibit 40 ar +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +January 6, 2011, email, JPM-SDNYLIT-00194062-00194063, produced by +JPMorgan in this Action, and previously marked as Ryan Exhibit 6 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +January 10, 2011, email and attachments, JPM-SDNYLIT-00157065_R- +00157082, produced by JPMorgan in this Action, and previously marked as +Ryan Exhibit 8 at deposition. JPMorgan initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation in part and the document is filed under seal in part. [Sealed in +Transcript excerpts of the Deposition of former head of Compliance at +JPMorgan, William Langford, taken on May 3, 2023, in this Action. J +JPMorgan has withdrawn its designation of Confidential for the testimony +contained in these excerpts. +Transcript excerpts of the Deposition of the Former Managing Director, +Global FIU Investigations, Phillip DeLuca, taken on April 19, 2023, in this +Action. JPMorgan has withdrawn its designation of Confidential for the +testimony contained in these excerpts. +March 12, 2013, email, || JPM-SDLIT-00194272-00194273, produced by +JPMorgan in this Action, and previously marked as DeLuca Exhibit 22 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in par +and the document is filed under seal in part. [Sealed in part] +"Bear Stearns Collapses, Sold to J.P. +Chase," available: +chase, accessed June 23, 2023. + + +Due Diligence Report, JPM-SDNYLIT-00037171-00037177, produced +by JPMorgan in this Action, and previously marked as | Exhibit 34 at +leposition. JPMorgan initially designated this document Confidential pursuant +15 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 16 of 34 + + + + + + + +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. (Sealed in part] +| JPM-SDNYLIT-00373074-00373076, produced by +JPMorgan in this Action, designated confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Arthur Middlemiss LinkedIn Profile, https://www.linkedin.com/in/arthurmiddlemiss-341абb11/. +January 10, 2011, email, JPM-SDNYLIT-00157192-00157193, produced by +JPMorgan in this Action, and previously marked as Langtord Exhibit 3/ at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation while +retaining its original redactions to the document. +Document at || JPM-SDNYLIT-00373247, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00373248-00373252, produced by +JPMorgan in this Action, designated confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +Aug. 27, 2006, email, +JPM-SDNYLIT-00099337, produced by +JPMorgan in this Action, and previously marked as Erdoes Exhibit 1.0 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +Document at JPM-SDNYLIT-00106627, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. Sealed] + + + +May 28, 2008, email, +JPM-SDNYLIT-00134475, produced by +JPMorgan in this Action, and previously marked as Erdoes Exhibit 44 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +Article by John M. Cunningham, Miley Cyrus, +http://www.britanica.com/biography/Miley-Cyrus, accessed July 12, 2023. +16 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 17 of 34 + + + + + + + + +February 9, 2011, email, L +|JPM-SDNYLIT-00453044, produced by +JPMorgan in this Action, and previously marked as Ryan Exhibit 13 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +Article, Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, +Gawker, https://www.gawker.com/5751094/law--order-commemorates-jeffreyepsteins-taste-for-teen-hookers, accessed June 30, 2023. +November 29, 2011, email, | JPM-SDNYLIT-00100689, produced by +JPMorgan in this Action, and previously marked as DeLuca Exhibit 20 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +JPM-SDNYLIT-00100935-00100936, produced +by JPMorgan in this Action, and previously marked as Erdoes Exhibit 29 at +deposition. JPMorgan initially designated this document Contidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00755203, produced by +PMorgan in this Action, and previously marked as Staley Exhibit 1y a +leposition. JPMorgan initially designated this document Confidential pursuan +to the Protective Order in this matter but has withdrawn the designation. +July 10, 2010, email, +JPM-SDNYLIT-00008669-00008670, produced by +JPMorgan in this Action, and marked as Staley Exhibit 35 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00006171, produced by +JPMorgan in this Action, and previously marked as Dimon Exhibit 11 at +eposition. JPMorgan initially designated this document Confidential pursuar +o the Protective Order in this matter but has withdrawn the designatior +September 1, 2009, email, +ESTATE_JPM002773, produced by nonparty + +December 20, 2009, email and attachment, +| JPM-SDNYLIT-00006791- +10006792, produced by JPMorgan in this Action, and previously markea a +Stalev Exhibit 37 at deposition. JPMorgan initially designated this documen +Confidential pursuant to the Protective Order in this matter but has withdrawn +17 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 18 of 34 + + + + + + +the designation in part and the document is filed under seal in part. [Sealed in +Morgan in this Action, and marked Staly 5 hibit 21 at position. IP Morgar +initially designated this document Confidential pursuant to the Protective Order +in this matter but has withdrawn the designation in part and the document Is +filed under seal in part. [Sealed in part] +December 5, 2009, email and attachment, +JPM-SDNYLIT-00006715- +00006716, produced by JPMorgan in this Action, and marked as Staley Exhibit +38 at deposition. JPMorgan initially designated this document Confidential +pursuant to the Protective Order in this matter but has withdrawn the +designation in part and the document is filed under seal in part. [Sealed in +| JPM-SDNYLIT-00006718-00006719, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Department of Financial Services announcement: "Superintendent Lacewell +Announces DFS Imposes $150 Million Penalty on Deutsche Bank in +Connection with Bank's Relationship with Jeffrey Epstein and Correspondent +Relationships with Danke Estonia and FBME Bank." Previously marked as +Cutler Exhibit 39 at deposition. +Consent Order, In the Matter of Deutsche Bank AG, et al., New York State +Department of Financial Services, signed July 6, 2020. Previously marked as +Cutler Exhibit 40 at deposition. +JPM-SDNYLIT-00921097, produced in Excel + + +Bank statement for account ending in 6312, +I JPM-SDNYL.IT-00085024- +00085031, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +[Sealed] +Bank statement for account ending in 4324, |||| JPM-SDNYLIT-00076877- +00076880, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +18 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 19 of 34 + + + + + + + + +Index of account statements for Epstein's JPMorgan account ending in 0663, +produced by JPMorgan in this Action. +Index of account statements for The C.O.U.Q. Foundation's JPMorgan account +ending in 1565, produced by JPMorgan in this Action." +Compilation of wire instructions, | JPM-SDNYLIT-00095431-95432; +JPM-SDNYLIT-00095431-95432; JPM-SDNYLIT-00095471; JPM- +SDNYLIT-00095709; JPM-SDNYLIT-00096355; JPM-SDNYLIT- +00097240; JPM-SDNYLIT-00097437-97438; JPM-SDNYLIT-00097820- +97821, produced by JPMorgan in this Action. Designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +(Sealed] +Account statement summary for account ending in 4810, JPM- +SDNYLIT-00091214, produced by JPMorgan in this Action, designated +Confidential by JPMorgan pursuant to the Protective Order in this matter and +filed under seal. [Sealed] +Documents related to Epstein's 2012 gift tax return, +MP-00000778- +00000832832, produced by nonparty Marks Paneth in this Action, designated +Confidential pursuant to the Protective Order in this matter and filed under seal. +[Sealed] +November 20, 2012, Private Bank Client Cash Transaction Guidelines, +JPM-SDNYLIT-00130224-00130226, produced by JPMorgan in this Action, +and previously marked as +Exhibit 32 at deposition. JPMorgan initially +designated this document Confidential pursuant to the Protective Order in this +matter but has withdrawn the designation. +Excerpt of document, +| JPM-SDNYLIT-W-00017133 - W-00017134, +JPM-SDNYLIT-W-00017206 - W-00017210, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-W-00000001-00000002, JPM-SDNYLIT +-W-00000175-00000182 (excerpts), produced by JPMorgan in this Action, +previously marked as Dimon Exhibit 132 at deposition. Designated Confidential +by JPMorgan pursuant to the Protective Order in this matter and filed under + +Transcript excerpts of the Deposition of former Private Banker Paul Morris +taken April 18, 2023, in this Action. Designated Confidential in part by +JPMorgan pursuant to the Protective Order in this matter and filed under seal in +19 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 20 of 34 + + + + +Document, +"Wealth Management Top 25 Investor Clients," JPM. +SDNYLIT-00133088, produced in Excel format by JPMorgan in this Action, +and previously marked as Staley Exhibit 3 at deposition. JPMorgan initiall +designated this document Confidential pursuant to the Protective Order in this +matter but has withdrawn the designation in part and the document is filed under +October 2, 2006, email, | JPM-SDNYLIT-00001091-00001099, produced +by JPMorgan in this Action, and previously marked as Erdoes Exhibit 5 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +JPM-SDNYLIT-00105030, produced by +JPMorgan in this Action, and previously marked as + +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00448615-00448616, + + + + +July 15, 2008, Rapid Response Team memorandum, +JPM-SDNYLIT- +0127944, produced by JPMorgan in this Action, and previously marked a +rdoes Exhibit 18 at deposition. JPMorgan initially designated this documen +Confidential pursuant to the Protective Order in this matter but has withdrawn +Document at JPM-SDNYLIT-00003755-00003758, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +JPM-SDNYLIT-00011654-00011655, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +Document at | JPM-SDNYLIT-00754975-00754979, produced by +JPMorgan in this Action, and previously marked Staley Exhibit 4 at deposition. +PMorgan initially designated this document Confidential pursuant to the +rotective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +20 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 21 of 34 + + + + + + + + + + +July 3, 2013, email, +JPM-SDNYLIT-00029230, produced by JPMorgan +in this Action, and previously marked as Nelson Exhibit 7 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation. +Document at JPM-SDNYLIT-00394015-00394017, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Transcript excerpts of the Deposition of Justin Nelson, taken April 21, 2023, in +this Action. JPMorgan has withdrawn its designation of Confidential for the +testimony contained in these excerpts. +Third-Party Defendant James E. Staley's Responses and Objections to the +Government of the United States Virgin Islands' First Set of Interrogatories, +dated April 20, 2023. +January 23, 2008, email, |JPM-SDNYLIT-00002152, produced by +PMorgan in this Action, and previously marked as Dimon Exhibit 113 a +deposition. JPMorgan initially designated this document as Confidentia +pursuant to the Protective Order in this matter but has withdrawn the +designation in part and the document is filed under seal in part. [Sealed in +June 5, 2009, email, +JPM-SDNYLIT-00005959, produced by JPMorgan +in this Action. Designated Confidential by JPMorgan pursuant to the Protective +Order in this matter and filed under seal. (Sealed] +Excerpt of document at +JPM-SDNYLIT-00907707, produced in Excel +format produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this Matter and filed under seal. +(Sealed] +JPM-SDNYLIT-00006005, produced by +JPMorgan in this Action, and previously marked as Dimon Exhibit 101 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00004763, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00007534-00007535, produced by +IPMorgan in this Action, designated Confidential by JPMorgan pursuant to th +Protective Order in this matter and filed under seal. (Sealed] +21 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 22 of 34 + + + + + + + + + + +Document at | JPM-SDNYLIT-00007970, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at ||| JPM-SDNYLIT-00009703, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. (Sealed] +December 2, 2010, email, | ESTATE_006071, produced by nonparty The +Estate of Jeffrey E. Epstein. The Estate initially designated this document +Confidential pursuant to the Protective Order in this matter but has withdrawn +the designation in part and the document is filed under seal in part. [Sealed in +Document at ||| JPM-SDNYLIT-00011808, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +November: 23, 2013, email, +JPM-SDNYLIT-00153462-00153463, +produced by JPMorgan in this Action, and previously marked as Staley Exhibit +13 at deposition. JPMorgan initially designated this document Confidential +pursuant to the Protective Order in this matter but has withdrawn the +Document at JPM-SDNYLIT-00102986, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. Sealed] +JPM-SDNYLIT-00102892-00102893, produced by +JPMorgan in this Action, and previously marked ||||| Exhibit 10 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +JPM-SDNYLIT-00000184_R-00000186_R, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYL.IT-00099558-00099560, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Documents at SB-0001-0006, produced by nonparty Sergey Brin in this +Action, designated Confidential pursuant to the Protective Order in this matter +and filed under seal. [Sealed] + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 23 of 34 + + + + + + + + + + + +Documents at AUBURN-001-AUBURN-024, produced by nonparty +Larry Page in this Action, designated Confidential pursuant to the Protective +Order in this matter and filed under seal. [Sealed]. +JPM-SDNYLIT-00902708-00902714, +produced by JPMorgan in this Action, and previously marked as Staley Exhibit +10 at deposition. JPMorgan initially designated this document Confidential +pursuant to the Protective Order in this matter but has withdrawn the +designation in part and the document is filed under seal in part. [Sealed in +Document at | JPM-SDNYLIT-00449185, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Orde +in this matter and filed under seal. [Sealed +Document at JPM-SDNYLIT-00390515, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00390516, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +I JPM-SDNYLIT-00390517, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00390519, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +October 26, 2006, email, | +JPM-SDNYLIT-00099356, produced by +JPMorgan in this Action, and previously marked as Staley Exhibit 9 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +Document at JPM-SDNYLIT-00390520-00390521, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00390522-00390523, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed +Document at | JPM-SDNYLIT-00390590-00390591, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +23 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 24 of 34 + + + + + + + + + + + +IJPM-SDNYLIT-00099423, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at | JPM-SDNYLIT-00134152, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +| JPM-SDNYLIT-00449668, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00449669-00449672, produced by +Do organ in this Action, designated Confidential by IPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +JPM-SDNYLIT-00390671, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +January 31, 2007, email, +JPM-SDNYL.IT-00390720, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00449037-00449038, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Mahmoud Difrawy LinkedIn Profile, available at: +https://www.linkedin.com/in/mahmoud-difrawy- +41889529/?originalSubdomain=uk. +JPM-SDNYLIT-00006724-00006725, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +December 8, 2009, email, +ESTATE_JPM002897, produced by nonparty +The Estate of Jeffrey E. Epstein in this Action. The Estate initially designated +this document Confidential pursuant to the Protective Order in this matter but +has withdrawn the designation. +I JPM-SDNYLIT-00006727, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +24 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 25 of 34 + + + + + + + + + + +Document at JPM-SDNYLIT-00006729, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00101010-00101011, produced +by JPMorgan in this Action, and previously marked as Erdoes Exhibit 49 at +deposition. JPMorgan initially designated this document Confidential pursuan! +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. (Sealed in part] +July 10, 2012, email, MI +JPM-SDNYLIT-00022569, produced by JPMorgan +in this Action, and previously marked as Erdoes Exhibit 31 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation in part and the +document is filed under seal in part. [Sealed in part] +JPM-SDNYLIT-00393112, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +| JPM-SDNYLIT-00028892-00028893, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +Document at JPM-SDNYLIT-00029911-00029913, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +Document at Apollo_VI_00000423, produced by nonparty Apollo Global +Management, Inc. in this Action, designated Confidential pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +Apollo_VI_00000646, produced by nonparty Apollo Global +Management, Inc. in this Action, designated Confidential pursuant to the +Protective Order in this matter and filed under seal. Sealed] +March 23, 2011, email, |||| JPM-SDNYLIT-00013841, produced by +JPMorgan in this Action, and previously marked as Staley Exhibit 12 at +leposition. JPMorgan initially designated this document Confidential pursuan +o the Protective Order in this matter but has withdrawn the designation in par +and the document is filed under seal in part. [Sealed in part] +Document at JPM-SDNYLIT-00014260, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +25 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 26 of 34 + + + + + + + + + + +Document at JPM-SDNYLIT-00017368, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. [Sealed) +Excerpt of JPMorgan Chase Bank, N.A.'s Responses and Objections to Third- +'arty Defendant's First Set of Interrogatories, dated May 18, 2023. Designate +Confidential by JPMorgan pursuant to the Protective Order in this Matter anc +filed under seal. [Sealed] +JPM-SDNYLIT-00032344-00032346, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +JPM-SDNYLIT-00032434-00032435, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +September 30, 2014, email, +| JPM-SDNYLIT-00032511-00032516, +produced by JPMorgan in this Action, and previously marked as Nelson Exhibit +6 at deposition. JPMorgan initially designated this document Confidential, +pursuant to the Protective Order in this matter but has withdrawn the +designation. +April 21, 2023, email, L +| JPM-SDNYLIT-00032218-0003220, produced by +JPMorgan in this Action, and previously marked as Nelson Exhibit 5 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +Excerpt of JPMorgan Chase Bank, N.A.'s First Supplemental Responses and +Objections to Interrogatories in Lieu of Rule 30(b)(6) Deposition Testimony, +dated April 14, 2023. JPMorgan has designated portions of the document +Confidential pursuant to the Protective Order in this matter and the document is +filed under seal in part. +JPM-SDNYLIT-00030644-00030645, produced by +PMorgan in this Action, designated Confidential by JPMorgan pursuant to th +rotective Order in this matter and filed under seal. Sealed +JPM-SDNYLIT-00031300, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00394592-00394593, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +26 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 27 of 34 + + + + + + + + + + + +Document at JPM-SDNYLIT-00032975-00032976, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +JPM-SDNYLIT-00033177-00033179, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +I JPM-SDNYLIT-00034618, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPMorgan Chase Bank, N.A.'s Supplemental Responses and Objections to Doe +Plaintiff's First Set of Interrogatories, dated April 11, 2023. +Document at || JPM-SDNYLIT-00233394, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +| JPM-SDNYLIT-00233392, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00791467, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +JPM-SDNYLIT-00448060-00448065, produced by +JPMorgan in this Action, and previously marked as Dimon Exhibit 107 at +leposition. Designated Confidential by JPMorgan pursuant to the Protective +Order in this matter and filed under seal. [Sealed] +ESTATE_JPM010125-010128, produced by +nonparty The Estate of Jeffrey E. Epstein in this Action. The Estate initially +designated this document Confidential pursuant to the Protective Order in this +matter but has withdrawn the designation in part and the document is filed under +JPM-SDNYLIT-00154163-00165164, produced by +JPMorgan in this Action, designated Contidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +February 15, 2005, email, | +JPM-SDNYLIT-00448590-00448591, +roduced by JPMorgan in this Action, and previously marked as Staley Exhib +at deposition. JPMorgan initially designated this document Confidentia +pursuant to the Protective Order in this matter but has withdrawn the +27 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 28 of 34 +designation in part and the document is filed under seal in part. [Sealed in + + + + + + + + + +June 16, 2004, email and attachments, I JPM-SDNYLIT-00448149- +00448196, produced by JPMorgan in this Action, and previously marked as +taley Exhibit 2 at deposition. JPMorgan initially designated this documer +onfidential pursuant to the Protective Order in this matter but has withdraw +Article by Andrew ||||| Sorkin and Landon ||| Jr., J.P.|| Chase to +Acquire Bank One in S58 Billion Deal, New York Times (January 0 4,q004), +-to acquirebank-one-in-58-billion-deal.html. +Document at JPM-SDNYLIT-00724984-00725000, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +I JPM-SDNYLIT-00448780, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at JPM-SDNYLIT-00016246-00016256, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to tne +Protective Order in this matter and filed under seal. [Sealed] +Article by Reuters, J.P.L +to Buy Control of Hedge Fund, The New York +imes (Sept. 28, 2004), https: www.nytimes.com/2004/09/28/business/j1 +|||1-to-buy-control-of-hedge-fund.html, accessed July 20, 202 +Article, Purchase of Highbridge Capital Management, J.P, LI +/ (June 11, +2009), +https://web.archive.org/web/20120426055706/https://careers.jpmorganchase.co +m/cm. Previously marked as Staley Exhibit 17 at deposition. +JPM-SDNYLIT-00004787-00004789, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. (Sealed] +August 8, 2006, email, L +JPM-SDNYLIT-00000254-00000255, produced +by JPMorgan in this Action, and previously marked as +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +28 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 29 of 34 + + + + + +Document at JPM-SDNYLIT-00026223, produced by JPMorgan in this +ction, and previously marked as Third-Party Exhibit 109 at the deposition o +ohn Duffy. Designated Confidential by JPMorgan pursuant to the Protectiv +Order in this matter and filed under seal. [Sealed] +Excerpt of "JPMC- Cumulative Privilege Log" (May 9, 2023), produced in +Excel format by JPMorgan in this Action, designated Confidential by JP Morgan +pursuant to the Protect Order in this matter and filed under seal. (Sealed] +Verified Complaint, Financial Trust Company, Inc. v. The Bear Stearns +Companies Inc.., 3:09-cv-00106-CVG-GWB (D.V.I. Div. St. I| +& St. +John, Aug. 5, 2009) +July 20, 2011, email, L +JPM-SDNYLIT-00274561, produced by JPMorgan +in this Action, and previously marked as Cutler Exhibit 21 at deposition. +JPMorgan initially designated this document Confidential pursuant to the +Protective Order in this matter but has withdrawn the designation while +retaining its original redactions to the document +July 22, 2011, email, +JPM-SDNYLIT-00135958_R-00135958_R, + + + +|| JPM-SDNYLIT-00269848, produced in Excel format by +PMorgan in this Action, and previously marked as Langford Exhibit 45 a +leposition, JPMorgan initially designated this document Contidential pursuan +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +JPM-SDNYLIT-00230025- +00230028, produced by JPMorgan in this Action, and previously marked as +McCleerey Exhibit 25 at deposition. JPMorgan initially designated this +document Confidential pursuant to the Protective Order in this matter but has +withdrawn the designation in part and the document is filed under seal in part. +[Sealed in part] +July 22, 2011, email, L +JPM-SDNYLIT-00754982-0075984, produced by +and the document is filed under seal in part. [Sealed in part] +29 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 30 of 34 + + + + + + + + + + +7/26/2011, email, | JPM-SDNYLIT-00136106, produced by JPMorgan in +this Action, produced by JPMorgan in this Action, designated Confidential by +JPMorgan pursuant to the Protective Order in this matter and filed under seal. +[Sealed] +March 29, 2011, email, || JPM-SDNYLIT-00731610, produced by. +JPMorgan in this Action, and previously marked as Cutler Exhibit 30 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation. +JPM-SDNYLIT-00790948_R-00790950 +_R, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00892560-00892561, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. Sealed] +August 16, 2010, email, L +JPM-SDNYLIT-00752910-000752912, +produced by JPMorgan in this Action, and previously marked as Cutler Exhibit +20 at deposition. JPMorgan initially designated this document Confidential +pursuant to the Protective Order in this matter but has withdrawn the +designation while retaining its original redactions to the document. +February 6, 2011, email, +ESTATE_JPM-001591, produced by nonparty +The Estate of Jeffrey E. Epstein in this Action. The Estate initially designated +this document Confidential pursuant to the Protective Order in this matter but +has withdrawn the designation. +Document at JPM-SDNYLIT-00016652-00016654, produced by +JPMorgan in this Action. Designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at A JPM-SDNYLIT-00016924, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at GF000664-000670, produced by nonparty Bill & Melinda +Gates Foundation in this Action, designated Confidential pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at GV000028, produced by nonparty Gates Ventures in this +Action, designated Confidential pursuant to the Protective Order in this matter +and filed under seal. [Sealed] +30 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 31 of 34 + + + + + + + + + + +Document at JPM-SDNYLIT-00133931-00133932, produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00005844, produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +Document at 1 JPM-SDNYLIT-00010121-00010122, produced by +JPMorgan in this Action, designated confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +December 12, 2008, email, L JPM-SDNYLIT-00099627, produced by +JPMorgan in this Action, and previously marked as Erdoes Exhibit 41 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +Full Transcript: CNN Anchor Poppy Harlow's exclusive interview with +JPMorgan Chase Chairman and CEO Jamie Dimon, CNN (April 7, 2023), +cnnpressroom.blogs.cnn.com/2023/04/07/full-transcript-cnn-anchor-poppyharlows-exclusive-interview-with-jpmorgan-chase-chairman-and-ceo-jamiedimon. Previously marked as Cutler Exhibit 3 at deposition. +Excerpt of Expert Report of Shaun O'Neill, CPA, CFF, CFE, dated May 16, +2023. Designated Confidential pursuant to the Protective Order in this matter +and filed under seal. +Due Diligence Report, l +JPM-SDNYLIT-00149678-00149683, produced +by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to +the Protective Order in this matter and filed under seal. [Sealed] +March 1, 2011, email, L +JPM-SDNYLIT-00100422-00100423, produced +by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to +the Protective Order in this matter and filed under seal. (Sealed] +Article by Constant Méheut, Epstein Associate Is Charged with Rape of Minors +in France, New York Times (December 19, 2020), +https://www.nytimes.com/2020/12/19/world/europe/france-epstein-brunel.html +(accessed July 20, 2023). +Transcript excerpts of the Deposition of former U.S. Virgin Islands Attorney +General Vincent Frazer, taken on July 13, 2023, in this Action. +31 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 32 of 34 + + + + + + + + +2012 correspondence between Hodge & Francois and the Office of the Attorney +General of the Virgin Islands at || VI-JPM-000012484 - 0000125491. This +is an excerpt of | VI-JPM-000012328-000012522, produced by Plaintifi +Government of the United States Virgin Islands in this Action, and previously +marked as Frazer Exhibit 18 at deposition. +Transcript excerpts of the 30(b)(6) Deposition of U.S. Virgin Islands +Department of Justice Sexual Offender Registry Coordinator Shani Pinney, +taken on July 18, 2023, in this Action. +2012 correspondence between Hodge & Francois or Darren Indyke and the +Office of the Attorney General of the Virgin Islands at || VI-JPM- +000012246-000012250, VI-JPM-000012263-000012265, and VI-JPM- +000012268-000012272. These are excerpts of VI-JPM-000012328- +000012522, produced by Plaintiff Government of the United States Virgin +Islands in this Action, and previously marked as Frazer Exhibit 4 at deposition. +Transcript excerpts of the Deposition of former U.S. Virgin Islands Attorney +General Denise +, taken on July 17, 2023, in this Action. +Transcript excerpts of the Deposition of U.S. Virgin Islands Board of +Education Interim Executive Director and former Economic Development +Authority Compliance Officer U.S. Sandra Bess, taken on May 17, 2023, in +this Action. +Industrial Development Certificate for Financial Trust Company, Inc., March +22, 1999, Ш +VI-JPM-000017992-000018004, produced by Plaintiff +Government of the United States Virgin Islands in this Action, and previously +marked as Bess Exhibit 1 at deposition. +Industrial Development Certificate (Extension) for Financial Trust Company, +Inc., effective January 1, 2012, I| +VI-JPM-000017983-000017991, +broduced by Plaintiff Government of the United States Virgin Islands in this +Action, and previously marked as Bess Exhibit 2 at deposition. +Industrial Development Certificate for Financial Trust Company, Inc., October +25, 2012, || +TVI-JPM-000018005-000018014, produced by Plaintiff +Government of the United States Virgin Islands in this Action, and previously +marked as Bess Exhibit 3 at deposition. + +32 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 33 of 34 + + +Outline, "Jeffrey Epstein's EDC Companies," with handwritten notes, Hill +VI-JPM-000019063-000019067, produced by Plaintiff Government of the +United States Virgin Islands in this Action, and previously marked as | +Exhibit 1 at deposition. +Outline, "Jeffrey Epstein's EDC Companies," VI-JPM-000019063 - +000019067, produced by Plaintiff Government of the United States Virgin +Islands in this Action, and previously marked as +• Exhibit 12 at +deposition. + + + + + + + +:VI-JPM-000016206-000016247, produced by +Plaintiff Government of the United States Virgin Islands in this Action, and +previously marked as +Exhibit 19 at deposition. +Transcript excerpts of the Deposition of U.S. Virgin Islands Governor Albert +Bryan, taken on June 6, 2023, in this Action. +Excerpt of transcript of Public Hearing of the Economic Development +Commission held February 12, 2009, +• VI-JPM-000016200-000016205, +produced by Plaintiff Government of the United States Virgin Islands in this +Action, and previously marked as Bryan Exhibit 1 at deposition. +Letter dated January 7, 2015, from Stephanie Berry to Jeffrey Epstein regarding +Southern Trust Company, +Estate_JPM018432, produced by nonparty +The Estate of Jeffrey E. Epstein in this Action, and previously marked as +Exhibit 32 at deposition. Designated Confidential pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Letter dated January 8, 2014, from Erika Kellerhals to Stephanie Berry +regarding Southern Trust Company, Inc., +VI-JPM-000040186, produced +by Plaintiff Government of the United States Virgin Islands in this Action. +Transcript excerpts of Deposition of U.S. Virgin Islands Congresswoman and +former Economic Development Authority Counsel Stacey Plaskett, taken on +May 9, 2023, in this Action. Designated confidential in part by Representative +Plasket pursuant to the Protective Order in this matter and filed under seal in +part. +Excerpt of transcript of Public Hearing of the Economic Development +Commission held February 12, 2009, L +| VI-JPM-000016200-000016205, +produced by Plaintiff Government of the United States Virgin Islands in this +Action, and previously marked as Plaskett Exhibit 2 at deposition. +33 + + +Case 1:22-cv-10904-JSR Document 241 Filed 07/25/23 Page 34 of 34 + + + + + + + +Transcript excerpts of Deposition of former Financial Trust Company and +Southern Trust Company Office Manager Cecile de Jongh, taken on May +29,2023, in this Action. +Transcript excerpts of the 30(b)(6) Deposition of U.S. Virgin Islands +Economic Development Authority Managing Director Margarita +, taken on July 14, 2023, in this Action. +Transcript excerpts of Deposition of U.S. Virgin Islands Superior Court +Judge and former Acting Attorney General Caroli +i, taken on +July 13, 2023, in this Action. +May 13-15, 2013, email thread regarding Quick response re: TOEFL, HI +ESTATE_JPM024114-024118, produced by nonparty The Estate of Jeffrey E. +Epstein in this Action, and previously marked as C. de Jongh Exhibit 25 at +deposition Designated Confidential pursuant to the Protective Order in this +matter and filed under seal. Sealed +August 28, 2008, email, +L JPM-SDNYLIT-00003706_R, produced by +JPMorgan in this Action, and previously marked as +• Exhibit 29 at +deposition. JPMorgan initially designated this document Confidential pursuant +to the Protective Order in this matter but has withdrawn the designation in part +and the document is filed under seal in part. [Sealed in part] +July 10-11, 2011, emails and attachment, +JPM-SDNYLIT-00110055- +00110056 and JPM-SDNYLIT-00100548-00100549, produced by JPMorgan +in this Action, and previously marked as Third-Party Exhibit 85 at the July 12, +2023, deposition of Mary Erdoes. Designated Confidential by JPMorgan +pursuant to the Protective Order in this matter and filed under seal. (Sealed] +Photograph, previously marked as Third-Party Exhibit 85B at the July 12, 2023, +deposition of Mary Erdoes. Designated Confidential pursuant to the Protective +Order in this matter and filed under seal. [Sealed] +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true +and correct. +Dated: July 24, 2023 +Mimi Liu \ No newline at end of file diff --git a/vision-fixhub/court-05/6578bd18d53a30ec5c3de60333458efa915cf7ecea3ae20d166d33d47343385d.receipt.json b/vision-fixhub/court-05/6578bd18d53a30ec5c3de60333458efa915cf7ecea3ae20d166d33d47343385d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..99bcd33bc35d6c388270b003ec10dfd70d1dafed --- /dev/null +++ b/vision-fixhub/court-05/6578bd18d53a30ec5c3de60333458efa915cf7ecea3ae20d166d33d47343385d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -5575, + "dataset": "marble-joined", + "doc_id": "6578bd18d53a30ec5c3de60333458efa915cf7ecea3ae20d166d33d47343385d", + "engine": "marble-apple-vision", + "event_count": 350, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "51566cff4ac075954cc7886b9244b3dbf97c319a84c9a7b70ae9675968e92c96", + "output_sha256": "a40d8658f983ffdb3351846fcbcd08504ce2f69f46c634b8179741203d30cff7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/657d220f07185732d31bbc434275c931041a7f5eea112c1de7b588fc353b7f65.md b/vision-fixhub/court-05/657d220f07185732d31bbc434275c931041a7f5eea112c1de7b588fc353b7f65.md new file mode 100644 index 0000000000000000000000000000000000000000..6feaf1e7eaae102c0c9722a8b1c2209f4f106bae --- /dev/null +++ b/vision-fixhub/court-05/657d220f07185732d31bbc434275c931041a7f5eea112c1de7b588fc353b7f65.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 265-40 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/657d220f07185732d31bbc434275c931041a7f5eea112c1de7b588fc353b7f65.receipt.json b/vision-fixhub/court-05/657d220f07185732d31bbc434275c931041a7f5eea112c1de7b588fc353b7f65.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c9fd6c94847ea7139ade602fefc09c2b43248c30 --- /dev/null +++ b/vision-fixhub/court-05/657d220f07185732d31bbc434275c931041a7f5eea112c1de7b588fc353b7f65.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "657d220f07185732d31bbc434275c931041a7f5eea112c1de7b588fc353b7f65", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "7a6355509a5c7aa0e08b9059986d4227ff5aea8bfcbf1a09ec44c2aed6db770f", + "output_sha256": "c7080325c2ee25da13f5f4a253c83c0105f7b3250396d9df62a7eb4d7abe1121", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/65b2245fe30792b1435ed114a7c930d9b7ef73e14812403387aef0a37bf4ae0a.md b/vision-fixhub/court-05/65b2245fe30792b1435ed114a7c930d9b7ef73e14812403387aef0a37bf4ae0a.md new file mode 100644 index 0000000000000000000000000000000000000000..82a8fe46c4765a61009f0c5ea6d17bd0ce299b26 --- /dev/null +++ b/vision-fixhub/court-05/65b2245fe30792b1435ed114a7c930d9b7ef73e14812403387aef0a37bf4ae0a.md @@ -0,0 +1,104 @@ +Case 1:20-cr-00330-PAE Document 675-2 Filed 06/25/22 Page 1 of 5 +VICTIM IMPACT STATEMENT OF +(TO BE READ AT THE +SENTENCING OF GHISLAINE MAXWELL +It has been a long journey to bring Maxwell to justice. Sadly, the accurate count of victims +will never be known. My book "Silenced No More" chronicles it as a "journey to hell and back". +Although I have escaped the hellish trap set by Epstein, Maxwell and others, I continue, now 17 +years later, to suffer from the horrific trauma it caused. +I came to New York at age 22, wanting to start my life over after an incredibly abusive +relationship. I hoped to attend FIT and work in the fashion industry. +Soon after arriving, I met an Epstein/Maxwell recruiter named Natalya +in a club. +She befriended me and, soon after that, arranged for me to meet Jeffery. She described him as a kind +philanthropist who could help me get into FIT and provide much-needed support, something which +was alien to me. +Over the next seven to eight months, I became, against my will, nothing more than a human +sex toy with a heartbeat and soul for the entertainment of Epstein, Maxwell and others. Sometimes I +was subjected to sexual predation multiple times per day, both in his New York mansion and on his +private island St. Little James in the US Virgin Islands. On one visit to the island, the sexual +demands, degradation and humiliation became so horrific that I tried to escape by attempting to +jump off a cliff into shark-infested waters, but was caught by Maxwell and company moments +before jumping. At the time, the extremely risky escape seemed more appealing than being raped +one more time. +As the evidence at the trial of Ms. Maxwell proved, and my own experience confirms, +Maxwell was Epstein's right-hand woman. She was the manager of several recruiters and many + + +Case 1:20-cr-00330-PAE Document 675-2 Filed 06/25/22 Page 2 of 5 +others who provided the means and cover for Epstein's predation. In several instances, +Ghislaine by her own hand, forced me into Epstein's room to be raped. +Epstein and Maxwell were masters at finding young, vulnerable girls and young women to +exploit. Upon targeting a vulnerable girl/young woman, they would ingratiate themselves to her, +giving her compliments and small gifts, telling her how special she was. They would tell her that +Epstein was a very wealthy, generous man whose primary purpose was to help the less fortunate. He +and Maxwell were sophisticated, worldly adults with deep ties to important people, world leaders +and institutions who could give her the lifeline she needed to make her dreams reality. +However, soon after lulling me and others into a false sense of comfort and security, they +pounced, ensnaring us in their upside-down, twisted world of rape, rape and more rape. Like Hotel +California, you could check into the Epstein-Maxwell dungeon of sexual hell, but you could never +leave. Ghislaine by her own hand, forced me into Epstein's room to be raped. +The manipulation, intimidation, and emotional abuse used to control the victims took many +forms. In my case, Epstein and Maxwell used my damaged upbringing, naivety, lack of a long-term +Visa, lack of education and my desire to go to FIT to manipulate and ensnare me. +Once ensnared, to pacify and keep me, they told me that I was exceptionally intelligent and +that I had real potential to be someone and something in life; that my dreams of making my family +one day proud of me were achievable; and that Epstein and Maxwell's strong ties to FIT could make +this happen. With their help, my admission was almost assured. +"But", there was always a "but". First, I had to write my application, which I did; but +Maxwell had to review it and conveniently always found fault. 'Then another, "but", I needed to lose +30 pounds because I was a "piglet" (Maxwell's numerous degrading descriptions of me). Epstein and + + +Case 1:20-cr-00330-PAE Document 675-2 Filed 06/25/22 Page 3 of 5 +Maxwell put me on a strict Atkin's diet while simultaneously sending me to a psychiatrist who +prescribed anti-depressants (among other drugs I did not need) that caused weight gain. +It was a classic no-win situation, and they knew it, precisely what human traffickers seck. I +never lost the weight, my application was never good enough, and it never got submitted. +I thank Almighty God that, in 2007, 1 managed to escape the horror by fleeing for my life to +the UK. +Since then, I have been coping with the daily all-consuming fear that someday Epstein and +Maxwell would harm me, my loved ones and my family, as Epstein repeatedly told me would +happen, if I ever dared to leave. +I frequently experience flashbacks and wake up in a cold sweat from nightmares reliving the +awful experience. I am hypervigilant, experience dramatic mood changes, and avoid certain places, +situations and people. I will sometimes start crying uncontrollably and without apparent reason. I +have worked hard with several mental health professionals who have diagnosed me with extreme +symptoms of anxiety, depression, low self-esteem, PTSD, and tendencies to self-harm. +Despite my earnest effort, I have not realized my God-given potential professionally or +entered healthy personal relationships. I have never married and do not have children, something +I always wished for, even as a little girl. I shy away from strangers and have difficulty making +new friends because I fear they could be associated with Epstein, Maxwell and the enablers. +To this day, I attend AA meetings, but I have had numerous relapses and know that only by +of God do I continue to live. I have attempted suicide twice since the abuse—both nearthe +fatal. + + +Case 1:20-cr-00330-PAE Document 675-2 Filed 06/25/22 Page 4 of 5 +Last year, I travelled internationally to New York to attend Maxwell's trial. That was both +therapeutic and traumatizing. It was therapeutic to hear the testimony of the four-brave victimwitnesses, whose experiences paralleled my own, to know that I was not alone and that our story +was finally being told for the world to hear. But it was also traumatizing to relive the experience, and +flashbacks and the nightmares have increased. +I am grateful that the jury believed the victims and returned a guilty verdict. But a question +still tears at my soul - After all of this, how can the manager of this enormous sex trafficking +conspiracy involving so many co-conspirators that snared 100's if not 1,000s of vulnerable girls and +young women over three decades continue to maintain her innocence? Who and what institution +enabled this sex trafficking ring to continue. Why haven't the institutions and important people that +enabled them been exposed and brought to justice? Reflecting on it, I know the answers to my +questions. +Maxwell is today the same woman I met almost 20 years ago - incapable of compassion or +common human decency. Because of her wealth, social status, and connections, she believes herself +beyond reproach and above the law. Sentencing her to the rest of her life in prison will not change +her, but it will give other survivors and I a slight sense of justice and help us as we +continue to work to recover from the sex-trafficking hell she perpetrated. She will never, +ever hurt another young woman or child in this lifetime. For that, I am sure. +As for the important, high-profile enablers - governmental institutions, politicians, and very +wealthy friends of Epstein/Maxwell here and abroad - so far their stature and power have protected +them. I hope that one day they will be exposed, and we will be able to say that the United States +truly is governed by the rule of law and not by powerful people. + + +Case 1:20-cr-00330-PAE Document 675-2 Filed 06/25/22 Page 5 of 5 +To Ghislaine I say, "You broke me in unfathomable ways. But you didn't break is my spirit, +nor did you dampen my internal flame that now +brighter than ever before!" diff --git a/vision-fixhub/court-05/65b2245fe30792b1435ed114a7c930d9b7ef73e14812403387aef0a37bf4ae0a.receipt.json b/vision-fixhub/court-05/65b2245fe30792b1435ed114a7c930d9b7ef73e14812403387aef0a37bf4ae0a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dc71966ee33171b3e7c46fe994bd8c6a732c7d24 --- /dev/null +++ b/vision-fixhub/court-05/65b2245fe30792b1435ed114a7c930d9b7ef73e14812403387aef0a37bf4ae0a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -64, + "dataset": "marble-joined", + "doc_id": "65b2245fe30792b1435ed114a7c930d9b7ef73e14812403387aef0a37bf4ae0a", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "82eecb2b81ab9714099bf2bc8698f4e5cf1bcfa6bd11125f80c8d08e08322e17", + "output_sha256": "573a20a613bd146d132d3f35bb0a34489d6fead3abb76c052df3a0eeffe9472d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/65bdf6e1b9544bce6cbedc87eb4acecf812ecbc28de6062f6b9e5eeb2f661cf6.md b/vision-fixhub/court-05/65bdf6e1b9544bce6cbedc87eb4acecf812ecbc28de6062f6b9e5eeb2f661cf6.md new file mode 100644 index 0000000000000000000000000000000000000000..e1b3e9857e7b3a2291736d03d75831635b42491c --- /dev/null +++ b/vision-fixhub/court-05/65bdf6e1b9544bce6cbedc87eb4acecf812ecbc28de6062f6b9e5eeb2f661cf6.md @@ -0,0 +1,54 @@ +Case 1:22-cV-10904-JSR Document 265-44 Filed 08/07/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 265-44 Filed 08/07/23 Page 2 of 2 +From: +Sent: +To: +CC: +Subject: +Jonathan | +3/7/20119:00:07 PM +Cutler, Stephen M [stephen.m.cutler@jpmorgan.com] +Langford, William D [william.d.langford@jpmchase.com]; Kolat, Gem [gem.kolat@jpmchase.com] +RE: Did you go back to Jes re: +Privileged +Gem is working on sending news links to you and william. +In the meantime, I got the name of Jay +Lefkowitz at Kirkland from Jes' +• haven't talked to him in years but we used to see each othei +now and then thru mutual friends in the 90s. +I can call him. +Another possible call is to will› +Ferrer, the US Attorney in SD Florida. +Used to be one of Reno's special assistants and very nice +Not sure he would tell me anything but could try. +-----Original +Message----- +From: +Cutler, +Stephen M +Sent: Monday. March 07, 2011 10:17 AM Eastern Standard Time +TO: +• Jonathan +Subject: +Re: Did you go back to Jes re: +Could you send me articles? +----- Original Message ----- +From: +I, Jonathan +Son non it 6 67:56:56 2012 +Subject: Re: Did you go back to Jes re: +Yes and didn't get anything back from him, so I just called him again. +He said he'll call Epstein and +get me a live name and number for a current lawyer. +The recent headlines (re FBI reopening its +investigation in Daily Mail and NY Post over the weekend, and guilt-by-being-friends stories about Prince +Andrew and former President Clinton) aint great. Cc'ing William. +-- original Message ----- +Stephen M +To: +Sent: Mon Mar 07 04:33:05 2011 +Subject: Did you go back to Jes re: +Ken Starr's best friend? diff --git a/vision-fixhub/court-05/65bdf6e1b9544bce6cbedc87eb4acecf812ecbc28de6062f6b9e5eeb2f661cf6.receipt.json b/vision-fixhub/court-05/65bdf6e1b9544bce6cbedc87eb4acecf812ecbc28de6062f6b9e5eeb2f661cf6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5fa6fb0d2acf3d1e410d1bc0efa8231efff59091 --- /dev/null +++ b/vision-fixhub/court-05/65bdf6e1b9544bce6cbedc87eb4acecf812ecbc28de6062f6b9e5eeb2f661cf6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -35, + "dataset": "marble-joined", + "doc_id": "65bdf6e1b9544bce6cbedc87eb4acecf812ecbc28de6062f6b9e5eeb2f661cf6", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "4d4bdb1954f412f63658b5e42544c0e99f261268e4392a81408bbdc65b368388", + "output_sha256": "ac543fb3fdc400f4fda007df339330dff52e5300a7dec62e54370ed514b8b8e7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/65c373693869dd5887fab5754bc8f1949c128a90e024ebaabd94a5e2643d1b4c.md b/vision-fixhub/court-05/65c373693869dd5887fab5754bc8f1949c128a90e024ebaabd94a5e2643d1b4c.md new file mode 100644 index 0000000000000000000000000000000000000000..57e590dab28a8d2e1c76c0b0ca7e2723bd0df7c3 --- /dev/null +++ b/vision-fixhub/court-05/65c373693869dd5887fab5754bc8f1949c128a90e024ebaabd94a5e2643d1b4c.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 311-15 Filed 08/25/23 Page 1 of 1 + +Filed Under Seal diff --git a/vision-fixhub/court-05/65c373693869dd5887fab5754bc8f1949c128a90e024ebaabd94a5e2643d1b4c.receipt.json b/vision-fixhub/court-05/65c373693869dd5887fab5754bc8f1949c128a90e024ebaabd94a5e2643d1b4c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ab65368ac2a6d996319614d51c15745982ef6687 --- /dev/null +++ b/vision-fixhub/court-05/65c373693869dd5887fab5754bc8f1949c128a90e024ebaabd94a5e2643d1b4c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "65c373693869dd5887fab5754bc8f1949c128a90e024ebaabd94a5e2643d1b4c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "82389aa515176feb909ae525a1e889b8b6eb968923619ceb0048b14bb911ee07", + "output_sha256": "207ca9cf359b305690882adfe517887920ba895ff683791ab7a24c0d9d5fa9bc", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/65cb858cd0f8c28f5c74e46040cc10290ceb58ae32ea133222352ba0e15614f8.md b/vision-fixhub/court-05/65cb858cd0f8c28f5c74e46040cc10290ceb58ae32ea133222352ba0e15614f8.md new file mode 100644 index 0000000000000000000000000000000000000000..fadb64c542e66f92ee35240d88f6b14f454def5f --- /dev/null +++ b/vision-fixhub/court-05/65cb858cd0f8c28f5c74e46040cc10290ceb58ae32ea133222352ba0e15614f8.md @@ -0,0 +1,405 @@ +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 1 of 12 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 22-cv-10904 +ACTION FOR DAMAGES +JURY TRIAL DEMANDED +JP +V. +CHASE BANK, N.A. +DEFENDANT. +PROTECTIVE ORDER +The parties having agreed to the following terms of confidentiality, and the Court having +found that good cause exists for issuance of an appropriately tailored confidentiality order +governing the pre-trial phase of this action, it is therefore hereby +ORDERED that any person subject to this Order -- including without limitation the parties +to this action, their representatives, agents, experts and consultants, all third parties providing +discovery in this action, and all other interested persons with actual or constructive notice of this +Order -- shall adhere to the following terms, upon pain of contempt: +1. +Any person subject to this Order who receives from any other person any +"Discovery Material" (i.e., information of any kind provided in the course of discovery +in this action) that is designated as "Confidential" pursuant to the terms of this Order +shall not disclose such Confidential Discovery Material to anyone else except as +expressly permitted hereunder. +The person producing any given Discovery Material may designate as +Confidential only such portion of such material as consists of: +previously nondisclosed financial information (including without + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 2 of 12 +b. +d. +e. +f. +limitation profitability reports or estimates, percentage fees, +design fees, royalty rates, minimum guarantee payments, sales +reports and sale margins); +previously +nondisclosed confidential reporting to law +enforcement agencies; +previously nondisclosed material relating to ownership or control +of any non-public company; +previously nondisclosed business plans, product development +information, or marketing plans; +any information of a personal or intimate nature regarding any +individual; +any information maintained by JPMorgan Chase Bank, N.A. or +its affiliates that is required to be kept confidential pursuant to the +Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336, or its +implementing regulations ("BSA") but for which the appropriate +regulatory authority has authorized disclosure, including but not +limited to the fact that no BSA information exists, ("BSA- +Protected Information"') and any information that, pursuant to 31 +U.S.C. 5318(g)(2)(A)(I), 31 C.F.R. § 1020.320, 12 C.F.R § +21.11, Section 314(a) or (b) of the PATRIOT ACT, 12 U.S.C. +§§ 3414(a)(3) and (c) or any other applicable regulations +'BSA-Protected Information maintained by other financial institutions are not within the scope +of this Order and remain subject to the standard confidentiality requirements of the BSA and its +implementing regulations. +2 + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 3 of 12 +g. +h. +concerning +potential suspicious activity ("SAR-Related +Information"), is not permitted to be produced unless authorized +by the appropriate regulatory authority ("SAR-Protected +Information"); +any information that is confidential supervisory information +("CSI") of the Board of Governors of the Federal Reserve System +as set forth in 12 C.F.R. § 261.2(c), non-public information of the +Office of the Comptroller of the Currency or the former Office of +Thrift Supervision as set forth in 12 C.F.R. § 4.32(b), exempt +information of the Federal Deposit Insurance Corporation as set +forth in 12 C.F.R. §$ 309.2, 309.5, and 309.6, and confidential +information of the Consumer Financial Protection Board as set +forth in 12 C.F.R. § 1070.2, and any other records concerning +supervision, regulation, and examination of banks, savings +associations, their holding companies and affiliates, and records +compiled in connection with the enforcement responsibilities of +federal and state financial regulatory agencies that is not +permitted to be disclosed to a third party absent consent of the +applicable regulator or government agency unless authorized by +the +appropriate +regulatory +authority +("CSI-Protected +Information"); or +any other category of information hereinafter given confidential +status by the Court. +3 + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 4 of 12 +3. +With respect to the Confidential portion of any Discovery Material other +than deposition transcripts and exhibits, the producing person or that person's counsel +may designate such portion as "Confidential" by stamping or otherwise clearly marking +as "Confidential" the protected portion in a manner that will not interfere with legibility +or audibility, and by also producing for future public use another copy of said Discovery +Material with the confidential information redacted. For the avoidance of doubt, +nothing herein is intended to prevent a party from designating the entirety of a given +document as "Confidential" if the party reasonably believes the entire document falls +within one or more of the categories in paragraph 2, above. With respect to deposition +transcripts and exhibits, a producing person or that person's counsel may indicate on the +record that a question calls for Confidential information, in which case the transcript of +the designated testimony shall be bound in a separate volume and marked "Confidential +Information Governed by Protective Order" by the reporter. +4. +If at any time prior to the trial of this action, a producing person realizes +that some portion[s] of Discovery Material that that person previously produced without +limitation should be designated as Confidential, he may so designate by so apprising all +parties in writing, and such designated portion[s] of the Discovery Material will +thereafter be treated as Confidential under the terms of this Order. If a party has +disclosed such designated portion[s] of Discovery Material to anyone other than the +individuals set forth in paragraph 5 below, that party shall make reasonable efforts to +promptly retrieve such Discovery Material, and inform any recipient of the terms of the +Order. +5. +With the exception of the qualifications pertaining to BSA-Protected +4 + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 5 of 12 +Information, SAR-Protected Information and/or CSI-Protected Information in +paragraph 6, no person subject to this Order other than the producing person shall +disclose any of the Discovery Material, designated by the producing person as +Confidential excluding any material containing BSA-Protected Information, SAR- +Protected Information and/or CSI-Protected Information to any other person +whomsoever, except to: +a. +b. +d. +e. +the parties to this action; +counsel retained specifically for this action, including any +paralegal, clerical and other assistant employed by such counsel +and assigned to this matter; +as to any document, its author, its addressee, and any other person +indicated on the face of the document as having received a copy; +any witness who counsel for a party in good faith believes may +be called to testify at trial or deposition in this action, provided +such person has first executed a Non-Disclosure Agreement in +the form annexed as an Exhibit hereto; +any person retained by a party to serve as an expert witness or +otherwise provide specialized advice or services to counsel in +connection with this action (including but not limited to +professional jury or trial consultants, mock jurors, and persons or +entities providing litigation support services - such as +photocopying, videotaping, translating, preparing exhibits or +demonstrations, and processing, hosting, organizing, storing, or +5 + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 6 of 12 +retrieving data in any form or medium - and their employees and +subcontractors), provided such person has first executed a Non- +Disclosure Agreement in the form annexed as an Exhibit hereto; +f. +any mediator or other dispute-resolution personnel, or any +employee thereof, provided such person has first executed a Non- +Disclosure Agreement in the form annexed as Exhibit hereto; +g. +insurers, +reinsurers, insurance adjusters, and/or third party +administrators of insurance policies that do or may provide +insurance coverage applicable to this action; +h. +stenographers engaged to transcribe depositions conducted in this +action and videographers engaged to record depositions +conducted in this action; and +1. +the Court and its support personnel. +6. +No person subject to this Order shall disclose any BSA-Protected +Information, SAR-Protected Information, and/or CSI-Protected Information to any +other person whomsoever, except to the following persons, consistent with any +authorization received from the appropriate regulatory authority: +a. +the Government of the U.S. Virgin Islands and its counsel and +JPMorgan Chase and its counsel, including any paralegal, clerical +and other assistant employed by such counsel and assigned to this +matter; +b. +any witness employed or formerly employed by JPMorgan Chase +who counsel for the Government of the U.S. Virgin Islands or +6 + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 7 of 12 +JPMorgan Chase in good faith believes may be called to testify +at trial or deposition in this action, provided such person has first +executed a Non-Disclosure Agreement in the form annexed as an +Exhibit hereto; +C. +any person retained by the Government of the U.S. Virgin Islands +or JPMorgan Chase to serve as an expert witness or otherwise +provide specialized advice to counsel in connection with this +action, provided such person has first executed a Non-Disclosure +Agreement in the form annexed as an Exhibit hereto; +stenographers engaged to transcribe depositions conducted in this +action and videographers engaged to record depositions +conducted in this action provided such person has first executed +a Non-Disclosure Agreement in the form annexed as Exhibit +hereto; and +e. +the Court and its support personnel. +Prior to any disclosure of any Confidential Discovery Material to any +person referred to in subparagraphs 5(d), 5(e), or 5(f) above, such person shall be +provided by counsel with a copy of this Protective Order and shall sign a Non-Disclosure +Agreement in the form annexed as an Exhibit hereto stating that that person has read +this Order and agrees to be bound by its terms. Said counsel shall retain each signed +Non-Disclosure Agreement, hold it in escrow, and produce it to opposing counsel either +prior to such person being permitted to testify (at deposition or trial) or at the conclusion +of the case, whichever comes first. +7 + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 8 of 12 +8. +All Confidential Discovery Material filed with the Court, and all portions +of pleadings, motions or other papers filed with the Court that disclose such Confidential +Discovery Material, shall be filed under seal with the Clerk of the Court and kept under +seal until further order of the Court. The parties will use their best efforts to minimize +such sealing. In any event, any party filing a motion or any other papers with the Court +under seal shall also publicly file a redacted copy of the same, via the Court's Electronic +Case Filing system, that redacts only the Confidential Discovery Material itself, and not +text that in no material way reveals the Confidential Discovery Material. +9. +Any party who either objects to any designation of confidentiality, or +who, by contrast, requests still further limits on disclosure (such as "attorneys' eyes +only" in extraordinary circumstances), may at any time prior to the trial of this action +serve upon counsel for the designating person a written notice stating with particularity +the grounds of the objection or request. If agreement cannot be reached promptly, +counsel for all affected persons will convene a joint telephone call with the Court to +obtain a ruling. +10. All persons are hereby placed on notice that the Court is unlikely to seal +or otherwise afford confidential treatment to any Discovery Material introduced in +evidence at trial, even if such material has previously been sealed or designated as +Confidential. The Court also retains unfettered discretion whether or not to afford +confidential treatment to any Confidential Document or information contained in any +Confidential Document submitted to the Court in connection with any motion, +application, or proceeding that may result in an order and/or decision by the Court. +11. +Each person who has access to Discovery Material that has been +8 + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 9 of 12 +designated as Confidential shall take all due precautions to prevent the unauthorized or +inadvertent disclosure of such material. +12. +If, +in connection with this litigation, a party inadvertently discloses +information subject to a claim of attorney-client privilege or attorney work product +protection, including any privilege or immunity from production associated with BSA, +SAR-Related Information, and/or CSI ("Inadvertently Disclosed Information"), such +disclosure shall not constitute or be deemed a waiver or forfeiture of any claim of +privilege or work product or such other applicable protection with respect to the +Inadvertently Disclosed Information and its subject matter. For avoidance of doubt, +outside of authorization from an appropriate regulatory authority, the disclosure of BSA, +SAR-Related Information and/or CSI shall not constitute or be deemed a waiver or +forfeiture of any claim of privilege or work product or such other applicable protection +with respect to such information. +13. +If a disclosing party makes a claim of inadvertent disclosure, the +receiving party shall not thereafter review the Inadvertently Disclosed Information for +any purpose, except by order of the Court. The receiving party shall, within five business +days, return or destroy all copies of the Inadvertently Disclosed Information, and +provide a certification of counsel that all such information has been returned or +destroyed. +14. +Within five business days of the notification that such Inadvertently +Disclosed Information has been returned or destroyed, the disclosing party shall produce +a privilege log with respect to the Inadvertently Disclosed Information. +15. +As with any information redacted or withheld, the receiving party may +9 + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 10 of 12 +move the Court for an Order compelling production of the Inadvertently Disclosed +Information. The motion shall be filed under seal, and shall not assert as a ground for +entering such an Order the fact or circumstances of the inadvertent production. +16. +The disclosing party retains the burden of establishing the privileged or +protected nature of any Inadvertently Disclosed Information. Nothing in this Order shall +limit the right of any party to request an in camera review of the Inadvertently Disclosed +Information. +17. +This Protective Order shall survive the termination of the litigation. +Within 30 days of the final disposition of this action, all Discovery Material designated +as "Confidential," and all copies thereof, shall be promptly returned to the producing +person, or, upon permission of the producing person, destroyed. For the avoidance of +doubt, counsel of record in this action shall be permitted to keep copies of filings and +work product that incorporates any Confidential Discovery Material, so long as counsel +continues to treat such Confidential Discovery Material in accordance with this Order. +18. +This Court shall retain jurisdiction over all persons subject to this Order +to the extent necessary to enforce any obligations arising hereunder or to impose +sanctions for any contempt thereof. +SO STIPULATED AND AGREED. + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 11 of 12 +/s/ Jordan Merson +Jordan Koel Merson +Merson Law, PLLC +950 Third Avenue, 18" Floor +New York, NY 10022 +212-603-9100 +jmerson@mersonlaw.com +/s/ Jennifer Plotkin +Jennifer Chloris Plotkin +Merson Law PLLC +950 Third Avenue 18" Floor +New York, NY 10522 +212-603-9100 +jplotkin@mersonlaw.com +Is/ Kimberly Kramer +Kimberly Kramer +Merson Law, PLLC +950 Third Avenue 18' Floor +New York, NY 10022 +212-603-9100 +kkramer@mersonlaw.com +David Ira Ackerman +Motley Rice LIC +401 9th Street NW Ste 630 +Washington, DC 20004 +202-849-4962 +dackerman@motleyrice.com +Counsel for Defendants USVI, Kenneth Mapp, +and Celestino +Dated: April 3, 2023 +Venetia Velazquez +Office of the Attorney General +Civil Division +213 Estate LA Reine +Rrl, Box 6151 +Kingshill, VI 00851 +340-773-0295 +venetia.velazquez@doj.vi.gov +Counsel for Defendants USVI, Kenneth Mapp, +and Celestino +Matthew G Kaiser +Kaiser PLLC +1099 14th Street NW 8th Floor West +Washington, DC 20005 +202-640-2850 +mkaiser@kaiserlaw.com +Counsel for Cecile De Jongh +Amelia +Kaiser PLLC +1099 14th Street NW Ste 8th Floor West +Washington, DC 20005 +202-869-1301 +aschmidt@kaiserlaw.com +Counsel for Cecile De Jongh +Courtney l +Forrest +cforrest@kaiserlaw.com +Counsel for Cecile De Jongh + + +Case 1:22-cv-10904-JSR Document 363-2 Filed 04/29/24 Page 12 of 12 +Daniel Louis Cevallos +Cevallos & Wong LLP +61 Broadway +Ste 2220 +New York, NY 10006 +917-699-5008 +Fax: 215-689-4375 +Danny@CevallosWong.com +Counsel for John De Jongh +David J Cattie +The Cattie Law Firm, P.C. +1710 Kongens Gade +St. +1 VI 00802 +340-775-1200 +Fax: 800-878-5237 +david.cattie@cattie-law.com +Counsel for John De Jongh +Eric R. Breslin +Juane Morris LLI +00 Campus Drive +Florham Park, NJ 07932 +Fax: 973-424-2001 +Corsi dune ris com +Melissa S. Geller +1340 BroadiaL. +New York, NY 10036 +212-692-1077 +Fax: 973-556-1562 +MSGeller(a)duanemorris.com +Counsel for Stacey Plaskett +SO ORDERED. +Dated: New York, New York diff --git a/vision-fixhub/court-05/65cb858cd0f8c28f5c74e46040cc10290ceb58ae32ea133222352ba0e15614f8.receipt.json b/vision-fixhub/court-05/65cb858cd0f8c28f5c74e46040cc10290ceb58ae32ea133222352ba0e15614f8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3ef08322e34398229fe611bd36b03565f717cf67 --- /dev/null +++ b/vision-fixhub/court-05/65cb858cd0f8c28f5c74e46040cc10290ceb58ae32ea133222352ba0e15614f8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -144, + "dataset": "marble-joined", + "doc_id": "65cb858cd0f8c28f5c74e46040cc10290ceb58ae32ea133222352ba0e15614f8", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "4dcc1ada580a3b1ae7750de67bff127ec8a1170645e20ba18fb71f985474088a", + "output_sha256": "79fb1c99825a9352beaeee1625684800fb196b8dfd48da9b6e03e993fff341d8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/65d594d057afbda56db60fb6c60f9243ecf102ba6b5a9ea6ef62b0d229e0c00b.md b/vision-fixhub/court-05/65d594d057afbda56db60fb6c60f9243ecf102ba6b5a9ea6ef62b0d229e0c00b.md new file mode 100644 index 0000000000000000000000000000000000000000..4f41dbff04a611dea4ec9dde4ea228c22b91bab2 --- /dev/null +++ b/vision-fixhub/court-05/65d594d057afbda56db60fb6c60f9243ecf102ba6b5a9ea6ef62b0d229e0c00b.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 158-72 Filed 05/23/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/65d594d057afbda56db60fb6c60f9243ecf102ba6b5a9ea6ef62b0d229e0c00b.receipt.json b/vision-fixhub/court-05/65d594d057afbda56db60fb6c60f9243ecf102ba6b5a9ea6ef62b0d229e0c00b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3367490c15016dc1943e3e242b2b2c6eec170f55 --- /dev/null +++ b/vision-fixhub/court-05/65d594d057afbda56db60fb6c60f9243ecf102ba6b5a9ea6ef62b0d229e0c00b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "65d594d057afbda56db60fb6c60f9243ecf102ba6b5a9ea6ef62b0d229e0c00b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "6f8e1083a06a667ced0b744a6d930987ed5b9be1bd7760a373507a4c4f586b91", + "output_sha256": "261bfc708b7210742a09b54cbc91d6fc468324d8a98864fcd817e727d1a056e3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/65d83451f6c837cec5fb56e461047b5905f0d044b5ad604cf30e7556ea85b6fb.md b/vision-fixhub/court-05/65d83451f6c837cec5fb56e461047b5905f0d044b5ad604cf30e7556ea85b6fb.md new file mode 100644 index 0000000000000000000000000000000000000000..d6e8e0a86ccf3548be658c0f3261ce8e3a4f162c --- /dev/null +++ b/vision-fixhub/court-05/65d83451f6c837cec5fb56e461047b5905f0d044b5ad604cf30e7556ea85b6fb.md @@ -0,0 +1,39 @@ +Case 1:22-cv-10904-JSR Document 11-1 Filed 01/06/23 Page 1 of 2 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +) +Case Number: 1:22-cv-10904 JSR +AFFIDAVIT OF +ELIZABETH PAIGE BOGGS +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +I, Elizabeth Paige Boggs, declare and state the following: +I have never been convicted of a felony; +I have never been censured, suspended, disbarred or denied admission or +readmission by any court; and +3. +there are no disciplinary proceedings presently against me. +I make this Affidavit in support of my Motion for Admission Pro Hac Vice to appear as counsel +for Plaintiff, Government of the United States Virgin Islands, in the above-captioned action. +Dated: January 5, 2023 +Elinaleth Paise Sa +ELIZABETH PAIGE BOGGS +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +(202) 386-9629 phone / (202) 386-9622 fax +pboggs@motleyrice.com + + +Case 1:22-cv-10904-JSR Document 11-1 Filed 01/06/23 Page 2 of 2 +DISTRICT OF COLUMBIA +SWORN to and subscribed before me this 5 +day of January 2023. +My Commission Expires: 10 14 2007 +COLUMBIN +DISTRICT OF +2 diff --git a/vision-fixhub/court-05/65d83451f6c837cec5fb56e461047b5905f0d044b5ad604cf30e7556ea85b6fb.receipt.json b/vision-fixhub/court-05/65d83451f6c837cec5fb56e461047b5905f0d044b5ad604cf30e7556ea85b6fb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..913f9f53dcd8d665b24fc500e5c2415eefca65cb --- /dev/null +++ b/vision-fixhub/court-05/65d83451f6c837cec5fb56e461047b5905f0d044b5ad604cf30e7556ea85b6fb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "65d83451f6c837cec5fb56e461047b5905f0d044b5ad604cf30e7556ea85b6fb", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "c7019460b296eb68e401d8a2ae24ed0fc4f411ef525be5468469009ced61d72c", + "output_sha256": "f0dce0aff0763c737a2f69ccf82782de98e95deaa72033f594a3bc3b0ad6aaa0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/65fe8c5a5112f1bba6927dfe2a1635952fbfd0553d2283cef5843269f4ad6dfb.md b/vision-fixhub/court-05/65fe8c5a5112f1bba6927dfe2a1635952fbfd0553d2283cef5843269f4ad6dfb.md new file mode 100644 index 0000000000000000000000000000000000000000..901a4c5cbca9c0f570eacdb04e898000047f8de4 --- /dev/null +++ b/vision-fixhub/court-05/65fe8c5a5112f1bba6927dfe2a1635952fbfd0553d2283cef5843269f4ad6dfb.md @@ -0,0 +1,65 @@ +Case 1:22-cv-10904-JSR Document 47 Filed 02/15/23 Page 1 of 3 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +Case No. 1: 22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A., +Defendant. +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +NOTICE OF FILING LESS REDACTED VERSION OF ITS +FIRST AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL +PLEASE TAKE NOTICE that Plaintiff, Government of the United States Virgin Islands, +(Government") hereby files a less redacted version of its First Amended Complaint and +Demand for a Jury Trial (attached as Exhibit A). This version of the Complaint is identical to +the First Amended Complaint filed on January 10, 2023 except that the Government has +removed certain redactions from the previously-filed version. +Dated: February 15, 2023 +CAROL +ESQ. +ACTING ATTORNEY GENERAL +Is/ David I. Ackerman +David I. Ackerman +Carol +(pro hac vice) +Acting Attorney General of the +United States Virgin Islands +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +St. +1. U.S. Virgin Islands 00802 +Tel: (340) 774-5666 ext. 10101 + + +Case 1:22-cv-10904-JSR Document 47 Filed 02/15/23 Page 2 of 3 +Linda +(pro hac vice) +Mimi Liu (pro hac vice pending) +David I. Ackerman +Paige Boggs (pro hac vice) +MOTLEY RICE LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Fax: (202) 232-5513 +Isinger@motleyrice.com +mliu@motleyrice.com +dackerman@motleyrice.com +pboggs@motleyrice.com +Attorneys for Plaintiff Government of the +United States Virgin Islands +2 + + +Case 1:22-cv-10904-JSR Document 47 Filed 02/15/23 Page 3 of 3 +CERTIFICATE OF SERVICE +I hereby certify that on February 15, 2023, I electronically filed the foregoing +Government of the United States Virgin Islands' Notice of Filing Less Redacted Version of First +Amended Complaint and Demand for a Jury Trial with the Clerk of the Court and served on +counsel of record using the Court's CM/ECF system. Notice of this filing will be sent to all +parties of record by operation of, and parties may access this filing through, the Court's CM/ECF +system. +By: Is/ David I. Ackerman +David I. Ackerman diff --git a/vision-fixhub/court-05/65fe8c5a5112f1bba6927dfe2a1635952fbfd0553d2283cef5843269f4ad6dfb.receipt.json b/vision-fixhub/court-05/65fe8c5a5112f1bba6927dfe2a1635952fbfd0553d2283cef5843269f4ad6dfb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8944cb066a13171aa60015b7b236bd02a77769ff --- /dev/null +++ b/vision-fixhub/court-05/65fe8c5a5112f1bba6927dfe2a1635952fbfd0553d2283cef5843269f4ad6dfb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "65fe8c5a5112f1bba6927dfe2a1635952fbfd0553d2283cef5843269f4ad6dfb", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2399379db4c71b8adb6e08cd5ab901ef7006e988fa88bc9482331babb0f4b6f7", + "output_sha256": "47e89a0f8c85d6aeb26c8a928684a8b9f7a98bc9ef89ac8022ae686f2ec3555b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6618ecde24956a5276f397312d3126b34ace0198d92f579561c05b5456691924.md b/vision-fixhub/court-05/6618ecde24956a5276f397312d3126b34ace0198d92f579561c05b5456691924.md new file mode 100644 index 0000000000000000000000000000000000000000..1964064d2501e214ba2c234c3929f8c5b200d22a --- /dev/null +++ b/vision-fixhub/court-05/6618ecde24956a5276f397312d3126b34ace0198d92f579561c05b5456691924.md @@ -0,0 +1,21 @@ +Case 1:22-cv-10904-JSR Document 186-5 Filed 06/14/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 186-5 Filed 06/14/23 Page 2 of 2 +Date: +Thursday, December 202018 05:35 PM +Subject: Charitable Donations +From: +Cecile de Jongh +@yahoo.com> +To: +Jeffrey Epstein ; +CC: +Richard Kahn < +@gmail.com>: +Albert asked that the $30K go to the VI Little League. +With warm regards, +Cecile de Jongh + +ESTATE_JPM016246 diff --git a/vision-fixhub/court-05/6618ecde24956a5276f397312d3126b34ace0198d92f579561c05b5456691924.receipt.json b/vision-fixhub/court-05/6618ecde24956a5276f397312d3126b34ace0198d92f579561c05b5456691924.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..aeb8be800577f0dfaba5521fb1f7d7a2cd6767e4 --- /dev/null +++ b/vision-fixhub/court-05/6618ecde24956a5276f397312d3126b34ace0198d92f579561c05b5456691924.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -45, + "dataset": "marble-joined", + "doc_id": "6618ecde24956a5276f397312d3126b34ace0198d92f579561c05b5456691924", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "fdc63f6f73fc5f518a344890711018c039beb6c7be9a50b75120c337fb476f21", + "output_sha256": "ddcb17207b4a5206b32661869ad15623e349b83f9a864c8be83cb197138eec53", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/663a4cd2411638de2176d1d3b843e2ae362c19dccee46e9e916de779a39b5923.md b/vision-fixhub/court-05/663a4cd2411638de2176d1d3b843e2ae362c19dccee46e9e916de779a39b5923.md new file mode 100644 index 0000000000000000000000000000000000000000..6012c007a9bb9968d347009f8e4d9f354584cee5 --- /dev/null +++ b/vision-fixhub/court-05/663a4cd2411638de2176d1d3b843e2ae362c19dccee46e9e916de779a39b5923.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 158-55 Filed 05/23/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/663a4cd2411638de2176d1d3b843e2ae362c19dccee46e9e916de779a39b5923.receipt.json b/vision-fixhub/court-05/663a4cd2411638de2176d1d3b843e2ae362c19dccee46e9e916de779a39b5923.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..18085a8b23ea5e0829501b6bdafc299d0870080c --- /dev/null +++ b/vision-fixhub/court-05/663a4cd2411638de2176d1d3b843e2ae362c19dccee46e9e916de779a39b5923.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "663a4cd2411638de2176d1d3b843e2ae362c19dccee46e9e916de779a39b5923", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "738d38556e9787e7a5cc586eade2f5a15df25efc3257e2297d83d7503f09831f", + "output_sha256": "07d204c593f16ed589a640c4d488390eca5067ad052cc728d56472efdbd19835", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/66572f47e8657586d6939662fa8fd26452351c511ce4c5202d95abe963c30efd.md b/vision-fixhub/court-05/66572f47e8657586d6939662fa8fd26452351c511ce4c5202d95abe963c30efd.md new file mode 100644 index 0000000000000000000000000000000000000000..a848b62cfc93e8694c77c57e91937f5542b72492 --- /dev/null +++ b/vision-fixhub/court-05/66572f47e8657586d6939662fa8fd26452351c511ce4c5202d95abe963c30efd.md @@ -0,0 +1,582 @@ +Case 1:22-cv-10904-JSR Document 285-21 Filed 08/15/23 Page 1 of 12 + + + +Case 1:2₴ 6Yr#994n1SPa Document 38ant Eled086563t Page beatr +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE +UNITED STATES VIRGIN +ISLANDS, +Plaintiff, +: +CASE NO. +: +1:22-CV-10904 +• • +-JSR +V. +JPMORGAN CHASE BANK, +N.A., +Defendant/Third Party +Plaintiff. +: +JPMORGAN CHASE BANK, +N.A., +Third Party Plaintiff, +: +• • +V. +JAMES EDWARD STALEY, +: +Third Party Defendant. +CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER +July 13, 2023 +Videotaped deposition of +JOHN R. DUFFY, taken pursuant to notice, +was held at Wilmer Hale, Seven World +Trade Center, New York, New York, +beginning at 9:17 a.m., on the above +date, before +I. Gray, a +Registered Professional Reporter, +Certified Shorthand Reporter, Certified +Realtime Reporter, and Notary Public. +GOLKOW LITIGATION SERVICES +877.370.3377 ph | 917.591.5672 fax +deps@golkow.com +Page 1 + + +Case 1:2₴6Yr#99en/SPa Document 38ant Eled086563t Page eder +1 those subsequent checkpoint meetings +2 prior to this August 4, 2011, meeting? +3 +A. +Not that I recall. +4 +5 +e. +Okay. Skipping down to the +section, "Excerpts From the Press." +6 +The first sentence there +7 +says, "Committee members reviewed recent +• press releases, summarized below," right? +9 +A. +Yes. +10 +e. +And going to the next page, +11 +12 +at the very end, if you see, it says, +"Conclusion: The client will remain +13 +flagged as high risk and we will proceed +14 +with business as usual. The client will +15 +remain a l +'banking' client only." +16 +Correct? +17 +A. +That's what it says. +18 +Is that your understanding +19 of the conclusion of the rapid response +20 +meeting? +21 +A. +It is. It is. What's -- +22 +what's different from this, from the +23 documents we were just looking at, is +24 +that the reviewed press releases were +Page 168 + + +Case 1:2₴6Yr#994nSPa Document 38ant Eled 086563t Page beder +1 different than some of the documents that +2 you walked me through previously. +3 +But you don't have any +4 reason to think that those documents that +5 +were e-mailed to you weren't provided to +you? +7 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +A. +I - like I said, don't have +8 a recollection of it. Don't doubt that +they were provided by the +system. +But as it relates to the +reputational risk meeting, these are the +excerpts that we reviewed, obviously, +from. +e. +It says those were the ones +that were reviewed during the meeting, +right? +A. +Yeah. Correct. +It doesn't say that other +documents weren't circulated previously, +right? +A. +It does not. +e. +Okay. And -- so at the end +of the August 4, 2011, reputational risk +committee meeting, the decision was made +Page 169 + + +Case 1:2₴ 6K#99en|SPa Documen 38āt Eiled 086563t Page 5ºtbr +1 +2 +who take out cash regularly, we +look for it to be consistent with +3 +what was expected for that +4 +account. And the DDR is the +5 +mechanism for setting the +6 +expectation of activity in an +7 +account. And Mr. Epstein's cash +8 +withdrawals were consistent with +the expectations as set by his +10 +11 +DDR. +BY MR. SCHIFFMANN: +12 +13 +So to answer my question, +you did not -- you were not concerned +14 +15 +about any aspect of his cash usage while +you were CEO of the U.S. Private Bank? +16 +17 +A. +asked him about it. +I was curious about it. I +18 +But you were not concerned +19 about it? +20 +A. +No. We spoke about it. He +21 gave me an answer, which was it was for +22 jet fuel. I took him at his word and +23 felt like I covered that with him. +24 +e. +And when he told you that, +Page 176 + + +Case 1:2₴6Yr#994nSPa Document 38ant Eled 086563t Page 69der +1 +you believed him? +2 +A. +I did. +3 +Did you ever think he was +4 being dishonest with you? +5 +A. +No, I did not. +6 +So did you always take +7 +Mr. Epstein at his word? +8 +A. +We didn't talk that often. +9 +But on that -- on that matter in +10 particular, yes. +11 +Do you remember ever not +12 +13 +taking him at his word during any of your +conversations? +14 +A. +They were limited, so no. +15 +Did you ever discuss your +16 +17 +concerns - well, withdrawn. +Did you ever discuss +18 +Mr. Epstein's use of cash with Mary +19 Erdoes? +20 +A. +Yes. +21 +e. +And what do you remember +22 about -- well, when was that +23 +conversation? +24 +A. +I don't recall. +Page 177 + + +Case 1:2₴6Yr#994nSPa Documen 38ant Eled 086563t Page beder +1 +A. +What I agree to is I had +reputational issues with Mr. Epstein as a +result of he being a felon and a sex +4 offender. +3 +5 +And would you agree that +6 being a felon and a sex offender and +7 +somebody who pled guilty to the +solicitation of a 14-year-old for +commercial sex does not necessarily +10 affect Mr. Epstein's willingness or +ability to pay? +MR. +: Objection. +THE WITNESS: I don't know. +11 +12 +13 +14 +BY MS. LIU: +15 +l. +You recall that you were +16 +asked a number of questions about, I +17 +think, what we can now refer to as the +18 cash or fuel explanation that was given +19 by Mr. Epstein? +20 +A. +Yes. +21 +Do you recall when you got +22 that explanation? +23 +A. +I don't recall exact date, +24 +no. +Page 336 + + +Case 1:2₴6Yr#994n/SPa Document 38ānt Eled 086563t Page 8eder +1 +And you recall you testified +2 +that the explanation was that he needed +3 +cash to pay for fuel when he was +4 traveling to foreign countries, correct? +5 +A. +That's correct. +6 +And then I think there was +7 +9 +some discussion about potentially there +being some OFAC countries; do you recall +that? +10 +A. +That was mentioned, yes. +11 +e. +And what is an OFAC country? +12 +A. +I'm not going to remember +13 +the actual words behind that. But I +14 +think it's the Office of Foreign Accounts +15 and Currency Control, something like +16 that. +17 +e. +And what does it mean to say +18 that Mr. Epstein travels to foreign +19 countries, including certain OFAC +20 +countries? What does that mean? +21 +A. +In - I will give you my +22 +recollection. +23 +24 +Io my recollection, +countries on the OFAC list are prohibited +Page 337 + + +Case 1:2Z6Yrł994nłSPa Documen 38ant Eled 086563t Page 8eder +from - for U.S. banking institutions to +2 do business there and U.S. corporations +3 to do business there. +4 +e. +And at the time you received +this explanation, did you ask him +6 specifically what countries are you +7 +traveling to? +8 +A. +I don't recall. +9 +e. +And is it fair to say, then, +10 that you did not also ask him what +11 +OFAC -- what countries on the OFAC list +12 +13 +are you traveling to? +A. +I don't recall. +14 +15 +16 +17 +e. +And are you aware of what +countries in Eastern Europe are on the +OFAC list or were on the OFAC list at +that time? +18 +A. +I don't recall. +19 +e. +So you do recall that there +20 +was derogatory information reported +21 +within the bank that Mr. Epstein was +22 known to fly women for trafficking +23 purposes from Eastern Europe to the +24 +United States, correct? +Page 338 + + +Case 1:22c0/n10996 8R a Document 3ªakit Filed pableetRage 10re} +1 +line, it says, "Mr. Epstein will continue +2 to be a banking-only client," correct? +3 +A. +It says that. +4 +He was not exited from the +5 +6 +bank at this time, correct? +A. +That's correct. +7 +And if you could turn back +8 to the first page. You'll see under +10 +"Nature of Existing Relationship," the +second paragraph says, "During the period +11 +12 +of March 2010 to December 2010, there +were eight large cash withdrawals +13 +totaling $240,000." +14 +Do you see that? +15 +16 +17 +A. +I do. +e. +And do you know, during that +period, whether Mr. Epstein was on house +18 +arrest? +19 +A. +One, I do not know that. +20 +And two, during that period of time, I +21 was not in charge of the U.S. Private +22 Bank. +23 +So is it fair to say that +24 +you never asked Mr. Epstein, after you +Page 344 + + +Case 1:22c0/n10996 8R a Document 3ªakit Filed pableetRage Wraz +received the cash for fuel explanation -- +2 or you never looked into whether or not +3 that explanation made sense, given that +4 he had spent a considerable number of +5 +6 +years in jail and then on house arrest? +MR. +: Objection. +7 +THE WITNESS: Could you +8 +repeat your question, please. +9 +MS. LIU: Can I have that +10 +question read back. +11 +12 +(Whereupon, the court +reporter read back the requested +13 +14 +portions of the transcript.) +THE WITNESS: That +15 +16 +explanation, to me, was taken at +face value and post the +17 +conversation with Mr. Epstein. +18 +19 +Many of his cash activities, as +recommended to him for his +20 +21 +aviation fuel needs, were switched +to his aviation account, Hyperion. +22 BY MS. LIU: +23 +24 +Taken at face value, meaning +you didn't do any digging into whether or +Page 345 + + +Case 1:22c0/n10996 8R a Document 3ªaki Filgd pebreetRage brez +not that explanation made sense? You +2 just took Mr. Epstein at his word, +3 +correct? +4 +A. +I took Mr. Epstein at his +5 +word. And then following that, his cash +6 +activity for fuel came out of the +7 Hyperion account, and that made sense. +8 +It came out of the Hyperion +10 +account at your suggestion, correct? +A. +Well, it came - if he is +11 +12 +13 +using money, his money for aviation +purposes, it's common sense and good +advice to give a client advice to make +14 +15 +16 +17 +sure that money comes out of your +aviation account so that when you're +accounting for your aviation expenses, +they are well documented. +18 +But you knew that the money +19 +was simply being transferred into the +20 aviation account a few days before it was +21 then taken out of the aviation account, +22 correct, Mr. Duffy? That's what the +23 documents in this case show? +24 +MR. +: Objection. +Page 346 \ No newline at end of file diff --git a/vision-fixhub/court-05/66572f47e8657586d6939662fa8fd26452351c511ce4c5202d95abe963c30efd.receipt.json b/vision-fixhub/court-05/66572f47e8657586d6939662fa8fd26452351c511ce4c5202d95abe963c30efd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ee896320ff15783e7d8b96027a7dcf3a5ad7df28 --- /dev/null +++ b/vision-fixhub/court-05/66572f47e8657586d6939662fa8fd26452351c511ce4c5202d95abe963c30efd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -452, + "dataset": "marble-joined", + "doc_id": "66572f47e8657586d6939662fa8fd26452351c511ce4c5202d95abe963c30efd", + "engine": "marble-apple-vision", + "event_count": 14, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "3d937abe4a8318aaad0d4c97d82fdad02689575f515ec663da7417c2021c6919", + "output_sha256": "51d8c7b76ac3555c3a71328ebbedeba98760771eecbc51fcf8ce54742f1f202b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/66876f3a16c08240e8aaae646cc2967549007fe9d19648cc6a6a4cf88549babb.md b/vision-fixhub/court-05/66876f3a16c08240e8aaae646cc2967549007fe9d19648cc6a6a4cf88549babb.md new file mode 100644 index 0000000000000000000000000000000000000000..692f9be131c02bbf8c5e890098a36cc9a426ff16 --- /dev/null +++ b/vision-fixhub/court-05/66876f3a16c08240e8aaae646cc2967549007fe9d19648cc6a6a4cf88549babb.md @@ -0,0 +1,73 @@ +Case 1:22-cv-10904-JSR Document 326-102 Filed 09/08/23 Page 1 of 3 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-102 Filed 09/08/23 Page 2 of 3 +Jes Staley +10/27/2010 3:48:58 PM +Fw: Peter Mandelson +I sent this to Peter +From: Jes Staley +To: +Sent: Wed Oct 27 07:36:13 2010 +Subject: Fw: Peter Mandelson +A good description of where we stand in Russia and the bank deal. +Best +Jes +From: Jes Staley +To: Jeffrey R Costello +Cc: Emilio R Saracho; Yan L Tavrovsky +Sent: Wed Oct 27 07:35:25 2010 +Subject: Re: Peter Mandelson +Thanks Jeff. Very helpful. When Lord Mandelson can help, please let me know. +Best +Jes +From: Jeffrey R Costello +To: Jes Staley +Cc: Emilio R Saracho; Yan L Tavrovsky +Sent: Wed Oct 27 05:20:44 2010 +Subject: Peter Mandelson +Jes: +Emilio mentioned that Lord Mandelson had informally offered to assist with discussions around Russian +privatizations. I thought it would be useful to give you some color on the situation. +We have been meeting regularly over the past year and a half with the Ministry of Economic Development, which is +charged with planning and executing the privatization program, and have recently been appointed as one of 10 +banks that are authorized by the Russian Government to advise on privatization transactions. Yan and I met +yesterday with the Deputy Minister of Economic Development who told us that MinEconDev expects to submit its +comprehensive privatization plan -- including the final list of assets - to the Prime Minister in early November. +Once the list and plan have been approved by the Government, we and the other authorized advisers will be invited +to bid for the projects we are interested in. +We have also initiated a high-level dialogue this year between Jamie and Finance Minister Kudrin - they met in St +Petersburg in June and in DC two weeks ago. Although the plan is being developed by MinEconDev, the MinFin +will need to approve all elements as they relate to federal budget planning. In DC, Kudrin spoke directly about +privatization and assured us that once the plan is approved, we will be asked by MinFin as well to give our views. +As an aside, we were just appointed by the MinFin to lead their debut Ruble-denominated Eurobond in 1H11. + +JPM-SDNYLIT-00010603 + + +companies. As you can imagine, there are only a handful that will be relevant for foreign investors and we are fullyengaged with each of those companies to ensure that we have the support of their management teams - as well +as the Government - when the time comes to award specific mandates. To give you some flavor of our +involvement, these target companies include: Russian Railways (we led their debut Eurobond this year and are +currently marketing the IPO of one of their largest subsidiaries); Sovcomflot (we led their debut Eurobond this +year); Gazprom (we led their benchmark Eurobond this year and were recently appointed their corporate broker); +and Sberbank (we led their benchmark Eurobond and are actively assisting them in establishing the first Russian +Depositary Receipts program). +In short, I think we are covering all of the bases at the moment. The plan may or may not approved this year - it +was supposed to be approved last year and the wheels of government grind exceedingly slowly in Russia. Once +we are in the running for specific deals, we will be leveraging all sources, including Jamie, Heidi, you, Jakob +Frenkel, etc. At that point, it may also make sense to see if Lord Mandelson can be helpful -- certainly would be +good to keep a few trump cards in our hand +TIl keep you apprised as the situation develops, and happy to discuss further if you have any questions. +best, +jrc +Jeffrey Costello | Managing Director & CEO | CB "J.P. +Bank International" (LLC) | Paveletskaya sq.2, bldg.1, 115054 Moscow, +Russia | T: +7 495 967 7100 | F: +7 495 967 1011 | Leffrey.rcostel @ipmorgan.com | ipmorgan.com + +JPM-SDNYLIT-00010604 \ No newline at end of file diff --git a/vision-fixhub/court-05/66876f3a16c08240e8aaae646cc2967549007fe9d19648cc6a6a4cf88549babb.receipt.json b/vision-fixhub/court-05/66876f3a16c08240e8aaae646cc2967549007fe9d19648cc6a6a4cf88549babb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..55f0e4227e33ead44b1718a6015b052fc5a30eb0 --- /dev/null +++ b/vision-fixhub/court-05/66876f3a16c08240e8aaae646cc2967549007fe9d19648cc6a6a4cf88549babb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -61, + "dataset": "marble-joined", + "doc_id": "66876f3a16c08240e8aaae646cc2967549007fe9d19648cc6a6a4cf88549babb", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "8a4121f3d75a70130f6fefce5f1166824b993eb167c4d37bb8369a0e3765e35e", + "output_sha256": "a9c0d2f0018fdcd6143d92f40bdbb53531a93bd6275b72afa99fe8487e22dbe5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/668c86f5b86a0b42d5c86b6cea222b323de59ff0b87531f03ad3ac13df516a44.md b/vision-fixhub/court-05/668c86f5b86a0b42d5c86b6cea222b323de59ff0b87531f03ad3ac13df516a44.md new file mode 100644 index 0000000000000000000000000000000000000000..2ed2ef297f7d5d8373a3685c03eb73d3175cd237 --- /dev/null +++ b/vision-fixhub/court-05/668c86f5b86a0b42d5c86b6cea222b323de59ff0b87531f03ad3ac13df516a44.md @@ -0,0 +1,75 @@ +Case 1:22-cv-10904-JSR Document 265-38 Filed 08/07/23 + + +FILED UNDER SEAL + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 265-38 Filed 08/07/23 Page 2 of 3 +Jes Staley +"jeevacation@gmail.com sjeevacation@gmail.com> +10/27/2010 3:48:58 PM +Fw: Peter Mandelson +I sent this to Peter +From: Jes Staley +To: +Sent: Wed Oct 27 07:36:13 2010 +Subject: Fw: Peter Mandelson +A good description of where we stand in Russia and the bank deal. +Best +Jes +From: Jes Staley +To: Jeffrey R Costello +Cc: Emilio R Saracho; Yan L Tavrovsky +Sent: Wed Oct 27 07:35:25 2010 +Subject: Re: Peter Mandelson +Thanks Jeff. Very helpful. When Lord Mandelson can help, please let me know. +Best +Jes +From: Jeffrey R Costello +To: Jes Staley +Cc: Emilio R Saracho; Yan L Tavrovsky +Sent: Wed Oct 27 05:20:44 2010 +Subject: Peter Mandelson +Jes: +Emilio mentioned that Lord Mandelson had informally offered to assist with discussions around Russian +privatizations. I thought it would be useful to give you some color on the situation. +We have been meeting regularly over the past year and a half with the Ministry of Economic Development, which is +charged with planning and executing the privatization program, and have recently been appointed as one of 10 +banks that are authorized by the Russian Government to advise on privatization transactions. Yan and I met +yesterday with the Deputy Minister of Economic Development who told us that MinEconDev expects to submit its +comprehensive privatization plan -- including the final list of assets - to the Prime Minister in early November. +Once the list and plan have been approved by the Government, we and the other authorized advisers will be invited +to bid for the projects we are interested in. +We have also initiated a high-level dialogue this year between Jamie and Finance Minister Kudrin - they met in St +Petersburg in June and in DC two weeks ago. Although the plan is being developed by MinEconDev, the MinFin +will need to approve all elements as they relate to federal budget planning. In DC, Kudrin spoke directly about +privatization and assured us that once the plan is approved, we will be asked by MinFin as well to give our views. +As an aside, we were just appointed by the MinFin to lead their debut Ruble-denominated Eurobond in 1H11. + +JPM-SDNYLIT-00010603 + + +companies. As you can imagine, there are only a handful that will be relevant for foreign investors and we are fullyengaged with each of those companies to ensure that we have the support of their management teams - as well +as the Government - when the time comes to award specific mandates. To give you some flavor of our +involvement, these target companies include: Russian Railways (we led their debut Eurobond this year and are +currently marketing the IPO of one of their largest subsidiaries); Sovcomflot (we led their debut Eurobond this +year); Gazprom (we led their benchmark Eurobond this year and were recently appointed their corporate broker); +and Sberbank (we led their benchmark Eurobond and are actively assisting them in establishing the first Russian +Depositary Receipts program). +In short, I think we are covering all of the bases at the moment. The plan may or may not approved this year - it +was supposed to be approved last year and the wheels of government grind exceedingly slowly in Russia. Once +we are in the running for specific deals, we will be leveraging all sources, including Jamie, Heidi, you, Jakob +Frenkel, etc. At that point, it may also make sense to see if Lord Mandelson can be helpful -- certainly would be +good to keep a few trump cards in our hand +TIl keep you apprised as the situation develops, and happy to discuss further if you have any questions. +best, +jrc +Jeffrey Costello | Managing Director & CEO | CB "J.P. +Bank International" (LLC) | Paveletskaya sq.2, bldg.1, 115054 Moscow, +Russia | T: +7 495 967 7100 | F: +7 495 967 1011 | Leffrey.rcostel @ipmorgan.com | ipmorgan.com + +JPM-SDNYLIT-00010604 \ No newline at end of file diff --git a/vision-fixhub/court-05/668c86f5b86a0b42d5c86b6cea222b323de59ff0b87531f03ad3ac13df516a44.receipt.json b/vision-fixhub/court-05/668c86f5b86a0b42d5c86b6cea222b323de59ff0b87531f03ad3ac13df516a44.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..42ffa37d2983f48ce0cedfb93143ed6b6c7e7cc5 --- /dev/null +++ b/vision-fixhub/court-05/668c86f5b86a0b42d5c86b6cea222b323de59ff0b87531f03ad3ac13df516a44.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -72, + "dataset": "marble-joined", + "doc_id": "668c86f5b86a0b42d5c86b6cea222b323de59ff0b87531f03ad3ac13df516a44", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "c880c0268a7400e9fc340835f8509257edbfa731b416a5daaeb45b80be849544", + "output_sha256": "dd4f602ef02be5d004e7efc3db7f78e120f74d4afc4e63bdd925200538131afb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6695ea675e1a8d6aab5886ec0fd9b7bcc40afe233bbf49113b9fd957f52b689b.md b/vision-fixhub/court-05/6695ea675e1a8d6aab5886ec0fd9b7bcc40afe233bbf49113b9fd957f52b689b.md new file mode 100644 index 0000000000000000000000000000000000000000..6495bdd5c3b0baccea381d92079748aea94ee72a --- /dev/null +++ b/vision-fixhub/court-05/6695ea675e1a8d6aab5886ec0fd9b7bcc40afe233bbf49113b9fd957f52b689b.md @@ -0,0 +1,598 @@ +Case 1:22-cV-10904-JSR Document 240-12 Filed 07/25/23 Page 1 of 7 + + + +Case 1:22-cV-10904-JSR Document 240-12 Filed 07/25/23 Page 2 of 7 +Ticket# + +Account# +Initiated Date +Client Name +ECI +LOB +JEFFREY E +EPSTEIN + +PB +Account Tille +Initiator +02/09/2013 10:43 +AM +JUSTIN D NELSON +Account Type +Initiating Team +PB FRONT OFFICE +Verity & Confirm for Jeffrey Epstein +Final Risk Rating +Initial Risk Rating +GCS Report Requested +Presence of Potential High Risk: +Indicators +Reason for Adjustment +Comments +Summary of Risk Attributes +Please summarize any material changes +which have occurred with the client +within the past 12 months: +High +Standard +Full +Yes +Convicted Felan +Per bank policy, felons are considered high risk and require additional approval: +The account stil has yearly monitoring as the client is sensitive. +Risk Updated History +Creation +Date +Entered by +Updated +Risk +Previous +Risk +Comment +GCS Grid +Search Type +Company Information +Corporate Records +Other Database Searches +(RDC/MIS/Factiva) +Internal Database Search (CSSS/FPS) +Security Service Detalls +No additional research necessary +No additional research necessary +No additional research necessary. +Further Review Required +No +No +No +Interal database search revealed prior: +GS&l research for The Financial Trust +Company & J Epstein and Co and nothing +derogatory to report. Internal database +search revealed prior GS&l research for +Jeffrey Edward Epstein and the following +derogatory information was reported: +Several newspaper articles were found that +detai the indictment of Jeffrey Epstein in +Florida on felony charges of soliciting +underage prostitutes. Jeffrey Epstein +served 13 months in jail. Numerous articles +detal various law enforcement agencies +investigating Jeffrey Epstein for allegedly +Yes +Jelfrey Epslein has settled a dozen civil +awsuits out of court from his victims +regarding solicitation for an undisclosed +amount. +No additianal research necessary. +No additional research necessary +No additional research necessary. +No additional research necessary +No additional rose +arch necessan +No additional n +No +No +State Court Searches. +Federal Court Searshes +Personal Particulars +Publications +Regulatory Sanctions +OFAC/Control List Search +Negative or Inconsistent Information +GCS Red Dot +Has this been identified as Red Dot KYC? +Red Dot (Derogatory Information) Identified +Security Service Details +(Include KYC names in which this was previously reported, if any.) +Red Dot Information +Negative Information Found + +17 +3/7/23 + +JPM-SDNYLIT-00036258 + + +Case 1:22-cV-10904-JSR Document 240-12 Filed 07/25/23 Page 3 of 7 +Banker Attestation Details +As the client sponsor, I understand that i am primarily +responsible for protecting the firm's reputation from +inappropriate business relationships, as well as from fraud +and money laundering. By approving this KYC, 1am +sponsoring this client as to their character and reputation +and from a legal/regulatory standpoint. +Please state your rationale for conducting business with this +Jeffrey Epstein has been an active trading client and keeps mos! +client +of his liquidity with us. Total assets over 5100MM. Both Mary +Erdoes and John Dufly are aware of the relationship. +Senior management is aware of the relationship with Jeffrey. +Please respond to any issue(s) identified in the GS&l grid +that either needs further review, or red dot which is not +already covered in a Business Case within this KYC +Comments +Primary Information +Client Type +Client Status +Front Office Restricted? +Confidential Names? +Country of Primary Domicile +Prefix/Title +First Name +Middle Name +Last Name +Suffix +PreviousName/MMN/Allas +Citizenship +Employer Name +Occupation +Years at Occupation +Individual +Client +Noimal +No +LINITED STATES +Generation +Active Indicator +Marital Status +Yes +Single +Jeffrey +Epstein. +Primary Domicile State +Insider Code (Reg. O) +Full Name +Gender +Date of Birth +Primary Country of Assets +Now York +Jettiey E Epstein: 23 +Male +UNITED STATES +UNITED STATES +Self +Entrepreneur +High Risk Jurisdiction +Industry Code (NAIC) +Secondary Industry Code +(NAIC) +No +Individuals (999940 +Personal Investment +Companies (525997) +Addresses) +Type +Notes +Address +City, State, +Country +Postal +Code +Tools +Entered by +Date of +Update +Preferred +I Legal +6100 RED +HOOK QTRS +STE B3 +VIRGIN +ISLANDS +U.S +Map it +BATCH +08/03/2012 +Yes +Phone(s)/Fax(s) +Type +Notes +Phone +Number +Tools +Entered by +Home +Date of +Update +02/22/2013 +Work +Work +Fax +Fax +Work +Work +Other +Verify "Do Not +Call List +Verify "Do Not +Call List +Verify Do. Not +Call List +Verity "Do Not +Call List +Verity "Do Not +Call" Lis +Verty 'Do No +• List +Verily "Do Not +Call List +Verify Do Not +Call" List +BATCH +ROSALIA +CRACCHIOLO +TECS_DATA +05/12/2011 +05/21/2011 +TECS DATA +04/30/2011 +TECS_DATA +04/30/2011 +SYSTEM +05/12/2011 +BATCH +03/08/2013 +SYSTEM +03/18/2013 +Preferred +Yes +No +No +No +No +No +No +No +Email(s) +Type +Other +Notes +Email: +Entered by +BATCH +Date of Update +03/16/2013 +Preferred +Yes +Cost Center & Hierarchy +Client Status +Client +Client Type + +JPM-SDNYLIT-00036259 + + +Case 1:22-cV-10904-JSR Document 240-12 Filed 07/25/23 Page 4 of 7 +Cilent Sponsor +Cost Center +Client Service Team +GIO +Trust Advisor +Identification +Withholding Federal Status +Form of goverment issued +Identification obtained for the +files +Primary Identification Number +Date Issued +Introduction and Wealth +Introduction Type +Net Worth of clients) +Additional Party Information +No additional parties available at this time +JUSTIN D NELSON +002753 - GREENWICH. +CHBG (DE14 +Paul S +New or Existing Client +Entity Type +Portfolio Manager +Investor +Existing +Decision Maker +Domeste Certified +Drivers License +01/15/2010 +Withholding SSN/TIN +Certification Date +SSN/TIN/EIN +09/18/2006 +Issued By +Expiration Date +VIRGIN ISLANDS, U.S. +01/20/2015 +Existing JPMorgan Client - Inside LOB +500,000,000.00 +Introduction +Form of government issued identification obtained for the +files 7 +Has an employee of JP +Wealth Management met the +client in person? +What independent background check, in addition to the +Global Corporate Security (GCS") background check, has +been carried out? Check all that apply and provide the date +in which the background check was conducted. (at least 1 +must be selected +JPMC Network Date +JPMC Network Comments +Politically Exposed Person +Is the client a current or former Senior United States or Non- +USA Omicial/ also known as a Politically Exposed Person +(PEP), related to a PEP, or closely associated with a PEP? +Drivers License +Yes +JPMC Network +03/12/2013 +Jeffrey Epstein is an existing client of PB. He is an active +brokerage client across asset classes currently covered by the +Firm's GiO desk. Jeffrey Epstein has been an investment advisor +for numerous high net worth clients and also a personal investor. +Jeffrey is very accessible and well known to the team We have +advised him on investments as well as estate planning +opportunities. Jeffrey has continues to be well connected across +business channels. +Epstein is well known to several JPM PB employees and senior +management including Jes Staley. The purpose of this DOR is to +refresh our due diligence on Mr. Epstein. Mr. Epstein was +convicted of a felony charge in 2000, Jes Staley conferred with +Stephen Cutler and the decision was made to. keep Mr. Epstein as +a PB client. Mr. Epstein completed his sentence and probation in +2010. The relationship has been reviewed with senior +management and compliancellegal on a few occasions over the +post year as news stories of Jeffrey's past are picked up. No new +claims or stories have surfaced recently. +No +Source of Wealth/Financial Information +Source of Wealth- Identify the clients source of wealth from +the following list of options. +Which country(les) is(are) the Clients primary Source of +Wealth or Income derived? +Other +UNITED STATES + +JPM-SDNYLIT-00036260 + + +Case 1:22-cv-10904-JSR Document 240-12 Filed 07/25/23 Page 5 of 7 +Provide detailed and specific information. +Epstein managed money for numerous high net with families +and has been an active investor himselt. +Epstein began his financial career in 1976 as an options trader at +Bear Steams. He specialized in mathematical models such as the +Black-Scholes option-pricing model and later worked in the +SODEGISLE +division advising high net worth clients on tax +trategles. In 1980, Epstein became a partner at Bear Steams. In +1982, Epstein founded his own financial management fim: J. +Bon in net worth, In 1987, Leslie Wexner, founder and chairma +of the Columbus, Chio-based Limited chain of women's-clothing +stores became a well-known client. In 1996, Epstein changed the +name of his firm to The Financial Trust Company and based it in +the US Virgin Islands. +500000000.00 +Financial Statements +Client Net Worth S +Documentation/information obtained to confirm stated net +worth of Client: +Business Case +Please specify why you are comfortable with this client giver +the Identified risk factors). Your answer is your "business +case" and should detail all mitigating factors. +Provide client history/detall, including when the relationship +was established, how it came to be in PB/PWM. client's +association with other JPM LOBS, etc. +Client known to whom (JPMorgan employees), how well, and +how longE +Overall PB/PWM relationship size and type of accounts: +Is this a shared client, what other LOB has a relationship with +the client? Provide relationship manager name (If known), +client of other LOB since (date), and relationship size? +When was the last time you met the client? What was the +reason for the meetingi +Describe any significant changes in the client's information +or material events that may have occurred over the last year +(Examples: address changes, change in authorized persons +on accounts, change in account type, change in business, +change in net worth, etc,l. +Cash Activity: Summarize client cash activity during the +period reviewed and explain the purpose / use of the funds: +eriod revlewed and explain the purpose / use of the funds +including any international/cross border wires: +Before answering the following question please review the +Annual Account History Activity Summary Report that has +been attached In the Summary tab. Did the actual transaction +activity appear reasonable, normal, and expected for the type +of business or Industry in which the client engages? +Was the nature, value, and volume of actual transaction +activity consistent with expected transaction activity? +Was any unusual or potentially suspicious transaction +activity detected? +Additional Comments +Long term dient of the PB, well known to senior staff and +elationship monitored closely with regular reviews. No materials +events or deveopmehts to note over past twelve months. +Jeffrey epstein has been a client of the Private Bank for over ter +years. +Jeffrey's felony offense is well documented and he +complele his sentence and probablion two years ago. No. +material developments or issues with client relationship over the +past twelve months. +Integrated team, sr. management (see notes). Known for ten +yeara. Regular dialogue with client +Jettrey maintains a brokerage trading relationship across multiple +entities (*$100 million) and also maintain numerous checking +accounts for personal and business working capital +No, as of now Jeffrey works with the U.S. Private Bank +saw Jeffrey this week with John Duffy. Purpose was to check in +and have John reconnect with Jeffrey. +The only main change is Jeffrey is now a US Virgin Islands +resident for tax purposes. He is stil a US Citizen: +Only major change is that his old entity, Financial Trust, merged +into a new entity, Southem Trust, which now holds all of Jeffrey's +assets. All assets are 100% owned by Jeffrey +Nothing unusual. +Yes +Yes +No +NIA +Expected Activity +Deposit Accounts) +Transaction Types +Expected Activity Levels +Anticipated Dollar Amount Totals +per Morith +Cash Deposits: +Cash Withdrawals +Low (1-10) +€S10,000 +Check Deposits +Checks Paid +Low (1.10) +$50,001 TO $100,000 +Incoming Wires (Domestic) +Outgoing Wires (Domestic) +Low (1-10) +$100,001 TO $500,000 +Incoming Wires (Intemational) +Outgoing Wires (International) +ACH Deposits +ACH Payments +Intemal Transfer (Debits/Credits) +jow (1-10) +Low (1-10) +$10,000 TO $50,000 +$51,000,000 +Asset Purchases/Sales +What is the Initialiongoing source of funding for the client's Deposit Account's 2 +This is a annual review. +The account has already been funded. Any ongoing source of funding wil be from assets obtained through +personal investments and from interrial transfer of funds from personal account held at JPMorgani +What is the purpose/intended use of accounts)? Please provide a detailed description of how the Deposit Accounts) will be +used by the client. + +JPM-SDNYLIT-00036261 + + +Case 1:22-cV-10904-JSR Document 240-12 Filed 07/25/23 Page 6 of 7 +Operationa//household checking accounts and custody account to hold money market tunds. +personal investment entity (which invests mostly in uPM MM. Funds). +Checking account is used for personal investments and to pay everyday and morthly expenses. +Review the activity for the perlod overall and explain how the client's transaction profile agrees with or doesn't agree with +expectations for the client based on the client relationship (purpose of accounts, occupation, business activity, etc.): +Compliance reviews activity maularly. +Was expected activity for the client modified in the transaction activity section of the KYC ticket? +Yes +LIf modified, explain. +Activity modified to reflect client's current transaction activity. +Client Directed Asset / Brokerage Accounts) +Transaction Types +Expected Activity Levels +Anticipated Dollar Amount Totals +per Month +Cash Deposits +Cash Withdrawals +Check Deposits +Checks Paid +Incoming Wires (Domestic) +Outgoing Wires (Domestic) +Incoming Wires (International) +Outgoing Wires (Intemational) +ACH Deposits +ACH Payments +Internal Transfer (Debits/Credits) +Asset Purchases/Sales +Low (1-10) +$10,000 +What Is the initiallongoing source of funding for the client's Client Directed Asset / Brokerage Accounts) ? +This is an annual review. The account has already been funded. Any ongoing source of finding will be from investment growth and +dividends. +What is the purposelintended use of accounts)? Please provide a detailed description of how the Client Directed Asset / +Brokerage Accounts) will be used by the client +The purpose of the account is for investments, trading and wealth accumulation +Review the activity for the period overall and explain how the client's transaction profile agrees with or doesn't agree with +expectations for the client based on the client relationship (purpose of accounts, occupation, business activity, etc.) +Compliance review activity regulary. +Was expected activity for the client modified in the transaction activity section of the KYC ticket? +Yes +If modified, explain. +The activity was upated to reflect the client's current transaction activity. +Additional Client Information +SPORT +Please include any additional information that would further explain your knowledge of the client (family tree/history, public +information, websites etc.l +Jeffrey Epstein is an existing client of PB. He is an active brokerage client covered on the GiO desk. Jeff is wall know to the +integrated team and senior management. Jeffrey Epstein has been a money manager for high net worth individuals, entrepreneur and +personal investor, the team has regular discussion with Mr. Epstein and he remains very accessible +Mr. Epstein is well known to several JPM PB employees. +6-18.10: Mr. Epstein completed serving out his house anest +We have met regularly with compliance and legal do discuss the +realtionship and any potential reputational risk concems. We continue to monitor the situation closely and monitoring the occasional +news stories regarding Mr. Epstein and civil lawsuits and monitor closely money movement. Mr. Epstein is managing his own +personal wealth. +January 27, 2011 update: A few news stories during 2010 connects Jeffrey Epstein to human trafficking The coverage team along +with Catherine Keating and William Langford all met to discuss the situation and agreed to enhance monitoring and document a +discussion with the client. Jes Staley discussed the topic with Jeffrey Epstein who replied there was no truth to the allegations, no +evidence and was not expecting any problems. We will continue to monitor the accounts and cash usage closely going forward. +We continue to monitor the relationship closely and no additional stories or allegations have surfaced recently and Jeffrey maintain a +professional relationship with the PB and integrated team. +Comment History +Stage Name +Creation Date +There are no comments entered at this time. +Entered By +Comment Preview +Approval History +Stage Name +Banker Attestation +Market Manager +Approval +Signoff Date +04/26/2013 11:04 +AM +05/01/2013 11:53 +AM +Owner SID +UD08568 +U117517 +Owner Name +JUSTIN D NELSON +TOWNSEND C + +JPM-SDNYLIT-00036262 + + +Case 1:22-cv-10904-JSR Document 240-12 Filed 07/25/23 Page 7 of 7 +Regional Director +Approval +CEO Approval +05/01/2013.05:18 +PM: +A 0820131023 +U095563 +U234588 +WILLIAM M SHERIDAN +BONNIE K + +JPM-SDNYLIT-00036263 diff --git a/vision-fixhub/court-05/6695ea675e1a8d6aab5886ec0fd9b7bcc40afe233bbf49113b9fd957f52b689b.receipt.json b/vision-fixhub/court-05/6695ea675e1a8d6aab5886ec0fd9b7bcc40afe233bbf49113b9fd957f52b689b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e087f3ce9a8b152fe6d1aa69a59947ce93ee70c4 --- /dev/null +++ b/vision-fixhub/court-05/6695ea675e1a8d6aab5886ec0fd9b7bcc40afe233bbf49113b9fd957f52b689b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -193, + "dataset": "marble-joined", + "doc_id": "6695ea675e1a8d6aab5886ec0fd9b7bcc40afe233bbf49113b9fd957f52b689b", + "engine": "marble-apple-vision", + "event_count": 17, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "0816b6cf1229da72ccd46fece95015977b5185737536f16b1b582a5248156477", + "output_sha256": "5e4ba25cac1ad7687d80262123731efcee4ecc368c579ab28dd736c5c41b8378", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/66c743f3c65918f920983a7dbf0fd63b5462e034826226c446c4fc2874ee0edc.md b/vision-fixhub/court-05/66c743f3c65918f920983a7dbf0fd63b5462e034826226c446c4fc2874ee0edc.md new file mode 100644 index 0000000000000000000000000000000000000000..8efa3d35429b8af117639789a3af6c7052d0c546 --- /dev/null +++ b/vision-fixhub/court-05/66c743f3c65918f920983a7dbf0fd63b5462e034826226c446c4fc2874ee0edc.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 242-27 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/66c743f3c65918f920983a7dbf0fd63b5462e034826226c446c4fc2874ee0edc.receipt.json b/vision-fixhub/court-05/66c743f3c65918f920983a7dbf0fd63b5462e034826226c446c4fc2874ee0edc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c6984b23ee82af0c9287f37b6e69dbe38602655e --- /dev/null +++ b/vision-fixhub/court-05/66c743f3c65918f920983a7dbf0fd63b5462e034826226c446c4fc2874ee0edc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "66c743f3c65918f920983a7dbf0fd63b5462e034826226c446c4fc2874ee0edc", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "5cba19a19b2ac7566bdfc3cbc68b3dd69d373966623e8199792b9a3764044e95", + "output_sha256": "abb809ee9fc87d14027717b88f50fc3ad12534e0c95b92f55296a8cdf879c755", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/66caa5143ad23487e1763d80e81408739ba2eb7e32c13a23b8767ab6d807bda1.md b/vision-fixhub/court-05/66caa5143ad23487e1763d80e81408739ba2eb7e32c13a23b8767ab6d807bda1.md new file mode 100644 index 0000000000000000000000000000000000000000..2604862b543ca9057553776c99c146b6102fb5a3 --- /dev/null +++ b/vision-fixhub/court-05/66caa5143ad23487e1763d80e81408739ba2eb7e32c13a23b8767ab6d807bda1.md @@ -0,0 +1,41 @@ +Case 1:20-cr-00330-PAE +Document 687 Filed 06/27/22 Page 1 of 1 +USDC SDNY +BSF +BOIES +I SCHILLER +FLEXNER +ELECTRONICALLY FILED +DOC I +DATE FILED: 6/27/22 +June 27, 2022 +Sigrid S. McCawley, Esq +Telephone: 954.356.0011 +Email: smccawley@bsfllp.com +The Court anticipates permitting counsel for +CVRA victim +to read a +shortened version of +previously +submitted written statement. SO ORDERED. +Alia ONto 6127122 +U.S. Circuit Judge +Sitting by designation +The Honorable Alison J. Nathan +United States District Court +Southern District of New York +United States Courthouse +40 Foley Square +New York, New York 10007 +Re: +United States v. Ghislaine Maxwell, S2 20 Cr. 330 (A.JN) +Dear Judge Nathan: +I am in receipt of the Court's Order, Dkt. No. 686. As explained in our submission, due to +a medical issue, +is not able to be present physically in the courtroom, but has asked +that I be able to read her statement at the hearing. I seek clarification of Your Honor's Order +that I will be allowed to read a portion of Ms. Guiffre's statement at the hearing. +Respectfully, +Sigrid S. McCawley +BOIES SCHILLER FLEXNER LLP +401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 33301 | (t) 954 356 0011 | (f) 954 356 0022 | www.bsfllp.com diff --git a/vision-fixhub/court-05/66caa5143ad23487e1763d80e81408739ba2eb7e32c13a23b8767ab6d807bda1.receipt.json b/vision-fixhub/court-05/66caa5143ad23487e1763d80e81408739ba2eb7e32c13a23b8767ab6d807bda1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1e69a9124c43693758e99822e7412de899a21c46 --- /dev/null +++ b/vision-fixhub/court-05/66caa5143ad23487e1763d80e81408739ba2eb7e32c13a23b8767ab6d807bda1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "66caa5143ad23487e1763d80e81408739ba2eb7e32c13a23b8767ab6d807bda1", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8d57f58a10253f3a2f301e807ac1c96b73aa7174d970dda19d8f69ebe94a187e", + "output_sha256": "cd0d229b69a65ed2c4c12dd482c75ec3a7a5478b8cf5ad2fb028fbd4d0e3df94", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/66ea2cf2a438a169d5a2ccf8affc0f0f1e39f227289e13dc1681f1190ef6f8c4.md b/vision-fixhub/court-05/66ea2cf2a438a169d5a2ccf8affc0f0f1e39f227289e13dc1681f1190ef6f8c4.md new file mode 100644 index 0000000000000000000000000000000000000000..434a95ba63bd83083a27bccea12431aa49c533dc --- /dev/null +++ b/vision-fixhub/court-05/66ea2cf2a438a169d5a2ccf8affc0f0f1e39f227289e13dc1681f1190ef6f8c4.md @@ -0,0 +1,26 @@ +Case 1:22-cV-10904-JSR Document 326-75 Filed 09/08/23 Page 1 of 2 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-75 Filed 09/08/23 Page 2 of 2 +Jeffrey Epstein +3/10/2011 1:33:03 AM +yup family dont worry +-- +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved diff --git a/vision-fixhub/court-05/66ea2cf2a438a169d5a2ccf8affc0f0f1e39f227289e13dc1681f1190ef6f8c4.receipt.json b/vision-fixhub/court-05/66ea2cf2a438a169d5a2ccf8affc0f0f1e39f227289e13dc1681f1190ef6f8c4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1ab9da555999591321ceda72b97911bd9f8b5764 --- /dev/null +++ b/vision-fixhub/court-05/66ea2cf2a438a169d5a2ccf8affc0f0f1e39f227289e13dc1681f1190ef6f8c4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "66ea2cf2a438a169d5a2ccf8affc0f0f1e39f227289e13dc1681f1190ef6f8c4", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "8f163a0364a9df2f9d2f8072affcf95f4fea20eaabd0ba53d166f3eb5fb32858", + "output_sha256": "b4a0bbc4d63f9bbedac6a8cbf363fd42f449220494aae1450bd91b30eb3c3ad0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/66f2c0a765a216a50068738ec8a3c306a366987a6078ab7622a050a1292028e3.md b/vision-fixhub/court-05/66f2c0a765a216a50068738ec8a3c306a366987a6078ab7622a050a1292028e3.md new file mode 100644 index 0000000000000000000000000000000000000000..55e620d1c3d1dd316366cde77fdca0ce49cd8141 --- /dev/null +++ b/vision-fixhub/court-05/66f2c0a765a216a50068738ec8a3c306a366987a6078ab7622a050a1292028e3.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 244-16 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/66f2c0a765a216a50068738ec8a3c306a366987a6078ab7622a050a1292028e3.receipt.json b/vision-fixhub/court-05/66f2c0a765a216a50068738ec8a3c306a366987a6078ab7622a050a1292028e3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..14448834033d7e4ff58549a742453d06495e240c --- /dev/null +++ b/vision-fixhub/court-05/66f2c0a765a216a50068738ec8a3c306a366987a6078ab7622a050a1292028e3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "66f2c0a765a216a50068738ec8a3c306a366987a6078ab7622a050a1292028e3", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "31bc4b067105d7c0dc8d86f4fbcd0f635f4a7d380e411c9b7cacd283887936fc", + "output_sha256": "4f89647a8c564269377672b959cb52302e12d59237e6e8be898eb7eeffc36fee", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/66f3b3185599ca50dcf453d8096b41a0400dd78c0c0889f5ef27943b7f760f39.md b/vision-fixhub/court-05/66f3b3185599ca50dcf453d8096b41a0400dd78c0c0889f5ef27943b7f760f39.md new file mode 100644 index 0000000000000000000000000000000000000000..5a73e3613015808141af5f04363dca8834e767db --- /dev/null +++ b/vision-fixhub/court-05/66f3b3185599ca50dcf453d8096b41a0400dd78c0c0889f5ef27943b7f760f39.md @@ -0,0 +1,604 @@ +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 1 of 14 + + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 2 of 14 +UNITED +Economic Development Authority +WWW.USVIEDA.ORG 1877432-8784 +January 31, 2014 +Mrs. Cecile deJongh +Office Manager +6100 Red Hook Quarter B3 +St. +VI 00802 +Re: Financial Trust Company, Inc. +Dear Mrs. deJongh, +A compliance review has been completed on Financial Trust Company, Inc. Enclosed for your +review and commentary is the compliance report which covers the period January 1, 2007 to +December 31, 2008. The company was found out of compliance with the procurement requirements. +Please provide a response to this compliance report within thirty (30) working days of receipt of this +correspondence. You may request an extension of time to file your response by submitting a formal +notice. If we do not receive a response from you by this date, we will conclude that you are in +agreement with the findings of this report. +Should you have additional questions concerning this matter, please do not hesitate to contact +Stephanie Berry, Director of Compliance at 340-773-6499. +Sincerely, +Cc: +Clouden, Chief Executive Officer +Tracy +Bhola, Legal Counsel +Stephanie J. Berry, Director of Compliance +Sandra Bess, CCP Compliance Officer +Erika Kellerhals, Legal Counsel for FTC +Ecanomic Develapment Commission +Enterprise lane Commission +Street, Frederiksted, USVI 00840 (340) 775-6499 FAX (340) 773-7701 ST. +Goversment Development Bank +Industrial Park Development Corporation +8000 Nisky Shopping Center Suite 620, St. +Small Business Developm +USMI 0080Z (340) 714-1700 FAD +VI-JPM-000023078 + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 3 of 14 +STATES VIRGIN IS1 +Economic Development Authority +WWW.USVIEDA.DRG : 877 432-8784 +CONFIDENTIAL COMPLIANCE REPORT +FINANCIAL TRUST COMPANY, INC. (INACTIVE) +As of December 31, 2008 +SUMMARY HIGHLIGHT: +• Financial Trust Company, Inc. received nine (9) years of tax benefits. +• A compliance review was completed on April 17, 2008, covering the period of April 1, +1999 through December 31, 2006. This review covers the period January 1, 2007 to +December 31, 2008. +• The Beneficiary met the capital investment of $300,000 as of December 31, 1999. +• Capital Expenditures from 2007 to 2008 were $76,806 of which 42% ($39,634) was +procured locally. +• Goods and Services from 2007 to 2008 were $1,404,02l of which 69% ($965,657) was +procured locally. +• The Beneficiary met its employment requirement of 11 full-time employees. +• The Beneficiary met its residency requirement. +• The Beneficiary met the 20% management, supervisory and/or technical requirement. +• The Beneficiary met the requirements of Special Conditions one through five. +• The Beneficiary did not comply with the requirements of the procurement process. +• The Beneficiary met the reporting requirements. +Economit Development Commission +Enterprise Zone Commission +ST. CROIX 116 +Street, Frederiksted, USVI 00840 (340) 773-6499 FAX (340) 773-7701 ST +Government Development Bank +Industrial Park Develapment Corporation +8000 Nisky Shapping Center Suite 620, St +Small Business Developmest Agency +L. USVI 00802 (340) 714-1700 FAX (340) 715-2753 +VI-JPM-000023079 + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 4 of 14 +As of December 31, 2008 +Title 29, Chapter 12 VIC, Section 715(a) states in part "upon proper application or reapplication, +public hearing and in compliance with all other relevant provisions of this chapter pertaining to +the grant of initial benefits, as determined and required by the Commission, any recipient of +industrial development benefits (sic), may be granted an extension, modification, or renewal of +benefits..." +HISTORY: +On November 6, 1998, Financial Trust Company, Inc. filed Articles of Incorporation with the +Office of the Lieutenant Governor. Then on November 30, 1998 Financial Trust Company, Inc. +obtained a Certificate of Incorporation authorizing them to conduct business in the Virgin +Islands. On February 22, 1999, Financial Trust Company, Inc. completed an application to the +Economic Development Commission "EDC", and was approved for tax benefits by the Governor +of the Virgin Islands on November 26, 1999. +The Chairman of the EDC Board of +Commissioners executed a certificate of benefits on March 21, 2000. +Financial Trust Company, Inc. was granted tax exemption benefits "to conduct the business of +financial and economic consulting, money management, investment advisory and fiduciary +services for its clients. +Such clients include individuals, trusts, foundations and business +entities," excluding residents of the United States Virgin Islands. Benefits were granted for a +period of ten (10) years commencing and terminating as follows: +Income Taxes +Gross Receipt Taxes +Excise Taxes (Raw Materials) +Excise Taxes (Equip., Mach.) +Dividend Withholdings +Interest Withholdings +Real Property Tax +COMMENCEMENT +April 1, 1999 +April 1, 1999 +January 1, 2000 +January 1, 2000 +April 1, 1999 +April 1, 1999 +January 1, 2000 +TERMINATION +March 31, 2009 +March 31, 2009 +December 31, 2009 +December 31, 2009 +March 31, 2009 +March 31, 2009 +December 31, 2009 +The Beneficiary, Financial Trust Company, Inc. received nine (9) years of benefits. +INVESTMENT: +"The Beneficiary shall invest in this business in the Virgin Islands of the United States not less +than the amount of U.S. $300,000 excluding inventory, no later than one year from April 1, +1999." + +2| Page +$3 +VI-JPM-000023080 + + +Case 1:22-CV-10904-JSR Document 268-54 Filed 08/07/23 Page 5 of 14 +As of December 31, 2008 +FINDINGS: +The investment requirement of $300,000 was met as of December 31, 1999, which was reported +by the previous compliance review. For the period covered in this review, the Beneficiary made +additional capital investments totaling $76,806. +CAPITAL EXPENDITURES: +ELIGIBLE VI +YEAR +2007 +2008 +SUPPLIER +-0. +-0- +TOTALS +VI +SUPPLIER +$ 29,925 +9,709 +$ 39,634 +NON-VI +SUPPLIER +-0- +$ 37,172 +$ 37,172 +TOTAL +$ 29,925 +46,881 +$ 76,806 +FINDINGS: +From 2007 to 2008, a total of $76,806 was procured in capital expenditures. Of the total +CAPITAL EXPENDITURES +2007-2008 +48% +• VI Supplie +52% +• Non-Vi Suaplier + +3|Page +бр +VI-JPM-000023081 + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 6 of 14 +As of December 31, 2008 +GOODS AND SERVICES: +YEAR +2007 +2008 +TOTAL +ELIGIBLE +VI +VI +SUPPLIER | SUPPLIER +$ 39,764 +$ 446,126 +57,252 +422,515 +$ 97,016 +$ 868,641 +NON-VI +SUPPLIER +$ 101,038 +337,326 +$ 438,364 +TOTAL +$ 586.928 +817,093 +$1,404,021 +FINDINGS: +From 2007 to 2008, the reported total procured for goods and services was $1,404,02l. +Purchases from Virgin Islands' suppliers totaled $868,641 (62%) of which the majority was +spent on rent, utilities, and supplies. Reported procurement from Non-Virgin Islands' suppliers +GOODS & SERVICES +2007-2008 +31% +7% +*Eligible VI Supplier +• VI Supplier +• Non-VI Supplier +62% + +4| Page +VI-JPM-000023082 + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 7 of 14 +As of December 31, 2008 +LOCAL PROCUREMENT: +In accordance with Division 10 of the Economic Development Commission Rules and +Regulations, the Beneficiary must comply with procurement procedures (Section 708-701 to +708-713). +FINDINGS: +For the period 2007-2008, the Beneficiary reported expending a total of $1,480,827. There was +a reported 61% ($908,275) expended to Virgin Islands' Suppliers. Of these purchases, the +majority was spent on rent, utilities, supplies, insurance, machinery & equipment, and leasehold +improvements. +There was also a reported 32% ($475,536) made from Non-Virgin Islands +Suppliers, of which the majority was spent on legal and accounting, machinery & equipment, +7% ($97,016) of expenditures were purchased from +ani fure Wire i fisands, andiersemainajority was spent on legal and aeroping services. +In accordance with the EDC Rules and Regulations, Section 708-709 the Beneficiary was +required to provide proof of solicitation for quotes on a competitive basis. +For the period covered in this report, the Beneficiary failed to provide proof of solicitation quotes +for purchases of machinery and equipment. +TOTAL PROCUREMENT +2007 - 2008 +100% +90% +80% +70% +60% +50% +40% +30% +20% +0% +Non-local +VI +Engible Vi +Suppliers +Cap Exp +37,172 +39.634 +Goods & +Sves +438,364 +868,641 +97,016 + +5| Page +VI-JPM-000023083 + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 8 of 14 +As of December 31, 2008 +EMPLOYMENT: +"The Beneficiary shall employ, no later than one year from September 7, 1999 no less than +eleven (11) persons on a full-time basis employees of which no less than 80% of all employees +shall be "Residents of the Virgin Islands" as defined in Title 29, V.I. Code Section 703(e) and +provided that not less than twenty percent (20%) shall be in the area of management, supervisory +and/or technical positions filled by residents of the Virgin Islands. Pursuant to Title 29, Chapter +12, Section 710(a)." +In accordance with Section 710(a) Title 29, Chapter 12, VIC (Amended 2006), "after the third +year of operation, a beneficiary shall be required to have at least 20% of its management, +supervisory, and/or technical positions filled by residents of the United States Virgin Islands +unless granted a waiver by the Commission." +EDC Rules and Regulations section 708-605 defines full-time employees or employment as +"employment, on a permanent and continuous basis, for thirty-two (32) hours or more per week". +FINDINGS: +YEAR +2007 +2008 +TOTAL += +11 +AVERAGE +FULL +AVERAGE +AVERAGE +AVERAGE +TIME +V.I. RES. +% V.I. Res. +11 +11 +96% +MGMT. +6 +11 +91% +5 +20% +V.I. +MGMT +92% +83% +For the period January 1, 2007 to December 31, 2008, the Beneficiary reported employing an +average of eleven (11) employees on a full-time basis, meeting the employment requirement of +the certificate. The Beneficiary also met the residency, management, supervisory, and technical +requirements for the period covered in this report. +SPECIAL CONDITIONS: +The following special conditions shall apply: +1. The Beneficiary shall provide all employees with health care insurance, funded by the +Beneficiary. +• For the years 2007 and 2008, the Beneficiary provided documentation for +employer funded health, life, and dental insurance provided to ten full-time + +6| Page +VI-JPM-000023084 + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 9 of 14 +As of December 31, 2008 +employees through United HealthCare Insurance Company. Noted and +reviewed at site visit was one employee who opted out of this coverage as +they had alternate insurance coverage. +United HealthCare Insurance Company is registered with the Lieutenant Governor's +Office of Banking and Insurance. +The Beneficiary met the requirements of this special condition. +2. The Beneficiary shall provide all employees a qualified retirement plan funded by the +Beneficiary. +• The Beneficiary provided documentation for an established American Funds +Savings Incentive Match Plan for Employees ("SIMPLE") incorporated with an +Individual Retirement Agreement (IRA). The plan was offered to all employees +receiving at least $5,000 in compensation. +The Beneficiary made matching +contributions equal to 100% of elective deferrals up to a limit of 3% per calendar +year. For the period 2007 through 2008, nine employees participated in the Simple +IRA Plan. Mr. Epstein, +» and l +opted out of the retirement +plan. +The Beneficiary met the requirements of this special condition. +3. The Beneficiary shall provide employee training and tuition reimbursement program for +eligible employees. +• The Beneficiary provided documentation for training in 2007 offered to employees +for a two-day SkillPath Windows Server Workshop and Continuing Accounting +Education courses through the VI Society of CPAs. +• The Beneficiary provided documentation for training in 2008 offered to employees +for an Excel seminar and three (3) continuing education courses in accounting. +The Beneficiary met the requirements of this special condition. +4. The Beneficiary shall make annual contributions of $50,000 or one percent (1%) of gross +receipts tax exemption value, whichever is greater, to be distributed annually as follows: +(a) 50% to educational scholarships +(b) 25% for charity +(c) 25% for co-op marketing with EDC + +7| Page +VI-JPM-000023085 + + +YEAR +2007 +2008 +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 10 of 14 +As of December 31, 2008 +However, after issuance of its certificate, applicant shall prepay the first five (5) years of +contribution fixed at $50,000, or the sum of $250,000, to be distributed as follows: +(a) $187,500 to a tax-exempt entity from which annual distributions of not less +than $25,000 to educational scholarship and $12,500 to charity shall be made, +(b) $62,500 for co-op marketing with IDC. +CERTIFICATE REQUIREMENT: +GROSS +RECEIPT +GROSS +RECEIPT +EXEMPTION +1% GROSS +RECEIPT +EXEMPTION +VALUE +CONTRIBUTION +REQUIREMENT +PER +CERTIFICATE +50,000 +50,000 +50% +EDUCATIONAL +SCHOLARSHIPS +25,000 +25,000 +TOTAL CONTRIBUTION PER EDC CERTIFICATE +100,000 +50,000 +25% +CHARITY +12,500 +12,500 +25,000 +25% CO. +OP +MARKETI +NG - EDC +12,500 +12,500 +25,000 +The Beneficiary provided documentation for contributions totaling $469,980 made from January +2007 to December 2008. Of the total contributions, $108,925 was made from Financial Trust +Co., Inc. and $361,055 from the J. Epstein Foundation. Contributions were made to charities, +educational scholarships, educational symposiums (other), and Co-op Marketing to the EDC. +ACTUAL CONTRIBUTIONS: FINANCIAL TRUST Co., INC. +YEAR +2007 +2008 +TOTAL +J. EPSTEIN +EDUCATIONAL +CONTRUBUTIONS +FOUNDATION +SCHOLARSHIPS +$ 18,565 +90,360 +$108,925 +- +37,500 +37,500 +300 +12,500 +12,800 +CHARITY +5,765 +27,860 +33,625 +CO-OP +MARKETING +WITH EDC +12,500 +12.500 +25,000 + +8| Page +JB. +VI-JPM-000023086 + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 11 of 14 +As of December 31, 2008 +In 2007, the Beneficiary contributed a total of $18,565. These contributions were +made to Antilles School's scholarship fund and organizations such as Atlas Tours, +Inc. and Charlotte Kimmelman Cancer Institute. +In 2008, the Beneficiary contributed a total of $90,360. These contributions were +made to Antilles and Sts. Peter & Paul Catholic Schools, organizations and +schools such as Friends of the St. +Public Libraries, Ivanna Eudora Kean High School, VI Council on the Arts, +Community Foundation of the VI, Boys and Girls Club of the VI, Inc., and United +Way of St. +-St. John. +In 2007, the Beneficiary did not contribute in accordance with the certificate's requirement in the +YEAR +2007 +2008 +ACTUAL CONTRIBUTIONS: J. EPSTEIN FOUNDATION +TOTAL +CONTRIBUTIONS +EDUCATIONAL +SCHOLARSHIPS +CHARITY +EDUCATIONAL +SYMPOSIUMS +INELIGIBLE +CONTRIBUTIONS +$ 218,542 +142,505 +20,650 +20,000 +152,500 +90,164 +$ 361,047 +40,650 +242,664 +45,392 +32,341 +77,733 +The J. Epstein Foundation is a tax-exempt entity established by Financial Trust, Company Inc, +primarily for making charitable contributions to the Virgin Islands community. Mr. Jeffrey +Epstein, sole owner of Financial Trust Company Inc., personally funds the J. Epstein Foundation. +In 2007, the J. Epstein Foundation made contributions totaling $218,550. These +contributions were made to The Junior Statesmen Foundation, Miss Virgin +Islands Scholarship, and Antilles School. Charitable organizations such as the +V.I. Tennis Association, Inc., +Virgin Islands Missions, Inc., Friends of the St. +Caribbean PromoMart, Dakota Sports, the Close Up Foundation, United Way of +St. Croix, Schneider Regional Medical Center, and the Family Resource Center, +Inc. +In 2008, the J. Epstein Foundation made contributions totaling $142,505. These +ontributions were made to Miss Virgin Islands Scholarship and the Junio +'tatesman Foundation. Charitabl + +9| Page +эВ. +VI-JPM-000023087 + + +Case 1:22-cv-10904-JSR , Document 268-54 Filed 08/07/23 Page 12 of 14 +As of December 31, 2008 +organizations and schools such as Antilles School, U.S. Customs & Border +Protection Explorer, C.A.H.S. L +Club, the Community Foundation of the +Virgin Islands, Family Resource Center, and the V.I. Tennis Association. +During the period covered in this report, the J. Epstein Foundation made contributions totaling +$26,500 to the St L +7St. John Chamber of Commerce. This contribution was disqualified in +accordance with the Internal Revenue Service code. +For the period covered in this report, total contribution made by Financial Trust Company, Inc. +and the J. Epstein Foundation, exceeded the certificate's requirement. +The Beneficiary met the requirements of this special condition. +5. The Beneficiary shall utilize the services of resident licensed broker dealers whenever +possible, given market conditions. +• The Beneficiary provided documentation showing Seslia Securities, a FINRA +registered broker was utilized as a Broker of Record for their Savings +Incentive Match Plan. +The Beneficiary met the requirements of this special condition. +REPORTING REQUIREMENTS: +EDC Annual Report: +Income Tax Return / +Audited Financial Statements +Current +Current +Lt. Governor's Annual Report: +Current +VIESA Report: +Current +Affidavit of IDC Beneficiary: +Current +Publication Notices +Current +FINDING: +The Beneficiary filed all reports within the filing deadlines. + +10 | Page +VI-JPM-000023088 + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 13 of 14 +As of December 31, 2008 +FINANCIAL ANALYSIS REVIEW: +Financial Trust Company, Inc reported operating with an average loss of +period 2007 to 2008. +for the +Years +2007 +2008 +Avg. +Ordinary +Income +Annual Net +Aggregate +% Change +S +(513.38%) +The Cost Benefit Analysis for 2007 to 2008 reflects a ratio of 1:66.75. For every $100,000 in tax +revenues forgone by the government during this time, the Virgin Islands of the United States +received approximately $6,680,000,000 in economic output across the local economy. +For every $100,000 in tax revenues foregone by the territory, $2,890,000 in total value added to +the Gross Territorial Product (GTP). The Virgin Islands Economic Development Commission +granted tax exemptions to the Beneficiary totaling +during 2007 to 2008. +This does not include the value of tax exemptions on personal income tax of Mr. Jeffrey Epstein. +OTHER FINDINGS: +At the time of application, Mr. Jeffrey Epstein was stated as the sole owner of Financial Trust +Company, Inc. +By letter dated November 26, 2007, the Beneficiary notified the Division of Corporations and +Trademarks that effective September 21, 2007 Mr. Darren Indyke assumed the position of +Director/President of Financial Trust Company, Inc. + +11| Page +VI-JPM-000023089 + + +Case 1:22-cv-10904-JSR Document 268-54 Filed 08/07/23 Page 14 of 14 +As of December 31, 2008 +CONCLUSION +1. Received nine years of benefits. +2. Met the investment requirement. +3. Met the full-time employment requirement. +4. Met the residency and management requirement. +5. Did not comply with the procurement requirements. +6. Complied with Special Condition one through five. +7. Complied with the reporting requirements of the EDC. +Prepared by: Sandra Bess, Compliance Officer +Reviewed by: Stephanie Bety, Compliance Director +January 31, 2014 +Jennifer Nugent-l +EO/Chief Operating Officer + +12| Page +VI-JPM-000023090 \ No newline at end of file diff --git a/vision-fixhub/court-05/66f3b3185599ca50dcf453d8096b41a0400dd78c0c0889f5ef27943b7f760f39.receipt.json b/vision-fixhub/court-05/66f3b3185599ca50dcf453d8096b41a0400dd78c0c0889f5ef27943b7f760f39.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3e20e66cc05facb470d0332a8909e2f86a2b4510 --- /dev/null +++ b/vision-fixhub/court-05/66f3b3185599ca50dcf453d8096b41a0400dd78c0c0889f5ef27943b7f760f39.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1403, + "dataset": "marble-joined", + "doc_id": "66f3b3185599ca50dcf453d8096b41a0400dd78c0c0889f5ef27943b7f760f39", + "engine": "marble-apple-vision", + "event_count": 27, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "1875e1ca495f9390d537a57f22fe7cb8f3f1cb66a20f5d148428f2fbb44a8054", + "output_sha256": "94c64a9a138bb627c7815a742ecd52e748cd44477af72123f7091b8a6aae0ec0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/671143f5794a3bd741160c373df12cd087b410756315a8bdb17c940701bb915d.md b/vision-fixhub/court-05/671143f5794a3bd741160c373df12cd087b410756315a8bdb17c940701bb915d.md new file mode 100644 index 0000000000000000000000000000000000000000..77cfc48d88c2449827dacdc6a2880bd78569efa0 --- /dev/null +++ b/vision-fixhub/court-05/671143f5794a3bd741160c373df12cd087b410756315a8bdb17c940701bb915d.md @@ -0,0 +1,46 @@ +Casse11222e0v1D99043S5R Doocumeet116643 Ffeeld055223283 Faggel10022 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-cv-10904-JSR +[PROPOSED| ORDER +GRANTING MOTION FOR +ADMISSION PRO HAC VICE +JPMORGAN CHASE BANK, N.A., +Defendant / +Third-Party Plaintiff +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +JAMES EDWARD STALEY, +Third-Party Defendant. +The motion of Jonathan Dunn for admission to practice pro hac vice in the above-captioned +action is GRANTED. Applicant has declared that he is a member in good standing of the bar of +Maryland and that his contact information is as follows: +Applicant's Name: +Jonathan Dunn +Firm Name: +& Connolly LLP +Address: +680 Maine Avenue, S.W. +City/State/Zip: +Telephone/Fax: +Email: +Washington, D.C. 20024 +(202) 434-5997 / (202) 434-5029 +jdunn@wc.com + + +Casse1122260/1D9904JSSR Doccuneet 116443 FfeeD55223283 Fagge220022 +Applicant having requested admission pro hac vice to appear for all purposes as counsel +for Third-Party Defendant James Edward Staley in the above-captioned action; +IT IS HEREBY ORDERED that Applicant Jonathan Dunn is admitted to practice pro +hac vice in the above-captioned action in the United States District Court for the Southern +District of New York. All attorneys appearing before this Court are subject to the Local Rules of +this Court, including the Rules governing discipline of attorneys. +Dated: 5/24/2023 +yed S. Rakoff +londfable Jed S. Rakofi +United States District Judge diff --git a/vision-fixhub/court-05/671143f5794a3bd741160c373df12cd087b410756315a8bdb17c940701bb915d.receipt.json b/vision-fixhub/court-05/671143f5794a3bd741160c373df12cd087b410756315a8bdb17c940701bb915d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..eea7b57359a2599d1a6e96778b76ac51f4aa9b4a --- /dev/null +++ b/vision-fixhub/court-05/671143f5794a3bd741160c373df12cd087b410756315a8bdb17c940701bb915d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "671143f5794a3bd741160c373df12cd087b410756315a8bdb17c940701bb915d", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f08dd5916a28959781b7839340f9d5fb783a8d7d713933034c040d3d87efb04f", + "output_sha256": "a9343108ebf75f80787b9f163f40142fd6e35d6a2b1e9856aac65f90cd7c29fd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/673c55c254e2076dfed0774cbfa95db221aa6f6d4609ecf736f1259e03e74391.md b/vision-fixhub/court-05/673c55c254e2076dfed0774cbfa95db221aa6f6d4609ecf736f1259e03e74391.md new file mode 100644 index 0000000000000000000000000000000000000000..74f29d32d8b2f3612bb6f1b884ca1143ae2bbd13 --- /dev/null +++ b/vision-fixhub/court-05/673c55c254e2076dfed0774cbfa95db221aa6f6d4609ecf736f1259e03e74391.md @@ -0,0 +1,18 @@ +Case 1:22-cv-10904-JSR Document 41-2 Filed 02/03/23 Page 1 of 1 +Certificate of Admission +To the Bar of Illinois +1, Cynthia A. Grant, Clerk of the Supreme Court of Illinois, do hereby certify that +Leonard A. Gail +has been duly licensed and admitted to practice as an Attorney and Counselor at +Law within this State; has duly taken the required oath to support the +CONSTITUTION OF THE UNITED STATES and of the STATE OF ILLINOIS, and +also the oath of office prescribed by law, that said name was entered upon the Roll +of Attorneys and Counselors in my office on 01/03/1989 and is in good standing, so +far as the records of this office disclose. +IN WITNESS WHEREOF, I have hereunto +subscribed my name and affixed the +seal of said Court, this 1st day of +February, 2023. +Cythia A. Grant +Clerk, +Supreme Court of the State of Illinois diff --git a/vision-fixhub/court-05/673c55c254e2076dfed0774cbfa95db221aa6f6d4609ecf736f1259e03e74391.receipt.json b/vision-fixhub/court-05/673c55c254e2076dfed0774cbfa95db221aa6f6d4609ecf736f1259e03e74391.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0391011bf66d1df42c71539742226ea9d66e6043 --- /dev/null +++ b/vision-fixhub/court-05/673c55c254e2076dfed0774cbfa95db221aa6f6d4609ecf736f1259e03e74391.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "673c55c254e2076dfed0774cbfa95db221aa6f6d4609ecf736f1259e03e74391", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5c811a84155f2eccb112551d2b43dd8a93f7e2868122297339d4059c6a010618", + "output_sha256": "154e10d62fc547e191e305ca223fbb4e8b8533514081a8b7cccd0953f09947da", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/67a41c2e2ac4306953870800c33248a1af972d37d21ed82e9cd5263d19f5c766.md b/vision-fixhub/court-05/67a41c2e2ac4306953870800c33248a1af972d37d21ed82e9cd5263d19f5c766.md new file mode 100644 index 0000000000000000000000000000000000000000..836e532029b27c7da0c12e8d36d84602ffe358ee --- /dev/null +++ b/vision-fixhub/court-05/67a41c2e2ac4306953870800c33248a1af972d37d21ed82e9cd5263d19f5c766.md @@ -0,0 +1,44 @@ +Case 1:22-cv-10904-JSR Document 98 Filed 03/27/23 Page 1 of 2 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-ev-10904-JSR +MOTION FOR ADMISSION +PRO HAC VICE +FOR ZACHARY K. +JPMORGAN CHASE BANK, N.A.., +Defendant / +Third-Party Plaintiff +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +JAMES EDWARD STALEY, +Third-Party Defendant. +Pursuant to Rule 1.3(c) of the Local Rules for the United States District Courts for the +Southern and Eastern Districts of New York, I, Zachary K. L +,. hereby move this Court for an +Order for admission to practice pro hac vice to appear as counsel in the above-captioned case on +behalf of Third-Party Defendant James Edward Staley. +I am a member in good standing of the bars of California and the District of Columbia, and +there are no pending disciplinary proceedings against me in any state or federal court. I have never +been convicted of a felony. + + +Case 1:22-cv-10904-JSR Document 98 Filed 03/27/23 Page 2 of 2 +I have never been censured, suspended, disbarred or denied admission or readmission by +any court. I have attached the affidavit pursuant to Local Rule 1.3. +Dated: March 27, 2023 +Respectfully submitted, +Is/ Zachary K.] +Applicant Signature +Applicant's Name: Zachary K +Firm name: +& Connolly LLP +Address: 680 Maine Avenue, S.W. +City / State / Zip: Washington, D.C. 20024 +Telephone: (202) 434-5252 +Fax: (202) 434-5029 +Email: ZWarren@wc.com +Attorney for James Edward Staley diff --git a/vision-fixhub/court-05/67a41c2e2ac4306953870800c33248a1af972d37d21ed82e9cd5263d19f5c766.receipt.json b/vision-fixhub/court-05/67a41c2e2ac4306953870800c33248a1af972d37d21ed82e9cd5263d19f5c766.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5355cd46d9510cae8ae00c9cf2fda138b6f68570 --- /dev/null +++ b/vision-fixhub/court-05/67a41c2e2ac4306953870800c33248a1af972d37d21ed82e9cd5263d19f5c766.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "67a41c2e2ac4306953870800c33248a1af972d37d21ed82e9cd5263d19f5c766", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "698e0ba8f50e39baf8bac37c3e100a2287b5807660def7f03f327a3a1eb87580", + "output_sha256": "dbe7f58356603ce4e4cbf00d77f9dd6bcd1369e4a509e603e59e1518e72a66dd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/67b4bc1c8077606fcb3b59c13b99ebe68d1cc391eaedd5c5191b8b5da62ef268.md b/vision-fixhub/court-05/67b4bc1c8077606fcb3b59c13b99ebe68d1cc391eaedd5c5191b8b5da62ef268.md new file mode 100644 index 0000000000000000000000000000000000000000..1dbe02f8ac651458eaafa128163a9be7122445d4 --- /dev/null +++ b/vision-fixhub/court-05/67b4bc1c8077606fcb3b59c13b99ebe68d1cc391eaedd5c5191b8b5da62ef268.md @@ -0,0 +1,335 @@ +Filed 11/19/19 + +ORIGINAL +UNITED STATES DISTRICT COURT +for the +Southern +District of New York +United States of America +V. +TOVA NOEL +Defendant +) +19 CR 830 +APPEARANCE BOND +Defendant's Agreement +TOVA NOEL +(defendant), agree to follow every order of this court, or any +court that considers this case, and I further agree that this bond may be forfeited if I fail: +(X) to appear for court proceedings; +(X) if convicted, to surrender to serve a sentence that the court may impose; or +(X) to comply with all conditions set forth in the Order Setting Conditions of Release. +Type of Bond +(2X) (1) This is a personal recognizance bond. +(X) (2) This is an unsecured bond of $ +100,000 PRB +([ ) (3) This is a secured bond of $ +, secured by: +(D) (a) $ +, in cash deposited with the court. +(L) (b) the agreement of the defendant and each surety to forfeit the following cash or other property +(describe the cash or other property, including claims on it — such as a lien, mortgage, or loan — and attach proof of +ownership and value): +If this bond is secured by real property, documents to protect the secured interest may be filed of record. +(• ) (c) a bail bond with a solvent surety (attach a copy of the bail bond, or describe it and identify the surety: +Forfeiture or Release of the Bond +Forfeiture of the Bond. This appearance bond may be forfeited if the defendant does not comply with the above +agreement. The court may immediately order the amount of the bond surrendered to the United States, including the +security for the bond, if the defendant does not comply with the agreement. At the request of the United States, the court +may order a judgment of forfeiture against the defendant and each surety for the entire amount of the bond, including +interest and costs. + + +Case 1:19-cr-00830-AT Document 9 Filed 11/19/19 Page 2 of 8 +Page 2 +Release of the Bond. The court may order this appearance bond ended at any time. This bond will be satisfied and the +security will be released when either: (1) the defendant is found not guilty on all charges, or (2) the defendant reports to +serve a sentence. +Declarations +Ownership of the Property. I, the defendant-- and each surety - declare under penalty of perjury that: +(1) all owners of the property securing this appearance bond are included on the bond; +(2) the property is not subject to claims, except as described above; and +(3) I will not sell the property, allow further claims to be made against it, or do anything to reduce its value +while this appearance bond is in effect. +Acceptance. I, the defendant - and each surety - have read this appearance bond and have either read all the conditions of +release set by the court or had them explained to me. I agree to this Appearance Bond. +I, the defendant - and each surety - declare under penalty of perjury that this information is true. (See 28 U.S.C.§ 1746.) +Date: 11/19/2019 +TOVA NOEL +SYLVIA EPHRAIM +Surety/property owner- +Surety property owner - signature and date +Surety property owner- +Surety/property owner - signature and date +Surety/property owner - +Surety property owner - signature and date +CLERK OF COURT +Date: 11/19/2019 +Signature of Clerk or Deputy Clerk- +Approved. +Date: +11/19/2019 +NWI +NICOLAS LANDSMAN ROOS + + +Filed 11/19/19 Page 3 of 8 +AO 199A (Rev. 12/11) Order Setting Conditions of Release +UNITED STATES DISTRICT COURT +for the +Southern +District of New York +Page 1 of +Pages +United States of America +V. +19 CR 830 (AT) +TOVA NOEL +Defendant +ORDER SETTING CONDITIONS OF RELEASE +IT IS ORDERED that the defendant's release is subject to these conditions: +(1) The defendant must not violate federal, state, or local law while on release. +(2) The defendant must cooperate in the collection of a DNA sample if it is authorized by 42 U.S.C. § 14135a. +(3) The defendant must advise the court or the pretrial services office or supervising officer in writing before making +any change of residence or telephone number. +(4) The defendant must appear in court as required and, if convicted, must surrender as directed to serve a sentence that +the court may impose. +The defendant must appear at: +Place +on +Date and Time +5) +If blank, defendant will be notified of next appearance. +The defendant must sign an Appearance Bond, if ordered. + + +Case 1:19-cr-00830-AT Document 9 Filed 11/19/19 Page 4 of 8 +AO 199B (Rev. 12/11) Additional Conditions of Release +Page +of +Pages +ADDITIONAL CONDITIONS OF RELEASE +IT IS FURTHER ORDERED that the defendant's relcase is subject to the conditions marked below: +(D) (6) The defendant is placed in the custody of: +Person or organization +Address (only if above is an organization) +who agrees to (a) supervise the defendant, (b) use every effort to assure the defendant's appearance at all court proceedings, and (c) notify the court +immediately if the defendant violates a condition of release or is no longer in the custodian's custody. +Signed: +Custodian +Date +(X) (7) The defendant must: +(X) (a) submit to supervision by and report for supervision to the PRETRIAL SUPERVISION AS DIRECTED , +BY PTS +telephone number +, no later than +( +) (b) continue or actively seek employment. +(D) (c) +continue or start an education program. +(X) (d) +surrender any passport to: +PSA (& NO NEW APPLICATIONS) +(X) +(e) +not obtain a passport or other international travel document. +(X) (f +abide by the following restrictions on personal association, residence, or travel: +(D) (g) +SDNY/EDNY; DNJ & EASTERN DISTRICT +OF PENNSYLVANIA +avoid all contact, directly or indirectly, with any person who is or may be a victim or witness in the investigation or prosecution, +including: +(X) (h) +get medical or psychiatric treatment: +MENTAL HEALTH EVALUATION/TREATMENT +(D) ( +return to custody each +or the following purposes: +at +o'clock after being released at +o'clock for employment, schooling, +(0) ₫ +maintain residence at a halfway house or community corrections center, as the pretrial services office or supervising officer considers +necessary. +(X) (k) not possess a firearm, destructive device, or other weapon. +(0) (1 +not use alcohol ( • ) atall ( • ) excessively. +(L]) (m) not use or unlawfully possess a narcotic drug or other controlled substances defined in 21 U.S.C. § 802, unless prescribed by a licensed +medical practitioner. +( ) (n) submit to testing for a prohibited substance if required by the pretrial services office or supervising officer. Testing may be used with +random frequency and may include urine testing, the wearing of a sweat patch, a remote alcohol testing system, and/or any form of +prohibited substance screening or testing. +The defendant must not obstruct, attempt to obstruct, or tamper with the efficiency and +accuracy of prohibited substance screening or testing. +() (o) participate in a program of inpatient or outpatient substance abuse therapy and counseling if directed by the pretrial services office or +supervising officer. +() (p) participate in one of the following location restriction programs and comply with its requirements as directed. +(D) (1) Curfew. You are restricted to your residence every day (D) from +_, or (D) as +directed by the pretrial services office or supervising officer; or +(D) (il) Home Detention. You are restricted to your residence at all times except for employment; education; religious services; +medical, substance abuse, or mental health treatment; attorney visits; court appearances; court-ordered obligations; or other +activities approved in advance by the pretrial services office or supervising officer, or +(• ) (il) Home Incarceration. You are restricted to 24-hour-a-day lock-down at your residence except for medical necessities anc +court appearances or other activities specifically approved by the court +(D) (q) submit to location monitoring as directed by the pretrial services office or supervising officer and comply with all of the program +requirements and instructions provided. +(D) You must pay all or part of the cost of the program based on your ability to pay as determined by the pretrial services office or +supervising officer. +(D) (r) report as soon as possible, to the pretrial services office or supervising officer, every contact with law enforcement personnel, including +arrests, questioning, or traffic stops. + + +Case 1:19-cr-00830-AT Document 9 Filed 11/19/19 Page 5 of 8 +ADDITIONAL CONDITIONS OF RELEASE +(X) (s) $100,000 PRB TO BE CO-SIGNED BY 2 FINANCIALLY RESPONSIBLE PERSONS; TRAVEL LIMITED TO +SDNY/EDNY; DISTRICT OF NEW JERSEY & EASTERN DISTRICT OF PENNSYLVANIA; SURRENDER +TRAVEL DOCUMENTS (& NO NEW APPLICATIONS); PRETRIAL SUPERVISION AS DIRECTED BY PTS; +MENTAL HEALTH EVALUATION/TREATMENT AS DIRECTED BY PTS; DEFT NOT TO POSSESS +FIREARM/DESTRUCTIVE DEVICE/OTHER WEAPON; DEFT TO BE RELEASED ON OWN SIGNATURE; +REMAINING CONDITIONS TO BE MET BY 11/26/2019; NO CONTACT WITH CO-DEFENDANT UNLESS IN +THE PRESENCE OF COUNSEL. + + +AO 199C (Rev. 09/08) Advice of Penalties +Case 1:19-cr-00830-AT Document 9 +Filed 11/19/19 Page 6 of 8 +Page +_of +Pages +ADVICE OF PENALTIES AND SANCTIONS +TO THE DEFENDANT: TOVA NOEL +19 CR 830 (AT) +11/19/2019 +YOU ARE ADVISED OF THE FOLLOWING PENALTIES AND SANCTIONS: +Violating any of the foregoing conditions of release may result in the immediate issuance of a warrant for your arrest, a +revocation of your release, an order of detention, a forfeiture of any bond, and a prosecution for contempt of court and could result in +imprisonment, a fine, or both. +While on release, if you commit a federal felony offense the punishment is an additional prison term of not more than ten +years +and for a federal misdemeanor offense the punishment is an additional prison termn of not more than one year. This sentence will be +consecutive (i.e., in addition to) to any other sentence you receive. +intimidation are significantly more serious if they involve a killing or attempted killing. +If, after release, you knowingly fail to appear as the conditions of release require, or to surrender to serve a sentence, +you may be prosecuted for failing to appear or surrender and additional punishment may be imposed. If you are convicted of: +(1) an offense punishable by death, life imprisonment, or imprisonment for a term of fifteen years or more — you will be fined +not more than $250,000 or imprisoned for not more than 10 years, or both; +(2) an offense punishable by imprisonment for a term of five years or more, but less than fifteen years - you will be fined not +more than $250,000 or imprisoned for not more than five years, or both; +Acknowledgment of the Defendant +I acknowledge that I am the defendant in this case and that I am aware of the conditions of release. I promise to obey all +conditions of release, to appear as directed, and surrender to serve any sentence imposed. I am aware of the penalties and sanctions +set forth above. +Defendant Refeased +TOVA NOEL- +City and State +Directions to the United States Marshal +(L) The defendant is ORDERED released after processing +••) The United States marshal is ORDERED to keep the defendant in custody until notified by the clerk or judge that the +defendant has posted bond and/or complied with all other conditions for release. If still in custody, the defendant must be +produced before the appropriate judge at the time and place specified. +Date: +Judicial Officer's Signature +Printed name and title + + +Filed 11/19/19 + +AO 199C (Rev. 09/08) Advice of Penalties +DISTRIBUTION: +COURT +DEFENDANT +PRETRIAL SERVICE +U.S. ATTORNEY +Page +U.S. MARSHAL +of +Pages +Dutchess +Sullivan +Orange +Putnam +Scuthern District ef New Yerk +The Brenx +Manhattan +Westchester +Reckland +Dutchess +Crange +Putnam +Eastern District cf New York +Erccklyn (Kines Ceunty) +Cueens (Queens Ccunty) +Staten Istand (Richmend Ceunty) +Lene Island (Nassau & Suffelk) +Westchester +Cockland +Suffolk +tan +Nassau +Erockly +EDPA + + +Document 9 Filed 11/19/19 Page 8 of 8 +DOCKET No. 19 Cr 830 (AT). +AUSA Nicolas Roos +INTERPRETER NEEDED +• Rule 5 DRule 9 • Rule 5(c)(3) • Detention Hrg. +• Other: +DEFENDANT Tova Noel +DEF'S COUNSEL James E. Fov. +/ RETAINED •FEDERAL DEFENDERS CIA LIPRESENTMENT ONLY +• DEFENDANT WAIVES PRETRIAL REPORT +DATE OF ARREST 11/19/2019 +Z VOL. SURR. +TIME OF ARREST +DION WRIT +TIME OF PRESENTMENT +BAIL DISPOSITION +O SEE SEP. ORDER +• DETENTION: RISK OF FLIGHT/DANGER SEE TRANSCRIPT +• DETENTION ON CONSENT W/O PREJUDICE +• DETENTION HEARING SCHEDULED FOR: +• AGREED CONDITIONS OF RELEASE +• DEF. RELEASED ON OWN RECOGNIZANCE +V$100.000 +_PRB 22 FRP +• SECURED BY $ +CASH/PROPERTY: +/ TRAVEL RESTRICTED TO SDNY/EDNY/District of New Jersey, Eastern District of Pennsylvania +• TEMPORARY ADDITIONAL TRAVEL UPON CONSENT OF AUSA & APPROVAL OF PRETRIAL SERVICES +ZI SURRENDER TRAVEL DOCUMENTS (& NO NEW APPLICATIONS) +Z PRETRIAL SUPERVISION: • REGULAR • STRICT 2 AS DIRECTED BY PRETRIAL SERVICES +• DRUG TESTING/TREATMT AS DIRECTED BY PTS 2 MENTAL HEALTH EVAL/TREATMT AS DIRECTED BY PTS +• DEF. TO SUBMIT TO URINALYSIS; IF POSITIVE, ADD CONDITION OF DRUG TESTING/TREATMENT +HOME INCARCERATION •HOME DETENTION +• CURFEW •ELECTRONIC MONITORING •GPS +• DEF. TO PAY ALL OF PART OF COST OF LOCATION MONITORING, AS DETERMINED BY PRETRIAL SERVICES +DEF. TO CONTINUE OR SEEK EMPLOYMENT [OR] • DEF. TO CONTINUE OR START EDUCATION PROGRAM +ZI DEF. NOT TO POSSESS FIREARM/DESTRUCTIVE DEVICE/OTHER WEAPON +] DEF. TO BE DETAINED UNTIL ALL CONDITIONS ARE MET +• DEF. TO BE RELEASED ON OWN SIGNATURE, PLUS THE FOLLOWING CONDITIONS: +REMAINING CONDITIONS TOBE MET BY: 1/2449 +ADDITIONAL CONDITIONS/ADDITIONAL PROCEEDINGS/COMMENTS: +No coutget with codef an dout waless in the presence +of counsel. +1Z DEF. ARRAIGNED; PLEADS NOT GUILTY +• DEF. WAIVES INDICTMENT +IZ SPEEDY TRIAL TIME EXCLUDED UNDER 18 U.S.C. § 3161(h)(7) UNTIL 11/25/2019 +or Rule 5(c)(3) Cases +] IDENTITY HEARING WAIVEL +• PRELIMINARY HEARING IN SDNY WAIVED +• DEFENDANT TO BE REMOVED +• CONTROL DATE FOR REMOVAL: _ +2 CONFERENCE BEFORE D.J. ON 11/25/2019 +PRELIMINARY HEARING DATE: 421192012. +DATE: 11/19/2019 +(ariginal) - COURT FILE +Rev'd 2016 +EINK - U.S. ATTORNEY'S OFFICE +• ON DEFENDANT'S CONSENT +UNITE STATES MACISTATE JUDGE SONY. +YELLOW - U.S. MARSHAL +GREEN - PRETRIAL SERVICES AGENCY \ No newline at end of file diff --git a/vision-fixhub/court-05/67b4bc1c8077606fcb3b59c13b99ebe68d1cc391eaedd5c5191b8b5da62ef268.receipt.json b/vision-fixhub/court-05/67b4bc1c8077606fcb3b59c13b99ebe68d1cc391eaedd5c5191b8b5da62ef268.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c726dd3652d191701c5bada4d0d91e4a55077ba7 --- /dev/null +++ b/vision-fixhub/court-05/67b4bc1c8077606fcb3b59c13b99ebe68d1cc391eaedd5c5191b8b5da62ef268.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -310, + "dataset": "marble-joined", + "doc_id": "67b4bc1c8077606fcb3b59c13b99ebe68d1cc391eaedd5c5191b8b5da62ef268", + "engine": "marble-apple-vision", + "event_count": 11, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "59172b796091c39d0b063c235373001eef7d1b6ea8e955a8ba1284846a8a4ec6", + "output_sha256": "91735ebed0ede95f174e6b2dd80ff9e81003088744cea49e9183e90b46a08415", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/67d70ab573de7766edc16d77b872d9261a0c218157e3fd3376a2eaf8688ade30.md b/vision-fixhub/court-05/67d70ab573de7766edc16d77b872d9261a0c218157e3fd3376a2eaf8688ade30.md new file mode 100644 index 0000000000000000000000000000000000000000..73f5e4a18210002769b11f3b53e05b062735a0cf --- /dev/null +++ b/vision-fixhub/court-05/67d70ab573de7766edc16d77b872d9261a0c218157e3fd3376a2eaf8688ade30.md @@ -0,0 +1,458 @@ +Case 1:20-cr-00330-PAE +Document 731-1 +Filed 07/14/22 Page 1 of 14 +PANISH +SHEA & +BOYLE +LLP +December 6, 2021 +VIA ECE +The Honorable Alison J. Nathan +Inited States District Cour +outhern District of New Yor +40 Foley Square +New York, NY 10007 +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Dear Judge Nathan: +I am writing on behalf of witness Jane who testified last week at trial in the abovereferenced case. I am in receipt of Ms. Maxwell's motion to compel Jane's attorney Robert +Glassman from my law firm to testify about whether he told Jane that testifying against Ms. +Maxwell at this trial would "help her case." But compelling Mr. Glassman to testify would +require him to violate his ethical duties to his client and would offer no relevant information. +Accordingly, Ms. Maxwell's motion must be denied. +As a preliminary matter, the subpoena served on Mr. Glassman was improper under Fed. +R. Crim. P. 17. But, without waiving the procedural argument, witness Jane would prefer that +the matter be decided on the merits to avoid further harassment of her lawyer and risk of +exposure of her confidential information.' +' Mr. Glassman was handed a handwritten trial subpoena on December 1, 2021 as he was +walking into Your Honor's courtroom to continue to be present for Jane's lengthy crossexamination. (Glassman subpoena is attached hereto as Exhibit 1). That practice seems at a +(footnote continued) +11111 Santa Monica Boulevard, Suite 700 • Los Angeles, Califomia 90025 • 310.477.1700 phone • 310.477.1699 fax • www.psblaw.com + + +The Honorable Alison J. Nathan +December 6, 2021 +Page 2 +PARISH +SHEA & +BOYLE™ +Ms. Maxwell's motion concerns an email AUSA Alison Moe sent her colleagues Lara +Pomerantz and Maurene Comey concerning an alleged conversation she had with Mr. Glassman +on August 17, 2021. Ms. Maxwell appears to seek to compel Mr. Glassman to essentially +corroborate a statement in Ms. Moe's email wherein she states "He also mentioned that he had +told her it would 'help her case'". +In the unusual effort to compel a witness's lawyer to testify against his own client, Ms. +Maxwell claims that Mr. Glassman waived the attorney-client privilege. It is axiomatic that Mr. +Glassman did not and could not waive the attorney-client privilege - only Jane could do that. To +be clear, Jane did not and does not waive the privilege in any way. And Jane does not authorize +Mr. Glassman to testify about any of his alleged communications with her. +Further, as a California attorney, Mr. Glassman is bound by California Rule of +Professional Conduct 1.6. (Rule 1.6 is attached hereto as Exhibit 2). Rule 1.6 prohibits an +attorney from disclosing confidential information of the client except in two extremely narrow +circumstances. A California attorney may only disclose confidential information if: (1) the client +gives informed consent, or (2) the attorney believes disclosure is necessary to prevent the client +from committing a crime that will cause death or grave bodily harm. Here, to the extent the +"her" in Ms. Moe's email refers to Jane, Jane gives no such informed consent. And Mr. +Glassman obviously has no reason to believe that disclosing any alleged communication he gave +minimum, distasteful and designed to intimidate the witness, and should be discouraged. But +procedurally, the appearance date on the subpoena is November 29, 2021 - two days before he +was served - making it impossible for him to comply. Additionally, Mr. Glassman was not +provided with a witness fee or milage fee as required by Rule 17. + + +PANISH +SHEA & +BOYLE. +The Honorable Alison J. Nathan +December 6, 2021 +Page 3 +Jane will prevent her from committing a crime that would cause death or great bodily harm. +Accordingly, Mr. Glassman cannot testify about any communication he allegedly had with Jane +without violating Rule 1.6. +Additionally, Mr. Glassman's testimony would be wholly irrelevant. Ms. Maxwell claims +the statement in Ms. Moe's email is relevant for only two reasons: (1) "Jane's motive to +cooperate and testify," and (2) "her memory and capacity as a witness since she cannot recall a +highly consequential conversation she just had months ago." (Maxwell Motion at 1-2). Both +alleged reasons are based on a faulty premise and are factually untrue. +The August 17, 2021 email from Ms. Moe expressly states that the alleged statement at +issue occurred before Ms. Maxwell was criminally charged - not "just ... months ago" in August +2021 -- as Ms. Maxwell appears to insinuate. Ms. Maxwell was arrested and charged on July 2, +2020 - more than a year before the email from Ms. Moe was written. +Jane's civil case settled on December 11, 2020—8 months before Ms. Moe's email was +written and approximately a year before she testified at this trial. Accordingly, once Jane made +the decision to settle her civil case in December of 2020, there was no case to "help" in August +of 2021 when the email was written or a year later when she testified at this trial. +Further, Ms. Maxwell contends that because Jane testified on cross-examination that she +did not know that cooperating with the government would help her civil case, Mr. Glassman's +purported statement to Ms. Moe in August of 2021 would somehow be relevant in shedding light +on that issue. Not only would this be improper impeachment and an attempt to force an attorney +to take a position adverse to his client, it is also misleading. + + +Case 1:20-cr-00330-PAE +Document 731-1 +The Honorable Alison J. Nathan +December 6, 2021 +Page 4 +PANISH +SHEA & +BOYLE +During her cross-examination of Jane, Ms. Menninger did not ask Jane if she was told +that cooperating with the government would "help her case." Rather, the testimony on this issue +is as follows: +Q. At any point during your cooperation with the government, including testifying, you +knew that your cooperation with the government, including testifying, would benefit you +in your civil litigation against the Epstein estate and Ms. Maxwell; correct? +A. No, I don't know that. +Q. You knew that cooperation with the government, including testifying, would benefit +you in your claim for the victims' compensation fund; correct? +A. No, I don't know that. (U.S. v. Maxwell Trial Testimony, 12/1/21 at 581:2-11). +Even if Mr. Glassman said to Jane at some time during her civil case before she decided +to settle it (i.e. January-December 2020) that he thought cooperating with the government would +"help" that civil case, that doesn't mean that Jane "knew" that to be a fact. The veracity and/or +significance of a statement Ms. Moe believes Mr. Glassman made to her about an alleged +statement he made to his client is simply irrelevant. +Jane respectfully requests that Ms. Maxwell's motion be denied outright. +But if the Court is inclined to entertain the motion further, Jane requests that Ms. +Maxwell provide the precise question or questions that Ms. Maxwell's counsel intends to ask Mr. +Glassman. And that Mr. Glassman be permitted time to obtain an advisory opinion from ethics +counsel and perhaps from the California State Bar as to whether he would be permitted to answer +such a question or questions. + + +The Honorable Alison J. Nathan +December 6, 2021 +Page 5 +PANISH +SHEA & +BOYLE +LLP +Respectfully submitted, +Is/ +Kevin Boyle +PANISH SHEA & BOYLE LLP +1111|1 Santa Monica Blvd., Ste. 700 +Los Angeles, CA 90025 +Phone: 310-477-1700 +Attorneys for Witness Jane +Cc: Counsel of record + + +Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 6 of 14 + + + +Filed 07/14/22 Page 7 of 14 +AO 89 (Rev. 08/09) Subpoena to Testify at a Hearing or Trial in a Criminal Case +UNITED STATES DISTRICT COURT +for the +Southern Diskicbof New York +United States of America +Case No. S2 20 Cr. 330 (AJN) +Ghislaine Maxwell +Defendant +SUBPOENA TO TESTIFY AT A HEARING OR TRIAL IN A CRIMINAL CASE +To: +ROBERT GLASSMAN +IIIII SANTA MONICA BOULEVARO, SUITE 700 +LOs ANGELES, CA 90025 +510-477-1699 +YOU ARE COMMANDED to appear in the United States district court at the time, date, and place shown +below to testify in this criminal case. When you arrive, you must remain at the court until the judge or a court officer +allows you to leave. +Place of Appearance: United States Courthouse +40 Foley Square +New York, NY 10007 +Courtroom No.: 318 +Date and Time: +11/29/2021 9:00 am +You must also bring with you the following documents, electronically stored information, or objects (blank if not +applicable): +(SEAL) +RUBY J. KRAJCK +Date: NOV 1 6 2021 +Signature of Clerk or Deputy Clerk +Ms. Ghislaine +Maxwell +The name, address, e-mail, and telephone number of the attorney representing (name of party) +, who requests this subpoena, are: +CHRISTIAN R. EVERDELL, COHEN & GRESSER LLP +800 THIRD Ave., New York, NY 10022 +212-957-7600 + + +Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 8 of 14 + + + +Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 9 of 14 +The State Bar of California +(a) +Rule 1.6 Confidential Information of a Client +(Rule Approved by the Supreme Court, Effective November 1, 2018) +A lawyer shall not reveal information protected from disclosure by Business and +Professions Code section 6068, subdivision (e)(1) unless the client gives +informed consent,* or the disclosure is permitted by paragraph (b) of this rule. +(b) A lawyer may, but is not required to, reveal information protected by Business +and Professions Code section 6068, subdivision (e)(1) to the extent that the +lawyer reasonably believes* the disclosure is necessary to prevent a criminal act +that the lawyer reasonably believes* is likely to result in death of, or substantial" +bodily harm to, an individual, as provided in paragraph (c). +(c) +Before revealing information protected by Business and Professions Code +section 6068, subdivision (e)(1) to prevent a criminal act as provided in +paragraph (b), a lawyer shall, if reasonable* under the circumstances: +(1) +make a good faith effort to persuade the client: (i) not to commit or to +continue the criminal act; or (ii) to pursue a course of conduct that will +prevent the threatened death or substantial* bodily harm; or do both (i) +and (ii); and +(2) +inform the client, at an appropriate time, of the lawyer's ability or decision +to reveal information protected by Business and Professions Code section +6068, subdivision (e)(1) as provided in paragraph (b). +(d) +In revealing information protected by Business and Professions Code section +6068, subdivision (e)(1) as provided in paragraph (b), the lawyer's disclosure +must be no more than is necessary to prevent the criminal act, given the +information known* to the lawyer at the time of the disclosure. +(e) +A lawyer who does not reveal information permitted by paragraph (b) does not +violate this rule. +Comment +Duty of confidentiality +Paragraph (a) relates to a lawyer's obligations under Business and Professions +Code section 6068, subdivision (e)(1), which provides it is a duty of a lawyer: "To +maintain inviolate the confidence, and at every peril to himself or herself to preserve the +secrets, of his or her client." A lawyer's duty to preserve the confidentiality of client +information involves public policies of paramount importance. (In Re Jordan (1974) 12 +Cal.3d 575, 580 [116 Cal.Rptr. 371].) Preserving the confidentiality of client information +contributes to the trust that is the hallmark of the lawyer-client relationship. The client is +thereby encouraged to seek legal assistance and to communicate fully and frankly with +the lawyer even as to embarrassing or detrimental subjects. The lawyer needs this +information to represent the client effectively and, if necessary, to advise the client to + + +Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 10 of 14 +refrain from wrongful conduct. Almost without exception, clients come to lawyers in +order to determine their rights and what is, in the complex of laws and regulations, +deemed to be legal and correct. Based upon experience, lawyers know* that almost all +clients follow the advice given, and the law is upheld. Paragraph (a) thus recognizes a +fundamental principle in the lawyer-client relationship, that, in the absence of the client's +informed consent," a lawyer must not reveal information protected by Business and +Professions Code section 6068, subdivision (e)(1). (See, e.g., Commercial Standard +Title Co. v. Superior Court (1979) 92 Cal.App.3d 934, 945 [155 Cal.Rptr.393].) +Lawyer-client confidentiality encompasses the lawyer-client privilege, the work-product +doctrine and ethical standards of confidentiality +[2] The principle of lawyer-client confidentiality applies to information a lawyer +acquires by virtue of the representation, whatever its source, and encompasses matters +communicated in confidence by the client, and therefore protected by the lawyer-client +privilege, matters protected by the work product doctrine, and matters protected under +ethical standards of confidentiality, all as established in law, rule and policy. (See In the +Matter of +_ (Rev. Dept. 2000) 4 Cal. State Bar Ct. Rptr. 179; +(1975) 46 Cal.App.3d 614, 621 [120 Cal.Rptr. 253].) The lawyer-client privilege and +work-product doctrine apply in judicial and other proceedings in which a lawyer may be +called as a witness or be otherwise compelled to produce evidence concerning a client. +A lawyer's ethical duty of confidentiality is not so limited in its scope of protection for the +lawyer-client relationship of trust and prevents a lawyer from revealing the client's +information even when not subjected to such compulsion. Thus, a lawyer may not +reveal such information except with the informed consent* of the client or as authorized +or required by the State Bar Act, these rules, or other law. +Narrow exception to duty of confidentiality under this rule +Notwithstanding the important public policies promoted by lawyers adhering to +the core duty of confidentiality, the overriding value of life permits disclosures otherwise +prohibited by Business and Professions Code section 6068, subdivision (e)(1). +Paragraph (b) is based on Business and Professions Code section 6068, subdivision +and Professions Code section 6068, subdivision (e)(1) even without client consent. +Evidence Code section 956.5, which relates to the evidentiary lawyer-client privilege, +sets forth a similar express exception. Although a lawyer is not permitted to reveal +information protected by section 6068, subdivision (e)(1) concerning a client's past, +completed criminal acts, the policy favoring the preservation of human life that underlies +this exception to the duty of confidentiality and the evidentiary privilege permits +disclosure to prevent a future or ongoing criminal act. +Lawyer not subject to discipline for revealing information protected by Business and +Professions Code section 6068, subdivision (e)(1) as permitted under this rule +Paragraph (b) reflects a balancing between the interests of preserving client +confidentiality and of preventing a criminal act that a lawyer reasonably believes* is +2 + + +Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 11 of 14 +likely to result in death or substantial* bodily harm to an individual. A lawyer who +reveals information protected by Business and Professions Code section 6068, +subdivision (e)(1) as permitted under this rule is not subject to discipline. +No duty to reveal information protected by Business and Professions Code section +6068, subdivision (e) (1) +[5] Neither Business and Professions Code section 6068, subdivision (e)(2) nor +paragraph (b) imposes an affirmative obligation on a lawyer to reveal information +protected by Business and Professions Code section 6068, subdivision (e)(1) in order to +prevent harm. A lawyer may decide not to reveal such information. Whether a lawyer +chooses to reveal information protected by section 6068, subdivision (e)(1) as permitted +under this rule is a matter for the individual lawyer to decide, based on all the facts and +circumstances, such as those discussed in Comment [6] of this rule. +Whether to reveal information protected by Business and Professions Code section +6068, subdivision (e) as permitted under paragraph (b) +[6] +Disclosure permitted under paragraph (b) is ordinarily a last resort, when no +other available action is reasonably* likely to prevent the criminal act. Prior to revealing +information protected by Business and Professions Code section 6068, subdivision +(e)(1) as permitted by paragraph (b), the lawyer must, if reasonable" under the +circumstances, make a good faith effort to persuade the client to take steps to avoid the +criminal act or threatened harm. Among the factors to be considered in determining +whether to disclose information protected by section 6068, subdivision (e)(1) are the +following: +(1) +the amount of time that the lawyer has to make a decision about +disclosure; +(2) +(3) +(4) +(5) +(6) +whether the client or a third-party has made similar threats before and +whether they have ever acted or attempted to act upon them; +whether the lawyer believes* the lawyer's efforts to persuade the client or +a third person* not to engage in the criminal conduct have or have not +been successful; +the extent of adverse effect to the client's rights under the Fifth, Sixth and +Fourteenth Amendments of the United States Constitution and analogous +rights and privacy rights under Article I of the Constitution of the State of +California that may result from disclosure contemplated by the lawyer; +the extent of other adverse effects to the client that may result from +disclosure contemplated by the lawyer; and +the nature and extent of information that must be disclosed to prevent the +criminal act or threatened harm. +3 + + +Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 12 of 14 +A lawyer may also consider whether the prospective harm to the victim or victims is +imminent in deciding whether to disclose the information protected by section 6068, +subdivision (e)(1). However, the imminence of the harm is not a prerequisite to +disclosure and a lawyer may disclose the information protected by section 6068, +subdivision (e)(1) without waiting until immediately before the harm is likely to occur. +Whether to counsel client or third person* not to commit a criminal act reasonably* likely +to result in death or substantial* bodily harm +17] +Paragraph (c)(1) provides that before a lawyer may reveal information protected +by Business and Professions Code section 6068, subdivision (e)(1), the lawyer must, if +reasonable* under the circumstances, make a good faith effort to persuade the client +not to commit or to continue the criminal act, or to persuade the client to otherwise +pursue a course of conduct that will prevent the threatened death or substantial* bodily +harm, including persuading the client to take action to prevent a third person* from +committing or continuing a criminal act. If necessary, the client may be persuaded to do +both. The interests protected by such counseling are the client's interests in limiting +disclosure of information protected by section 6068, subdivision (e) and in taking +responsible action to deal with situations attributable to the client. If a client, whether in +response to the lawyer's counseling or otherwise, takes corrective action — such as by +ceasing the client's own criminal act or by dissuading a third person* from committing or +continuing a criminal act before harm is caused — the option for permissive disclosure +by the lawyer would cease because the threat posed by the criminal act would no longer +be present. When the actor is a nonclient or when the act is deliberate or malicious, the +lawyer who contemplates making adverse disclosure of protected information may +reasonably* conclude that the compelling interests of the lawyer or others in their own +personal safety preclude personal contact with the actor. Before counseling an actor +who is a nonclient, the lawyer should, if reasonable" under the circumstances, first +advise the client of the lawyer's intended course of action. If a client or another person* +has already acted but the intended harm has not yet occurred, the lawyer should +consider, if reasonable* under the circumstances, efforts to persuade the client or third +person* to warn the victim or consider other appropriate action to prevent the harm. +Even when the lawyer has concluded that paragraph (b) does not permit the lawyer to +reveal information protected by section 6068, subdivision (e)(1), the lawyer nevertheless +is permitted to counsel the client as to why it may be in the client's best interest to +consent to the attorney's disclosure of that information. +Disclosure of information protected by Business and Professions Code section 6068, +subdivision (e)(1) must be no more than is reasonably* necessary to prevent the +criminal act +18] +Paragraph (d) requires that disclosure of information protected by Business and +Protessions Code section 6ub8, subdivision (e) as permitted by paragrapn (b), when +made, must be no more extensive than is necessary to prevent the criminal act +Disclosure should allow access to the information to only those persons* who the lawyer +reasonably believes* can act to prevent the harm. Under some circumstances, a lawyer +may determine that the best course to pursue is to make an anonymous disclosure to +4 + + +Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 13 of 14 +the potential victim or relevant law-enforcement authorities. What particular measures +are reasonable* depends on the circumstances known* to the lawyer. Relevant +circumstances include the time available, whether the victim might be unaware of the +threat, the lawyer's prior course of dealings with the client, and the extent of the adverse +effect on the client that may result from the disclosure contemplated by the lawyer. +Informing client pursuant to paragraph (c)(2) of lawyer's ability or decision to reveal +information protected by Business and Professions Code section 6068, subdivision +(e) (1) +[9] A lawyer is required to keep a client reasonably* informed about significant +developments regarding the representation. (See rule 1.4; Bus. & Prof. Code, § 6068, +subd. (m).) Paragraph (C)(2), however, recognizes that under certain circumstances, +informing a client of the lawyer's ability or decision to reveal information protected by +section 6068, subdivision (e)(1) as permitted in paragraph (b) would likely increase the +risk of death or substantial* bodily harm, not only to the originally-intended victims of the +criminal act, but also to the client or members of the client's family, or to the lawyer or +the lawyer's family or associates. Therefore, paragraph (c)(2) requires a lawyer to +inform the client of the lawyer's ability or decision to reveal information protected by +section 6068, subdivision (e)(1) as permitted in paragraph (b) only if it is reasonable* to +do so under the circumstances. +Paragraph (c)(2) further recognizes that the +appropriate time for the lawyer to inform the client may vary depending upon the +circumstances. (See Comment [10] of this rule.) Among the factors to be considered in +determining an appropriate time, if any, to inform a client are: +(1) whether the client is an experienced user of legal services; +(2) +the frequency of the lawyer's contact with the client; +(3) +the nature and length of the professional relationship with the client; +(4) whether the lawyer and client have discussed the lawyer's duty of +confidentiality or any exceptions to that duty; +(5) the likelihood that the client's matter will involve information within +paragraph (b); +(6) +the lawyer's belief,* if applicable, that so informing the client is likely to +increase the likelihood that a criminal act likely to result in the death of, or +substantial* bodily harm to, an individual; and +(7) +the lawyer's belief," if applicable, that good faith efforts to persuade a +client not to act on a threat have failed. +Avoiding a chilling effect on the lawyer-client relationship +ability or dearsion to evel formation protected by usiness and protest ions Code +5 + + +Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page 14 of 14 +section 6068, subdivision (e)(1) recognizes the concern that informing a client about +limits on confidentiality may have a chilling effect on client communication. (See +Comment [1].) To avoid that chilling effect, one lawyer may choose to inform the client +of the lawyer's ability to reveal information protected by section 6068, subdivision (e)(1) +as early as the outset of the representation, while another lawyer may choose to inform +represention, we ano +a client only at a point when that client has imparted information that comes within +paragraph (b), or even choose not to inform a client until such time as the lawyer +attempts to counsel the client as contemplated in Comment [7]. In each situation, the +lawyer will have satisfied the lawyer's obligation under paragraph (c)(2), and will not be +subject to discipline. +Informing client that disclosure has been made; termination of the lawyer-client +relationship +[11] When a lawyer has revealed information protected by Business and Professions +Code section 6068, subdivision (e) as permitted in paragraph (b), in all but extraordinary +cases the relationship between lawyer and client that is based on trust and confidence +will have deteriorated so as to make the lawyer's representation of the client impossible. +Therefore, when the relationship has deteriorated because of the lawyer's disclosure, +the lawyer is required to seek to withdraw from the representation, unless the client has +given informed consent* to the lawyer's continued representation. The lawyer normally +must inform the client of the fact of the lawyer's disclosure. If the lawyer has a +compelling interest in not informing the client, such as to protect the lawyer, the lawyer's +family or a third person* from the risk of death or substantial* bodily harm, the lawyer +must withdraw from the representation. (See rule 1.16.) +Other consequences of the lawyer's disclosure +[12] Depending upon the circumstances of a lawyer's disclosure of information +protected by Business and Professions Code section 6068, subdivision (e)(1) as +permitted by this rule, there may be other important issues that a lawyer must address. +For example, a lawyer who is likely to testify as a witness in a matter involving a client +must comply with rule 3.7. Similarly, the lawyer must also consider his or her duties of +loyalty and competence. (See rules 1.7 and 1.1.) +Other exceptions to confidentiality under California law +This rule is not intended to augment, diminish, or preclude any other exceptions +to the duty to preserve information protected by Business and Professions Code section +6068, subdivision (e)(1) recognized under California law. +6 \ No newline at end of file diff --git a/vision-fixhub/court-05/67d70ab573de7766edc16d77b872d9261a0c218157e3fd3376a2eaf8688ade30.receipt.json b/vision-fixhub/court-05/67d70ab573de7766edc16d77b872d9261a0c218157e3fd3376a2eaf8688ade30.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..12da871f0009b419fe6168e1802458eb9da95a84 --- /dev/null +++ b/vision-fixhub/court-05/67d70ab573de7766edc16d77b872d9261a0c218157e3fd3376a2eaf8688ade30.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -403, + "dataset": "marble-joined", + "doc_id": "67d70ab573de7766edc16d77b872d9261a0c218157e3fd3376a2eaf8688ade30", + "engine": "marble-apple-vision", + "event_count": 19, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "cd49d6efc9ed84cbcd851c92caf508c469c44ad229fc75f9baccc6f38183c717", + "output_sha256": "7c3b19500a348fda7295e66793cc6d75d265d899db5be69db92dc6be0d39b47e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/67f83d99652d7473a6d415644373b27f4b822036b06bd93bce378ecd8a1a702e.md b/vision-fixhub/court-05/67f83d99652d7473a6d415644373b27f4b822036b06bd93bce378ecd8a1a702e.md new file mode 100644 index 0000000000000000000000000000000000000000..4fd25e699e66516b4ca4fc438252a18e34e55b46 --- /dev/null +++ b/vision-fixhub/court-05/67f83d99652d7473a6d415644373b27f4b822036b06bd93bce378ecd8a1a702e.md @@ -0,0 +1,247 @@ +Case 1:22-cV-10904-JSR Document 194-19 Filed 06/20/23 Page 1 of 4 + + + +Case 1:22-cV-10904-JSR Document 194-19 Filed 06/20/23 Page 2 of 4 +United States Vingin Islands +ECONOMIC DEVELOPMENT COMMISION ANNUAL REPORT +Fiscal/Calendar Year Ending +December 31, 2018 +Souther Trust Company, Ing. +Truestora Dream ross Sales (ineligible Sales) & Eligible for Tax Benefits.... +Other Income (Ineligible) & Eligible for Tax Benefits +Gross Wages Paid in the V.J. (Include vacalion & sick pay, bonuses, overtime, elc.) +Average No, of Employees; Full Time & (Part Time/Other) +Average No. of Residents, Ful Time & (Part Time/Other). +Average No. of Non-Residents, Full Time & (Part Time/Oihef). +Other Employee Costs (Unemployment & health insurance, pension, allowance, etc.) +Employse Income Taxes Paid and Withheid +7.092.966 +15 +TAXES AND DUTIES (Provide dollar amount paid, and value of exemptlonirefund for each tax) +Gross Receipts: +Amount Pard +Dollar Value of Exemption +Real Property Tax: +Amount Paid +Dollar Value of Exemption +Excise Taxes: +Total Paid +Dollar Value of Exemption/Refund +Income Taxes: +Total Paid +Dollar Value of Exemption/Refund +Customs Duties: +Total Paid +Dollar Value of Exemption/Refund +Other: +Hoted room taxes paid +Other Taxes, Fee Paid Io V.i. Govemment +TOTAL. TAXES PAID: +TOTAL VALUE OF EXEMPTIONS AND OR REFUNDS: +EXPENDITURES FOR GOODS, SERVICES, PLANT & EQUIPMENT +Eligible Suppler +V.l. Suppliers +Goods and Services: +Raw materiats. components +Food, beverage +Freight Charges +Insurance +Legall Accounting +Advertising / Promotion +Ublities (tel., water, elect. etc.) +Interest & Other Bank Chg +Supplies and office expense +Repairs/Maintenance +Other (List Separately) +Subtotal, Goods and Svcs: +Capital Expenditures: +Buikling & Improvements +Leasehold Improvements +Machinery / Equipment +Fumiture / Fixtures +Vehicles +Software +Subtotal, Capital Expend: +Non-Local +3,955 +71,250 +1,763 +5.561 +82,530 +615 +3,030 +2,640 +31,745 +677 +6,118 +645 +150.515 +197-985 +1.290.100 +705 +6,700 +1.297.505 +10,131 +41 +GRAND TOTALS +CUMULATIVE CAPITAL EXPENDITURES UNDER EDC CERTIFICATE +Mama/Signature of Preparer: +Yeste +Jeanne +82,530 +10131 +208,117 +1.287.505 5 +Date: +_Telephone Number: +2/9/15 +340-775-2525 +13.173.675. +060,869. +202,434 +264,625 +209,560 +111.432 +790 +300,370 +111.932 +Totals +4.570 +1,203,130 +2,640. +102,995 * +1.381.: +16,581 +8,208 +150.515 / +1,578,020 +10.131 +10,031 +1.588.151. +450.854 +Page 1 +VI-JPM-000007534 + + +Case 1:22-cv-10904-JSR Document 194-19 Filed 06/20/23 Page 3 of 4 +Company Name. +oods and Service +ues and subscriptio +Auto +Postage and defivery +Travel and related +Meals and transportation +EDC Fees +Rent +Business expenses +Other expenses +Miscellaneous +Subtotal, Goods and Svcs: +Fiscal/Calendar Year Ending +Southern Trust Company. Ine. +EXPENDITURES FOR GOODS, SERVICES, PLANT & EQUIPMENT -Other +Eligible Supplier V.J. Suppliers +1,160 +7,040 +1,633 +1.534 +3.372 +20.500 +108.718_ +5.640 +900 +150 515. +December 21, 2910 +Non-Local +OTHER EMPLOYEE COSTS +Emplovee benefits - health, life insurance, education +Simple IRA - emplover contributions of 3% +Seminars and continuing education +ECONOMIC DEVELOPMENT COMMISSION FEES +BOE Territorial Scholarshis Fund +Department of Labor - Work Force Development Fund +Certificale fees - Annual Compliance Fee +EXPENDITURES FOR CHARITABLE CONTRIBUTIONS +V.l. Publie Education += 25,000 s +Name - recipient +Community Foundation of ine V. I +Organization Black Aerospace Professional +Lutheran Socal Sansces of the VI. +Antilles School, anc +Community Foundation of the V. 1. +Hemonic Lodge +V.l. Charity +28.250 +Date +084052201E +04282O1E + + +0SM13/2016 + +Totale +1,180 * +7.040 +-1833 +1.534 +3,3721 +20,500~ +108,716 " +-3.0407 +- 909 +150,515 +176,554 +20,747 +_ 5.133 +292,434 +3,000 +2,500 +_3.500 +13,000 +Totals +53,250 +Amount +10,000 +15,000 +20,000 +5.500 +2,500 +250 +53,250 +Page 2 +VI-JPM-000007535 + + +EDC ANNUAL REPORT +Value of Exemptions of Stockholders/Partners/Members +BENEFICIARY_ +Stockholders, +Partners or Members +Jeffrey E. Epstein +Social Security +No. +Southern Trust Company, Inc. +Physical +Address +% +Distributable +Shares +Business +100 +EDC Income +See page 1 of of EDC +EDC Annual +Fiscal Year Ending December 31, 2016 +Total Tax Due EDC Credit +EDC Annual +report. +EDC Annual +report. +Balance Tax +Due +Case 1:22-CV-10904-JSR Document 194-19 Filed 06/20/23 Page 4 of 4 +VI-JPM-000007536 +TOTAL S +Note: Totals of EDC Credit and Balance Tax Due must be carried forward to the EDC Annual Report and reported under Taxes and Duties (See instructions). \ No newline at end of file diff --git a/vision-fixhub/court-05/67f83d99652d7473a6d415644373b27f4b822036b06bd93bce378ecd8a1a702e.receipt.json b/vision-fixhub/court-05/67f83d99652d7473a6d415644373b27f4b822036b06bd93bce378ecd8a1a702e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ea778862eb67f3bc49e187f3c05755ffd92dc02d --- /dev/null +++ b/vision-fixhub/court-05/67f83d99652d7473a6d415644373b27f4b822036b06bd93bce378ecd8a1a702e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -228, + "dataset": "marble-joined", + "doc_id": "67f83d99652d7473a6d415644373b27f4b822036b06bd93bce378ecd8a1a702e", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "744edf54bc6e249d28db5b657d49e3ded708f1b6b3e5693eb9bd3fccc7f57556", + "output_sha256": "bbb1a5e957276ddd2fd8e5e4b531a5cec5eb347e913f0b24a6cd922540e4a5b7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/67f956cb25b4744a502d96a389362f6e46bcb145c8c01cb9a3d6b9f42bf93fe4.md b/vision-fixhub/court-05/67f956cb25b4744a502d96a389362f6e46bcb145c8c01cb9a3d6b9f42bf93fe4.md new file mode 100644 index 0000000000000000000000000000000000000000..183538a8a8529a5b82239b37bc13b321856363bc --- /dev/null +++ b/vision-fixhub/court-05/67f956cb25b4744a502d96a389362f6e46bcb145c8c01cb9a3d6b9f42bf93fe4.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 244-18 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/67f956cb25b4744a502d96a389362f6e46bcb145c8c01cb9a3d6b9f42bf93fe4.receipt.json b/vision-fixhub/court-05/67f956cb25b4744a502d96a389362f6e46bcb145c8c01cb9a3d6b9f42bf93fe4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d1d3c7e10d182b23255e06433e5b065c3a518a2b --- /dev/null +++ b/vision-fixhub/court-05/67f956cb25b4744a502d96a389362f6e46bcb145c8c01cb9a3d6b9f42bf93fe4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "67f956cb25b4744a502d96a389362f6e46bcb145c8c01cb9a3d6b9f42bf93fe4", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "a775b3968351b3cbacccaecb239bd807071b6966f66428de23c29ae969671a72", + "output_sha256": "9f230becce7cd7a7d958332aade7527ca7fdf8db17602a6345a398dddf8f77f0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6822154952da41f2e4c4675c5737920e257073efaee9777d4e569044a2766cc6.md b/vision-fixhub/court-05/6822154952da41f2e4c4675c5737920e257073efaee9777d4e569044a2766cc6.md new file mode 100644 index 0000000000000000000000000000000000000000..83abbcef714b4d0b306a1a85ef5f989f3c77ab52 --- /dev/null +++ b/vision-fixhub/court-05/6822154952da41f2e4c4675c5737920e257073efaee9777d4e569044a2766cc6.md @@ -0,0 +1,96 @@ +Case 1:22-cv-10904-JSR , Document 115 Filed 04/07/23 Page 1 of 2 +MASSEY +50 East Washington St. +Suite 400 +Chicago, IL 60602 +&GALL... +1000 Maine Avenue, SW +Suite 450 +Washington, DC 20024 +April 7, 2023 +The Honorable Jed S. Rakoff +Judge, United States District Court +Southern District of New York +Via ECF +Re: +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., +1:22-cv-10904-JSR (S.D.N.Y). +Dear Judge Rakoff: +JPMorgan Chase Bank, N.A. files this response to the motion by James E. "Jes" Staley, +seeking reconsideration of the Court's denial of his motion to sever JPMC's claims against Staley. +Staley primarily asserts that +is required because he is prejudiced by the court's schedule. +As discussed below, Staley fails to provide any reason to reconsider the Court's decision. +THE COURT SHOULD NOT RECONSIDER ITS DECISION TO REFRAIN FROM +SEVERING JPMC'S THIRD-PARTY COMPLAINT AGAINST STALEY. +This Court has twice denied Staley's request to sever JPMC's third-party complaint against +him. Staley's reconsideration request, therefore, faces a particularly high threshold. "A motion for +reconsideration should be granted only when the [moving party] identifies an intervening change +of controlling law, the availability of new evidence, or the need to correct a clear error or prevent +manifest injustice." Kolel Beth Yechiel Mechil of Tartikov, Inc. v. YLL Irrevocable Tr., 729 F.3d +99, 104 (2d Cir. 2013) (internal quotation marks omitted). +In addition, a party moving for | +is needed to avoid prejudice or confusion and to promote the ends of justice." Bey v. +City of N.Y., 2009 WL 1911742, at *1 (S.D.N.Y. June 30, 2009). As this Court has recognized, +"the joinder of claims is 'strongly encouraged,' ... and, concomitantly, L +should generally +be granted only in 'exceptional circumstances. '" Compania Embotelladora del Pacifico v. Pepsi +Cola Co., 256 F.R.D. 131, 133 (S.D.N.Y. 2009) (citations omitted). There is no basis upon which +to grant reconsideration of the Court's previous orders here. +As this Court heard in open court the first time it considered Doe's motion to sever (to +which Staley merely indicated non-opposition), courts consider five factors in deciding a motion +to sever: (1) whether the claims arise out of the same transaction or occurrence, (2) whether the +claims present common questions of fact or law, (3) whether +would serve judicial +economy, (4) whether +would cause or avoid prejudice to the parties, and (5) whether the +claims involve different witnesses and evidence. See Boston Post Road Med. Imaging, P.C. v. +Allstate Ins. Co., 2004 WL 1586429 at *1 (S.D.N. Y. July 15, 2004). All of the factors require denial +of Staley's request. +DRAFT- PRIVILEGED ATTORNEY WORK PRODUCT + + +Case 1:22-cv-10904-JSR Document 115 Filed 04/07/23 Page 2 of 2 +April 7, 2023 +Page |2 +Staley makes little effort to show that factors 1, 2, and 5 favor +. Nor could they. +JPMC's claims arise out of the same transactions and occurrences as the Plaintiffs' claims (factor +1), they concern common questions of fact and law (factor 2), and involve many of the same +witnesses and evidence (factor 5). In particular, JPMC's third party complaint against Staley seeks +indemnification and contribution, as well as damages for fiduciary duty breaches and faithless +servant conduct. And Staley's alleged conduct and knowledge form a significant part of the +Plaintiffs' claims. Doe's amended complaint mentions him ninety-seven times and repeatedly +alleges that JPMC knew of or participated in Epstein's sex trafficking venture "through Staley." +See, e.g., Dkt. 36, FAC, 1111 135, 164, 200, 205-206, 230-231, 239, 327-328, 360. And the USVI's +amended complaint mentions Staley thirty-nine times, citing (and reproducing) numerous emails +between Staley and Epstein to provide a basis for its claims against JPMC. See, e.g., Dkt. 17, +USVI FAC, 111 52-63. Not surprisingly, JPMC's claims against Staley involve the very same +alleged conduct and knowledge, and will therefore involve substantially overlapping witnesses and +evidence. See Dkt. 59, Doe Third-Party Complaint, 11 22-33; Dkt. 70, USVI Third-Party +Complaint, 111 22-33. +Staley's assertion that his defenses "raise different issues and require broader discovery" +(Staley Ltr., at 3) is puzzling. Staley's employment at JPMC is not a new issue: Both Doe and the +USVI seek to impute Staley's conduct and knowledge to JPMC. JPMC's request for additional +damages due to Staley's disloyalty does not change the fact that its underlying claims against +Staley turn on the same facts as Plaintiffs' claims against JPMC, and it does not warrant two +separate trials with the same evidence and witnesses. Indeed, +will not serve judicial +economy (factor 3), but instead will result in duplicative and wasteful litigation. +Staley's assertion of prejudice does not justify reconsideration. Indeed, his complaint is +primarily with the schedule set by the Court and not with the concept of joining the litigation. See, +e.g., Staley Ltr., 3 ("Mr. Staley is severely prejudiced by the schedule"); id. ("the current schedule +deprives Mr. Staley of basic procedural rights"). But this Court is fully capable of exercising its +discretion to set a schedule that accommodates the interest of all parties; indeed, it already has. +And while Staley continues to complain that he is a recent entry to the case, he was already +involved with (and faced potential legal jeopardy from) Doe's allegations. Facing legal +consequences for his alleged relationship with Epstein is also not new to Staley, as he had already +been subject to rigorous and ongoing investigations well before this case was filed. He also +produced documents to the USVI in its prior case against Epstein's estate. Both complaints contain +serious accusations against Staley, and the parties to this case had already sought his testimony +and scheduled his deposition by agreement - all before JPMC impleaded him. Staley was no merc +witness among many; he was the central focus of both Doe's and USVI's claims. The Court should +therefore deny Staley's motion. +Sincerely, +Is/ Leonard A. Gail +Leonard A. Gail diff --git a/vision-fixhub/court-05/6822154952da41f2e4c4675c5737920e257073efaee9777d4e569044a2766cc6.receipt.json b/vision-fixhub/court-05/6822154952da41f2e4c4675c5737920e257073efaee9777d4e569044a2766cc6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bc42ff0587d3b963bea1a0b60f3fa7127e2da192 --- /dev/null +++ b/vision-fixhub/court-05/6822154952da41f2e4c4675c5737920e257073efaee9777d4e569044a2766cc6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "6822154952da41f2e4c4675c5737920e257073efaee9777d4e569044a2766cc6", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "bba3ac81d7a86a67171c46e404a4dafc41dc469d037b116b27ede8dc3f91ae29", + "output_sha256": "f2732bd2874e425b2cee87632512dedb70f52516fda8c0cedb590654487b0d28", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/682617aa8e3dd2fc9833b89f64667a623bd73e432c8e615406d778769710f34c.md b/vision-fixhub/court-05/682617aa8e3dd2fc9833b89f64667a623bd73e432c8e615406d778769710f34c.md new file mode 100644 index 0000000000000000000000000000000000000000..0ee7f661e7efbe2bfce9747ade9afd0908e0c854 --- /dev/null +++ b/vision-fixhub/court-05/682617aa8e3dd2fc9833b89f64667a623bd73e432c8e615406d778769710f34c.md @@ -0,0 +1,36 @@ +Case 1:22-cv-10904-JSR Document 10 Filed 01/05/23 Page 1 of 1 +AO 458 (Rev. 06/09) Appearance of Counsel +UNITED STATES DISTRICT COURT +for the +Southern District of New York +GOVT OF THE UNITED STATES VIRGIN ISLANDS +Plaintiff +V. +JPMORGAN CHASE BANK, N.A. +Defendant +) +) +) +) +) +APPEARANCE OF COUNSEL +Case No. 1:22-CV-10904-UA +To: +The clerk of court and all parties of record +1 am admitted or otherwise authorized to practice in this court, and 1 appear in this case as counsel for: +Government of the United States Virgin Islands +Date: +01/05/2023 +Attorney's signature +William H. Narwold (WH-1713) +Printed name and bar number +MOTLEY RICE LLC +20 Church Street, 17th Floor +Hartford, CT 06103 +Address +bnarwold@motleyrice.com +E-mail address +(860) 882-1676 +Telephone number +(860) 882-1682 +FAX number diff --git a/vision-fixhub/court-05/682617aa8e3dd2fc9833b89f64667a623bd73e432c8e615406d778769710f34c.receipt.json b/vision-fixhub/court-05/682617aa8e3dd2fc9833b89f64667a623bd73e432c8e615406d778769710f34c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..690c78eb23c84da84966bbcb281415f48ff8c03d --- /dev/null +++ b/vision-fixhub/court-05/682617aa8e3dd2fc9833b89f64667a623bd73e432c8e615406d778769710f34c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "682617aa8e3dd2fc9833b89f64667a623bd73e432c8e615406d778769710f34c", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b7df738fea491fa16913b82d4326e57769a4a75bcff7f5f1f2ffa83d4c8ddcf5", + "output_sha256": "1987c2291c908939889926a36100e26f9741e8b3944ccc5e2dd6988d7f044f48", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6851a71ed3d18f59d964a38b4402c1692dde2091a1c5392931d2b49d483a5f17.md b/vision-fixhub/court-05/6851a71ed3d18f59d964a38b4402c1692dde2091a1c5392931d2b49d483a5f17.md new file mode 100644 index 0000000000000000000000000000000000000000..0b47801311a096550a459a7f50530f5364b54e04 --- /dev/null +++ b/vision-fixhub/court-05/6851a71ed3d18f59d964a38b4402c1692dde2091a1c5392931d2b49d483a5f17.md @@ -0,0 +1,81 @@ +Case 1:20-cr-00330-PAE +Document 731-2 Filed 07/14/22 Page 1 of 3 +PANISH +SHEA & +BOYLE +LLP +December 15, 2021 +VIA EMAIL +The Honorable Alison J. Nathan +Soutem District or New York. +40 Foley Square +New York, NY 10007 +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Dear Judge Nathan: +I am writing on behalf of witness Jane in regard to Ms. Maxwell's recent filing regarding +her attorney Robert Glassman who represented her in her civil case against the Epstein Estate +and Ms. Maxwell that settled over a year ago. +Ms. Maxwell raises three areas that she wants to solicit testimony from Mr. Glassman. +The "Help her case" email +Jane stands on the opposition she submitted on December 6, 2021 and the Government's +opposition regarding that email. +2. +The Lion | +email +As the Government points out, Jane was extensively cross-examined on this issue. Mr. +Glassman would have nothing to add, and anything he could say would require him to disclose +confidential information in violation of California Rule of Professional Conduct 1.6. +3. +Settlement Demands to Ms. Maxwell and the EVCP +11111 Santa Monica Boulevard, Suite 700 • Los Angeles, Califomia 90025 • 310.477.1700 phone • 310.477.1699 fax • www.psblaw.com + + +Case 1:20-cr-00330-PAE Document 731-2 Filed 07/14/22 +The Honorable Alison J. Nathan +December 15, 2021 +Page 2 +PANISH +SHEA & +BOYLE +Ms. Maxwell would like to ask Mr. Glassman whether he made a $25 million demand to +Ms. Maxwell to settle the civil case against her. It should be noted that defense counsel did not +question Jane about this demand when they had a chance, so there is no impeachment value to +anything Mr. Glassman could say. It should also be noted that Ms. Maxwell or Ms. Menninger +(who represented Ms. Maxwell in the civil case), who are both already present in the courtroom, +could testify about any such demand. So there is nothing Mr. Glassman could offer on this +subject that would be probative and outweigh the risk of possible disclosure of confidential +information inherent in calling Jane's attorney to the witness stand. Additionally, whether a +settlement demand would have been made in the civil case against Ms. Maxwell seems wholly +irrelevant as that civil case settled well over a year before Jane testified; that is, at the time Jane +testified in the criminal trial, she had no financial incentive to do so. +With regard to demands to the EVCP, Jane adopts the arguments made by the +Government in its opposition, and adds again that the civil case settled long before Jane's +testimony in the criminal trial against Ms. Maxwell - so Jane had no financial interest in the +substance of her testimony. +Finally, we remind the Court that we believe that the subpoena that was served on Mr. +Glassman was invalid under Fed. R. Crim. Pro 17, and that Mr. Glassman is not currently under +valid subpoena. +Accordingly, we respectfully request that the Defendant's motion to compel Mr. +Glassman to testify should be denied. + + +Case 1:20-cr-00330-PAE Document 731-2 Filed 07/14/22 +PANISH +SHEA & +BOYLE. +The Honorable Alison J. Nathan +December 15, 2021 +Page 3 +To the extent the Court were to compel Mr. Glassman's testimony, Mr. Glassman would +need time to consult ethics counsel and perhaps the California State Bar. We would also +respectfully request that any testimony be conducted remotely to prevent the time, expense, and +COVID risk in light of what should be extremely limited testimony. +Respectfully submitted, +/sl +Kevin Boyle +PANISH SHEA & BOYLE LLP +11111 Santa Monica Blvd., Ste. 700 +Los Angeles, CA 90025 +Phone: 310-477-1700 +Attorneys for Witness Jane +Ce: Counsel of record diff --git a/vision-fixhub/court-05/6851a71ed3d18f59d964a38b4402c1692dde2091a1c5392931d2b49d483a5f17.receipt.json b/vision-fixhub/court-05/6851a71ed3d18f59d964a38b4402c1692dde2091a1c5392931d2b49d483a5f17.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2b9df20c3e49f2e7b847a57bf1b79a4cdea1ea16 --- /dev/null +++ b/vision-fixhub/court-05/6851a71ed3d18f59d964a38b4402c1692dde2091a1c5392931d2b49d483a5f17.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "6851a71ed3d18f59d964a38b4402c1692dde2091a1c5392931d2b49d483a5f17", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "1276ef73fba436048c9d2d8e7efbc3e24ad3287b054a5042cc110359f3bc636c", + "output_sha256": "c79911e9c07765b07505febb9078ff839d23abb1b2cc156a2f2fad55d51b8417", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6854efcacb667fad926688b6966f8363be1d8c8f080b58c3e4c9c0bd855611c8.md b/vision-fixhub/court-05/6854efcacb667fad926688b6966f8363be1d8c8f080b58c3e4c9c0bd855611c8.md new file mode 100644 index 0000000000000000000000000000000000000000..26bdbaa8e8ba5fba35528d2572071bfae6d45388 --- /dev/null +++ b/vision-fixhub/court-05/6854efcacb667fad926688b6966f8363be1d8c8f080b58c3e4c9c0bd855611c8.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 267-23 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6854efcacb667fad926688b6966f8363be1d8c8f080b58c3e4c9c0bd855611c8.receipt.json b/vision-fixhub/court-05/6854efcacb667fad926688b6966f8363be1d8c8f080b58c3e4c9c0bd855611c8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3c6c4061abccfd2b18984d48f9fbe3bc3f9ed672 --- /dev/null +++ b/vision-fixhub/court-05/6854efcacb667fad926688b6966f8363be1d8c8f080b58c3e4c9c0bd855611c8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "6854efcacb667fad926688b6966f8363be1d8c8f080b58c3e4c9c0bd855611c8", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "6b1c89aaf7895ccfaa784fcc9a784dae23469ac010ac6f37ae8dcc9b30395b32", + "output_sha256": "88c1e670831c1c62fb0f90dd0ce300150a989db0fd97a8e068066dc85c3e4f03", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6860d2a72dfe20a97f31472aa81e8dcc32e05552b972aa6362acd68a4df88421.md b/vision-fixhub/court-05/6860d2a72dfe20a97f31472aa81e8dcc32e05552b972aa6362acd68a4df88421.md new file mode 100644 index 0000000000000000000000000000000000000000..632d7c56952799fe61013c04125f5cc7250d65f4 --- /dev/null +++ b/vision-fixhub/court-05/6860d2a72dfe20a97f31472aa81e8dcc32e05552b972aa6362acd68a4df88421.md @@ -0,0 +1,35 @@ +Case 1:19-cr-00830-AT +Document 25 +Filed 02/02/20 + +AO 458 (Rev. 06/09) Appearance of Counsel +UNITED STates DISTRICT CourT +for the +Southern District of New York +United States +Plaintiff +V. +Tova Noel +Defendant +Case No. +1:19-CR-00830-AT +APPEARANCE OF COUNSEL +To: +The clerk of court and all parties of record +I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for: +Tova Noel +Date: +02/02/2020 +Attorne +Eric J. Sarraga ES6095 +Printed name and har number +Foy & Seplowitz +105 Main Street +Hackensack, NJ 07601 +Address +esarraga@foyseplowitz.com +E-mail address +(201) 457-0071 +Telephone number +(201) 457-0072 +FAX number diff --git a/vision-fixhub/court-05/6860d2a72dfe20a97f31472aa81e8dcc32e05552b972aa6362acd68a4df88421.receipt.json b/vision-fixhub/court-05/6860d2a72dfe20a97f31472aa81e8dcc32e05552b972aa6362acd68a4df88421.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a7bc122370a9be93e0431338533362e41b57f9eb --- /dev/null +++ b/vision-fixhub/court-05/6860d2a72dfe20a97f31472aa81e8dcc32e05552b972aa6362acd68a4df88421.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "6860d2a72dfe20a97f31472aa81e8dcc32e05552b972aa6362acd68a4df88421", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "2d891c1caba837f59201d9f7ab82439bc747c3bb010fa698faa07ed8dc8757f2", + "output_sha256": "e941f8827256c2f67e5eef81be302233a5dc1cc3483e6daea1db36b75cd6e7f6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6865b6676948c75dc28e169af6ad0d91f0895f0f78eeb22e25b581c846b6f86f.md b/vision-fixhub/court-05/6865b6676948c75dc28e169af6ad0d91f0895f0f78eeb22e25b581c846b6f86f.md new file mode 100644 index 0000000000000000000000000000000000000000..dc68264aa86ac2ac00a2ff21eee281d22808f2ce --- /dev/null +++ b/vision-fixhub/court-05/6865b6676948c75dc28e169af6ad0d91f0895f0f78eeb22e25b581c846b6f86f.md @@ -0,0 +1,72 @@ +Case 1:22-cv-10904-JSR Document 186-58 Filed 06/14/23 + + + + +Case 1:22-cV-10904-JSR Document 186-58 Filed 06/14/23 Page 2 of 3 +Date: +Thursday, October 12015 01:54 PM +Subject: Re: +From: +jeffrey E. sjeevacation@gmail.com> +To: +Cecile de Jongh < +@yahoo.com >: Karyna Shuliak < +@icloud.com>: +i spoke to her and she application was complete and the board would look at it on oct 30 +On Thu, Oct 1, 2015 at 6:50 AM, Cecile de Jongh ‹ +@yahoo.com > wrote: +Another thought: it might be good to have Karyna call as well. I'm not sure if +her. I will continue to call too. +has ever spoken to +With warm regards, +Cecile +Sent from my iPhone and misspellings courtesy of iPhone. +On Oct 1, 2015, at 6:15 AM, jeffrey E. wrote: +pleaes lets have the request chain in writing. we were told twice before that the applicaiton was complete. +can you send me her number. ? +On Wed, Sep 30, 2015 at 9:41 PM, Cecile de Jongh < +@yahoo.com > wrote: +again this afternoon since I did not get a return call but no answer. I'm not entirely sure that +having Randy involved will help rather than hinder the cause at this point in the process. I would prefer that +we wait to get confirmation that there is absolutely nothing left to do with her file. +Randy is not exactly a light touch or diplomatic and I don't want the board members to feel that they are +threatened into approving Karyna. I will call everyday and I will call Donald as well. Please note that the +board members are not Gov't employees. +With that said, it's obviously your decision re calling Randy. +With warm regards, +Cecile +Sent from my iPhone and misspellings courtesy of iPhone. +On Sep 30, 2015, at 8:36 PM, jeffrey E. Seevacation@gmail.com > wrote: +should i call randy knight re karyna? +please note +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +JEE +Unauthorized use, disclosure or copying of this + +ESTATE_JPMO21434 + + +Case 1:22-cV-10904-JSR Document 186-58 Filed 06/14/23 Page 3 of 3 +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved +please note +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +JEE +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved diff --git a/vision-fixhub/court-05/6865b6676948c75dc28e169af6ad0d91f0895f0f78eeb22e25b581c846b6f86f.receipt.json b/vision-fixhub/court-05/6865b6676948c75dc28e169af6ad0d91f0895f0f78eeb22e25b581c846b6f86f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b83105740600c596a34feda525c892c685354e73 --- /dev/null +++ b/vision-fixhub/court-05/6865b6676948c75dc28e169af6ad0d91f0895f0f78eeb22e25b581c846b6f86f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -698, + "dataset": "marble-joined", + "doc_id": "6865b6676948c75dc28e169af6ad0d91f0895f0f78eeb22e25b581c846b6f86f", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": false, + "input_sha256": "4d2645622c2f6d660a7748b940b7dd42846aaaca8b408ca2e605fdad2417c0e6", + "output_sha256": "d158df4c7677ca1da0dcbc03a60bcef728601aa41f7c1aced6c134e9dff4b3aa", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/688e7c779e9d86483b5200c716484e52c804238dbb45644c44d5b48d8edd3c43.md b/vision-fixhub/court-05/688e7c779e9d86483b5200c716484e52c804238dbb45644c44d5b48d8edd3c43.md new file mode 100644 index 0000000000000000000000000000000000000000..28deeeecc712883c64cbf66312e45721c6b7a919 --- /dev/null +++ b/vision-fixhub/court-05/688e7c779e9d86483b5200c716484e52c804238dbb45644c44d5b48d8edd3c43.md @@ -0,0 +1,22 @@ +Case 1:22-cV-10904-JSR Document 284-53 Filed 08/14/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 284-53 Filed 08/14/23 Page 2 of 2 +Date: 11/22/2013 9:03:03 PM +From: "Jeanne +To : "Cecile deJongh" +Ce: "Una Pascal" +Attachment: 20131122150104423.pdf; +The 2 five thousand S checks we wrote to UVI are still outstanding. Do you +think we should follow up. They were written in August. +Jeanne +Wiebract, CPA +The infomation contained in this e-mail may be privileged, confidential, +and protected from disclosure. If you are not the intended recipient, you +are hereby notified that any dissemination, distribution or duplication of +this communication is strictly prohibited. If you have received this +communication in enor, please notify the sender immediately and delete all +copies. + +ESTATE_JPM064398 diff --git a/vision-fixhub/court-05/688e7c779e9d86483b5200c716484e52c804238dbb45644c44d5b48d8edd3c43.receipt.json b/vision-fixhub/court-05/688e7c779e9d86483b5200c716484e52c804238dbb45644c44d5b48d8edd3c43.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..984014c8fbd16c363ebf79be0e63db2aa0451dd6 --- /dev/null +++ b/vision-fixhub/court-05/688e7c779e9d86483b5200c716484e52c804238dbb45644c44d5b48d8edd3c43.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "688e7c779e9d86483b5200c716484e52c804238dbb45644c44d5b48d8edd3c43", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "8ace755223fd32832478db9939db852628b8c420185f2b25ca9e872fde02b7d7", + "output_sha256": "a61dd5d25d668053308a568ee6c65b8cb89f10eb85c0472244c83fed12535129", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6891104c2dea42ce4550abbd416fcaaa396a60ce52bb5e794a09bcc7ac8942d5.md b/vision-fixhub/court-05/6891104c2dea42ce4550abbd416fcaaa396a60ce52bb5e794a09bcc7ac8942d5.md new file mode 100644 index 0000000000000000000000000000000000000000..612269618d66c91052b1ec55a3efd63dd9edfeba --- /dev/null +++ b/vision-fixhub/court-05/6891104c2dea42ce4550abbd416fcaaa396a60ce52bb5e794a09bcc7ac8942d5.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 226-6 Filed 07/24/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6891104c2dea42ce4550abbd416fcaaa396a60ce52bb5e794a09bcc7ac8942d5.receipt.json b/vision-fixhub/court-05/6891104c2dea42ce4550abbd416fcaaa396a60ce52bb5e794a09bcc7ac8942d5.receipt.json new file mode 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08/25/23 Page 1 of 1 + +Filed Under Seal diff --git a/vision-fixhub/court-05/68c88770ddae5fd9bd7dcae2d77530ddcdfdc7e9d546c63ceece537fe48d70b6.receipt.json b/vision-fixhub/court-05/68c88770ddae5fd9bd7dcae2d77530ddcdfdc7e9d546c63ceece537fe48d70b6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b46aa6a0feea1923041f9cde358abd9fe728f6d6 --- /dev/null +++ b/vision-fixhub/court-05/68c88770ddae5fd9bd7dcae2d77530ddcdfdc7e9d546c63ceece537fe48d70b6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "68c88770ddae5fd9bd7dcae2d77530ddcdfdc7e9d546c63ceece537fe48d70b6", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "ffb6c05256ebd61ce52e2db4ffaae32f344db5783a408337cf6aafb66e815a5f", + "output_sha256": "981463dacc8e36df6e59d262c0ac86020d4214e4abd3d31315dccf5db6d0f3c8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6908e7ea30136e40be84a1a597b96e6f6f182f2de2a6a4384dd1379646bab360.md b/vision-fixhub/court-05/6908e7ea30136e40be84a1a597b96e6f6f182f2de2a6a4384dd1379646bab360.md new file mode 100644 index 0000000000000000000000000000000000000000..27434db918d4e753d902ec2567b735723be44edb --- /dev/null +++ b/vision-fixhub/court-05/6908e7ea30136e40be84a1a597b96e6f6f182f2de2a6a4384dd1379646bab360.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 226-40 Filed 07/24/23 + + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6908e7ea30136e40be84a1a597b96e6f6f182f2de2a6a4384dd1379646bab360.receipt.json b/vision-fixhub/court-05/6908e7ea30136e40be84a1a597b96e6f6f182f2de2a6a4384dd1379646bab360.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bcdb1b543781f1df252d795f564b8399106165eb --- 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0000000000000000000000000000000000000000..49c226fd72ae3260f03bb54cf58023df4184e685 --- /dev/null +++ b/vision-fixhub/court-05/691372f5e730b62bffaf352efaeaa56974871eb8506115a679c48913c1857bdc.md @@ -0,0 +1,227 @@ +Case 1:22-cv-10904-JSR Document 355 Filed 03/12/24 Page 1 of 5 +STEPHEN L WOHLGEMUTH +(202) 434-5390 +swohigemuth(@)wc.com +LAW OFFICES +& CONNOLLY uP* +680 MAINE AVENUE SW +WASHINGTON, DC 20024 +(202) 434-5000 +WWW.WC.coM +EDWARD BENNETT +11920-1988) +PAUL R. CONNOLLY (1922-1978) +VIA ECE +Re: +Doe v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10019 (JSR); USVI v. +JPMorgan Chase Bank, N.A., 1:22-cv-10904 (JSR) - Deposition Testimony +Sealed Under Protective Order +Dear Judge Rakoff: +Mr. Staley opposes in part the letter motions filed by nonparty The New York Times +Company ("the Times") in the above-captioned matters. +This Court has previously recognized the sensitive nature of the allegations in these cases +and found "good cause" to issue an "appropriately tailored" protective order that governed the use +of confidential information created or exchanged during discovery. See ECF No. 35, 22-cv-10019; +ECF No. 15, 22-cv-10904. The Times seeks to unseal five exhibits to motions that contain excerpts +from Jane Doe's deposition, all of which were filed under seal and subject to the Court's protective +order. Two of the exhibits were filed in connection with Doe's class-certification motion. Mr. +Staley takes no position on those, as they do not contain information relating to him. +The other three were filed in connection with the parties' various motions for summary +judgment, none of which were ruled upon by the Court.' Mr. Staley opposes the unsealing of these +three exhibits. The Times fails to address the most on-point authority explaining that sealed filings +associated with motions that have not and will never be decided are not "judicial documents" +subject to the public's presumption of access. And even if they were judicial documents, under +every relevant standard these documents should remain sealed. Each contains deposition +testimony regarding Doe's allegation of assault against Mr. Staley. Mr. Staley has consistently +and repeatedly denied those false allegations. Moreover, the deposition in question occurred +before Mr. Staley was a party to these cases—meaning that Mr. Staley's counsel did not participate +in that deposition and had no opportunity to cross-examine her then. Indeed, Mr. Staley has never +cross-examined Doe, because Mr. Staley's deposition of Doe was repeatedly delayed, including at +' Decl. of Felicia H. Ellsworth in Support of Mem. of Law in Opp'n to Mr. Staley's Mot. for +Summ. J., Ex. 57, Doe v. JPMorgan Chase & Co., No. 1:22-cv-10019 (JSR), ECF 212-57; Decl. +of Felicia H. Ellsworth in Support of JPMC's Opp'n to USVI's Mot. for Partial Summ. J., Ex. 128, +USVI v. JPMorgan Chase Bank, N.A., 1:22-cv-10904 (JSR), ECF No. 265-4; Decl. of Felicia H. +Ellsworth in Support of JPMC's Opp'n to Mr. Staley's Mot. for Summ. J., Ex. 57, USVI v. +JPMorgan Chase Bank, N.A., 1:22-cv-10904 (JSR), ECF 326-57. + + +Case 1:22-cv-10904-JSR Document 355 Filed 03/12/24 Page 2 of 5 +& CONNOLLYu* +Page 2 +Doe's request, and the case settled before the deposition took place. Nor has this Court ever had +occasion to pass on the veracity of Doe's allegations, much less after being heard on the merits +from Mr. Staley. The Times's motions therefore implicate the Second Circuit's concern that court +files might be used to "promote scandal arising out of unproven potentially libelous statements." +v. Maxwell, 929 F.3d 41, 51 (2d Cir. 2019). Well-established law protects the judicial +process from being coopted in this manner and requires denial of the Times's request. +As the Times recognizes, the first step in evaluating any unsealing request under either the +common law or the First Amendment is determining whether the documents at issue are "judicial +documents" subject to a presumption of access. Mot. at 3-5; Trump v. Deutsche Bank AG, 940 +F.3d 146, 151 (2d Cir. 2019). The "mere filing of a paper or document with the court is insufficient +to render that paper a judicial document subject to the right of public access." United States v. +Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) ("Amodeo "). Rather, an item "must be relevant to the +performance of the judicial function and useful in the judicial process in order for it to be +designated a judicial document." Id. (emphasis added). A court "performs the judicial function +... when it rules on motions currently before it" or "properly exercis[es] its inherent 'supervisory +powers." +929 F.3d at 49 (cleaned up). So to constitute a judicial document, a filed +document must be (1) relevant to an actual exercise of judicial authority—whether adjudicatory or +supervisory-and (2) useful in the exercise of that judicial action. Filings that do not meet both +criteria are not "judicial documents" subject to a presumption of public access. +The three sealed exhibits at issue are not judicial documents as defined in the doctrine. The +exhibits came before the Court in connection with JPMorgan's opposition briefs to summary +judgment motions filed by Mr. Staley and the USVI. But the Court never ruled on those motions +before the parties settled and the two cases were closed. The sealed documents therefore were not, +and never will be, useful in the exercise of any judicial authority. For that reason, unsealing the +exhibits would provide the public no window into assessing the Court's performance, which is the +sole justification for unsealing. United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) +("Amodeo II") ("IT]he presumption of access is based on the need for the public monitoring of +federal courts."); see also S.E.C. v. TheStreet.Com, 273 F.3d 222, 233 (2d Cir. 2001) (ruling that +pretrial deposition transcripts "did not directly affect an adjudication nor ... significantly +determine litigants' substantive rights" and thus were not "judicial documents"). +The Times fails to grapple with this basic issue, which dooms its motions. The Times +ignores the holding from the undeniably most on-point authority on this issue. In +Maxwell, the court confronted the question of which, if any, sealed documents from a civil suit +and Ghislaine Maxwell should be unsealed. 2020 WL 133570, at *1 +(S.D.N.Y. Jan. 13, 2020), reconsideration denied 2020 WL 917057 (S.D.N.Y. Feb. 26, 2020). +After the Second Circuit clarified the standard for unsealing, see +, 929 F.3d 41, Judge Preska +on remand concluded that "only motions actually decided by Judge Sweet [the presiding judge] +along with documents relevant to Judge Sweet's decisions on those motions are properly +considered judicial documents to which a presumption of public access attaches." +WL 133570, at *1. The reason for that is obvious: "[w]ith respect to motions left undecided... +there was never, and now never can be, a judicial decision-making process that would trigger the +public's right to access the undecided motions and the documents relevant to them." Id. at *2. + + +Case 1:22-cv-10904-JSR Document 355 Filed 03/12/24 Page 3 of 5 +& CONNOLLYu* +Page 3 +Although the Times cites to | +, it ignores the part of the case that precisely describes the +inquiry applicable to the three exhibits whose confidentiality Mr. Staley asks this Court to protect. +Regarding the summary judgment exhibits, the Times merely states that "[d]ocuments +submitted to a court for its consideration in a summary judgment motion are - as a matter of law - +judicial documents to which a strong presumption of access attaches, under both the common law +and the First Amendment." Mot. 3, 5 (quoting Lugosch v. Pyramid Co. of Onondaga, 435 F.3d +110, 121 (2d Cir. 2006)). As support for that proposition, the Times cites the Second Circuit's +decision in Lugosch. But Lugosch dealt with an ongoing case where the summary judgment +motion was still pending. Thus, the motions for summary judgment at issue there—which had +been contested and pending for over a year—likely would be ruled on by the district court, thereby +providing a judicial adjudication that would incorporate the documents and be subject to public +scrutiny. See id. at 121 (explaining that the summary judgment ruling would be "an adjudication +[which is] a formal act of government, the basis of which should, absent exceptional +circumstances, be subject to public scrutiny" (citation omitted)). And the Second Circuit grounded +its ruling in the prejudice posed by the "long delays in adjudication" that the public deserved to +assess in real-time. Id. at 127. Not so here, since the Doe and USVI cases are closed without any +decision on the associated motions. The +court distinguished Lugosch on this same basis, +explaining that Lugosch "involved the unsealing of materials relevant to a pending motion for +summary judgment in active litigation, not motions that were rendered moot by settlement of a +case." 2020 WL 133570, at *3 n.3.? +The fact that the three exhibits at issue here are not judicial documents is enough on its +own to deny the Times's request. But even if they were judicial records, unsealing would be +inappropriate under either the common law or First Amendment. The Court must balance the +public's perceived benefits with the "countervailing factors," including the privacy interests of +those resisting disclosure and innocent third parties. See Amodeo II, 71 F.3d at 1050; see also +Matter of New York Times Co., 828 F.2d 110, 116 (2d Cir. 1987) ("Certainly, the privacy interests +of innocent third parties as well as those of defendants that may be harmed by disclosure of ... +material should weigh heavily in a court's balancing."). In addition: +2 More recent Second Circuit case law further confirms that documents become judicial documents +only when they are tied to an actual judicial ruling. For example, in Olson v. Major League +Baseball, the court reinforced that the "mere filing of" a document did not make it a judicial +document; rather, the document at issue in that case was a judicial document because it "was +explicitly considered and rejected by the district court in its Memorandum Order." 29 F.4th 59, +89 (2d Cir. 2022) (emphasis added). Such language would be unnecessary if documents merely +attached to motions qualified as judicial documents. See id. (explaining that "access to" judicial +material "assists the public in evaluating the merits of the court's decision" (emphasis added)). +The Second Circuit likewise clarified in Trump v. Deutsche Bank AG, that assessing "court action" +drives the judicial-document determination. If a document is neither "relevant to any issue [that +the Court] need[s] to decide ... nor a record of any court action," then "it is not a "judicial +document.'" 940 F.3d at 151-52. The case law is thus clear: Where there is no associated past or +pending "court action" to scrutinize, there are no judicial documents. + + +Case 1:22-cv-10904-JSR Document 355 Filed 03/12/24 Page 4 of 5 +& CONNOLLY LEF +Page 4 +In determining the weight to be accorded an assertion of a right of privacy, courts +should first consider the degree to which the subject matter is traditionally +considered private rather than public... The nature and degree of injury must also +be weighed. This will entail consideration not only of the sensitivity of the +information and the subject but also of how the person seeking access intends to +use the information... The court should consider the reliability of the information. +Raw, unverified information should not be as readily disclosed as matters that are +verified.. +.. Similarly, a court may consider whether the nature of the materials is +such that there is a fair opportunity for the subject to respond to any accusations +contained therein. +Amodeo II, 71 F.3d at 1051. +These factors weigh against disclosure. Mr. Staley's interest in keeping Doe's false and +untested testimony confidential is immense. +The Second Circuit has recognized that "[r]aw, +unverified information should not be as readily disclosed as matters that are verified." Id. Other +courts have routinely cited the untested nature of accusations against even convicted criminal +defendants as a basis to keep them sealed from the public. See, e.g., United States v. Corbitt, 879 +F.2d 224, 231 (7th Cir. 1989) (applying common law and First Amendment tests and justifying +continued sealing of convicted felon's presentence report in part because "the defendant does not +have the right to challenge "evaluations'... contained in the report; thus, some of the most +subjective, and potentially embarrassing or inflammatory, material in the report is immune to +challenge");? United States v. Charmer Indus., Inc., 711 F.2d 1164, 1175 (2d Cir. 1983) +(explaining that "frailties" of material appearing in presentence reports and grand jury testimony, +including lack of cross-examination and untested accusations, justified not unsealing reports). +Amodeo II highlights this very concern. There the Second Circuit considered a sealed +investigative report into allegations of corruption at a national union that contained "various +accusations" about a prominent lawyer turned politician, Harold Ickes. Amodeo II, 71 F.3d at +1047. The Court reversed the district court's unsealing order as an abuse of discretion. Id. at 1053. +Among other complications, the identities of the "sources and of Ickes' accusers [were] redacted" +in the report, and unsealing "would circulate accusations that cannot be tested by the interested +public because the sources and much of the subject matter" were obscured. Id. at 1052. Similarly, +with Doe's name redacted but other salacious details of her false allegations revealed, Mr. Staley +would not have a "fair opportunity ... to respond to any accusations contained" in the unsealed +documents especially with these cases now closed. Id. at 1051. Continued sealing is entirely +appropriate for inflammatory accusations from a publicly anonymous witness that has never had +her allegations tested in court or been subjected to any examination by Mr. Staley's counsel. +3 Id. ("[T]here is a strong possibility that the report will contain material which is untrustworthy +or simply incorrect, or which the defendant has not been given a full opportunity to rebut," and +"It]his consideration, together with the certainty that the report will contain much highly personal, +though accurate, information, counsels against disclosure of presentence reports to third parties, +especially where the defendant objects."). + + +Case 1:22-cv-10904-JSR Document 355 Filed 03/12/24 Page 5 of 5 +& CONNOLLYLF° +Page 5 +The Times's contrary invocations of the "public interest" are unpersuasive. To start, the +public's general interest in class action litigation does not apply to the three exhibits at issue here, +as the Doe class settled with JPMorgan before motions for summary judgment were filed. Nor are +these particular submissions because the case settled before the Court decided the relevant +motions. See supra. Otherwise, the Times largely relies on vague references to "transparency" +and contributing to greater public "understanding" of Jeffrey Epstein's misdeeds that do not +approach any well-defined public interest, let alone a "compelling" one that overcomes Mr. +Staley's interest in confidentiality. +To be sure, Mr. Staley recognizes that there is some public interest in understanding +Epstein's criminal activities. But even if that interest outweighed Mr. Staley's privacy concerns +(it does not), the unverified, untested testimony of Jane Doe in the exhibits at issue is hardly a +unique font of information on this subject. And even intense public interest does not suspend the +normal rules for determining what constitutes judicial records or negate the interests of affected +parties such as Mr. Staley. See L +1. 2020 WL 133570, at *3 (maintaining sealing despite same +public interest); Amodeo II, 71 F.3d at 1052-53 (maintaining sealing over part of report despite +public interest in corruption investigation into then-Deputy Chief of Staff to President Clinton); +Corbitt, 879 F.2d at 230 (enforcing judicial-document inquiry for presentence report of police +chief convicted of bribery and extortion). Moreover, the risk is too great that "[e]ven ordinarily +critical readers may take the reference to 'court papers' as some sort of marker of reliability" for +allegations that have never been tested in any court and denied by Mr. Staley. +1, 929 F.3d at +Avoiding the promotion of public scandal through unproven (and we say slanderous) +accusations contained in judicial filings is "not only within a district court's power, but also among +its responsibilities." Id. at 51. +For the foregoing reasons, Mr. Staley asks the Court to deny in part the motions of nonparty +The New York Times Company. +Respectfully submitted, +Is/ Stephen L. Wohlgemuth +Stephen L. Wohlgemuth +4 See, e.g., Priscilla DeGregory & Emily Crane, Epstein Accuser Claims Pedophile Had Sex +Tapes of Trump, Clinton, Prince Andrew and Richard Branson: New Docs, NY Post (Jan. 8, +2024), https://nypost.com/2024/01/08/news/new-batch-of-jeffrey-epstein-court-documents-arereleased. \ No newline at end of file diff --git a/vision-fixhub/court-05/691372f5e730b62bffaf352efaeaa56974871eb8506115a679c48913c1857bdc.receipt.json b/vision-fixhub/court-05/691372f5e730b62bffaf352efaeaa56974871eb8506115a679c48913c1857bdc.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..aebf38e550b17ab87fab8b8577ee7002abc148a7 --- /dev/null +++ b/vision-fixhub/court-05/691372f5e730b62bffaf352efaeaa56974871eb8506115a679c48913c1857bdc.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -138, + "dataset": "marble-joined", + "doc_id": "691372f5e730b62bffaf352efaeaa56974871eb8506115a679c48913c1857bdc", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "471c24b0f948a6dae001b2f7864972febb38161749839cabc89e4ba95e17861c", + "output_sha256": "8f17b08eebceebcca871e0de1db33855ac4218f89a056e99d275ac163814a5b8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/695a28b9aa9c2b89bf108d89c440a0899ea856d8d721014466a01167fd806e7f.md b/vision-fixhub/court-05/695a28b9aa9c2b89bf108d89c440a0899ea856d8d721014466a01167fd806e7f.md new file mode 100644 index 0000000000000000000000000000000000000000..bb09e65d768b704ca4db43f74949ff631be5f1da --- /dev/null +++ b/vision-fixhub/court-05/695a28b9aa9c2b89bf108d89c440a0899ea856d8d721014466a01167fd806e7f.md @@ -0,0 +1,19 @@ +Supreme Court of California +JORGE E. NAVARRETE +Clerk and Executice Officer of the Sapreme Court +CERTIFICATE OF THE CLERK OF THE SUPREME COURT +OF THE +STATE OF CALIFORNIA +MICHAEL BAYERL +1, JORGE E. NAVARRETE, Clerk/Executive Officer of the Supreme Court of the State of +California, do hereby certify that +MICHAEL BAYERL, #330085, was on the +17th day of January 2020 duly admitted to practice as an attorney and counselor at law +in all the courts of this state, and is now listed on the Roll of Attorneys as a member of +the bar of this state in good standing. +Witness my hand and the seal of the court +on the 30th day of June 2023. +JORGE E. NAVARRETE +Clerk/Executive Officer of the Supreme Court +By:_ +Deputy Clerk diff --git a/vision-fixhub/court-05/695a28b9aa9c2b89bf108d89c440a0899ea856d8d721014466a01167fd806e7f.receipt.json b/vision-fixhub/court-05/695a28b9aa9c2b89bf108d89c440a0899ea856d8d721014466a01167fd806e7f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d77234e88c3b8fca535420e3267df7575821c2e5 --- /dev/null +++ b/vision-fixhub/court-05/695a28b9aa9c2b89bf108d89c440a0899ea856d8d721014466a01167fd806e7f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "695a28b9aa9c2b89bf108d89c440a0899ea856d8d721014466a01167fd806e7f", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "b00cb6aa0ac493cf717abeaf1fd3b5de7748fd07235dfb1a16247a065d325607", + "output_sha256": "aa720166f50e0c06d3d83ae0351bc5520d310c4844a019ffc2405e6b6d1d3611", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6965296a2c499f59b831dfa3d52c0d44849423efcd4d0ae7b82f1b2c54ae0fae.md b/vision-fixhub/court-05/6965296a2c499f59b831dfa3d52c0d44849423efcd4d0ae7b82f1b2c54ae0fae.md new file mode 100644 index 0000000000000000000000000000000000000000..49b918081bd2c8a792fd7636d81b4150f19805ff --- /dev/null +++ b/vision-fixhub/court-05/6965296a2c499f59b831dfa3d52c0d44849423efcd4d0ae7b82f1b2c54ae0fae.md @@ -0,0 +1,146 @@ +Case 1:19-cr-00830-AT +Document 59 +Filed 05/2 9 0 88; 05 +DOCUMENT +ELECTRONICALLY FILED +DOC#: +DATE FILED: 5/25/2021 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +United States of America +v. +Deferred Prosecution Agreement +19 Cr. 830 (AT) +Tova Noel, +Defendant. +TO: TOVA NOEL +On November 19, 2019, a grand jury sitting in this District returned a six-count indictment +(the "Indictment"), which charged Tova Noel ("you") with committing offenses against the United +States, to wit, conspiring to knowingly defraud the United States and to knowingly make and use +a false writing or document, in violation of 18 U.S.C. § 371, and five counts of knowingly making +and using a false writing or document, in violation of 18 U.S.C. § 100l. However, after a thorough +investigation, and based on the facts of this case and your personal circumstances, the U.S. +Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined that +the interests of justice will best be served by deferring prosecution in this District. Upon your +acceptance of responsibility for your behavior and by your signature on this deferred prosecution +agreement (the "Agreement"), prosecution will be deferred during the term of your behavior and +satisfactory compliance with the terms of this Agreement for the period of six months from the +date of this Agreement. +The terms and conditions constituting your good behavior and satisfactory compliance are +as follows: +(1) You shall refrain from violating any federal, state, or local law. You shall immediately +contact your U.S. Pretrial Services Officer if arrested or questioned by a lawenforcement officer. +You shall associate only with law-abiding persons. +(2) +(3) +(4) +Officer prior to any work or school changes. +You shall not leave the contiguous United States without permission of your +- 1- + + +Filed 05/25/21 Page 2 of 5 +(5) You shall notify your supervising U.S. Pretrial Services Officer immediately of any +change in your place of residence. +(6) You shall follow your supervising U.S. Pretrial Services Officer's instructions and +advice. +(7) You shall report to your supervising U.S. Pretrial Services Officer as directed. +As a further condition you hereby consent to disclosure, by any federal, state, or local +government agency, or by any medical or substance abuse treatment provider, to the U.S. Pretrial +Services Officer supervising your case, of such medical and treatment records as may be requested +by the Pretrial Services Officer to evaluate deferral of prosecution in this case. You further agree +that you will execute any additional consent forms that any such agency or provider may require +to release such information. +Special conditions are as follows: +You shall truthfully and completely disclose all information with respect to the activities +of yourself and others related to your employment by the Bureau of Prisons ("BOP"), which +information can be used for any purpose. You shall agree to meet with and be interviewed by the +USAO-SDNY, the Federal Bureau of Investigation, the Department of Justice, Office of the +Inspector General ("DOJ-OIG"), and any other law enforcement agency designated by this Office. +You shall complete 100 documented hours of community service, preferably related to the +criminal justice system, including working with recently released inmates. The specific type of +community service to be performed must be approved by your Pretrial Services Officer. +The USAO-SDNY may at any time revoke or modify any condition of this provisional +release or change the period of such supervision, which shall in no case exceed six months. The +USAO-SDNY may discharge you from supervision at any time. The USAO-SDNY may at any +time proceed with the prosecution for this offense should the USAO-SDNY, in its sole discretion, +deem such action advisable. +If upon completion of your supervision a written report from your supervising U.S. Pretrial +Services Officer is received to the effect that you have complied with all the rules, regulations and +conditions and special conditions applicable to your deferred prosecution, no further prosecution +will be instituted in this District for the above offenses. +Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from +taked any drits aleged inion gaintent, the tacts denied on theirs or of investigatin, +that led to the Indictment, or your own statements to the DOJ-OIG or any other law enforcement +entity. Nothing in this Agreement shall be interpreted to require the BOP or the DOJ-OIG to delay +- 2 - + + +Filed 05/25/21 Page 3 of 5 +any administrative action until after the expiration of the period of deferment contemplated by this +Agreement. You agree that a copy of this Agreement, including your admission and acceptance +of responsibility, shall be provided to the BOP. +* +If you successfully complete the term of supervision and fulfills all the terms and +conditions of this Agreement, the Government will move the Court to dismiss the Indictment as to +the defendant. +It is further understood that this Agreement and the terms and conditions set forth herein +are limited to the facts and circumstances of this case and lack precedential value. +Dated: New York, New York +May 20, 2021 +AUDREY STRUASS +United States Attorney for the +Southern District of New York +By: Jensen Lmergan +Nicolas Roos +Jessica Lonergan +Assistant United States Attorneys +Tel.: 212-637-2421 / 1038 +- 3- + + +Case 1:19-cr-00830-AT Document 59 Filed 05/25/21 Page 4 of 5 +The undersigned hereby consents to the foregoing. The undersigned hereby further admits +that she willfully and knowingly completed materially false count and round slips regarding +required counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center +("MCC") on August 9, 2019 and August 10, 2019. The undersigned expressly waives any and all +rights to a speedy trial pursuant to the Sixth Amendment to the United States Constitution, the +Speedy Trial Act, §5 3161 el seq., and any other pertinent provisions, and consents to the +adjournment of all pending proceedings in this case. The undersigned further waives the +applicable statute of limitations with respect to any prosecution that is not time-barred on the date +that this agreement is signed. It is the intent of this provision to toll the applicable statute of +limitations during the pendency of the deferred prosecution. +The undersigned understands that pursuant to Title 18, United States Code, Section +3161(h)(2), this Agreement is subject to approval by the Court. Should the Court refuse to +approve, and thereby reject, this Agreement, neither party shall be bound to any term of this +Agreement, and no admissions in this Agreement may be used against the undersigned. +Finally, the undersigned acknowledges that she has read this Agreement and has carefully +reviewed each provision with her attorney. The undersigned and her attorney acknowledge that +no threats, promises, or representations have been made, nor agreements reached, other than those +set forth in this Agreement. The undersigned further acknowledges that she understands and +voluntarily accepts each and every term and condition of this Agreement. +Dated: New York, New York +May 20, 2021 +Lattin +Attorhey for Defenda +e +Tova Noel +Defendant +- 4- + + +Filed 05/25/21 Page 5 of 5 +Pursuant to 18 U.S.C. §3161(h)(2), exclusion under the Speedy Trial Act of the period of +time during which the prosecution of the defendant is deferred pursuant to this Agreement is +hereby approved. +Dated: New York, New York +May 25,2021 +Honorable Analisa +United States District Judge +The undersigned hereby consents to the foregoing and will accept supervision of the +above-named defendant on the conditions set forth herein. +Dated: New York, New York +May 24, 2021 +oksm +Ented states Pretrial Services Onicer +- 5- \ No newline at end of file diff --git a/vision-fixhub/court-05/6965296a2c499f59b831dfa3d52c0d44849423efcd4d0ae7b82f1b2c54ae0fae.receipt.json b/vision-fixhub/court-05/6965296a2c499f59b831dfa3d52c0d44849423efcd4d0ae7b82f1b2c54ae0fae.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b5dcbd19af4f8590216dcab908151cf9345d72f3 --- /dev/null +++ b/vision-fixhub/court-05/6965296a2c499f59b831dfa3d52c0d44849423efcd4d0ae7b82f1b2c54ae0fae.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -165, + "dataset": "marble-joined", + "doc_id": "6965296a2c499f59b831dfa3d52c0d44849423efcd4d0ae7b82f1b2c54ae0fae", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "81a760422f9502ae879c8c301fa0f344f7f2f2f6e55b301df086e4e5d1df4cbc", + "output_sha256": "b197eadc1ca07cd925699ef5bc27c4d646151fa2612f77f5b33783b868a2fb57", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6968ebbb7861fc31d8d14cba7b0010a77cc4fc91c211c27882128dbe2534332a.md b/vision-fixhub/court-05/6968ebbb7861fc31d8d14cba7b0010a77cc4fc91c211c27882128dbe2534332a.md new file mode 100644 index 0000000000000000000000000000000000000000..0e99450d82917c8469960e8d6d023a8da126f8dc --- /dev/null +++ b/vision-fixhub/court-05/6968ebbb7861fc31d8d14cba7b0010a77cc4fc91c211c27882128dbe2534332a.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 226-12 Filed 07/24/23 + + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6968ebbb7861fc31d8d14cba7b0010a77cc4fc91c211c27882128dbe2534332a.receipt.json b/vision-fixhub/court-05/6968ebbb7861fc31d8d14cba7b0010a77cc4fc91c211c27882128dbe2534332a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..519efae8a7a280696beb3d58daed9293d3f04e06 --- /dev/null +++ b/vision-fixhub/court-05/6968ebbb7861fc31d8d14cba7b0010a77cc4fc91c211c27882128dbe2534332a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "6968ebbb7861fc31d8d14cba7b0010a77cc4fc91c211c27882128dbe2534332a", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "9b88e40cdf3373b7b281d26e29a2ec56a9c99c19dd1a52d89b0c0fce7a43fd6f", + "output_sha256": "81fe06fedc4ed6e8626e40a6ccb5c7da6826af812354013480506a1fa263aa52", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/696a860896c940712cf092dddaa38f416d13d9c22a3354ac742fb7cc60386b36.md b/vision-fixhub/court-05/696a860896c940712cf092dddaa38f416d13d9c22a3354ac742fb7cc60386b36.md new file mode 100644 index 0000000000000000000000000000000000000000..2b84105a512f5fe80bb16d8978e822b64a4ede59 --- /dev/null +++ b/vision-fixhub/court-05/696a860896c940712cf092dddaa38f416d13d9c22a3354ac742fb7cc60386b36.md @@ -0,0 +1,45 @@ +Case 1:22-cv-10904-JSR Document 99-3 Filed 03/27/23 Page 1 of 2 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-cv-10904-JSR +[PROPOSED] ORDER +GRANTING MOTION FOR +ADMISSION PRO HAC VICE +JPMORGAN CHASE BANK, N.A., +Defendant / +Third-Party Plaintiff +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +V. +JAMES EDWARD STALEY, +Third-Party Defendant. +The motion of Stephen Wohlgemuth for admission to practice pro hac vice in the abovecaptioned action is GRANTED. Applicant has declared that he is a member in good standing of +the bars of the District of Columbia and New York and that his contact information is as follows: +Applicant's Name: +Stephen Wohlgemuth +Firm Name: +Address: +& Connolly LLP +680 Maine Avenue, S.W. +City/State/Zip: +Telephone/Fax: +Email: +Washington, D.C. 20024 +(202) 434-5390 / (202) 434-5029 +SWohlgemuth@wc.com + + +Case 1:22-cv-10904-JSR Document 99-3 Filed 03/27/23 Page 2 of 2 +Applicant having requested admission pro hac vice to appear for all purposes as counsel +for Third-Party Defendant James Edward Staley in the above-captioned action; +IT IS HEREBY ORDERED that Applicant Stephen Wohlgemuth is admitted to practice +pro hac vice in the above-captioned action in the United States District Court for the Southern +District of New York. All attorneys appearing before this Court are subject to the Local Rules of +this Court, including the Rules governing discipline of attorneys. +Dated:. +Honorable Jed S. Rakoff +United States District Judge diff --git a/vision-fixhub/court-05/696a860896c940712cf092dddaa38f416d13d9c22a3354ac742fb7cc60386b36.receipt.json b/vision-fixhub/court-05/696a860896c940712cf092dddaa38f416d13d9c22a3354ac742fb7cc60386b36.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6f18666540e48ade05878a277be65806c757a494 --- /dev/null +++ b/vision-fixhub/court-05/696a860896c940712cf092dddaa38f416d13d9c22a3354ac742fb7cc60386b36.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "696a860896c940712cf092dddaa38f416d13d9c22a3354ac742fb7cc60386b36", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "fe148f908480ca8cdf21fb2e68946325d6143461e08382c434f3e09570373197", + "output_sha256": "25c3936b8b042e9c08945d2e00eff10cd55f5ac56292a9c4c2465540c015e514", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/69845d77c37a6fca0c208c01d8abd360a8bc29596bdba2c70128524a7295d1d0.md b/vision-fixhub/court-05/69845d77c37a6fca0c208c01d8abd360a8bc29596bdba2c70128524a7295d1d0.md new file mode 100644 index 0000000000000000000000000000000000000000..a010658da36a3c5a7ae196625099265a69103886 --- /dev/null +++ b/vision-fixhub/court-05/69845d77c37a6fca0c208c01d8abd360a8bc29596bdba2c70128524a7295d1d0.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 240-9 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/69845d77c37a6fca0c208c01d8abd360a8bc29596bdba2c70128524a7295d1d0.receipt.json b/vision-fixhub/court-05/69845d77c37a6fca0c208c01d8abd360a8bc29596bdba2c70128524a7295d1d0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8be841f36953288b50c43ffed7dbfe26fc59bca4 --- /dev/null +++ b/vision-fixhub/court-05/69845d77c37a6fca0c208c01d8abd360a8bc29596bdba2c70128524a7295d1d0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "69845d77c37a6fca0c208c01d8abd360a8bc29596bdba2c70128524a7295d1d0", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "ae946388965d3e6c0b85df8bb224c67805c5433027630f8fdd106e6aa1fb35f0", + "output_sha256": "20b4fa5abe082150897267f234feed5e3b084ff783ab57c517e6ff6a1149c280", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/698b2933219a51245fb8e0a953b44d2fefae9ad197da552aeb4e14e6d03d2184.md b/vision-fixhub/court-05/698b2933219a51245fb8e0a953b44d2fefae9ad197da552aeb4e14e6d03d2184.md new file mode 100644 index 0000000000000000000000000000000000000000..ce8ae018ba60ab2876fbfa466d7e5eaa38dc25a7 --- /dev/null +++ b/vision-fixhub/court-05/698b2933219a51245fb8e0a953b44d2fefae9ad197da552aeb4e14e6d03d2184.md @@ -0,0 +1,139 @@ +Case 1:22-cV-10904-JSR Document 186-52 Filed 06/14/23 Page 1 of 6 + + + +Case 1:22-cV-10904-JSR Document 186-52 Filed 06/14/23 Page 2 of 6 +Date: +From: +To: +Wednesday. May 15 2013 10:58 AM +Subject: Re: Quick response re: TOEFL +Cecile de Jongh < +@yahoo.com> +Jeffrey Epstein : +Ok. We should put them on the list for the fall semester. +With warm regards, +Cecile +Sent from my iPhone +On May 15, 2013, at 6:49 AM, Jeffrey Epstein wrote: +IF it worked both +and +would sign up, +currently has a fl and studies english in ny +On Tue, May 14, 2013 at 10:32 PM, Cecile de Jongh +FYI below. +With warm regards, +Cecile +Sent from my iPhone +Begin forwarded message: +@yahoo.com > wrote: +From: Dionne + +Date: May 14, 2013, 9:57:40 PM GMI-04:00 +To: Cecile de Jongh < +@yahoo.com> +Subject: Re: Quick response re: TOEFL +Hi Cecile, +Here's what I was able to find out: +Because of low enrollment, the ESL class isn't offered every semester. +Professor Violetta Donavon keeps a list of names and when the list grows to ten, they offer the +course. They hope to offer it next semester. In the interim, there are English skills courses that +could help. +Here is Professor Donavon's contact information: +340-693-1049 +vdonova@livc.uvi.edu +Here is a direct link to our course catalog: +www.uvi.edu/sites/uvi/Pages/Academics- Catalog and Graduate_Bulletin.aspx + +ESTATE_JPM024114 + + +Case 1:22-cv-10904-JSR Document 186-52 Filed 06/14/23 Page 3 of 6 +I emailed Professor Donavon to let her know you might reach out to her with questions. +Please let me know ifl may be of further assistance. +My best, +Dionne +Sent from an undisclosed location via my iPad +On May 14, 2013, at 10:01 AM, "Cecile de Jongh" +@yahoo.com > wrote: +Thanks Dionne! +With warm regards, +Cecile +Sent from my iPhone +On May 13, 2013, at 5:33 PM, Dionne + wrote: +Hi Cecile, +Left a few messages and am waiting to hear back. Here's to tomorrow! +My best, +Dionne +From: Cecile de Jongh [mailto: +Sent: Monday, May 13, 20135:20 PM +To: Dionne +Subject: Re: Quick response re: TOEFL +@yahoo.com] + +ESTATE_JPM024115 + + +Case 1:22-cV-10904-JSR Document 186-52 Filed 06/14/23 Page 4 of 6 +Thank Dionne. Does UVI have ESL classes? +With warm regards, +Cecile +DISCLAIMER: The information contained in this e-mail may be +privileged, confidential, and protected from disclosure. If you are not the intended +recipient, you are hereby notified that any dissemination, distribution or duplication +of this communication is strictly prohibited. If you have received this communication +in error, please notify the sender immediately and delete all copies. +"Nearly all men can stand adversity, but if you want to test a man's character, give him power." - +Lincoln +* Please consider the environment before printing this e-mail. + +ESTATE_JPM024116 + + +Case 1:22-cV-10904-JSR Document 186-52 Filed 06/14/23 Page 5 of 6 +From: Dionne +To: Cecile de Jongh • +Sent: Monday, May 13, 2013 5:10PM +Subject: Quick response re: TOEFL +I +@yahoo.com> +Hi Cecile, +Just wanted to let you know quickly that UVI is listed as a test center on St. +I will let you know the exact office to contact tomorrow. +My best, +Dionne V. +Dionne V. +Vice-President for Institutional Advancement & +Executive Director, Foundation for Reichhold Center for the Arts +University of the Virgin Islands +#2 John +Bay +St. +USVI 00802 + +ESTATE_JPM024117 + + +Case 1:22-cV-10904-JSR Document 186-52 Filed 06/14/23 Page 6 of 6 +p: 340-693-1040 +m: 340-514-7480 +f: 340-693-1015 +e: djackso @uvi.edu +w: http://www.uvi.edu/ +****#* +#H.......****T:: +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved + +ESTATE_JPM024118 diff --git a/vision-fixhub/court-05/698b2933219a51245fb8e0a953b44d2fefae9ad197da552aeb4e14e6d03d2184.receipt.json b/vision-fixhub/court-05/698b2933219a51245fb8e0a953b44d2fefae9ad197da552aeb4e14e6d03d2184.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e744024a59afd554ce05a47654204c9422472d37 --- /dev/null +++ b/vision-fixhub/court-05/698b2933219a51245fb8e0a953b44d2fefae9ad197da552aeb4e14e6d03d2184.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -142, + "dataset": "marble-joined", + "doc_id": "698b2933219a51245fb8e0a953b44d2fefae9ad197da552aeb4e14e6d03d2184", + "engine": "marble-apple-vision", + "event_count": 12, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "4834952f7ac96c0e4c0fdebb8a27606ec565f6e21cb81c01e702244796fff7cb", + "output_sha256": "2a269fe7504370a7b2a4f208841930a11dde60eb43a0ab5aaaf1df71fa9f45bb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/698d9c3960dd42629b00a90e571bc6e5f4dc798f2cfa168d2c01497ab3a56b58.md b/vision-fixhub/court-05/698d9c3960dd42629b00a90e571bc6e5f4dc798f2cfa168d2c01497ab3a56b58.md new file mode 100644 index 0000000000000000000000000000000000000000..89900d96cbade60229d372fb48ceb6bdeb89b146 --- /dev/null +++ b/vision-fixhub/court-05/698d9c3960dd42629b00a90e571bc6e5f4dc798f2cfa168d2c01497ab3a56b58.md @@ -0,0 +1,23 @@ +Case 1:22-cv-10904-JSR Document 226-32 Filed 07/24/23 + + + + +Case 1:22-cv-10904-JSR Document 226-32 Filed 07/24/23 Page 2 of 2 +From: +Sent: +To: +Subject: +Mary E Erdoes [mary.erdoes@jpmorgan.com] +7/31/2010 4:10:35 PM +Jes Staley [jes.staley@jpmorgan.com] +Re: +The feds may not be quite done with (JE). +Having just completed 13 months in a fl jail for solicing + +----- original Message +From: Jes Staley +To: Mary E Erdoes +Sent: Sat Jul 31 11:06:43 2010 +Subject: +what's in the Post, it was soild out here. diff --git a/vision-fixhub/court-05/698d9c3960dd42629b00a90e571bc6e5f4dc798f2cfa168d2c01497ab3a56b58.receipt.json b/vision-fixhub/court-05/698d9c3960dd42629b00a90e571bc6e5f4dc798f2cfa168d2c01497ab3a56b58.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..08d034bc49d09ea0962ff49a04df7effadd96aa1 --- /dev/null +++ b/vision-fixhub/court-05/698d9c3960dd42629b00a90e571bc6e5f4dc798f2cfa168d2c01497ab3a56b58.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -52, + "dataset": "marble-joined", + "doc_id": "698d9c3960dd42629b00a90e571bc6e5f4dc798f2cfa168d2c01497ab3a56b58", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "8e8714189cd65ab992b02c7dd7811784bc9843972f9332c996e7757512e6ee83", + "output_sha256": "0cc039ba4729f4855a17e2b088e55a7afdc94ade69d456087fef3c6782add286", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/699ce7a9a5adfaa0ba49321d9846c54ef59e6b5842b58926ec3b35d75f889b76.md b/vision-fixhub/court-05/699ce7a9a5adfaa0ba49321d9846c54ef59e6b5842b58926ec3b35d75f889b76.md new file mode 100644 index 0000000000000000000000000000000000000000..e009fdd5d28958b668a9970e08277251b6ccab32 --- /dev/null +++ b/vision-fixhub/court-05/699ce7a9a5adfaa0ba49321d9846c54ef59e6b5842b58926ec3b35d75f889b76.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 268-63 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/699ce7a9a5adfaa0ba49321d9846c54ef59e6b5842b58926ec3b35d75f889b76.receipt.json b/vision-fixhub/court-05/699ce7a9a5adfaa0ba49321d9846c54ef59e6b5842b58926ec3b35d75f889b76.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..614363c89dd6988a3a722361e8ec12439507b3db --- /dev/null +++ b/vision-fixhub/court-05/699ce7a9a5adfaa0ba49321d9846c54ef59e6b5842b58926ec3b35d75f889b76.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "699ce7a9a5adfaa0ba49321d9846c54ef59e6b5842b58926ec3b35d75f889b76", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "5c78f07effbda1f7600cf04db4b16a44042c523041fe4afb0f8af0db44edf5aa", + "output_sha256": "948546777c0967b84b5093e884235b6b135db308605622dd845cefdcd4501ee1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/699e5d1ecde336834151c068adb00912e732181dd4f68586f5b1f3bef2e8510e.md b/vision-fixhub/court-05/699e5d1ecde336834151c068adb00912e732181dd4f68586f5b1f3bef2e8510e.md new file mode 100644 index 0000000000000000000000000000000000000000..f96ee3f25a07dc5b840818eb8d85016840a0c765 --- /dev/null +++ b/vision-fixhub/court-05/699e5d1ecde336834151c068adb00912e732181dd4f68586f5b1f3bef2e8510e.md @@ -0,0 +1,55 @@ +IH-32 +Rev: 2014-1 +United States District Court +Southern District of New York +Related Case Statement +Full Caption of Later Filed Case: +Government of the United States Virgin +Islands +Plaintiff +VS. +JPMorgan Chase Bank, N.A. +Case Number +1:22-CV-10904-UA +Defendant +Full Caption of Earlier Filed Case: +(including in bankruptcy appeals the relevant adversary proceeding) +Jane Doe 1, individually and on behalf of +all other similarly situated +Plaintiff +Case Number +1:22-CV-10019 +JP| +VS. +Chase & Co. +Defendant +Page 1 + + +IH-32 +Rev: 2014-1 +Status of Earlier Filed Case: +(If so, set forth the procedure which resulted in closure, e.g., voluntary +Closed +dismissal, settlement, court decision. Also, state whether there is an appea +pending.) +Open +(If so, set forth procedural status and summarize any court rulings.) +The earlier filed case was filed on November 24, 2022. +Explain in detail the reasons for your position that the newly filed case is related to the +earlier filed case. +Pursuant to Local Civil Rule 1.6(a), the Government of the United States Virgin Islands +believes that this action is related to Doe 1 v. JP +Chase & Co., No. 1:22-cv-10019 +(S.D.N.Y +. Nov. 24, 2022), because both actions arise from the same nucleus of operative +facts and conduct involving Defendant JP +| alleged facilitation of Epstein's sextrafficking venture. +Signature: +T.d I. Ackerman/ mmB +Motley Rice, LLC, counsel for Plaihtiff, +Government of the United States Virgin Islands +Date: +12/20/22 +Firm: +Page 2 diff --git a/vision-fixhub/court-05/699e5d1ecde336834151c068adb00912e732181dd4f68586f5b1f3bef2e8510e.receipt.json b/vision-fixhub/court-05/699e5d1ecde336834151c068adb00912e732181dd4f68586f5b1f3bef2e8510e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..92c50adbcad636d72e77436ee906a41ad53302ba --- /dev/null +++ b/vision-fixhub/court-05/699e5d1ecde336834151c068adb00912e732181dd4f68586f5b1f3bef2e8510e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "699e5d1ecde336834151c068adb00912e732181dd4f68586f5b1f3bef2e8510e", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "d3f2773188f81c56ff5c79603db753cbd6e2c669927a710a073358b1c1b72b26", + "output_sha256": "3f0462c504fc28276b6bca41b8e1f5422f42ff0cefa2703d6704f4cbd901b358", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/69b486dcb0b5274779b0eedb37ed98270ff55dc37409667c0e3464f05263a7f1.md b/vision-fixhub/court-05/69b486dcb0b5274779b0eedb37ed98270ff55dc37409667c0e3464f05263a7f1.md new file mode 100644 index 0000000000000000000000000000000000000000..fb7ca9f39fc0d4b07451cdd5b4c3cb0f6807a05c --- /dev/null +++ b/vision-fixhub/court-05/69b486dcb0b5274779b0eedb37ed98270ff55dc37409667c0e3464f05263a7f1.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 237-8 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/69b486dcb0b5274779b0eedb37ed98270ff55dc37409667c0e3464f05263a7f1.receipt.json b/vision-fixhub/court-05/69b486dcb0b5274779b0eedb37ed98270ff55dc37409667c0e3464f05263a7f1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bb78111a419fa4151c4f9c3a823837ca9cb48feb --- /dev/null +++ b/vision-fixhub/court-05/69b486dcb0b5274779b0eedb37ed98270ff55dc37409667c0e3464f05263a7f1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "69b486dcb0b5274779b0eedb37ed98270ff55dc37409667c0e3464f05263a7f1", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "deac78f0a8296ff143f30d5b9757517aa167dc7797db54b0006f71a33be1372d", + "output_sha256": "199039c032744113cc3a2607b3fe9b391764363b8735810839bf09c2a83e6574", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/69b99539e82cc7a8b18ab50542b840400a146d0053f375efe339e1207065217b.md b/vision-fixhub/court-05/69b99539e82cc7a8b18ab50542b840400a146d0053f375efe339e1207065217b.md new file mode 100644 index 0000000000000000000000000000000000000000..1483321247b00a349eae67bea38b2b5d8dcc2dd9 --- /dev/null +++ b/vision-fixhub/court-05/69b99539e82cc7a8b18ab50542b840400a146d0053f375efe339e1207065217b.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 199-3 Filed 06/22/23 Page 1 of 1 + +Filed Under Seal diff --git a/vision-fixhub/court-05/69b99539e82cc7a8b18ab50542b840400a146d0053f375efe339e1207065217b.receipt.json b/vision-fixhub/court-05/69b99539e82cc7a8b18ab50542b840400a146d0053f375efe339e1207065217b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..467561e38171506816103141747a1b2ed61b9ce7 --- /dev/null +++ b/vision-fixhub/court-05/69b99539e82cc7a8b18ab50542b840400a146d0053f375efe339e1207065217b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "69b99539e82cc7a8b18ab50542b840400a146d0053f375efe339e1207065217b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "014994cf8292ce317f017334df7d286b6edca0a93debb725dfff9fc48ed1fa64", + "output_sha256": "bbfec1cc6f9048c030123d864b1df00092dc5e689c1096a0de6b3aa356d7d3f8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/69bbc654f905f073e4940e47f52ed8bbc411a2d2711b9e0ae183e26ff669abdb.md b/vision-fixhub/court-05/69bbc654f905f073e4940e47f52ed8bbc411a2d2711b9e0ae183e26ff669abdb.md new file mode 100644 index 0000000000000000000000000000000000000000..8d1dbc5b90f0500f2eacbebf67669387b18a0956 --- /dev/null +++ b/vision-fixhub/court-05/69bbc654f905f073e4940e47f52ed8bbc411a2d2711b9e0ae183e26ff669abdb.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 226-11 Filed 07/24/23 + + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/69bbc654f905f073e4940e47f52ed8bbc411a2d2711b9e0ae183e26ff669abdb.receipt.json b/vision-fixhub/court-05/69bbc654f905f073e4940e47f52ed8bbc411a2d2711b9e0ae183e26ff669abdb.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7798b81dd4e39c0d023355c89c212e0451b013b7 --- /dev/null +++ b/vision-fixhub/court-05/69bbc654f905f073e4940e47f52ed8bbc411a2d2711b9e0ae183e26ff669abdb.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "69bbc654f905f073e4940e47f52ed8bbc411a2d2711b9e0ae183e26ff669abdb", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "57cd2a7ef5afab3cefe99e2d03d04b024bfc5fa63950821411cbf6fb19a0cd0e", + "output_sha256": "3293e68086a23b35bfc62fe9b79c7b139d389478a9863e01871d9a1ee68e093a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/69fef75b08a30dba52d7f0bca2b58b607f5ffb9ab2647492b85f3ebf2a173e02.md b/vision-fixhub/court-05/69fef75b08a30dba52d7f0bca2b58b607f5ffb9ab2647492b85f3ebf2a173e02.md new file mode 100644 index 0000000000000000000000000000000000000000..42a5c841f3d23666635dae673ef4fb54c30a51de --- /dev/null +++ b/vision-fixhub/court-05/69fef75b08a30dba52d7f0bca2b58b607f5ffb9ab2647492b85f3ebf2a173e02.md @@ -0,0 +1,40 @@ +Case 1:22-cV-10904-JSR Document 186-17 Filed 06/14/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 186-17 Filed 06/14/23 Page 2 of 2 +Date: +Subject: +From: +To: +Wednesday. July 24 2013 08:07 PM +Fwd: Jeffrey Epstein-Contract with Celestino A. +Cecile de Jongh 9 +@yahoo.com> +JEE : +Attachments: Jeffrey Epstein.docx; Untitled attachment 99629.htm +Consulting and Management Firm +Do you want me to send this to Darren as well? +With warm regards, +Cecile +Sent from my iPhone +Begin forwarded message: +From: Rometa Dorsey < +@gmail.com> +Date: July 24, 2013, 3:53:58 PM GMT- 04:00 +To: Cece de Jongh < +@yahoo.com> +Ce: +@myexperiencematters.org +Subject: Jeffrey Epstein-Contract with Celestino A. +Consulting and Management Firm +Mrs. de Jongh: +Please find the contract attached to be presented to Mr. Jeffrey Epstein for the commissioning of services +regarding the island commonly known as Little St. James. Should you have any questions or concerns +please don't hesitate to contact us. Thank you once again for considering Celestino A. +Sr. +Consulting and Manangement Firm... where "Experience Matters." +Sincerely, +Rometa L. Dorsey + +ESTATE_JPM024203 diff --git a/vision-fixhub/court-05/69fef75b08a30dba52d7f0bca2b58b607f5ffb9ab2647492b85f3ebf2a173e02.receipt.json b/vision-fixhub/court-05/69fef75b08a30dba52d7f0bca2b58b607f5ffb9ab2647492b85f3ebf2a173e02.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..65520d9022d81437ed2999376e0eb7e3a069cc48 --- /dev/null +++ b/vision-fixhub/court-05/69fef75b08a30dba52d7f0bca2b58b607f5ffb9ab2647492b85f3ebf2a173e02.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -46, + "dataset": "marble-joined", + "doc_id": "69fef75b08a30dba52d7f0bca2b58b607f5ffb9ab2647492b85f3ebf2a173e02", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "9ac8db7aced36f81155ad8edbd8a016adea4c1e4d9636d54a72be85667dade83", + "output_sha256": "32e2f5b541cf454272fd66b2574d4201f84cc9a0b09c330752aed76e34c08de7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6a08b090cc5935ff5e5637bd66fe1a173cf71a895866570adffa5564cce844d9.md b/vision-fixhub/court-05/6a08b090cc5935ff5e5637bd66fe1a173cf71a895866570adffa5564cce844d9.md new file mode 100644 index 0000000000000000000000000000000000000000..2a072ce679ab2f960a1fc78ddf6f3503e9b90382 --- /dev/null +++ b/vision-fixhub/court-05/6a08b090cc5935ff5e5637bd66fe1a173cf71a895866570adffa5564cce844d9.md @@ -0,0 +1,69 @@ +Case 1:22-cV-10904-JSR Document 158-19 Filed 05/23/23 Page 1 of 4 + + + +Case. le2@3M+ 20004PJSBan Destment vit8glAng File do@ 5h2 BeRratedP agen2| Ofgilislandsdailynews.com +who/article_17b3cbb1-448b-52b4-a19a-d1b62d7f44d6.html +V.L. files lawsuit against JP +in Epstein case while +ignoring local pols who benefited +Feb 14, 2023 +Janelle Sarauw +Dear Editor, +In response to the Office of the Attorney General lawsuit against JP +relative to the estate of +Jeffrey Epstein, lawyers for the financial institution noted the following in their motion, on Feb. 1, +to dismiss: +"Indeed, as a law-enforcement agency, USVI had access to much more, along with the +investigative advantage of physical proximity to Epstein's crimes. USVI did nothing to stop +Epstein during this period, notwithstanding the fact that he registered with the USVI as a Tier 1 +sex offender. To the contrary, during the same period, USVI granted Epstein and his businesses +lucrative privileges and massive tax incentives." +I couldn't agree more. Our government is filing claims against this financial institution while +turning a blind eye to some local officials who may have personally benefited from Mr. Epstein. +Let us put a few facts on the table: The chair of the Economic Development Authority (EDA) must +448b-52b4... 1/3 + + +Case. le2@8M+ 20004PJSBan Destment v58glOng File do@ 5h2 BeRrated ageoB| Ofgilislandsdailynews.com +sign off on all benefit documents. Who was the chair of the EDA at that time? Our present +Governor was. After the chair signs the benefit document, it is forwarded to the governor for his +signature. Who was the governor? Gov. John P. de Jongh Jr. Who was the EDC beneficiary? +Southern Trust Co. owned by Mr. Epstein. And, who managed said company? The former first lady, +Mrs. Cecile de Jongh. +If we are to dive deeper, there appears to be a conflict of interest. How could a governor, whose +wife managed the operations of Southern Trust Co., sign the benefit document without that being +a conflict of interest? By Gov. de Jongh signing such, it gives the appearance that he enriched +himself. +Epstein has contributed to the political campaigns of various senatorial, gubernatorial, and +congressional candidates within the local Democratic Party. His attorney and local base in the +Virgin Islands were the ones holding major fundraisers for the incumbent. Unequivocally, a +political culture was fostered within the local Democratic Party of the Virgin Islands that allowed +Epstein to remain unchecked in exchange for his sponsorship and financial contributions. We +must be honest about this discussion. This background calls into question the true reason Gov. +Bryan fired his Attorney General. Government House has said that Bryan fired| +over +concerns of inaction on local issues at the AG's office. +Bryan, in a recent interview with another publication, confirmed that was part of what led to her +dismissal, while seeking distance from the Epstein saga. +"First and foremost, you know, I can't have an attorney general that's launching civil suits that I +don't know about," the governor said in the article. "I personally, and I'm sure many other Virgin +Islanders alike, don't like our name being associated with Jeffrey Epstein and child pornography. +You know, why are we going down that rabbit hole? And the irony to me was, you know, four years +ago everybody was scrambling not to have been on Jeffrey Epstein's receiving end of donations. +Now we're suing him for the same dirty money. That seems a little awkward, right? I mean, that's +inconsistent. And I just want to get us away from that. That's not the light we want to be seen in. If +we never mention Jeffrey Epstein again, it would be good for me." +Bryan also said that he never met Epstein but acknowledged it was likely that some residents +knew what was going on at Epstein's Little St. James private island estate. +Within our local political arena, we have turned a blind eye to Epstein because we, too, benefited +from his sex-trafficking enterprise. To put it bluntly, the Virgin Islands of the United States aided +and abetted Jeffrey Epstein. That's without question. +- Janelle Sarauw, St. +governor. +, is a former educator, senator and candidate for lieutenant +2/3 + + +Case. ilé2 BrBh+ 2@904PJSBan Desumentwi8gdAng Foile do@5h2 BeReBtedPagy@ort| Ofgifislandsdailynews.com +3/3 \ No newline at end of file diff --git a/vision-fixhub/court-05/6a08b090cc5935ff5e5637bd66fe1a173cf71a895866570adffa5564cce844d9.receipt.json b/vision-fixhub/court-05/6a08b090cc5935ff5e5637bd66fe1a173cf71a895866570adffa5564cce844d9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f0baf39a892d874bf9d44d123a1f028d9bb6f203 --- /dev/null +++ b/vision-fixhub/court-05/6a08b090cc5935ff5e5637bd66fe1a173cf71a895866570adffa5564cce844d9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -113, + "dataset": "marble-joined", + "doc_id": "6a08b090cc5935ff5e5637bd66fe1a173cf71a895866570adffa5564cce844d9", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "d67c145079c353727337a69722582c3d3d61e9606ccd564009f1052b80b9abb8", + "output_sha256": "f43f2c7b2b21192ee0c40381a29ba1fcd5d7c050ef762f31a0d700f751696aff", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6a214fc699470d3050ac2f066a3c9f953f70e1e1f80c7cb9ae9931246e8e405c.md b/vision-fixhub/court-05/6a214fc699470d3050ac2f066a3c9f953f70e1e1f80c7cb9ae9931246e8e405c.md new file mode 100644 index 0000000000000000000000000000000000000000..fea5e794dccb0e066f5d3e5798b65913f6420583 --- /dev/null +++ b/vision-fixhub/court-05/6a214fc699470d3050ac2f066a3c9f953f70e1e1f80c7cb9ae9931246e8e405c.md @@ -0,0 +1,1108 @@ +Case 1:20-cr-00330-PAE | +Document 690 +Filed 11/19/21 Page 1 of 23 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC#:_ +DATE FILED: 11/19/21 +United States of America, +-V- +Ghislaine Maxwell, +Defendant. +20-CR-330 (AJN) +MEMORANDUM +OPINION & ORDER +ALISON J. NATHAN, District Judge: +Before the Court is the Defendant's fourth motion in limine to "exclude evidence related +to Accuser-3," to whom the Court refers as Witness-3, on the grounds that the testimony is not +direct evidence of the charged conspiracies and is inadmissible under Federal Rules of Evidence +404(b) and 403. Dkt. Nos. 387, 444. The Court has twice heard argument related to this motion, +including argument at the November 10, 2021 in camera hearing that was sealed pursuant to +Federal Rule of Evidence 412. See generally Nov. 1, 2021 Transcript; Nov. 10, 2021 Transcript. +At the November 1, 2021 hearing, the Court provided a brief explanation of its current position +based on the information then before it, but the Court ultimately reserved ruling pending +additional briefing. The Court is now in receipt of the parties' additional briefing and +accordingly is prepared to resolve the motion.' +The Government now proffers that the anticipated testimony of Witness-3 will describe +how she met the Defendant and her relationship with the Defendant and Mr. Epstein. In +particular, Witness-3 is anticipated to testify how Defendant introduced her to Mr. Epstein, how +' This Memorandum Opinion & Order is filed temporarily under seal to permit the parties the opportunity to propose +sealing or limited redactions pursuant to Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006), and +Federal Rule of Evidence 412(c)(2). +1 + + +Case 1:20-cr-00330-PAE Document 690 Filed 11/19/21 Page 2 of 23 +massages progressed to involve sexual activity, and Ms. Maxwell's role in facilitating those +massages. Based on all of the information now before the Court, including a substantially more +detailed proffer by the Government as to the anticipated testimony, see Gov. Supp. Ltr. at 2-3 +(Nov. 5, 2021); see also Dkt. No. 452 at 42-43, the Court concludes that some of the anticipated +testimony may serve as direct evidence of the +Act counts. +The Government rightly acknowledged at the November 1 pretrial conference that Ms. +Maxwell cannot be found guilty on this witness's testimony alone for any of the crimes charged +in the Indictment. Nov. 1, 2021 Tr. at 67:12-25, 68:13-19, 69:4-9, 70:23-71:2, 72:22-25. As the +Government acknowledged, with respect to the jury's determination in this case, this witness is +not a victim of any of the crimes charged in the Indictment. See id. at 69:4-9; Nov. 10, 2021 Tr. +at 164:19-165:3.2 However, evidence of legal conduct can of course be relevant evidence of +illegality. And conduct that cannot itself form the basis of a conviction can serve as direct +evidence of the crimes charged. See, e.g., United States v. +702 F.3d 22, 37 (2d Cir. +2012) (affirming admission of defendant pimp's relationship with and control over women who +worked as prostitutes as direct evidence of 18 U.S.C. § 1591(a) charge). Thus some of the +anticipated testimony described above can serve as direct evidence, notwithstanding the fact that +the alleged conduct as to Witness-3 was not illegal for the purpose of the charges in this case. +Portions of the anticipated testimony may also serve permissible purposes under Rule +404(b), namely proving motive, intent, and knowledge. See Fed. R. Evid. 404(b)(2). The +witness is expected to testify about certain statements by Ms. Maxwell. For example, the +" At the November 1 conference, the Court denied the Defendant's motion to preclude the Government from +referring to alleged victims as "victims" and "minor victims." Nov. 1, 2021 Tr. at 4. In contrast to the other alleged +victim witnesses, it is not (nor could it be) the Government's litigating position that this witness is a victim of the +crimes charged in the Indictment. Given this, the Government may not refer to this witness as a "victim" or a +"minor victim" in front of the jury. Doing so would constitute prejudicial error for the reasons explained in this +Memorandum Opinion & Order. +2 + + +Case 1:20-cr-00330-PAE Document 690 Filed 11/19/21 Page 3 of 23 +Government expects the witness to testify: +Gov. Supp. Ltr, at 2-3 (Nov. 5, 2021). These statements are relevant because the jury may +conclude that they tend to establish that the Defendant knew the alleged massages were +sexualized and the Defendant's motive for facilitating the encounters. +Id. at 3, 9. This testimony is relevant because the jury may conclude that it tends to +establish the Defendant's intent to recruit girls for sexualized massages. +Id. at 3. Although it is not the only +available interpretation of this evidence, the jury could conclude that +Such knowledge and intent are of course proper purposes under Rule +404(b).3 +3 Defendant argues that this witness's testimony is impermissible propensity evidence as to Mr. Epstein under Rule +404(b). Def. Supp. Resp. at 5-7 (Nov. 11, 2021). The Court is unpersuaded. The testimony is not offered to show +that Mr. Epstein acted in accordance with a certain character trait on a particular occasion. Rather, it is probative of +whether Ms. Maxwell knew of or at least believed he had a sexual interest in +, which a jury may find +tends to establish the Defendant's intent and motive as to the charged crimes. See Roe v. Howard, 917 F.3d 229, +245-46 (4" Cir. 2019) (rejecting argument that husband's assault of a non-party housekeeper was improper character +evidence under Rule 404(b) in a Trafficking Victims Protection Act action against the wife for facilitating husband's +assaults of live-in housekeeper). +3 + + +Case 1:20-cr-00330-PAE Document 690 Filed 11/19/21 Page 4 of 23 +The probative value of the anticipated testimony must of course be balanced with any +potential prejudice under Rule 403. As the Court noted at the November 1 conference, there is a +risk that the jury may confuse the issues and think that the sexual conduct this witness is +describing itself constitutes the illegality charged in the Indictment due to the closeness in age of +this witness to the age of consent. Nov. 1, 2021 Tr. at 89-90. There is also the risk that the jury +Maxwell due to feelings of immorality or sympathy for the witness despite the +lack of illegality with regard to the crimes charged in the Indictment. However, the Court +concludes that this risk of prejudice can be sufficiently minimized through two avenues. First, +the testimony must be carefully limited. Second, there must be a clear limiting instruction. +As to the first, the witness is limited to stating that sexual activity occurred but is +precluded from providing detailed descriptions of the sexual activity. There is little to no +probative value of a witness describing sexual activity when that witness's testimony regarding +the sexual activity cannot form the basis for the conviction of the crimes charged. For example, +any prejudice from +described above is substantially diminished +by limiting the proffered testimony to the Defendant's interaction with the witness and testimony +indicating that sexual activity allegedly took place without describing the details of that sexual +activity. Unlike the details of the sexual conduct itself, this anticipated testimony would not be +unduly prejudicial. In contrast, the minimal probative value of the details of sexual conduct +would be substantially outweighed by the risk of the jury convicting Ms. Maxwell on an +improper basis. The same is true of the witness's subjective experience of the sexual conduct +and any emotional or other impact the sexual conduct had on the witness because such testimony +cannot form the basis of a conviction in this case. Accordingly, the witness is limited, as the +Government phrased it, to describing her "factual experience" as to the lines of testimony +4 + + +Case 1:20-cr-00330-PAE Document 690 Filed 11/19/21 Page 5 of 23 +described above. See Gov. Supp. Ltr. at 12 (Nov. 5, 2021). For example, in a recent murder +trial, the Court permitted the nephew of the victim to describe his uncle's wounds because the +nephew, who had served as a caretaker, had some information that was not cumulative of the +medical records. The Court expressly cautioned the Government that it would not permit +emotional testimony, or the probative value would be outweighed by the prejudice: +[It's clearly a 403 line here. You have cumulativeness with the medical testimony, you +have graphic descriptions from a relative who cared for the victim which could very well +produce sympathies and prejudice that would interfere with and overcome the medical +facts that you need for purposes of proving causation. ... I am certainly going to cut off +the line at any graphic descriptions. To the extent that walking this person through +questions regarding the medical condition is emotional testimony, I think we are - it will +have to be stopped. +United States v. Berry, No. 20 Cr. 84 (AJN), Dkt. No. 138 at 13; see also id. at 15. In that case, +the Government agreed that the line had to be carefully guarded. Id. at 13-14. The transcript of +that ruling is attached for counsel's reference. See Exhibit A. The Court cautions the +Government to proceed carefully because the Court will not allow testimony that steps over this +403 line. The Court will allow some leading questions for this portion of the testimony to help +ensure that it does not. +Finally, the Court concludes that this witness's anticipated testimony as to the sex +trafficking counts is inadmissible. Although the Government's letter points to some relevant +direct evidence that this witness could provide regarding these counts, see Gov. Supp. Ltr. at 6-7, +any minimal probative value of this evidence is diminished by its remoteness in time to the +charged sex trafficking conspiracy, which is alleged to have run from 2001 to 2004. This +evidence does not face the same problem as it relates to the +Act conspiracies, which are +alleged to have begun in 1994 (and when the Defendant allegedly began her relationship with +this witness.). Because the risk of' unfair prejudice substantially outweighs the probative value of +5 + + +Case 1:20-cr-00330-PAE Document 690 Filed 11/19/21 Page 6 of 23 +this evidence as to the sex trafficking counts, the witness is precluded from testifying that +The Court thus draws the line described above for limiting Witness-3's testimony. +Permitting the entirety of the proffered testimony carries a risk that the jury +Maxwell due to conduct that cannot form the basis of a conviction for the charged crimes. But +by limiting the testimony to the few categories of relevant testimony outlined above, the +prejudice is substantially minimized. +Moreover, whether as direct evidence of the +Act counts or offered for a proper +purpose under 404(b), this testimony must be paired with a proper limiting instruction to guard +against potential juror confusion. The Defense has submitted proposed limiting instructions, and +the Government agrees that some sort of instruction is appropriate, although it disagrees with the +basis for the instruction. Dkt. No. 452 at 50 n.12; Gov. Supp. Ltr. at 12 (Nov. 5, 2021). In +accordance with this ruling, the Court proposes the following instruction before this anticipated +witness testifies: +You will hear testimony from the next witness about interactions that she says she had +with the Defendant and Mr. Epstein. I instruct you that because the witness was over the +relevant age of consent at the relevant time period, any sexual conduct she says occurred +with Mr. Epstein was not "illegal sexual activity" as the Government has charged in the +Indictment. I instruct you that this witness is not a victim of the crimes charged in the +Indictment. To the extent you conclude that her testimony is relevant to the issues before +you, you may consider it. However, you may not convict the Defendant on the basis of +the testimony regarding the sexual conduct between this witness and Mr. Epstein. Nor +may you consider this testimony as any kind of reflection on Mr. Epstein's nor Ms. +Maxwell's character or propensity to commit any of the crimes charged in the Indictment. +The Court also proposes the following instruction before any testimony by other witnesses +regarding sexual activity that occurred after the relevant age of consent: +I anticipate that you will hear testimony from the next witness about sexual conduct that +she says she had with Mr. Epstein in [insert relevant jurisdiction, e.g. New Mexico]. I +instruct you that because the witness was over the age of consent in [insert relevant +6 + + +Case 1:20-cr-00330-PAE Document 690 Filed 11/19/21 Page 7 of 23 +jurisdiction, e.g. New Mexico] at the relevant time period, the sexual conduct she says +occurred with Mr. Epstein was not "illegal sexual activity" as the Government has +charged in the Indictment. However, to the extent you conclude that her testimony is +relevant to the issues before you, you may consider it. However, you may not consider +this testimony as any kind of reflection on Mr. Epstein's nor Ms. Maxwell's character or +propensity to commit any of the crimes charged in the Indictment. +The parties may submit any requested edits to the proposed limiting instructions that are +consistent with the Court's ruling or indicate that they have none on or before November 21, +2021. +This resolves Dkt. Nos. 387, 444. +SO ORDERED. +Dated: November 19, 2021 +New York, New York +Alia Mattor +ALISON J. NATHAN +United States District Judge +7 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Casase: 20206003308RAGN Documenta88 Freet|101069221 Pagage 8fđ/623 +1 +L9L5ber1 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +- X +UNITED STATES OF AMERICA, +New York, N.Y. +V. +20 Cr. +84 (AJN) +RALPH BERRY, +Defendant. +-X +September 21, 2021 +9:45 a.m. +Before: +HON. ALISON J. NATHAN, +U.S. District Judge +And A Jury +APPEARANCES +AUDREY STRAUSS +United States Attorney for the +Southern District of New York +BY: JACOB R. FIDDELMAN +DOMINIC A. GENTILE +ADAM HOBSON +Assistant United States Attorneys +LAW OFFICE OF MARK S. DEMARCO +Attorneys for Defendant +BY: MARK DeMARCO +-AND- +LAW OFFICES OF EZRA SPILKE, +PLLC +BY: EZRA SPILKE + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Casase: 2020F6003308RAQN +L9L5ber1 +Document G98 Frtet101082/1 Pagage Ofdf623 +2 +(Case called) +THE DEPUTY CLERK: Counsel, please state your name for +the record, starting with the government. +MR. HOBSON: Good morning, your Honor. Adam Hobson, +Jacob Fiddelman, and Dominic Gentile for the government. +THE COURT: Good morning. +For the defendant? +MR. DeMARCO: Good morning. For Mr. Berry, Mark +DeMarco and Ezra Spilke, Ms. Mayerlin Ulerio, and of course +Mr. Berry. +THE COURT: Good morning, counsel. +Good morning, Mr. Berry. +THE DEFENDANT: Good morning. +THE COURT: I had hoped to start at 9:00 but Mr. Berry +wasn't brought until now. Hopefully that won't repeat going +forward. We will make sure that things are in place to prevent +that so we can timely get started each day. +I thank everyone for being here on time. Let me ask, +as a matter of procedure, we will wait for the jury department +to let us know when the panel is checked in and assembled and +in their seats, and then can head over to 500 Pearl to commence +jury selection. My purpose for today is to confirm the receipt +of the voir dire questionnaire that I sent yesterday with the +noted change, make sure everybody got that. The second is to +confirm that there have been no additional plea offers. And + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Cafede2020 00ВRRAEN me Filed 10/002 P8998 0623 +3 +L9L5ber1 +lastly, I made the note, make sure there are no questions +regarding jury selection now that you have been to the +walk-through in the jury selection room where selection will +take place. +So, let me ask, everybody received the voir dire with +the noted changes? +MR. HOBSON: Yes, your Honor. We did. +THE COURT: Nothing additional, Mr. Hobson? +MR. HOBSON: Nothing additional. +MR. DeMARCO: Yes, your Honor; and nothing additional. +THE COURT: Thank you. +Any additional plea offers that I need to allocute on? +MR. HOBSON: No additional plea offers have been +extended, your Honor. +THE COURT: OK. And then let me confirm if anybody +has any questions about jury selections. Io repeat the basic +process, I will qualify 33 potential jurors that represents 12 +jurors and three alternates, 10 peremptories as to the main +panel for the defense, six peremptories for the government, one +peremptory per side with respect to the alternates. And the +way that we are operating under the COVID protocols, the jury +department will, after the jury panel members are checked in, +they'll be randomly assigned a number consistent with a list +that the jury department generates, they will be seated in that +numerical order in the jury selection room. I understand 1 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Cafede2020 0080084J [De6998 Filed 10/00/21 PEggel nf 623 +4 +L9L5ber1 +through 42 will be in the main jury selection room and then 43 +through, I believe 82 -- we will get the final number once we +see what the return on the summons is -- will be seated in +courtroom 9C also at 500 Pearl, with a live feed to 9C of +everything taking place in the jury assembly room. +I will make preliminary instructions which you have +seen after you and I enter the courtroom. The panel members +will be seated at that point. I will make my preliminary +remarks, the written questionnaire that the jurors can read +along with will be handed out at that point, both in the jury +assembly room and in 9C simultaneously through court staff. I +will instruct the jurors not to write anything on the +questionnaire with the exception of circling a number if they +have a "yes" response to that question as I read through the +questionnaire. +So, at that point I will turn to panel member juror +no. 1 and go through and read the questionnaire getting "yes" +or "no" response to each question. If the answer is "yes" +following up as appropriate. Io the extent that the matters +touched upon could influence other jurors or are of a sensitive +nature, we will bring that juror over to the plexiglass area to +my right in the jury assembly room, there is markings on the +floor where folks stand and the noise machine will be on so +that others cannot hear, and I will inquire with the juror as +to any necessary follow-up. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Cafede2020 0088084EN [698 Filed 10/00/21 P89951 623| +L9L5ber1 +5 +Once we get through, assuming we get through juror +no. 1 without any for-cause issues, I will turn to juror no. 2 +and say do you have any "yes" responses? And then we will take +those in order as they come. +If any juror needs to be dismissed for cause, let's +say juror no. 2 needs to be dismissed for cause, then we will +proceed with the same process with juror no. 3. Any "yes" +questions, taking those one at a time, continuing until we have +33 qualified jurors. +Once we have 33 qualified jurors you will exercise +your peremptory strikes by list and simultaneously, that is, +each side will produce a list with the government's six strikes +as to the main panel and one strike as to the alternate panel, +and the defense will write its list with 10 strikes as to the +main panel and one strike as to the alternate panel. +Obviously, before anyone is dismissed, I will hear from counsel +if any applications or issues need to be raised if you are +satisfied with our jury. Once we get there we will read the +names of the selected jurors, dismiss to the jury department +the unused jurors, and then proceed over back across the street +over here. I believe what we will do is have +take +the jurors to the jury room, which is an outfitted courtroom so +they can put their belongings down, she can give them notebook +and pen, bring them back in. At that point she will swear the +jury and I will give preliminary instructions and opening + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Cafede2020 0088084EN [698 Filed 10/00/21 899618 0623 +L9L5ber1 +6 +statements. +Whether that happens today or tomorrow we will +see. +Hopefully today. +Any questions or issues to raise with the process I +have described? Mr. Hobson? +MR. HOBSON: Your Honor, no. One small thing on the +voir dire. +We submitted a list of names for the Court to read. +One thing I wanted to flag for the Court is one of the +witnesses' names we asked you to include is Jesus Ortiz, and +that's how he pronounces his name, with a hard J. I want to +flag that for the Court so that his name is read accurately to +the jury. +THE COURT: Let me see if there are any other +pronunciation issues. +Mr. DeMarco, while I am pulling that up, any other +questions or issues with respect to the process? +MR. DeMARCO: No, your Honor. +THE COURT: And, Mr. DeMarco, you are going to keep +your mask on so I don't have to keep coming at you about it? +MR. DeMARCO: I will do my best. +THE COURT: OK. Don't take it off to talk. +MR. DeMARCO: Sorry? +THE COURT: Don't take it off to talk. +MR. DeMARCO: OK. I took it off to listen the last +time. +THE COURT: That's an anatomical anomaly. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Cafed 20200088 mes Fed 121 99e 623 +L9L5ber1 +7 +I should say, of course, once we are in the courtroom +then counsel +in the plexiglass box with the HEPA filter will be +able to remove their mask for questioning, and to the extent +outside of the jury we have argument or the like, we can do +that in there to aid that that process. +It's Ms. Ulerio, Mayerlin, am I saying that correctly? +MS. ULERIO: Yes. +THE COURT: And you have another paralegal Dylan +Schneider who may be here? +MR. DeMARCO: Yes, your Honor, but he won't be with us +in court. +THE COURT: And what about Jeremy Schneider? +Mr. Schneider. +MR. DeMARCO: He is unable to be with us. +THE COURT: He won't be at trial at any point? +MR. DeMARCO: No. I don't expect him to be here. +THE COURT: Should I include him in the voir dire just +in case. +MR. DeMARCO: I think you should, Judge, because his +name might come up and I just can't see how or where or under +what scenario. But, just to be safe. +MR. HOBSON: His name is on the stipulations, so maybe +to be safe. +THE COURT: Just to note, when I do introduce counsel +for purposes of the voir dire, and Mr. Berry, and the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Cafede2020 0088024J [De698 Filed 10/00/21 PEgg81 0623 +8 +L9L5ber1 +paralegals, I will ask each of you to stand as I say your name +so that the jurors can see you, the panelists can see you. So, +I will note Mr. Schneider is part of the team but not present +today and may not be present every day of the trial. +Appropriate, Mr. DeMarco? +MR. DeMARCO: Yes, Judge. +THE COURT: OK. +So Jesus Ortiz is the pronunciation. +How about, Mr. Hobson, how do I pronounce no. Q? +MR. HOBSON: I believe, your Honor, it is Vyacheslav, +and the last name is Polosin. +THE COURT: Vyacheslav Polosin. OK. +Special Agent Stefano Braccini? +MR. HOBSON: And he is in the courtroom. +THE COURT: OK. I think that's it. Other issues to +take up? +MR. HOBSON: I don't think so, your Honor. +THE COURT: Mr. DeMarco? +MR. DeMARCO: No, your Honor. Not now. +Judge, how much time do we have before we walk over? +Maybe we could use this time efficiently, because I do have -- +I raised with the government an issue I was going to raise with +their first witness so you tell me. +THE COURT: I was told around between 10:00 and 10:30 +but we won't know until they actually call over so I'm happy to +use the time and if we get the call, we will pause. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Cafede2020 00BRAEN [e698 Filed 10/00/21 P89901 623 +L9L5ber1 +9 +MR. DeMARCO: OK. +THE COURT: Was it an issue you wanted to speak to the +government about first? +MR. DeMARCO: I did consult with the government. I +was unpersuasive. I was hoping to be more successful with your +Honor. +THE COURT: OK. And the first witness is? +MR. DeMARCO: Mr. Rasheen Vega. +THE COURT: Go ahead. And if you could speak into the +mic, please? +MR. DeMARCO: It seems to me, your Honor, from my +reading of the 3500 material, that we can expect Mr. Vega to +testify to something like this: That he was the nephew of +Mr. +, that he was 11 years old at the time that Mr. +was shot in June of 2000, that he witnessed a portion of that +shooting or the aftermath of that shooting which I am OK with. +The problem that I have with his prospective testimony is this: +It also appears from reading the 3500 that the government will +seek to elicit from Mr. Vega testimony about the horrific, +horrific bedsores or compression sores that Mr. +was +suffering from at the time of his death. I believe there is at +least notes that Mr. Vega observed the sores to be oozing, +observed Mr. +to be in terrible, terrible pain and +suffering at or near the time of his death, and my concern is +that, A, in light of the fact that two doctors are being called + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Casase: 2020F0003308 +L9L5ber1 +N +Document 698 Friet 10060221 Pagg₴Oløtaf623 +10 +by the government and, even apart from that, Mr. Vega is not +qualified to testify about the injuries that he observed; and +B, that this type of testimony serves no purpose but to elicit +or garner sympathy from the jury and will be unduly prejudicial +to Mr. Berry. +So, that's the basis of my objection to Mr. Vega, +should he be asked those types of questions. +THE COURT: Understood. +Mr. Hobson? +MR. HOBSON: Your Honor, there are two large topics +that Mr. Vega is anticipated to testify about. I think it is +consistent with what Mr. DeMarco says is, one, he was a +percipient witness to the shooting itself; and two, he observed +the victim's injuries after the shooting and was involved in +the victim's care in the 10 years between the shooting and the +victim's death. I take it it is the second category that the +defendant is objecting to. But here, cause of death is +obviously a big issue in this case and it is something that it +is our burden to prove, that the injuries from the shooting +lead to his death. And we expect the evidence to show that, as +a result of the shooting, the victim became paralyzed from the +waist down and that meant that he was confined to a +wheelchair -- whereas he was not in a wheelchair before -- and +developed serious complications as a result of that including +serious sores which later led to infection and the victim's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Casase: 2020F003308 +L9L5ber1 +death. +N Document 698 Freet/10060221 Payag₴118f d/623 +11 +We will not be eliciting expert medical testimony or +opinion from this witness, he will be simply testifying to what +he observed with respect to the victim's physical condition +during the 10 intervening years between the shooting and the +death +and that's important evidence, it's evidence that will +then be consistent with things that medical experts to be +qualified as experts will be called to testify about, but those +experts did not observe these injuries during the 10 +intervening years. They also did not observe Mr. +prior +to the shooting. For instance, they wouldn't be able to tell +you whether he was in a wheelchair before the shooting or after +the shooting. They wouldn't be able to tell you if he +developed those bedsores before the shooting or after the +shooting. It is Mr. Vega's observations that will allow the +jury to connect those dots. Given how important causation is +in this case, we think it is important that the jury understand +those injuries. +THE COURT: Will medical records, that will be +introduced, describe the bedsores? +MR. HOBSON: They will describe the bedsores at the +time of the autopsy which was in November of 2010. +THE COURT: What is the connection between bedsores +and cause of death? Infection? +MR. HOBSON: Your Honor, essentially what I expect the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Casase: 2020r0EK30BRAGN DocurmentG98 Fridet/104060221 Pagege219fdf623 +L9L5ber1 +testimony will be from the medical experts is that as a result +of the gunshot wound, that caused paralysis and paraplegia in +the victim. +Paraplegia commonly leads to things such as +bedsores or pressure sores from not being able to move one's +body; also other conditions such as a colostomy bag, a +collapsed rectum, a permanent catheter, all of which can lead +to infections and that in this particular case it was the +complications of the paraplegia that led into infections or +sepsis and that it was the sepsis that ultimately, in 2010, +killed Mr. +MR. DeMARCO: Your Honor, if I may? +THE COURT: Sure. +MR. DeMARCO: In my reading of the 3500 notes that +were disclosed it's more than that. He describes oozing-type +wounds, he describes a horrific odor, I think he described it +as the smell of death in Mr. +' apartment at or near the +time of his death. It's facts like these that I am focusing +on. +12 +THE COURT: Yes. +MR. DeMARCO: The paraplegia, the medical testimony +from the medical examiners will establish that Mr. +was a +paraplegic and he was in a wheelchair. But, my concern is +about the graphic description of the bedsores, the compression +sores, and also the horrific odor witnessed by Mr. Vega. +MR. HOBSON: Your Honor, we are certainly cognizant of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Casase: 2020608K308RAGN Document&98 Friet/104060221 Pagg₴320f df623 +13 +L9L5ber1 +not crossing the 403 line here. We think it is important that +the jury understand +the nature of these injuries and how they +could lead to his death and what the injuries were during the +intervening time between the shooting and the autopsy. We are +not looking to be gratuitous or to pile on here. +THE COURT: Yes. Well, it's clearly a 403 line here. +You have +cumulativeness with the medical testimony, you have +graphic descriptions from a relative who cared for the victim +which could very well produce sympathies and prejudice that +would interfere with and overcome the medical facts that you +need for purposes of proving causation. So, because this +witness is testifying first it's difficult for me to know +exactly what additional facts you need to extract from the +witness but I am certainly going to cut off the line at any +graphic descriptions. To the extent that walking this person +through questions regarding the medical condition is emotional +testimony, I think we are -- it will have to be stopped. +So, I think what you need to think about is what -- +and I'm going to allow a little bit of leading to ask the +specific factual questions you believe that you need and that +are not cumulative with the medical testimony, but I'm going to +guard this line very carefully, and you should too. +MR. HOBSON: Your Honor, I understand that. I will +say that in meeting with this witness we have tried to follow +that line and I am -- with the ability to maybe construct some + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Casase: 2020F003308RAON Document G98 Ffieet/10Y069221 Pageg฿420fdl623 +14 +L9L5ber1 +of my questions in a leading way, I will hope to enforce that +line. +It is, again, certainly not our intention to be +gratuitous but to simply get in the nature of the injuries and +their relationship. +THE COURT: You don't have pre-autopsy medical records +that you are putting in that describes these injuries? +MR. HOBSON: No, your Honor. +MR. DeMARCO: I'm sorry. What was that? Pre? +THE COURT: No. I asked if there were -- +MR. DeMARCO: I misunderstood your question, Judge. +I'm sorry. +THE COURT: I asked if there were pre-autopsy medical +records that describes these infections and injuries and the +answer is no. +MR. DeMARCO: The government has disclosed, pursuant +to Rule 16, some of these records that your Honor references, +so. +MR. HOBSON: Your Honor's question was I think if we +are introducing them. There are voluminous medical records +that are almost incomprehensive to a layperson. We are not +introducing those records. +THE COURT: But you have a medical expert. +MR. HOBSON: We do have a medical expert. +MR. DeMARCO: Your Honor, if I just might add another +fact to this? Based on the exhibit list and the exhibits + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Casase: 2020r@EK30BRAGN DocurentG98 Friet/1040E0221 Pageg$52af df623 +15 +L9L5ber1 +provided to us by the government, the government intends to +introduce, through the medical examiner, photographs of these +bedsores. +So, I think that expert testimony, by itself, +sufficiently will describe the bedsores that Mr. +was +suffering at the time of his death. +MR. HOBSON: To be clear of what photographs we are +introducing, we are not introducing the most graphic pictures +of the bedsores. +In fact, we were concerned in introducing +some of the pictures that they wouldn't fully show how serious +the bedsores were but we are not going to be putting in the +most graphic pictures. +THE COURT: What I am going to allow is you will have +some permission to lead with respect to the description of the +injuries and sores. It's going to be brief and extraction of +facts that you need that is not cumulative with medical +testimony and evidence that's coming in. We will see how it +goes but I am -- I intend to be extremely cautious given that +this is non-expert medical testimony coming from a relative. +So, the prospect of prejudice and emotion and sympathy is real +and I'm not going to let it happen. +MR. HOBSON: Yes, your Honor. We understand. +THE COURT: Anything else? +MR. DeMARCO: No thank you, your Honor. +THE COURT: OK. Any word, +(Discussion off record) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Casase:2020F@0K308RAON +Document G98 Fritet/10X060221 Pagege628f df623 +L9L5ber1 +16 +THE COURT: They said 15 to 20 minutes so I imagine +the marshals need time to get Mr. Berry across the street. +So, +unless +anyone has anything further, we will break and +re-assemble across the street at 500 Pearl. Thank you. +So, one question. Mr. Hobson, is the government ready +to commence trial? +MR. HOBSON: Yes, your Honor. +THE COURT: Mr. DeMarco? +MR. DeMARCO: Yes, Judge. +THE COURT: Thank you. +MR. DeMARCO: Your Honor, we are going to meet over at +the jury room? +THE COURT: We will meet in the alcove outside the +jury assembly room. There will be jury department staff there +to assist. +Thank you. +(Jury selection contained under separate cover) \ No newline at end of file diff --git a/vision-fixhub/court-05/6a214fc699470d3050ac2f066a3c9f953f70e1e1f80c7cb9ae9931246e8e405c.receipt.json b/vision-fixhub/court-05/6a214fc699470d3050ac2f066a3c9f953f70e1e1f80c7cb9ae9931246e8e405c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..378c54927b2b1296bac8f0b0bec29d26cae73076 --- /dev/null +++ b/vision-fixhub/court-05/6a214fc699470d3050ac2f066a3c9f953f70e1e1f80c7cb9ae9931246e8e405c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1061, + "dataset": "marble-joined", + "doc_id": "6a214fc699470d3050ac2f066a3c9f953f70e1e1f80c7cb9ae9931246e8e405c", + "engine": "marble-apple-vision", + "event_count": 24, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "d5163174cb40762be93e4eca82efbf855ce35ad16c76081cd192b2e36a80709b", + "output_sha256": "dcb5df04429112fbdead0bf65e80f591358005cb1e19ddb394d5fe9606d3d9c2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6a4fdc810c781affe4a1067c649c6d4210adb10569452f5fe19a771e77d18c64.md b/vision-fixhub/court-05/6a4fdc810c781affe4a1067c649c6d4210adb10569452f5fe19a771e77d18c64.md new file mode 100644 index 0000000000000000000000000000000000000000..2829c09c002bc0c1429ca0efb1163fbdb8b42a69 --- /dev/null +++ b/vision-fixhub/court-05/6a4fdc810c781affe4a1067c649c6d4210adb10569452f5fe19a771e77d18c64.md @@ -0,0 +1,79 @@ +Case 1:22-cv-10904-JSR Document 285-9 Filed 08/15/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 285-9 Filed 08/15/23 Page 2 of 3 +The Blotter +ABC News: The Blotter +Warrants Were Prepared to Arrest Others in Millionaire Sex Scandal +July 28, 2006 12:24 PM +Maddy Sauer Reports: + +Palm Beach police were planning to arrest two women in connection with their +investigation into Jeffrey Epstein, the New York financier who has been charged +with solicitation, though police say he also engaged in illegal sexual activity +with minors. +According to police investigative documents obtained by ABC News, police +prepared and submitted arrest warrant requests in May for +Epstein's assistant, standing on the right side of the picture, and +pictured in the middle, who police say was paid by Epstein to bring over young +and underage girls to his house to massage Epstein. +was to be arrested as a principal in the first degree on four counts of unlawful sexual activity with certain +minors and as a principal in the first degree on one count of lewd and lascivious molestation. +Is warrant +was for lewd and lascivious acts on a victim under 16 years of age. +According to police documents, some of the girls who massaged Epstein claimed that his assistant, +ould often prepare the massage table and arrange the oils before Epstein's massage +would also +legedly call the girls when Epstein was in town to see if they wanted "work." One girl told police, "Work is tl +term used by +to provide the massage in underwear," according to police documents. +One girl also claimed that +had attempted to reach her after the girl had been interviewed by police to talk +about the questioning, according to police documents. +did not return a call seeking comment. +was interviewed by police in October 2005, and police say she admitted she brought six girls, ages 14 to +16, to Epstein's house to massage him. +was paid $200 each time she brought a girl over, according to her +statement to police. +Police say +Police say that as +told them she wished to assist in their investigation in hopes of receiving a lesser charge. +was being driven home from questioning, she remarked, "I'm like a Heidi Fliess." +Another woman involved in the scandal was Epstein's girlfriend +, standing to the left in the +above picture. Though the documents do not mention that any charges were being sought against +one girl, who began massaging Epstein when she was 16-years-old, told police that she was paid by Epstein to +have sex with +as he watched. The girl also told police that "Epstein bragged he brought her +into the United States to be his Yugoslavian sex slave," according to the documents. +Attempts to contact +and +have not been successful. +The warrants for +and +were submitted to the state attorney's office on May 4. A week later, no +arrests had taken place. One police detective noted in the documents that he asked the assistant state attorney to +take action. +http://blogs.abcnews.com/theblotter/2006/07/warrants_were_p.html +10/19/2007 + +JPM-SDNYLIT-00269657 + + +Case 1:22-cv-10904-JSR Document 285-9 Filed 08/15/23 Page 3 of 3 +The Blotter + +"I asked that she either issue the warrants or direct file, as so much time has elapsed since the original request to +the Grand Jury," he noted. "I explained that the Palm Beach Police Department had concluded the case in +December of 2005 and has been waiting for the case to go forward." +About six weeks later, after the state attorney's office had conducted their own additional investigation into the +matter, State Attorney Barry Krischer decided to send the case to the grand jury. +Earlier this week the grand jury indicted Epstein for solicitation of a prostitute. No charges were brought against +The case is now closed as far as the state attorney's office is concerned. The police, +meanwhile, have tuned the matter over to the FBI. +Click here to read ABC News' full coverage on the Millionaire Sex Scandal. +http://blogs.abcnews.com/theblotter/2006/07/warrants_were_p.html + +10/19/2007 +JPM-SDNYLIT-00269658 diff --git a/vision-fixhub/court-05/6a4fdc810c781affe4a1067c649c6d4210adb10569452f5fe19a771e77d18c64.receipt.json b/vision-fixhub/court-05/6a4fdc810c781affe4a1067c649c6d4210adb10569452f5fe19a771e77d18c64.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..463e15545223d55482280f5ab27f19bdb6641989 --- /dev/null +++ b/vision-fixhub/court-05/6a4fdc810c781affe4a1067c649c6d4210adb10569452f5fe19a771e77d18c64.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -92, + "dataset": "marble-joined", + "doc_id": "6a4fdc810c781affe4a1067c649c6d4210adb10569452f5fe19a771e77d18c64", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "cbbc4c8b2ed2bd1b7ea94eb9fd6a5abc51a042e59fc3fb373a5fd0ff3a0bbd59", + "output_sha256": "07cc11b477481af13c23818e477c33342a493f14e7c43f140f19c9049819c9ac", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6a6020bdeca2ea2707f5668d8f10df1bc0ae97cb235fe6df261ef614706dc87a.md b/vision-fixhub/court-05/6a6020bdeca2ea2707f5668d8f10df1bc0ae97cb235fe6df261ef614706dc87a.md new file mode 100644 index 0000000000000000000000000000000000000000..22cd32d4d17c4272c4397bf7606f4c1c92af2b4d --- /dev/null +++ b/vision-fixhub/court-05/6a6020bdeca2ea2707f5668d8f10df1bc0ae97cb235fe6df261ef614706dc87a.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 240-8 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/6a6020bdeca2ea2707f5668d8f10df1bc0ae97cb235fe6df261ef614706dc87a.receipt.json b/vision-fixhub/court-05/6a6020bdeca2ea2707f5668d8f10df1bc0ae97cb235fe6df261ef614706dc87a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f3b17682862036dd9ef559a8ba7e2fe35097f8ee --- /dev/null +++ b/vision-fixhub/court-05/6a6020bdeca2ea2707f5668d8f10df1bc0ae97cb235fe6df261ef614706dc87a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "6a6020bdeca2ea2707f5668d8f10df1bc0ae97cb235fe6df261ef614706dc87a", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "6af546aacf3ff20540ad861240c8153fe19673722b1819a98c0ff5e0b383d489", + "output_sha256": "cddc5e2c8892b89fd824ddee192975f7b75201768cd048e3eb206ff79e8529a9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6a6c528d4ce3dca34d1acc8a6925ecd16ed82acd305c2e7dc6dd3ddd71dda9db.md b/vision-fixhub/court-05/6a6c528d4ce3dca34d1acc8a6925ecd16ed82acd305c2e7dc6dd3ddd71dda9db.md new file mode 100644 index 0000000000000000000000000000000000000000..c4dc7ab7e220a099d48d12f04c7b5460db9c86b0 --- /dev/null +++ b/vision-fixhub/court-05/6a6c528d4ce3dca34d1acc8a6925ecd16ed82acd305c2e7dc6dd3ddd71dda9db.md @@ -0,0 +1,914 @@ +Case 1:20-cr-00330-PAE +Document 809 +Filed 08/11/25 Page 1 of 31 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +-V- +GHISLAINE MAXWELL, +20 Cr. 330 (PAE) +OPINION & ORDER +Defendant. +PAUL A. ENGELMAYER, District Judge: +On December 29, 2021, a jury convicted defendant Ghislaine Maxwell of five felonies +involving the sexual abuse of young girls that she and the notorious pedophile Jeffrey Epstein +committed between 1994 and 2004. This decision resolves the Government's July 18, 2025 +motion to unseal grand jury transcripts and exhibits in Maxwell's case, subject to redactions +aimed at protecting victim confidentiality. Dkt. 785; see also Dkt. 808. For the reasons that +follow, the Court denies the motion.' +Background to the Motion to Unseal +A. Indictments +In late November 2018, prompted by investigative journalism, the United States Attorney +in this District opened an investigation into Epstein and his co-conspirators. On July 2, 2019, a +grand jury returned an indictment that charged Epstein with participating in a sex trafficking +conspiracy, in violation of 18 U.S.C. § 1591(a) and (b).? On July 6, 2019, Epstein was arrested. +' A motion seeking, on similar terms, the unsealing of grand jury materials in Epstein's case is +pending before the Hon. Richard M. Berman. See United States v. Epstein, 19 Cr. 490 (RMB) +(S.D.N.Y. July 18, 2025), Dkt. 61. +2 See United States v. Epstein, 19 Cr. 490 (RMB) (S.D.N.Y. July 2, 2019), Dkt. 2. + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 2 of 31 +On August 10, 2019, Epstein committed suicide while in pretrial custody at the Metropolitan +Correctional Center ("MCC"). See generally Dkt. 670 at 3-4; Dkt. 785 at 2. +On June 29, 2020, a grand jury in this District returned a six-count indictment against +Maxwell, alleging that she had facilitated and participated in Epstein's sexual abuse of multiple +minor girls. It charged her with conspiracy to entice minors to travel to engage in illegal sex +acts, in violation of 18 U.S.C. § 371; enticement of a minor to engage in illegal sex acts, in +violation of 18 U.S.C. §§ 2422 and 2; conspiracy to transport minors with intent to engage in +illegal sexual activity, in violation of 18 U.S.C. § 371; transportation of a minor with intent to +engage in illegal sexual activity, in violation of 18 U.S.C. §§ 2423(a) and 2; and, in two counts, +perjury, in violation of 18 U.S.C. § 1623. See Dkt. 1 ("Initial Indictment"). It based these +charges on Maxwell's conduct with respect to three minor victims, whom the Government +identified pseudonymously. On July 8, 2020, the grand jury returned a superseding indictment +that made ministerial corrections. Dkt. 17 ("S1 Indictment"). On March 29, 2021, a different +grand jury in this District returned a second superseding indictment. It added two counts, based +on a fourth minor victim, to whom it also referred pseudonymously. One charged a sex +trafficking conspiracy, in violation of 18 U.S.C. § 371; the other charged sex trafficking of a +minor, in violation of 18 U.S.C. §§ 1591(a), (b)(2), and 2. See Dkt. 187 ("S2 Indictment"). The +S2 Indictment also broadened the time period of the sexual abuse crimes, originally alleged to +span 1994 to 1997, to span 1994 to 2004. +B. +Trial +Trial commenced on November 29, 2021, before the Honorable Alison J. Nathan, to +whom this case was then assigned, and a jury, on six counts in the S2 Indictment-all but the +2 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 3 of 31 +two perjury counts.? It ended on December 29, 2021, with Maxwell's conviction on five of the +six counts and her acquittal on the substantive enticement count. +The evidence adduced at trial is well-summarized in Judge Nathan's post-trial decision +denying Maxwell's post-trial motions, including under Federal Rule of Criminal Procedure 29 +for a judgment of acquittal, Dkt. 657; in the Government's brief in Maxwell's appeal, see United +States v. Maxwell, No. 22-1426 (2d Cir. June 29, 2023), Dkt. 79; and in the Second Circuit's +decision in that appeal, see United States v. Maxwell, 118 F.4th 256 (2d Cir. 2024). +In brief, the Government's evidence included the testimony of four women who +described the sexual abuse they had suffered, as girls, at the hands of Epstein and Maxwell; the +testimony of individuals who worked for Epstein and Maxwell; the testimony of law +enforcement officials; corroborating physical evidence, including photographs of and evidence +recovered from searches of Epstein's residences, and Epstein's and Maxwell's black address +book; and other corroborating records, such as flight logs of Epstein's private planes and FedEx +records. +The trial evidence focused on six girls, including the four testifying victims, who suffered +abusive sexual contact as a result of Maxwell's criminal actions: Jane, Kate, Annie, Carolyn, +Virginia, and Melissa. It established that Maxwell had been instrumental in an approximately +decade-long scheme with Epstein to entice, groom, transport, and traffic numerous young +women and underage girls to engage in sexual activity with Epstein. Maxwell helped identify +vulnerable girls for abuse, targeting those who faced difficult family circumstances, including +3 On April 16, 2021, Judge Nathan granted Maxwell's motion to sever the perjury charges. +Dkt. 207. After Maxwell's sentencing, the Government moved to dismiss these counts, in light +of victims' interests in closure and avoiding the trauma of testifying again. Judge Nathan +granted that motion. See Dkt. 670 at 5 n. l; Dkt. 737 at 99. +3 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 4 of 31 +financial hardship, substance use disorders, and prior sexual abuse. Maxwell purported to +befriend the girls to gain their trust and create the illusion of friendship and responsible adult +supervision, while isolating them from others. She then manipulated that trust to normalize +sexual abuse by Epstein and herself, often through the pretext of giving Epstein "massages." +Maxwell personally participated in acts of sexual abuse, including, for example, instructing +then-14-year-old Jane how to touch Epstein's penis during a "massage," and touching Jane's +breasts herself. Maxwell and Epstein also paid young girls hundreds of dollars of cash in +exchange for meeting Epstein to be sexually abused. Once a girl was introduced to these +sexualized massages, she was offered more money if she brought other girls to engage in +sexualized massages. Maxwell also fostered a culture of silence at Epstein's various households +where sexual abuse occurred, directing employees to "see nothing, hear nothing, say nothing." +C. Post-Trial Motions +On January 19, 2022, Maxwell moved for a new trial under Federal Rule of Criminal +Procedure 33, based on a juror's provision of inaccurate information during jury deliberations. +Dkt. 580. On April 1, 2022, after an evidentiary hearing, Judge Nathan denied that motion. +Dkt. 653. +On February 11, 2022, Maxwell made other pretrial motions, under Rules 29 and 33. +Dkt. 600. On April 29, 2022, Judge Nathan denied all but one of these motions. In the motion +she granted, Judge Nathan found that the three conspiracy counts were multiplicitous, and +therefore entered judgment on only one of them. Dkt. 657. +D. +Sentencing +Sentencing was held on June 28, 2022. The Government sought a sentence of at least +360 months' imprisonment. Dkt. 670 at 53. The defense sought a sentence below the Guidelines +4 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 5 of 31 +range (188-235 months) calculated by Judge Nathan. Dkt. 737 at 84. Eight victims submitted +victim impact statements. Dkt. 686. +Judge Nathan imposed an above-Guidelines sentence of 240 months' imprisonment. +Dkt. 737 at 96. Maxwell, she stated, had "directly[.] repeatedly, and over the course of many +years participated in a horrific scheme to entice, transport, and traffic underage girls, some as +young as 14, for sexual abuse by and with Jeffrey Epstein." Id. at 89. As an example, she noted, +after Carolyn had confided in Maxwell her personal history of having been raped and molested +by her grandfather starting at a very young age, Maxwell used that knowledge to continue the +"cycle of sexual abuse," inducing Carolyn to give Epstein "sexualized massages" for "years," +and by herself touching Carolyn's breasts when Carolyn was 14 years old. Id. at 90-91. Judge +Nathan also noted that Maxwell had repeatedly deflected blame and lied about her offenses, +including in a civil deposition and to Pretrial Services and the Court. Id. at 95.4 +E. +Appeal +On February 28, 2023, Maxwell appealed her conviction and sentence. United States v. +Maxwell, No. 22-1426 (2d Cir. Feb. 28, 2023), Dkt. 59. The Second Circuit affirmed. It upheld +Judge Nathan's (1) holding that a 2007 non-prosecution agreement between Epstein and the U.S. +Attorney's Office for the Southern District of Florida did not bar Maxwell's prosecution in this +District; (2) holding that the S2 Indictment had been timely filed; (3) denial of Maxwell's Rule +33 motion based on juror misconduct; (4) response to a jury note, which Maxwell had argued +resulted in a constructive amendment of or prejudicial variance from the S2 Indictment; and (5) +sentence as procedurally reasonable. United States v. Maxwell, 118 F.4th 256, 270 (2d Cir. +* Judge Nathan also sentenced Maxwell to a post-imprisonment term of five years' supervised +release and to pay a $750,000 fine (the maximum allowable). +5 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 6 of 31 +2024). On November 25, 2024, the Second Circuit denied Maxwell's petition for rehearing. +United States v. Maxwell, No. 22-1426 (2d Cir. Nov. 25, 2024), Dkt. 120. +On April 10, 2025, Maxwell petitioned for a writ of certiorari before the Supreme Court. +Her petition argues that Epstein's non-prosecution agreement with the U.S. Attorney's Office for +the Southern District of Florida barred her prosecution in this District. See United States v. +Maxwell, No. 24-1073 (S. Ct. Apr. 10, 2025). On July 14, 2025, the Government opposed the +petition. On July 28, 2025, Maxwell replied. As of this decision, the petition remains pending. +F. DOJ's Recent Statements Regarding the Disclosure of Epstein Records +On February 27, 2025, the Department of Justice ("DOJ") issued a press release. It stated +that the Attorney General ("AG") and Federal Bureau of Investigation ("FBI") had declassified +and were publicly releasing files relating to Epstein's exploitation of more than 250 girls. +Quoting the AG and the FBI Director, the press release stated: +"This [DO] is following through on President Trump's commitment to +transparency and lifting the veil on the disgusting actions of Jeffrey Epstein and his +co-conspirators," said Attorney General Pamela Bondi. "The first phase of files +released today sheds light on Epstein's extensive network and begins to provide the +public with long overdue accountability." +"The FBI is entering a new era one that will be defined by integrity, +accountability, and the unwavering pursuit of justice," said FBI Director Kash +Patel. "There will be no cover-ups, no missing documents, and no +unturned —and anyone from the prior or current Bureau who undermines this will +be swiftly pursued. If there are gaps, we will find them. If records have been +hidden, we will uncover them. And we will bring everything we find to the DOJ +to be fully assessed and transparently disseminated to the American people as it +should be. +U.S. Dep't of Just., Attorney General Pamela Bondi Releases First Phase of Declassified Epstein +Files (Feb. 27, 2025), https://www.justice.gov/opa/pr/attorney-general-pamela-bondi-releasesfirst-phase-declassified-epstein-files [https://perma.cc/H2QZ-WZCV].5 +5 The released documents are described and accessible on the DOJ's website. +6 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 7 of 31 +In the same press release, the DOJ quoted a letter from the AG to the FBI Director, +stating that the AG had just learned that the FBI possessed "thousands of pages of documents +related to the investigation and indictment of Epstein." The AG's letter continued: +By 8:00 a.m. tomorrow, February 28, the FBI will deliver the full and complete +Epstein files to my office, including all records, documents, audio and video +recordings, and materials related to Jeffrey Epstein and his clients, regardless of +how such information was obtained. There will be no withholdings or limitations +to my or your access. The [DOJ] will ensure that any public disclosure of these +files will be done in a manner to protect the privacy of victims and in accordance +with law, as I have done my entire career as a prosecutor. ... +I appreciate your immediate attention to this important matter. I know that we are +both committed to transparency for the American people, and I look forward to +continuing to work with you to serve our President and our country. +Id. +On July 6, 2025, the DOJ and the FBI issued another memorandum regarding Epstein. It +stated, in part: +As part of our commitment to transparency, the [DOJ] and the [FBI] have +conducted an exhaustive review of investigative holdings relating to Jeffrey +Epstein. To ensure that the review was thorough, the FBI conducted digital +searches of its databases, hard drives, and network drives as well as physical +searches of squad areas, locked cabinets, desks, closets, and other areas where +responsive material may have been stored. These searches uncovered a significant +amount of material, including more than 300 gigabytes of data and physical +evidence. +The files relating to Epstein include a large volume of images of Epstein, images +and videos of victims who are either minors or appear to be minors, and over ten +thousand downloaded videos and images of illegal child sex abuse material and +other pornography.... Only a fraction of this material would have been aired +publicly had Epstein gone to trial, as the seal served only to protect victims and did +not expose any additional third-parties to allegations of illegal wrongdoing. +Through this review, we found no basis to revisit the disclosure of those materials +and will not permit the release of child pornography. +This systematic review revealed no incriminating "client list." There was also no +credible evidence found that Epstein blackmailed prominent individuals as part of +his actions. We did not uncover evidence that could predicate an investigation +against uncharged third parties. ... +7 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 8 of 31 +One of our highest priorities is combatting child exploitation and bringing justice +to victims. Perpetuating unfounded theories about Epstein serves neither of those +To that end, while we have labored to provide the public with maximum +information regarding Epstein and ensured examination of any evidence in the +government's possession, it is the determination of the Department of Justice anc +the Federal Bureau of Investigation that no further disclosure would be appropriate +or warranted. +U.S. Dep't of Just., Untitled Memo (July 2025), https://www.justice.gov/opa/media/1407001 +/dl?inline, at 1. The memorandum included a hyperlink to video footage from Epstein's housing +unit, which, it stated, supported the FBI's investigative conclusion that Epstein had committed +suicide in his cell at the MCC on August 10, 2019. Id. at 2. +Ensuing news accounts reported public and congressional dissatisfaction with the July 6, +2025 memorandum, and calls for the release of records held by the DOJ and FBI regarding their +investigation into Epstein.° +" See, eg., +et al., Rift Erupts Among Justice, FBI Leaders Over Epstein Memo, +Sources Say, Wash. Post (July 11, 2025), https://www.washingtonpost.com/national-security/ +2025/07/11/trump-bondi-patel-bongino-epstein-files/; Sadie Gurman & Alex Leary, Top Trump +Officials Split Over Epstein Investigation Conclusion, Wall St. J. (July 11, 2025, 4:38 PM), +https://www.wsj.com/politics/policy/top-trump-officials-split-over-epstein-investigationconclusion-9449t83f; Emma Colton, DOJ Brass Vowed Full Transparency on Epstein Before +Turning Up Empty-Handed, Fox News (July 13, 2025, 4:56 PM), https://www.foxnews.com/ +politics/doj-brass-vowed-full-transparency-epstein-before-turning-up-empty-handed +[https://perma.ce/V8SV-KSRT]; Hannah Rabinowitz et al., House Speaker +Growing Number of Republicans Pressing Trump Administration for More Transparency on +Epstein Case, CNN (July 15, 2025, 7:05 PM), https://www.cnn.com/2025/07/15/politics/epsteinfiles-trump-bondi [https://perma.cc/7SCN-LGVZ]. +8 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 9 of 31 +II. Motion to Unseal the Maxwell Grand Jury Materials +On July 18, 2025, the Deputy Attorney General ("DAG") filed a three-and-a-half-page +motion to unseal the grand jury transcripts in this case. Dkt. 785 ("Motion to Unseal")? The +motion stated: +On July 6, 2025, the [DOJ] and [FBI] issued a memorandum describing an +exhaustive review undertaken of investigative holdings relating to Jeffrey Epstein +(the "Memorandum"). The Memorandum detailed the steps taken by the [DOJ] +and [FBI] to determine whether evidence existed that could predicate an +investigation into uncharged third parties. As the Memorandum concluded, no such +evidence was uncovered during the review. +Since July 6, 2025, there has been extensive public interest in the basis for the +Memorandum's conclusions. While the [DOJ] and [FBI] continue to adhere to the +conclusions reached in the Memorandum, transparency to the American public is +of the utmost importance to this Administration. Given the public interest in the +investigative work conducted by the [DOJ] and [FBI] into Epstein, the [DOJ] +moves the Court to unseal the underlying grand jury transcripts in [United States v. +Maxwell and] United States v. Epstein, subject to appropriate redactions of victimrelated and other personal identifying information. +Id. (citation omitted).® The motion noted that the Second Circuit has recognized that, in "special +circumstances," release of grand jury records may be appropriate even where not authorized by +Federal Rule of Criminal Procedure 6(e). Id. at 3 (citing In re Petition of Craig, 131 F.3d 99, +102 (2d Cir. 1997)) ("In re Craig"). +On July 22, 2025, after the case was reassigned to this judge, Dkt. 786, the Court issued +an order stating that it required further information to resolve the motion, Dkt. 789. It ordered +the Government, by July 29, 2025, to file a memorandum addressing the factors identified in In +" The same day, the DAG filed a similar motion on the docket of Epstein's case. See United +States v. Epstein, 19 Cr. 490 (RMB) (S.D.N.Y. July 18, 2025), Dkt. 61. +& On July 19, 2025, the +House press secretary announced that the President had directed +the AG "to move forward with requesting grand juries related to the Epstein files unseal their +relevant documents." +House, MAGA Minute (July 19, 2025), https://www.whitehouse +gov/videos/maga-minute-july-19-2025/ [https://perma.cc/Q3BJ-V24S]. +9 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 10 of 31 +re Craig; to disclose whether it had given notice of its motion to Maxwell's victims; and to file +under seal the grand jury transcripts (unredacted and as redacted for proposed public release) and +other grand jury materials, including exhibits. Id. at 3. The order authorized Maxwell and her +victims to file, by August 5, 2025, letters addressing the Government's motion.? +On July 29, 2025, the Government' submitted a memorandum responding to the July 22, +2025 order. It represented that it had now given notice of its filing to all but one victim, and +sought leave to file a supplemental submission responding to the victims' submissions. Dkt. 796 +("Gov't Mem."). The Government also filed, under seal, the grand jury materials the Court had +requested. +On July 31, 2025, the Court directed the Government to file a letter (1) stating whether, +as its July 29 memorandum suggested, it was moving to unseal the grand jury exhibits along with +the transcripts; and (2) identifying the portions of the grand jury transcripts and exhibits that, as +proposed for public release, are not already matters of public record. Dkt. 797. +On August 4, 2025, the Government submitted a letter seeking leave to advise the Court +by August 8, 2025, of its position with respect to unsealing the grand jury exhibits. Dkt. 800. It +also filed, under seal, a document indicating the portions of the grand jury transcripts that are not +matters of public record. +On August 5, 2025, Maxwell filed a letter opposing unsealing the grand jury transcripts. +Dkt. 803. That day and the next, the Court docketed a total of six letters that representatives of +° In a later order, the Court provided victims with logistical instructions for the submission (and +redaction) of their letters. Dkt. 801. +1° The July 29, 2025 filing (and all ensuing Government filings) were filed by both the DAG and +the United States Attorney for this District. +10 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 11 of 31 +victims and other witnesses had submitted to the Government, which the Government in turn +furnished to the Court. See Dkts. 804, 806. +On August 8, 2025, the Government clarified that it was moving to unseal the Maxwell +grand jury exhibits, subject to appropriate redactions, in addition to the transcripts. Dkt. 808." +It also submitted a sealed letter that identified the portions of those exhibits that were not already +matters of public record. +III. Grand Jury Secrecy: Applicable Legal Principles +A. Federal Rule of Criminal Procedure 6(e) +The policy that "proceedings before a grand jury shall generally remain secret" is "older +than our Nation itself." In re Biaggi, 478 F.2d 489, 491 (2d Cir. 1973) (quoting Pittsburgh Plate +Co. v. United States, 360 U.S. 395, 399 (1959)). The rule of secrecy "contribute[s] to the +success of grand juries and to the protection of those who appear before them." In re Craig, 131 +F.3d at 101-02. The purposes served by grand jury secrecy include: +(1) [tlo prevent the escape of those whose indictment may be contemplated; +(2) to insure the utmost freedom to the grand jury in its deliberations, and to prevent +persons subject to indictment or their friends from importuning the grand jurors; +(3) to prevent subornation of perjury or tampering with the witnesses who may +testify before [the] grand jury and later appear at the trial of those indicted by it; +(4) to encourage free and untrammeled disclosures by persons who have +information with respect to the commission of crimes; [and] +(5) to protect [the] innocent accused who is exonerated from disclosure of the fact +that he has been under investigation, and from the expense of standing trial when +there was no probability of guilt. +" The Court hereinafter refers to the grand jury transcripts and exhibits together as the "grand +jury materials." +11 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 12 of 31 +Id. (quoting United States v. Procter & Gamble Co., 356 U.S. 677, 681-82 n.2 (1958)) +(alterations in original); see also In re Biaggi, 478 F.2d at 491-92. +The rule of secrecy is today embodied in Rule 6(e), which bars disclosure of grand jury +matters by persons privy to them: grand jurors, attorneys for the Government, court reporters, +operators of recording devices, and interpreters. See Fed. R. Crim. P. 6(e)(2)(B). Rule 6(e)(3) +defines narrow exceptions. It authorizes disclosures: +• to other Government personnel assisting in the enforcement of federal criminal +law, id. at 6(e)(3)(A)-(B); +• to another federal grand jury, id. at 6(e)(3)(C); +• to law enforcement or national security officials, where the disclosures involve +foreign-intelligence or counter-intelligence information and assist in the +performance of official duties, id. at 6(e)(3)(D); and +• to persons as authorized by a court in the district where the grand jury convened, +id. at 6(e)(3)(E) (F), provided the disclosure is: "preliminarly] to or in +connection with a judicial proceeding," id. at 6(e)(3)(E)(i); "at the request of a +defendant who shows that a ground may exist to dismiss the indictment because +of a matter that occurred before the grand jury," id. at 6(e)(3)(E)(ii); "at the +request of the government, when sought by a foreign court or prosecutor for use +in an official criminal investigation," id. at 6(e)(3)(E)(iii); "at the request of the +government if it shows that the matter may disclose a violation of State, Indian +tribal, or foreign criminal law," provided that the disclosure is to an appropriate +such government official for the purpose of enforcing that law, id. at +6(e)(3)(E)(iv); or "at the request of the government if it shows that the matter +may disclose a violation of military criminal law under the Uniform Code of +Military Justice," provided that the disclosure is to an appropriate military +official for the purpose of enforcing that law, id. at 6(e)(3)(E)(v). +B. The "Special Circumstances" Doctrine +The Second Circuit has recognized that in "special circumstances," the disclosure of +grand jury materials may be appropriate even where it is not authorized by Rule 6(e). The +Second Circuit developed this doctrine in three cases where disclosure was sought of grand jury +matters claimed to be of unusual historical or public interest. See In re Biaggi, 478 F.2d at 492- +93; In re Craig, 131 F.3d at 101-02; Laws. ' Comm. for 9/11 Inquiry, Inc. v. Garland, 43 F.4th +12 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 13 of 31 +276, 285-87 (2d Cir. 2022) ("Lawyers" Committee for 9/11"). The doctrine is based on the +district court's supervisory authority over the grand juries it empanels. In re Craig, 131 F.3d at +102 & n.2. It today is recognized in the Second and Seventh Circuits, but not elsewhere.!? +The Second Circuit has set out a "non-exhaustive list of [nine] factors that a trial court +might want to consider when confronted with these highly discretionary and fact-sensitive +"special circumstances' motions." Id. at 106. These are: +(i) the identity of the party seeking disclosure; +(ii) whether the defendant to the grand jury proceeding or the government opposes +the disclosure; +(ill) why disclosure is being sought in the particular case; +(iv) what specific information is being sought for disclosure; +12 Most Circuits to address the issue have held that the only justifications for disclosing grand +jury matters are those set out in Rule 6(e)(3). See, e.g., McKeever v. Barr, 920 F.3d 842, 843, +850 (D.C. Cir. 2019), cert. denied, 140 S. Ct. 597 (2020); In re Grand Jury 89-4-72, 932 F.2d +481, 488 (6th Cir. 1991); United States v. McDougal, 559 F.3d 837, 841 (8th Cir. 2009); Pitch v. +United States, 953 F.3d 1226, 1241 (11th Cir. 2020) (en banc), cert. denied, 141 S. Ct. 624 +(2020). The Seventh Circuit is in accord with the Second Circuit that a district court may order +the release of grand jury materials upon a showing of special circumstances. See Carlson v. +United States, 837 F.3d 753, 766-67 (7th Cir. 2016). The First Circuit has held that a district +court may not authorize disclosure of grand jury materials based on their historical or public +interest, but has left open whether a court could do so "when the fair administration of justice in +a proceeding is at issue." Lepore v. United States, 27 F.4th 84, 93-94 (Ist Cir. 2022). +Before the D.C. Circuit's 2019 decision finding Rule 6(e) to supply the only bases for disclosure, +district courts in that Circuit had considered —and sometimes granted petitions to disclose +grand jury materials of historical importance, citing the Second Circuit's precedents recognizing +their authority to permit such disclosures. Compare In re Petition of Kutler, 800 F. Supp. 2d 42, +50 (D.D.C. 2011) (granting request to disclose President Nixon's grand jury testimony about +Watergate due to its historical importance), and In re Application to Unseal Dockets Related to +the Independent Counsel's 1998 Investigation of President Clinton, 308 F. Supp. 3d 314, 330-36 +(D.D.C. 2018) (ordering disclosure of some grand jury materials related to the investigation of +President Clinton's business dealings and his relationship with a +House intern), with In re +Shepard, 800 F. Supp. 2d 37, 39-40 (D.D.C. 2011) (denying as overbroad request for disclosure +of all testimony and materials associated with every witness before three Watergate grand juries), +and In re Nichter, 949 F. Supp. 2d 205, 212-13 (D.D.C. 2013) (denying disclosure of certain +grand jury records about Watergate because at least one subject of the testimony was still alive). +13 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 14 of 31 +(v) how long ago the grand jury proceedings took place; +(vi) the current status of the principals of the grand jury proceedings and that of +their families; +(vii) the extent to which the desired material-either permissibly or +impermissibly—has been previously made public; +(vili) whether witnesses to the grand jury proceedings who might be affected by +disclosure are still alive; and +(ix) the additional need for maintaining secrecy in the particular case in question. +Id. +The doctrine is to be applied only in "exceptional circumstances," and it does not justify +granting "garden variety" petitions for disclosure unauthorized by Rule 6(e). Id. at 103 (citation +omitted). The burden is on the requestor to demonstrate that disclosure is appropriate, and "the +baseline presumption [is] against disclosure." Lawyers' Committee for 9/11, 43 F.4th at 285 +(alteration in original). "IT]he discretion of a trial court in deciding whether to make public the +ordinarily secret proceedings of a grand jury investigation is one of the broadest and most +sensitive exercises of careful judgment that a trial judge can make." In re Craig, 131 F.3d +at 104; see also Lawyers' Committee for 9/11, 43 F.4th at 285-86. +IV. Discussion +A. The Government's Basis for Claiming "Special Circumstances" +No Rule 6(e)(3) exception authorizes the disclosure the Government proposes here: of, +subject to redactions, all testimony and exhibits before the two grand juries that indicted +Ghislaine Maxwell. The Government's motion to unseal does not contend otherwise. It does not +argue that these materials would aid federal, state, military, tribal, or foreign law enforcement; or +would be relevant to national security officials, another grand jury, or another judicial +proceeding. Nor does the Government (or Maxwell) argue that the materials could reveal a +14 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 15 of 31 +ground to dismiss the indictment against her. And any such motion to dismiss on this basis today +would very likely be futile, because Maxwell's conviction at trial renders all but the most serious +errors in the grand jury proceedings harmless. See Midland Asphalt Corp. v. United States, 489 +U.S. 794, 799-802 (1989) ("Only a defect so fundamental that it causes the grand jury no longer +to be a grand jury, or the indictment no longer to be an indictment, gives rise to the constitutional +right not to be tried."); United States v. Mechanik, 475 U.S. 66, 70-73 (1986). '3 +The Government instead invokes the "special circumstances" doctrine, on the ground that +there is an "abundant public interest" in obtaining additional information about Epstein and +Maxwell's crimes, and the DOJ and FBI's investigation into them. Gov't Mem. at 4; see also id. +at 1. It states that "[a]ttention given to the Epstein and Maxwell cases has recently intensified in +the wake of the July 6, 2025 Memorandum announcing the conclusions of the Government's +review into the investigation," id. at 5, and that release of the Maxwell grand jury materials is +essential to the goal of "transparency to the American public," which "is of the utmost +importance to this Administration," Motion to Unseal at 1. "Public officials, lawmakers, pundits, +and ordinary citizens," it states, "remain deeply interested and concerned about the Epstein +matter." Id. at 3. And the Maxwell grand jury materials, the Government represents, are +"critical pieces of an important moment in our nation's history," and "[t]he time for the public to +guess at what they contain should end." Id. at 3-4 (quoting In re Petition of Nat. Sec. Archive, +104 F. Supp. 3d 625, 629 (S.D.N.Y. 2015)). +13 A district court in the Southern District of Florida recently denied the Government's motion to +unseal grand jury materials relating to the Government's investigation of Epstein in that district, +finding that no Rule 6(e) exception applied. See Order Den. Pet. to Unseal Grand Jury Trs., In re +Grand Jury 5-02 (WPB) & 7-103 (WPB), 25 Misc. 80920 (S.D. Fla. July 23, 2025), Dkt. 4. +Because the Eleventh Circuit does not recognize the "special circumstances" doctrine, that +argument for disclosure was not available to the Government in that district. +15 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 16 of 31 +The Government's invocation of special circumstances, however, fails at the threshold. +Its entire premise—-that the Maxwell grand jury materials would bring to light meaningful new +information about Epstein's and Maxwell's crimes, or the Government's investigation into +them- +—is demonstrably false. +The Court, after receiving the Government's motion to unseal, ordered it to provide +materials to substantiate its claim that the Maxwell grand jury materials contained undisclosed +information of significant historical or public interest. Specifically, the Court ordered the +Government to submit the grand jury transcripts and exhibits for in camera review, with the +portions the Government proposed to redact highlighted. And it ordered the Government to file +a submission identifying the portions of the transcripts and exhibits, if any, that are not today +matters of public record, including based on Maxwell's month-long jury trial on the charges +returned by the grand jury. +The Government's submissions in response to the Court's orders were telling. They +belied the Government's claim, in its motion to unseal, that the Maxwell grand jury materials +contain significant, undisclosed information about Epstein's and Maxwell's crimes, or the +investigation into them. Two features of these materials, which were not disclosed in the +Government's motion, are noteworthy. The Court reports these here, at a level of generality that +does not disclose the substance of grand jury proceedings. +First, the grand juries in this case were not used for investigative purposes. They did not +hear testimony from any firsthand witness to any event at issue. They did not hear testimony +from any victim, eyewitness, suspect, or even a records custodian. The grand juries met instead +for the quotidian purpose of returning an indictment. +16 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 17 of 31 +Each grand jury received evidence on a single day. On that day, it heard testimony from +one person: a law enforcement agent who, acting as a summary witness, testified to information +obtained in the Government's investigation to support the charges in the proposed indictment. +The agent, responding to tightly structured questions from an Assistant United States Attorney +("AUSA"), provided highly abbreviated, hearsay accounts of the statements of select witnesses +(e.g., the victims on whom counts in the proposed indictment were based). 4 The agent led the +jury through a PowerPoint of exhibits (e.g., photographs and business records). At the end of the +testimony, the agent testified that he or she had not disclosed all that he or she knew, but had +only responded to the AUSA's questions. Afterwards, each grand jury voted to return the +proposed indictment. 's +14 Under federal law, "Fi]t is entirely permissible for the government to use hearsay evidence in +its presentation to the grand jury." United States v. +1. 413 F.3d 201, 213 (2d Cir. 2005) +(quoting United States v. Ruggiero, 934 F.2d 440, 447 (2d Cir. 1991)); see also United States v. +Dukagjini, 326 F.3d 45, 54 (2d Cir. 2003) (noting the common "grand jury practice, improper at +trial, of a single agent simply summarizing an investigation by others"). +15 The first Maxwell grand jury met on June 29, 2020. It heard testimony from an FBI special +agent. The agent's testimony lasted approximately one hour and 25 minutes, spanning 7. +louble-spaced transcript pages. Two exhibits were put before the grand jury: a PowerPoin +containing slides referred to during the agent's testimony; and the proposed indictment of +Maxwell. The same grand jury briefly met again on July 8, 2020, for the purpose of returning +the "S" superseding indictment, which corrected two typographical errors in the indictment. +Compare Dkt. 17, with Dkt. 1. The grand jury did not receive additional evidence. +The second Maxwell grand jury met on March 29, 2021. It heard testimony from a New York +Police Department detective. The detective's testimony lasted approximately an hour and 48 +minutes, not including a brief recess, and spanned 117 double-spaced transcript pages. Nearly +two-thirds of the testimony consisted of reading into the record the special agent's June 29, 2020 +testimony. Six exhibits were put before the grand jury: the transcript of the June 29, 2020 grand +jury testimony; the PowerPoint put before the June 29, 2020 grand jury; a new PowerPoint with +further exhibits; the two earlier indictments of Maxwell; and the proposed "S2" superseding +indictment. +17 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 18 of 31 +Second, the evidence put before the Maxwell grand juries is today, with only very minor +exceptions, a matter of public record. The Government admitted as much in response to the +Court's order: "The enclosed, annotated transcripts show that much of the information provided +during the course of the grand jury testimony—with the exception of the identities of certain +witnesses —was made publicly available at [Maxwell's] trial or has otherwise been publicly +reported through the public statements of victims and witnesses." Dkt. 800 at 3. And because +the Government proposes to redact the witnesses' identities, the exception it noted does not +reflect information that the public would learn were the grand jury transcripts unsealed. +The Court's review confirmed that unsealing the grand jury materials would not reveal +new information of any consequence. In response to the Court's order, the Government supplied +the Court with a binder highlighting any information that the Government had been unable to +determine is public. Only scattered words, clauses, and occasional sentences are highlighted. +These items are few and far between.! The highlighted snippets supply, at most, tertiary details +about the same conduct that was the focus of Maxwell's month-long trial. The same is so for the +exhibits put before the grand juries. Save inconsequential portions of a few exhibits, these were +received in evidence at Maxwell's trial. Some were reproduced in the Maxwell indictments. +A member of the public familiar with the Maxwell trial record who reviewed the grand +jury materials that the Government proposes to unseal would thus learn next to nothing new. +The materials do not identify any person other than Epstein and Maxwell as having had sexual +contact with a minor. They do not discuss or identify any client of Epstein's or Maxwell's. +They do not reveal any heretofore unknown means or methods of Epstein's or Maxwell's crimes. +16 And the Government's highlighting is significantly over-inclusive: On the Court's review of +the trial record, a number of items highlighted in fact were covered by testimony at Maxwell's +trial. +18 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 19 of 31 +They do not reveal new venues at which their crimes occurred. They do not reveal new sources +of their wealth. They do not explore the circumstances of Epstein's death. They do not reveal +the path of the Government's investigation. +Insofar as the motion to unseal implies that the grand jury materials are an untapped mine +lode of undisclosed information about Epstein or Maxwell or confederates, they definitively are +not that. A "public official," "lawmaker," "pundit," or "ordinary citizen" "deeply interested and +concerned about the Epstein matter," Motion to Unseal at 3, and who reviewed these materials +expecting, based on the Government's representations, to learn new information about Epstein's +and Maxwell's crimes and the investigation into them, would come away feeling disappointed +and misled. There is no "there" there. +This case is thus a far cry from every reported case applying the Second Circuit's +"special circumstances" doctrine. In each such case, the petition to unseal, whether granted or +denied, sought unique, undisclosed information. That information generally consisted of +firsthand testimony from a public figure or a witness to an important event. See, e.g., In re +Biaggi, 478 F.2d at 490-91 (granting petition to unseal grand jury testimony of New York City +mayoral candidate Mario Biaggi); In re Craig, 131 F.3d at 101 (denying petition to unseal 1948 +grand jury testimony of Harry Dexter +1, an Assistant Secretary of the Treasury accused of +being a Communist spy); In re Petition of Nat'/ Sec. Archive, 104 F. Supp. 3d 625, 626, 629 +(S.D.N.Y. 2015) ("In re National Security Archive") (granting petition to unseal 1950 grand jury +records leading to the indictment of Julius and Ethel +for conspiracy to commit +espionage); In re Petition of Am. Hist. Ass'n for Order Directing Release of Grand Jury Minutes, +49 F. Supp. 274, 278, 297-98 (S.D.N.Y. 1999) ("In re AHA") (granting in part and denying in +part petition to unseal transcripts of 1947-1950 grand jury testimony regarding alleged espionage +19 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 20 of 31 +by State Department official Alger Hiss); see also note 12, supra (citing similar D.D.C. cases). +None of these cases involved the secondhand, summary-witness testimony of law enforcement +agents. None involved testimony that, by the time of the motion, had already come to light as a +result of trial testimony by percipient witnesses on the indictment returned by the grand jury. +The Government has not cited any case finding such materials to present a "special +circumstance" that justifies the exceptional step of unsealing grand jury materials. There is none. +The one colorable argument under that doctrine for unsealing in this case, in fact, is that +doing so would expose as disingenuous the Government's public explanations for moving to +unseal. A member of the public, appreciating that the Maxwell grand jury materials do not +contribute anything to public knowledge, might conclude that the Government's motion for their +unsealing was aimed not at "transparency" but at diversion —aimed not at full disclosure but at +the illusion of such. And there is precedent—In re Biaggi, the fountainhead of the Second +Circuit's "special circumstances" doctrine permitting a court to order the release of grand jury +testimony to correct a movant's misleading public characterization of it. +In re Biaggi arose from a motion by a mayoral candidate, Mario Biaggi, to reveal his +earlier grand jury testimony, ostensibly to rebut a news report that he had invoked the Fifth +Amendment. 478 F.2d at 490-91. Denying he had done so, Biaggi asked, on television and later +in a motion, that the court examine his testimony and publicly confirm that he had claimed no +constitutional privileges. Id. at 491. The Government moved for disclosure of Biaggi's +testimony, redacted to protect others' names, and the district court granted that motion; Biaggi +appealed, seeking disclosure of his testimony without redactions. Id. The Second Circuit, per +Chief Judge Friendly, authorized disclosure of the testimony, emphasizing that Biaggi and the +Government had waived objections to disclosure, and that others' interests could be protected by +20 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 21 of 31 +redactions. Id. at 492-93. And once Biaggi's testimony had been released, the Circuit +elaborated in a supplemental opinion: In demanding that a court review his testimony, Biaggi +had misleadingly implied to the public that he had answered every question before the grand +jury. In fact, Biaggi had refused to answer 17 questions. Id. at 494. In these "special +circumstances," the Circuit stated, "the public interest required" disclosure of Biaggi's +testimony—in other words, to put the lie to Biaggi's false account. Id. +This Court gave careful consideration to unsealing the Maxwell grand jury materials on a +similar rationale. But with the Government having now conceded that the information it +proposes to release is redundant of the public record that this information was "made publicly +available at [Maxwell's] trial or has otherwise been publicly reported"-the public interest in +testing the Government's bona fides does not require the extraordinary step of unsealing grand +jury records. Dkt. 800 at 3. Without any need to review the grand jury materials, the public can +evaluate for itself the Government's asserted bases for making this motion. +The Court therefore denies the Government's motion to unseal at the threshold. Contrary +to the Government's depiction, the Maxwell grand jury testimony is not a matter of significant +historical or public interest. Far from it. It consists of garden-variety summary testimony by two +law enforcement agents. And the information it contains is already almost entirely a matter of +longstanding public record, principally as a result of live testimony by percipient witnesses at the +2021 Maxwell trial. +B. +Application of the In re Craig Factors +In cases involving grand jury testimony of significant historical or public interest, In re +Craig supplies a framework for evaluating whether disclosure, on balance, is warranted. It +identifies non-exclusive factors that may weigh against disclosure, including the interests of the +defendant and witnesses. Because the secondhand testimony at issue here is redundant of the +21 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 22 of 31 +public-record trial testimony of firsthand witnesses, and thus is not of significant historical or +public interest, there is arguably no charter for even undertaking the In re Craig inquiry. After +all, the "special circumstances" exception to Rule 6(e) only applies in "exceptional +circumstances," not to "garden variety" grand jury testimony. In re Craig, 131 F.3d at 103 +(citation omitted); see also Gov't Mem. at 3-4 ("acknowledg[ing] the extraordinary nature of +[its] request"). +Nonetheless, for completeness, the Court evaluates the Government's motion in light of +the non-exhaustive factors listed in In re Craig. The Court also addresses two other factors +implicated by the motion: the perspectives of Epstein's and Maxwell's victims, as expressed in +letters to the Court; and the systemic interest in grand jury secrecy. +As this assessment shows, the Government has failed, by a wide margin, to carry its +burden. These factors, considered together, favor denial of its motion to unseal. +Identity of the Party Seeking Disclosure +This factor ordinarily carries "great weight," and "the government's position should be +paid considerable heed." In re Craig, 131 F.3d at 106. But the Government's position is "not +dispositive." Id. "Government support cannot "confer' disclosure, nor can government +opposition preclude it." Id. And courts in this District, applying the In re Craig factors, have +ruled against the Government's position. See In re National Security Archive, 104 F. Supp. 3d +at 628-29 (ordering, over Government's objection, disclosure of testimony of two witnesses +before grand jury that indicted Julius and Ethel +for espionage); In re AHA, 49 F. +Supp. 2d at 278, 297-98 (ordering, over Government's objection, disclosure of testimony before +grand juries that investigated and/or indicted Alger Hiss for espionage). +This factor favors disclosure. But for two reasons, the Court accords this factor limited +weight. +22 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 23 of 31 +First, as the Second Circuit has explained, the Government's position is mainly relevant +because it reflects whether there is an ongoing need for grand jury secrecy. See In re Craig, 131 +F.3d at 106 (where "the government supports a motion for disclosure, that should serve as a +preliminary indication that the need for secrecy is not especially strong"). But the central +infirmity of this motion to unseal does not concern an ongoing need for secrecy in this case. The +infirmity is that, as the Government has conceded, the Maxwell grand jury materials do not +reveal information outside the public domain. +Second, any argument that the Government's motion to unseal merits substantial +deference is weakened by a host of irregularities with respect to that motion. That motion was +not made, nor has it been joined in, by any member of the Government's trial team the DOJ +lawyers presumably most familiar with the Maxwell case and the broader Epstein-Maxwell +investigation. The motion was filed by the DAG alone, without any signatory from the U.S. +Attorney's Office in this District. And it was made under circumstances suggestive of haste +rather than reflective deliberation. The motion was three-and-a-half pages in length; there were +no supporting materials filed, under seal or otherwise; the motion did not disclose (or reflect +awareness of) the summary-witness nature of the Maxwell grand jury testimony; and the motion +was made without advance notice to Epstein's and Maxwell's victims, a fact which, as reviewed +below, has alarmed numerous victims. Only after the Court inquired on that point was notice to +victims given. See Dkt. 789; Dkt. 796 at 9. Finally, the Government's highlighting of the grand +jury transcripts did not suggest close familiarity with the Maxwell trial record, because a number +of details that it identified as non-public in fact had been testified to during the trial. See note 16, +supra. +23 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 24 of 31 +Whether the Defendant to the Grand Jury Proceedings or the +Government Opposes Disclosure +Maxwell opposes disclosure because, among other reasons, her case remains on direct +appeal. Dkt. 803 at 2 ("Because this is ongoing litigation in a criminal case involving a living +defendant with existing legal remedies, the government's motion should be denied.") +This factor thus weighs against unsealing. The Court, however, assigns limited weight to +this factor because Maxwell, who does not have a legal right to access the grand jury materials, +has not seen it. Her opposition is therefore fairly viewed as precautionary. Had Maxwell been +aware that the grand jury materials are duplicative of information in the public record, her +position might have been different. +Why Disclosure Is Being Sought in the Particular Case +This factor addresses the present-day significance of the grand jury materials at issue and +whether their disclosure would advance the public interest. This factor so decisively weighs +against unsealing that it alone would require denying the Government's motion. +Arguments to disclose grand jury testimony on account of historical or public interest are +"totally appropriate" and sometimes may even be weighty. In re Craig, 131 F.3d at 106. But for +the reasons reviewed above, the grand jury materials here are neither of historical nor publicinterest importance. This evidence was put before the grand juries in June 2020 and March +2021, in a case that remains on direct appeal. Cf. In re National Security Archive, 104 F. Supp. +3d at 628-29 (1950 grand jury testimony regarding Julius and Ethel +); In re AHA, 49 +F. Supp. at 278, 297-98 (1947-1950 grand jury testimony regarding Alger Hiss). And it is not +of present-day public importance because it consists of summary testimony by law enforcement +agents recounting information that today is a matter of public record, on account of the monthlong trial on the charges returned by the grand jury. Cf. In re Biaggi, 478 F.2d at 494 (grand jury +24 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 25 of 31 +testimony of mayoral candidate exposing as false his representation to the public that he had +answered all questions before grand jury). And the Government's stated rationale for its motion +bears no resemblance to any "grounds that justify disclosure under the existing exceptions listed +in Rule 6(e)." In re Craig, 131 F.3d at 106. +In arguing that this factor favors disclosure, the Government makes broad proclamations +about the public's interest in learning more about the Epstein-Maxwell investigation. See Gov't +Mem. at 5 ("Many questions remain unanswered, and the public's interest remains." (quoting In +re AHA, 49 F. Supp. 2d at 294)). That interest is undeniable. But the Government has failed to +connect it to the materials at issue, which would not answer any of the public's questions. +This factor decisively weighs against unsealing. +4. +What Specific Information Is Being Sought for Disclosure +"The specificity of the data sought is significant in at least two ways." In re Craig, 131 +F.3d at 106. +First, there are obvious differences between releasing one witness"[s] testimony, +the full transcript, or merely the minutes of the proceeding. And, second, it is highly +relevant whether the disclosure is general or limited to a specified number of people +under special circumstances. +Id. at 106-107 (citation omitted). +Here, the Government does not seek tailored disclosure of discrete items within a grand +jury record. Nor does it seek leave to disseminate grand jury materials to a specified audience. +It seeks disclosure to the public at large of the entire proceedings before the Maxwell grand jury, +subject only to redactions aimed at protecting privacy. +This factor weighs against unsealing. The Government has identified no information of +consequence within the grand jury record that is not already public. And, under In re Craig, the +blanket quality of the motion to unseal weighs against unsealing. +25 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 26 of 31 +5. +How Long Ago the Grand Jury Proceedings Took Place +The Second Circuit has instructed: +The timing of the request remains one of the most crucial elements. Time matters +in several ways. First, if historical interest in a specific case has persisted over a +number of years, that serves as an important indication that the public's interest in +release of the information is substantial. (Hence the hypotheticals involving John +Wilkes Booth and Aaron Burr.)' Second, the passage of time erodes many of the +justifications for continued secrecy. See Douglas Oil [Co. v. Petrol Stops +Northwest, 441 U.S. 221, 222 (1979)] (noting that the interests in grand jury secrecy +are reduced after the grand jury has ended its activities). Third, the passage of time +eventually, and inevitably, brings about the death of the principal parties involved +in the investigations, as well as that of their immediate families. And the continued +existence and vulnerability of such parties is, of itself, a factor that a court should +consider. +Id. at 107 (footnote added). +This factor presents countervailing considerations. On the one hand, 20-30 years have +passed since Maxwell (and Epstein) committed the crimes for which they were charged. (The +conduct for which Maxwell was convicted spanned 1994 to 2004.) +On the other hand, the grand juries that indicted Maxwell met approximately five years +ago. Maxwell's trial occurred under four years ago. Her conviction remains on direct appeal. +And numerous victims of Epstein and Maxwell are still alive. These circumstances starkly +contrast with most precedents in this line of cases, which involved testimony decades earlier. +See, e.g., id. at 100 (1948 testimony); In re National Security Archive, 104 F. Supp. 3d at 626 +(1950 testimony); In re AHA, 49 F. Supp. 2d at 277-78 (1947-1950 testimony); see also note 12, +supra (citing similar D.D.C. cases). But see In re Biaggi, 478 F.2d at 492-93 (testimony less +than two years earlier). +' The Circuit, in illustrating earlier in its opinion why historical or public interest considerations +could justify the release of grand jury information, stated: "To the extent that the John Wilkes +ooth or Aaron Burr conspiracies, for example, led to grand jury investigations, historic +terest might by now overwhelm any continued need for secrecy." Id. at 10 +26 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 27 of 31 +This factor, on balance, weighs against unsealing. +6. +Current Status of the Principals of the Grand Jury and That of Their +Families +This factor is aimed primarily at protecting the reputations and interests of unindicted +individuals, about whom unsealed grand jury testimony would reveal damaging information not +previously disclosed. See In re Craig, 131 F.3d at 107. There is no such person or information +here. Insofar as Maxwell was the subject of the grand jury testimony, this factor suggests +considering here "the continued existence and vulnerability" of her and her family. Id. Maxwell +is alive and so theoretically could be harmed by the disclosure of adverse testimony. But here, +the grand jury materials, being cumulative of the public trial evidence, do not add anything to the +formidable public record inculpating her. And no family member of hers has expressed a +position on the motion to unseal. Gov't Mem. at 6. This factor is neutral. +Extent to Which the Desired Material Has Previously Been Made +Public +"IT]he extent to which the grand jury material in a particular case has been made public +is clearly relevant because even partial previous disclosure often undereuts many of the reasons +for secrecy." See In re Craig, 131 F.3d at 107. Here, as explained, substantially all the +information testified to by the summary witnesses in the grand juries has been revealed at +Maxwell's trial. And the Government proposes to redact victim identities, consistent with the +approach that it took at trial. This factor is consistent with unsealing. +8. +Whether Witnesses to the Grand Jury Proceedings Who Might be +Affected by Disclosure Are Still Alive +Both law enforcement agents who testified are still alive. Gov't Mem. at 7. The +Government, however, proposes to redact their names. This factor is neutral. +27 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 28 of 31 +Additional Need for Maintaining Secrecy in the Case in Question +The Government identifies under this factor the privacy interests of victims and third +parties referenced in the grand jury materials. Id. The Government proposes to redact their +names and other personally identifying information. On the Court's review, the proposed +redactions would satisfactorily do so. This factor is neutral. +10. +Perspectives of Epstein's and Maxwell's Victims +The Court has received, and reviewed with care and great respect, letters on behalf of +numerous victims of Epstein and Maxwell. See Dkts. 804, 806. Their letters address whether +the Maxwell grand jury materials should be disclosed. They also express broader concerns about +recent Government actions with respect to Maxwell and the Epstein-Maxwell investigation. +The letters, in the main, urge broad disclosure of the Government's investigative records +regarding Epstein and Maxwell. Consistent with this view, they generally support release of the +Maxwell grand jury materials, provided that, before release, any records be rigorously redacted +to protect identities and privacy. See, e.g., Dkt. 804 at 6 ("We are in full agreement with the +publie disclosure of the grand jury transcripts, and further state that all Epstein-related +information and documents in the possession and control of law enforcement, prosecutorial[.] +and other government agents and entities should be fully disclosed."). +This factor therefore favors unsealing. But there is an important qualification. The +victims' interest in reviewing the grand jury materials appears to be premised on the +understandable but mistaken belief that these materials would reveal new information. See, e.g., +id. at 10 ("Unsealing the grand jury transcripts would allow additional important information to +emerge ...."); id. at 9 ("[T]he instant motion for unsealing will help expose the magnitude and +abhorrence of Epstein's and Maxwell's crimes."). The Government had, after all, publicly +portrayed these as "critical pieces of an important moment in our nation's history." Motion to +28 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 29 of 31 +Unseal at 3. Had the Government's motion made clear that these records are redundant of the +evidence at Maxwell's public trial, the victims' responses to the motion to unseal might well +have been different. +Various letters also express alarm or dismay at other recently reported, or anticipated, +Government actions regarding Maxwell. ' These concerns, however, are properly directed to the +political branches. The Court has not considered them in resolving the motion to unseal. +11. +The Systemic Interest in Grand Jury Secrecy +A final consideration is systemic. "IT]he proper functioning of our grand jury system +depends upon the secrecy of grand jury proceedings." Douglas Oil Co., 441 U.S. at 218. For +that reason, the Supreme Court has instructed lower courts "considering the effects of disclosure +on grand jury proceedings" to assess "the possible effect upon the functioning of future grand +juries," mindful that "[p]ersons called upon to testify will consider the likelihood that their +testimony may one day be disclosed to outside parties." Id. at 222; see also Procter & Gamble +Co., 356 U.S. at 682 ("The grand jury as a public institution serving the community might suffer +if those testifying today knew that the secrecy of their testimony would be lifted tomorrow."); +Baker v. U.S. Steel Corp., 492 F.2d 1074, 1076 n.2 (2d Cir. 1974) (similar). +18 These include the Government's decision, while pursuing release of the grand jury materials, +to not publicly release further records from its investigation of Epstein and Maxwell, see, e.g., +Dkt. 804 at 9 (noting "the much larger volume of information available in the "more than 300 +gigabytes of data and physical evidence' in the Government's possession that should be +disclosed as well"); its "suggestion that no further criminal investigations are forthcoming," id. +at 8; its not having given notice to victims before it filed the instant motion to unseal, id. at 8, 16, +21; its transfer of Maxwell to a lower security prison, which, a letter states, "has further eroded +the victims' confidence that their safety and dignity are priorities," id. at 15; the possibility that +Maxwell might receive clemency, id. at 15-16; and the DAG's decision to meet with Maxwell +"as though she were a credible authority," which, one letter states, has publicly "legitimiz(ed] +her," id. at 15; see also id. at 20. +29 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 30 of 31 +That admonition requires courts applying the Second Circuit's "special circumstances" +exception to grand jury secrecy to invoke it only in rare, "exceptional circumstances," mindful of +the precedent that unsealing would set. In re Craig, 131 F.3d at 103. The exception, after all, +derives from a district court's supervisory authority over grand juries, id. at 102 & n.2, which +carries with it the duty to safeguard "the traditional functioning of the institution," United States +, 504 U.S. 36, 51 (1992). Applying the exception casually or promiscuously, as the +Government's motion to unseal the summary-witness grand jury testimony here invites, would +risk "unravel[ing] the foundations of secrecy upon which the grand jury is premised," In re +Craig, 131 F.3d at 103, and eroding confidence by persons called to testify before "future grand +juries," Douglas Oil Co., 441 U.S. at 222, that the general rule of secrecy still holds. +This factor weighs heavily against unsealing. Granting the Government's motion would +bloat the "special circumstances" doctrine, which to date has warranted disclosure in only a tiny +number of cases, all involving unique testimony by firsthand witnesses to events of obvious +public or historical moment. And it is no answer to argue that releasing the grand jury materials, +because they are redundant of the evidence at Maxwell's trial, would be innocuous. The same +could be said for almost any grand jury testimony, by summary witnesses or others, given in +support of charges that later proceeded to trial. +30 + + +Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 31 of 31 +CONCLUSION +For the reasons above, the Court denies the Government's motion to unseal the grand +jury materials in this case. The Clerk of Court is respectfully directed to terminate the motion at +docket 785. +SO ORDERED. +Paul A. Engelnager +PAUL A. ENGELMA' +United States District Judge +Dated: August 11, 2025 +New York, New York +31 diff --git a/vision-fixhub/court-05/6a6c528d4ce3dca34d1acc8a6925ecd16ed82acd305c2e7dc6dd3ddd71dda9db.receipt.json b/vision-fixhub/court-05/6a6c528d4ce3dca34d1acc8a6925ecd16ed82acd305c2e7dc6dd3ddd71dda9db.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fa91c1746170c230b23b6734a5383f2f9a36c881 --- /dev/null +++ b/vision-fixhub/court-05/6a6c528d4ce3dca34d1acc8a6925ecd16ed82acd305c2e7dc6dd3ddd71dda9db.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -384, + "dataset": "marble-joined", + "doc_id": "6a6c528d4ce3dca34d1acc8a6925ecd16ed82acd305c2e7dc6dd3ddd71dda9db", + "engine": "marble-apple-vision", + "event_count": 37, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "5babade16e3f9791731bbcaccfc0165dffe33ded8afa1833896aa1f17af39575", + "output_sha256": "c058c8650bbb100b971ffd8f67c63646af011f77e46ab9336ec7c9bf51c7af08", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6a7f3f929d0f8e97f8dc0ec0fa147a868a96608338a962a183170f46540345ca.md b/vision-fixhub/court-05/6a7f3f929d0f8e97f8dc0ec0fa147a868a96608338a962a183170f46540345ca.md new file mode 100644 index 0000000000000000000000000000000000000000..b00585cd33751ecd94bfb8f712a2919fca017cb4 --- /dev/null +++ b/vision-fixhub/court-05/6a7f3f929d0f8e97f8dc0ec0fa147a868a96608338a962a183170f46540345ca.md @@ -0,0 +1,3669 @@ +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 1 of 148 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +Case Number: 1:22-cv-10904-JSR +JAMES EDWARD STALEY +Third-Party Defendant. +STATEMENT OF MATERIAL FACTS AS TO WHICH +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS +CONTENDS THERE IS NO GENUINE DISPUTE +Epstein Engaged in a Sex-Trafficking Venture +1. +In the May 26, 2023 class certification hearing, counsel for JPMorgan stated, "I think the +way the Court could use those grand jury findings would be to ascertain something not contested, +which is Mr. Epstein was engaged in horrendous criminal activity, including sex trafficking. +That's not something being contested at all by JPMorgan." Tr. Class Certification Hr'g at 19:3-7, +Doe 1 v. JPMorgan Chase Bank, N.A., No. 22-cv-10019 (S.D.N.Y. May 26, 2023); see also id. at +33:10-14 ("Your colleague has just acknowledged, as indeed JPMorgan has repeatedly, that they +do not dispute, you do not dispute that Mr. Epstein was engaged in a longtime trafficking venture + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 2 of 148 +that involved enumerable young women and that required money to make it work." (emphasis +added)). +2. +In statements to the press following JPMorgan's settlement with Doe, JPMorgan stated: +"We all now understand that Epstein's behavior was monstrous, and we believe this settlement is +in the best interest of all parties, especially the survivors, who suffered unimaginable abuse at the +hands of this man." "Any association with him was a mistake and we regret it. We would never +have continued to do business with him if we believed he was using our bank in any way to help +commit heinous crimes." Ex. 1' +Ex. 2 at - 196. +4. +Ex. 3 at - 195. +Ex. 4 at - +460. +' All references to "Ex. +'" are to Exhibits to the Declaration of Mimi Liu. +2 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 3 of 148 +6. +In 2019, a grand jury found that Epstein "sexually exploited and abused dozens of minor +girls at his homes in Manhattan, New York, and Palm Beach, Florida, among other locations." +Sealed Indictment at 1, United States v. Epstein, 19-cr-490 (S.D.N.Y. July 2, 2019), ECF No. 1. +Ex. 5 at -364. The article stated that federal prosecutors had charged Epstein with sex trafficking +in July 2019, Epstein was arrested on July 6, 2019, and Epstein died on August 10, 2019. Ex. 6. +8. +Ghislaine Maxwell was indicted and arrested in 2020 by the United States Attorney's +Office for the Southern District of New York for conspiracy to entice minors to travel to engage +in illegal acts, enticement of a minor to travel to engage in illegal sex acts, conspiracy to transport +minors with intent to engage in criminal sexual activity, and transportation of a minor with intent +to engage in criminal sexual activity. Sealed Indictment, United States v. Maxwell, 20-cr-330 +(S.D.N.Y. June 29, 2020), ECF No. 1. Maxwell was convicted on June 28, 2022. +9. JPMorgan admits that Epstein pled guilty to "felony solicitation of prostitution and +procurement of minors to engage in prostitution," "was sentenced to 18 months in jail," and "was +required to register as a sex offender." Def. JPMorgan Chase Bank, N.A.'s Answer to 2d Am. +Compl. and Statement of Affirmative Defenses, 1 38, ECF No. 124. +10. +A Level 3 sex offender is the highest risk level and poses a "high risk of repeat offense and +threat to public safety." Ex. 7. +11. +In November 2011, Epstein's Level 3 sex offender status was unanimously affirmed by the +New York Supreme Court, Appellate Division. The court found that "[c]lear and convincing +evidence ... supported the assessment of points for risk factors sufficient for a level three sex +offender adjudication." +3 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 4 of 148 +The evidence before the [Sex Offender Registration Act] hearing court established +that defendant committed multiple offenses against a series of underage girls. The +girls were brought to defendant's home to provide "massages' that led to very +serious sex crimes. These facts were established by ... Florida law enforcement +authorities after their investigation .... The probable cause affidavit was extremely +detailed. It set forth the sworn, tape-recorded statements of the victims. The +victims" detailed accounts of defendants' crimes corroborated each other, and were +also corroborated by other evidence, including declarations against penal interest +made by defendant's accomplice. +People v. Epstein, 89 A.D.3d 570, 571, 933 N.Y.S.2d 239 (App. Div. Ist Dept. 2011). +12. +Ex. 8 at -006. +13. +At Ghislaine Maxwell's criminal trial, a victim testified under oath, using the pseudonym +"Kate." Kate testified that, starting when she was 17 years old, Maxwell and Epstein flew her "to +Palm Beach, to New York, and to the island," and Kate gave Epstein sexualized massages in each +of those locations. Trial Tr. at 1195:7-25, 1198:2-19, 1203:4-9, United States v. Maxwell, No. 20- +cr-330 (S.D.N.Y. Dec. 6, 2021), ECF No. 751. +14. +Bridgette Carr, an expert in human trafficking for the U.S. Virgin Islands, +15. +Ex. 9 at 65-66. +U.S. District Judge Marra stated in an opinion in February 2019: +4 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 5 of 148 +From about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor +girls, including Petitioners . .., at his mansion in Palm Beach, Florida and +elsewhere in the United States and overseas. Because Epstein and his coconspirators knowingly traveled in interstate and international commerce to +sexually abuse Jane Doe 1, Jane Doe 2 and others, they committed violations of not +only Florida law, but also federal law. In addition to his own sexual abuse of the +victims, Epstein directed other persons to abuse the girls sexually. Epstein used +paid employees to find and bring minor girls to him. Epstein worked in concert with +others to obtain minors not only for his own sexual gratification, but also for the +sexual gratification of others. +Jane Doe 1 & Jane Doe 2 v. United States, 359 F. Supp. 3d 1201, 1204 (S.D. Fla. 2019) (internal +citations omitted). +16. +After Epstein's death, Judge Berman held a hearing at which several of Epstein's victims +gave statements. Victim +testified: "On my third or fourth time meeting [Epstein +and Maxwell], they brought me to Jeffrey's island for the first time, and on the first night there, +came tapping on my door late at night to inform me Jeffrey was ready for another +massage." That night, Epstein sexually assaulted her. Hr'g Tr. at 44:4-22, United States v. Epstein, +No. 19-cт-490 (S.D.N.Y. Aug. 27, 2019), ECF No. 53. +17. At the same August 27, 2019 hearing, Jane Doe No. 9 testified: "[I]n 2004, when I was 15 +years old, I flew on Jeffrey Epstein's plane to Zorro Ranch, where I was sexual [sic] molested by +him for many hours." Id. at 75:10-12. +18. +Ex. 10 at -003. +Id. at -018. Over the course of their relationship, Epstein persuaded | +to give +Id. at -018-19. +Id. at -019-20. +5 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 6 of 148 +19. +Ex. 11 +at -036. +Ex. 12 at -029. +Id. +20. +Ex. +13 at -440-41. +Id. at -462. +21. +Ex. 15 at -458. +22. +Jane Doe 981 filed a creditor's claim in the Epstein estate probate proceeding, alleging that +Epstein sexually abused her in New York and the U.S. Virgin Islands "[b]eginning in 2004 and +continuing for years thereafter." Ex. 1692. +23. +filed a creditor's claim in the Epstein estate probate proceeding, alleging that +Epstein sexually abused her in New York, New Mexico, and the U.S. Virgin Islands from 2002 to +2004. Ex. 17 91 42-59. +24. +Dozens of Epstein's victims filed private civil suits against him and his coconspirators, +including but not limited to: +a. +Jane Doe No. 2, who alleged that in 2004 or 2005 when she was 16 years old, +Epstein sexually assaulted her during a massage in Epstein's Palm Beach residence. +Ex. 18 9 8. +6 + + +25. +26. +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 7 of 148 +b. +C. +d. +who alleged that in 2002, when | +was 16 years old, Epstein sexually +assaulted her more than 20 times during massages in his Palm Beach residence. Ex. +19 at "1l 24-37. Epstein paid _ +$300 each time. Id. at | 36. +Jane Doe No. 102, who alleged that Epstein abused her for four years starting in +1998 when she was 15 years old. She traveled with Epstein to locations including +New York City, Santa Fe, Los Angeles, San Francisco, St. Louis, Europe, the +Caribbean, and Africa, and in each location Epstein "abused her to serve his every +sexual whim." Ex. 20 99 17-20. +Jane Doe 43, who alleged that she was recruited into Epstein's sex trafficking +scheme beginning in October 2006 and continuing through April 2007. Ex. 21 +11 34, 38. Epstein and his recruiters told Doe 43 that Epstein would secure her +admission to fashion school in New York City. Doe 43 was coerced into engaging +in sexual acts with Epstein both in New York and in the U.S. Virgin Islands. Id. +• 45. While in the U.S. Virgin Islands, Epstein maintained control of Doe 43's +passport and once conducted a search party to find Doe 43 after she attempted to +escape the island. Id. 949. +Ex. 9 at 74. +Ex. 22 at -454. +Id. at -464. +7 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 8 of 148 +Id. at -466. +Id. at -474. +27. +Ex. 22 at -500. +Id. at -536. +Id. at +-566. +28. +Ex. 23 at -570. +Id. at -572. +Ex. 24 at -256-57. +29. +Ex. 24 at -205-06. +Ex. 25 at - +8 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 9 of 148 +401-02. +Id. at 391-92. +30. +Ex. 25 at -381-82. +Id. at -362-63. +Id. at - 339-40. +Ex. 26 at - +491-92. +31. +Ex. 26 at -473-74. +Id. at -429-30. +Id. at -423-24. +32. +a. +Ex. 27 at -408. +Id. +9 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 10 of 148 +b. +Ex.27 at -406. +Id. +C. +Ex. 27 at -403. +d. +Ex. 27 at -403. +e. +Ex. 27 +at -406. +f. +Ex. 27 at -407. +g. +Ex. 27 at -407. +10 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 11 of 148 +JPMorgan Knew or Recklessly Disregarded that Epstein Ran a Sex-Trafficking Venture +33. +JPMorgan admits Mary Erdoes, Catherine Keating, and Mary +were aware in 2006 +that Epstein was arrested for solicitation of prostitution. Ex. 28 at Resps. 90, 147, 112. +34. +An internal JPMorgan document defines Know Your Client (KYC) as a "due diligence +process that ensures we 'know' the clients we deal with and understand how and why they use our +products and services. Without KYC, we become vulnerable. Unknowing to us, our clients could +easily use PCS as a vehicle to perpetrate illegal activities." Ex. 29 at -026. +35. +Ex. 30 at -915. +36. +Red Dot information "is any derogatory information identified by Global Security Services +which warrants the attention of the banker." Ex. 31 at -574. +37. +JPMorgan's due diligence process required that it research and review news publications +about clients or clients' businesses. Ex. 32 at 42:13-19. +38. Negative news media was one of the main categories of information reviewed as part of +JPMorgan's ongoing due diligence monitoring. Ex. 33 at 53:3-54:3; 60:8-20. +Ex. 34 at 31:14-32:10. +JPMorgan's Global Security Services searched databases for negative media regarding clients to +escalate to bankers and risk management. Ex. 35 at 340:6-341:3. JPMorgan Private Bank +conducted negative media reviews as part of its approach to determine whether a client's activity +was suspicious. Ex. 36 at 187:25-188:22. +39. +A JPMorgan Due Diligence Report for Epstein's entity YHS, LLC includes a section for +news publications. Ex. 37 at - 185-199. +11 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 12 of 148 +40. +Another JPMorgan Due Diligence Report for Epstein includes a section for news +publications. Ex. 38 at -558-567. +41. +JPMorgan admits certain JPMorgan employees received, reviewed, or read articles +covering Epstein's 2006 arrest in Florida. Ex. 39 at Resps. 32, 33. +42. +JPMorgan admits certain JPMorgan employees received, reviewed, or read a 2006 Palm +Beach Post article stating that Epstein was indicted on one count of felon[y] solicitation of +prostitution. Ex. 39 at Resp. 41. +43. +The 2006 Palm Beach Post article states: "Palm Beach billionaire Jeffrey Epstein paid to +have underage girls and young women brought to his home, where he received massages and +sometimes sex" and "police thought there was probable cause to charge Epstein with unlawful sex +acts with a minor and lewd and lascivious molestation." Ex. 40 at 1. The article lays out in detail +evidence from the Palm Beach Police Department Probable Cause Affidavit, including: +a. +A college student gave Epstein a naked massage and then "brought him six girls, +ages 14 to 16, for massage and sex-tinged sessions" at Epstein's home. Id. at 2. +A 27-year-old Epstein employee, +prepare the massage table. Id. at 2. +would arrange the sessions and +c. +Police obtained statements from five alleged victims and 17 witnesses. Police +contend Epstein "had sex with the girls" on three occasions. Id. at 2. +d. +met Epstein at age 17 and was recruited to massage him. Epstein told +her he would "pay her to bring him more girls- the younger the better." She stated +she once brought a 23-year-old woman to him and "Epstein said she was too old .. +.." She brought six girls to Epstein and said the girls were paid $200 for each +session. +told police, "I'm like a Heidi Fleiss." Id. at 3. +e. +One 14-year-old vietim recounted the details of her encounter in February 2005 +including being paid $300 for a massage in her bra and panties. For bringing this +child to Epstein, +received $200. Id. at 3. +f. +Police scoured the trash from Epstein's house and found notes with names and +phone numbers, sex toys and female hygiene products. Notes stated that one female +12 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 13 of 148 +could not "come over at 7 p.m. because of soccer. Another said a girl had to work +Sunday— 'Monday after school?' And still another note contained the work hours +of a girl, saying she leaves school at 11:30 a.m. and would come over the next day +at 10:30 a.m." Id. at 4. +The 2006 Palm Beach Post article also states, "Palm Beach police often conducted +surveillance ... at Palm Beach International Airport to see if his private jet was there ...." Ex. 40 +44. +at 4. +45. The 2006 Palm Beach Post article said that Epstein paid $200 or $300 cash to the girls and +$200 cash to +for recruiting the girls. Ex. 40 at 3. +46. JPMorgan admits the 2006 Palm Beach Post article mentioned +Ex. 39 at +Resp. 42. +47. The Palm Beach Police Department Probable Cause Affidavit discussed in the 2006 Palm +Beach Post article was filed May 1, 2006. Ex. 41 at 24. +48. JPMorgan admits certain of its employees received, reviewed, or read one or more articles +that reference +JPMorgan otherwise refers to those articles for their contents. +Ex. 39 at Resp. 43. +49. A July 28, 2006 ABC News article, "Warrants Were Prepared to Arrest Others in Millionaire +Sex Scandal," states: "Palm Beach police were planning to arrest two women in connection with +their investigation into Jeffrey Epstein... +Epstein's assistant... and +.. who police say was paid by Epstein to bring over young and underage girls to his house to massage +Epstein .... Another woman involved in the scandal was Epstein's girlfriend +.. Though the documents do not mention that any charges were being sought against +one girl, who began massaging Epstein when she was 16 years old, told police that she was paid by +Epstein to have sex with +a as he watched. The girl also told police that 'Epstein bragged +he brought her +into the United States to be his Yugoslavian sex slave,' according to +13 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 14 of 148 +the documents." The article also states that the police submitted arrest warrant requests for | +and +According to the report, "l +was to be arrested... on four counts +of unlawful sexual activity with certain minors and ... on one count of lewd and lascivious +molestation. +warrant was for lewd and lascivious acts on a victim under 16 years of age." +Ex. 42 at - 657. +50. +On August 14, 2006, Doreen +emailed Maria Hornak, Mary +and other +JPMorgan employees, subject: "Re: Article of J Epstein's Arrest" with the link +http://www.nypost.com/news/regionalnews/mystery_moguls_teen_sex_secret_bared_in_probe_r +egionalnews_dan_mangan.htm. Ex. 43 at -859. The article states: +a. +"….. According to one girl, 'Epstein asked for her real age, [and she] stated she was +16. Epstein advised her not to tell anyone her real age,' the records say. The girl +alleged Epstein paid her to have sex with his girlfriend, +Epstein would then watch the women have sex and take photos of their trysts to +display at home, the records claim. ... The teen told cops she always refused to +have intercourse with Epstein .. +. But one time ... Epstein allegedly grabbed her +and forced himself on her. When the girl became upset and screamed, 'No!' Epstein +apologized, and he later paid her $1,000 for the visit, the records allege. Palm Beach +cops prepared an arrest-warrant request proposing that Epstein be charged with +unlawful sexual activity with certain minors and with lewd and lascivious +molestation. Instead, in a rare move, prosecutors brought the evidence to a grand +jury, which indicted Epstein only on the prostitution charge. The frustrated police +now have given their evidence to the FBI's Miami division, which is considering +14 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 15 of 148 +whether to investigate Epstein for possible federal crimes involving underage girls, +said Special Agent Judy Orihuela." +b. +The article also states that Epstein's "assistant, +helped arrange the +sessions" and that "[s]everal girls allege that +26, led them to Epstein's +bedroom, where she would set up a massage table and give them oils to rub +on Epstein. Cops wanted to charge +and +for their roles in procuring +the girls..." Ex. 43 at 3-4. +51. +In "AML Operations Human Trafficking Overview, A "Reference Document on human +trafficking prepared by JPMorgan Corporate AML Compliance," dated August 5, 2008, JPMorgan +states: "Sexual Slavery" means "the coercion of the unwilling into various sexual practices." Ex. +44 at -052. +52. +Ex. 45 at - 395-97. +53. +On July 25, 2006, Staley met with Epstein in person at Epstein's home. In that visit, Epstein +admitted to the alleged "conduct of engaging in sex for money with young women"— only denying +the "ages"-to Staley. Ex. 46 at 796:11-799:6. +54. +On July 26, 2006, Staley wrote Erdoes: "I went and saw him last night. I've never seen him +so shaken. He also adamantly denies the ages." Ex. 47 at -334. +55. +Staley admits that in 2006 Jamie Dimon communicated with him regarding Epstein's arrest +on charges of procuring a minor for prostitution and solicitation of a prostitute. Ex. 48 at Resp. +15 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 16 of 148 +111. Staley also testified that on or about July 26, 2006, he spoke to Dimon about Epstein's +indictment because Dimon was his boss and the indictment of Epstein, a client of the bank, "was +a very public event." Ex. 46 at 17:2-19:16. +56. +JPMorgan admits that certain of its employees received, reviewed, or read the 2003 Vanity +Fair article, "The Talented Mr. Epstein" and refers to the article for its content. Ex. 39 at Resp. 36. +57. +In May 2003, +(then Rieth) sent the Vanity Fair article along with the Due Diligence +Report ("DDR") for Epstein's Financial Trust Company, Inc. to JPMorgan employee Paul Lahiff +so he would "get everything at once." Ex. 49 at -281. +58. +"The Talented Mr. Epstein" states: "Epstein is known about town as a man who loves +women—lots of them, mostly young. Model types have been heard saying they are full of gratitude +to Epstein for flying them around, and he is a familiar face to many of the Victoria's Secret girls. +One young woman recalls being summoned by Ghislaine Maxwell to a concert at Epstein's town +house, where the women seemed to outnumber the men by far. "These were not women you'd see +at Upper East Side dinners,' the woman recalls. 'Many seemed foreign and dressed a little +bizarrely.' This same guest also attended a cocktail party thrown by Maxwell that Prince Andrew +attended, which was filled, she says, with young Russian models. "Some of the guests were +horrified,' the woman says." Ex. 49 at p. 7-8. +59. +"The Talented Mr. Epstein" states: "There are many women in his life, mostly young, but +there is no one of them to whom he has been able to commit. He describes his most public +companion of the last decade, Ghislaine Maxwell, 41, the daughter of the late, disgraced media +baron Robert Maxwell, as simply his "best friend." Ex. 49 at 3-4. +60. +16 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 17 of 148 +Ex. 50 at -790-790_003. +ld. at - 790_003. +61. +Ex. 51 at -792-792_003. +Id. at - 792_003. +62. +Ex. 52 at -791-791 +1003. +63. +Id. at 791_003. +A JPMorgan training document "What is Human Trafficking" identified "structured +transactions" as a "Key Indicator/Red Flag[] of potential Human Trafficking activity." Ex. 53 at - +918; Ex. 33 at 186:3-188:13, 191:23-192:7. +64. The JPMorgan training document also states: "Previous AML history, while not +necessarily HT-related, may be associated with an investigation related to suspicious activity, such +as interstate, excessive, or structured cash activity." Ex. 33 at 191:23-192:7. +65. +Ex. 54 at -390. +17 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 18 of 148 +66. +Ex. 55 at -475. +67. +From October 1999 through July 2006, JPMorgan handled $25,146,955.30 in payments +from Epstein's JPMorgan accounts to Ghislaine Maxwell. Ex. 56 at 45-46 and Figure 15.? +68. +Ex. 61 at -033. +69. +70. +71. +was a customer of JPMorgan. Ex. 62 at Resp. 7. +had a credit card with the Retail Bank. Ex. 63 at 651. +In 2005, JPMorgan made two separate $25,000 payments from Epstein's JPMorgan +accounts to +Ex. 56 at 34, 36, and Figure 9.3.3 +72. From August 2006 through August 2013, JPMorgan handled $678,741.57 in payments +from Epstein's JPMorgan accounts to +Ex. 56 at 34, 36, and Figure 9.3. +73. +was a customer of JPMorgan. Ex. 62 at Resp. 6. +74. +teenagers, +In 2004, sponsored by Epstein, JPMorgan opened accounts and credit cards for two +and +1. "models in NYC and friends of Jeffrey Epstein." Ex. 65 +at -316; Ex. 66 at -804; Ex. 36 at 230:6-231:20. +75. +Ex. 67 at -700. +2 Figure 15 is a summary of information from the following account statements: Epstein's +PMorgan account ending in 0438 (Ex. 57); Epstein's JPMorgan account ending in 1001 (Ex. 58) +inancial Trust's (owned by Epstein) JPMorgan account ending in 0001 (Ex. 59); and Financia +Trust's (owned by Epstein) JPMorgan account ending in 5001 (Ex. 60). +Figure 9.3 is a summary of information from the following account statements: Epstein' +PMorgan account ending in 0438 (Ex. 57); Butterfly Trust's JPMorgan account ending in 281 +18 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 19 of 148 +76. +The DDR for +was approved by the Private Bank even though there was no +birthdate, passport number, driver's license number, or "confirmed" social security number. The +Private Banker ( +never met +as JPMorgan's process contemplated. Ex. 68 at - +567. +77. The DDR stated that" +is a Slovakian citizen who has come to the US +for modelling work. Jeffrey Epstein knows the model personally." and "Jeffrey Epstein often +provides support to emerging models. In this case, +has arrived from the Slovak +Republic and Epstein has asked us the favor of opening a checking account for her and he will +guarantee her credit card application." Ex. 68 at -567. +78. The DDR represented +net worth as $100,000 "earned" from "modeling +assignments." Ex. 68 at -566. +79. The DDR listed +address as +80. +Ex. 68 at -565; Ex. 69 at -545. +In 2004, 2005, and 2006, JPMorgan handled $36,565.56, S67,754.28, and $82,897.80, +respectively, in payments from Epstein's JPMorgan accounts to +Ex. 56 at 34-35 and +Figure 9.2.4 +81. On January 7, 2011, Ryan (AML Compliance) emails DeLuca (AML Compliance), +copying Middlemiss (AML Compliance): "I also spent a good deal of time looking at his assistant +or young lady he brought over from Praque( [sic] or some place like that) account. She was +involved in some of the detailed escapades. She opened accounts in PB sponsored by him. +my +were her debit transactions enlighting [sic] as compared to countless stories related to his +4 Figure 9.2 is a summary of information from the following account statements: Epstein's +Morgan account ending in 0438 (Ex. 57); Butterfly Trust's JPMorgan account ending in 2810 +19 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 20 of 148 +escapades. Lots of salon, lingerie shops, drug stores ny palm beach and in st +(his places +of residence). Plus lots of video like girls gone +and some other shops not fit for my good +catholic upbringing! The transactions are old 05 to 08. Besides frequent frequent spa like charges +it has died down. Surprised she was never subpoenaed." Ex. 70 at -749_R. +82. +JPMorgan's own Human Trafficking +paper, "Human Trafficking Finance: Nature, +Scope and Control Project," discussed "upscale" sex-trafficking operations "incurr[ing] expenses +such as jewelry, lingerie, cosmetics, [and] sex toys." Ex. 71 at -983. +83. +From August 2006 through January 2013, JPMorgan handled $607,804.30 in payments +from Epstein's JPMorgan accounts to +1. Ex. 56 at 34-35 and Figure 9.23 +84. +Ex. 2 at -196. +Id. at - +196. +85. The article cited +"Meet +Part of Epstein Scandal," first published on July 28, 2006, referred to +Epstein scandal" and "an unknown Czech sex puppet" of Epstein's. Ex. 72 at 1-2. +Star Girl of the Raunchiest +as "star girl of +•Figure 9.2 is a summary of information from the following account statements: Epstein's +Morgan account ending in 0438 (Ex. 57); Butterfly Trust's JPMorgan account ending in 2810 +20 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 21 of 148 +86. +On March 8, 2007, Maria Hornak forwards an email from Rich Kahn (Epstein's +accountant) to Mary +, subject "FW: New Chase Credit Cards" with the attachment "JE - +Chase Credit Cards.xls." Ex. 73 at -494. The attachment lists "Jeffrey Epstein Chase Credit Cards" +for +and +through NES LLC c/o Jeffrey Epstein. Expected charges on the credit +cards were for "travel[] through Paris, Europe and US Virgin Islands and US monthly." Id. at - +496. +87. The attachment also lists credit cards for Larry Visoski and David Rodgers, +through Jege, LL.C. Ex. 73 at -496; Ex. 24 at - 198. +88. +On June 9, 2010, Bonnie +(in Private Bank Risk Management) emailed Epstein's thenbanker (Paul Morris): "3 entities within the relationship do not currently have DDRs ...116 East +65" St LLCL.] NES, LLC[, and] Zorro Trust." Ex. 74 at -237. +89. +Ex. 75 at -318. +90. On October 17, 2006, JPMorgan held a "Rapid Response Team" meeting. Ex. 76 at -953. +91. Rapid Response meetings were "escalations of ... derogatory information to management +... [who would] review it and make a determination on how they want to proceed." Ex. 77 at +53:21-54:4. +92. +The Rapid Response meeting memo notes: "Derogatory Information reported by Security +Services. ... Several newspaper articles were found that detail the indictment of Jeffrey Epstein +in Florida on felony charges of soliciting underage prostitutes." Ex. 76 at -953. +93. +The memo from the Rapid Response meeting stated that Epstein had accounts "with +balances totaling approximately $32 million." The Rapid Response memo also noted: "Cash +withdrawals are routinely made in amounts for $40,000 to $80,000 several times a month, which +total over $750,000 year to date." Ex. 76 at -953. +21 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 22 of 148 +94. +Ex. +78 at -995. +95. +96. +In 2004 and 2005, JPMorgan recorded cash withdrawals from Epstein's JPMorgan +accounts totaling $1,744,337. Ex. 56 at 24-26 and Figure 8.° +Ex. +80 at - 718-19 (emphasis added); Ex. 36 at 19:13-19. +97. +Id. at -937. +Id. at-936. +• Figure 8 is a summary of information from currency transaction reports filed by JPMorgan (Ex. +79). +22 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 23 of 148 +98. +On July 18, 2013, Ryan (AML compliance) emailed DeLuca (AML compliance), subject +Epstein more info found, and states: "Issue is he really never stopped the large cash withdrawals." +Ex. 82 at -965. DeLuca responds, "Shouldn't the business have been telling us this?" Id. at -965. +99. On July 19, 2013, John Duffy (then CEO US Private Bank) emails Erdoes (then CEO +AWM), subject JE talking points, and asks what Erdoes thinks of three talking points for Epstein's +exit conversation: "1. The repetitive nature of your cash transactions is a problem for us and our +relationship with you[:] 2. The regulatory standards in the banking industry continue to evolve +with a very low tolerance for cash activity when combined with your personal historyl:] 3. So, +given the intersection of these circumstances we are in a uniquely challenged situation. +Remediation is required and we need to ask you - in an orderly manner - to find another bank for +your needs." Ex. 83 at -966. Erdoes replies, "I think that is fine," Id. +100. The Rapid Response Team memo states: "Conclusion from follow-up Rapid Response of +1/07/11: Further meetings held with Jes Staley to discuss LOB decision for reapproval. Banker +Paul Morris spoke with Mr. Epstein with regard of large cash withdrawals. Mr. Epstein withdraws +anywhere from $2OK to $40K in cash to pay for fuel expenses when he travels to foreign countries. +Banker Paul Morris was instructed by the Committee to update the entity KYC which holds the +operating account for Mr. Epstein's personal airplane, Hyperion, to document the purpose of the +cash withdrawals. Further, Paul Morris informed Mr. Epstein that the SBLC [Stand By Letter of +Credit to MC2] would not be renewed. Mr. Epstein will continue to be a banking only client." Ex. +84 at -932. +101. +23 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 24 of 148 +Ex. 85 at -825. +Id. at -826. +102. +Ex. 86 at -885, -890. +103. +24 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 25 of 148 +Ex. 87 at -089-93, -096. +Id. at -094. +104. +Ex. 88 at 176:12-177:10, +344:23-346:17. +105. The Rapid Response memo states: "During the period of March 2010 to December 2010, +there were eight large cash withdrawals totaling $240,000 where Currency Transaction Reports +were filed." Ex. 84 at -930. +106. Epstein was in jail from June 30, 2008 to July 2009 (13 months) and on house arrest from +July 2009 to July 20, 2010. Ex. 89 at -049; Ex. 90 at -814-815. +107. The Rapid Response memo includes excerpts from the press and quotes a Palm Beach Post +article dated August 1, 2010: "According to the news website The Daily Beast, the feds are also +checking whether a modeling agency run by a friend of the Wall Street investor Epstein fed his +appetite for underage foreign girls. Epstein was known to fly young women from Eastern Europe +to Palm Beach, where they'd massage him, among other services. Because of double jeopardy +rules, Epstein - now a registered sex offender - can never be prosecuted again for crimes covered +by the state charges. He pleaded guilty to felony solicitation of prostitution and procuring a person +under 18 for prostitution, also a felony. Child trafficking, however, would offer two advantages to +federal prosecutors: The charge would not be covered by double jeopardy; and there's no statute +of limitations." Ex. 84 at -930. +108. In 2006, JPMorgan's due diligence included multiple news reports that Epstein +"assembl[ed] a team of star lawyers" including Alan Dershowitz, Jack Goldberger, Roy Black, +and Gerald Lefcourt—to "look into the backgrounds of his young accusers" and "to undermine the +25 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 26 of 148 +credibility of the 14- to 17-year-old girls." Ex. 37 at -188, -196. The same set of reports explain +that another of Epstein's lawyers, Jack Goldberger, said Epstein "would never knowingly break +the law." Id. at -192. Gerald Lefcourt, "one of Epstein's high-powered lawyers," says his client is +innocent[J" Id. at - 194. "Epstein's camp was ready 'to get their story out.' They did that Monday +via Goldberger and ... attorney Roy Black, who also has represented Epstein in the case. 'We just +think there has been a distorted view of this case in the media presented by the Palm Beach Police." +Id. at - 197. +109. +On July 26, 2006, Philip Schlakman emailed +(then Epstein's banker), subject: +"epstein press" and states "it gets worse" with a link to a Palm Beach Post Article that notes the +Palm Beach police spent months monitoring the Palm Beach International Airport to keep tabs on +Epstein's private jet. Ex. 91 at -335, 1. +110. +Ex. 45 at -395, -397-98. +111. +26 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 27 of 148 +Ex. 45 at -397. +112. +In September 2007, Lisa Waters (then Managing Director AWM) emails Erdoes an article +about Epstein from Page Six that stated: "Sources tell Page Six that Epstein's high-powered +lawyers - including Alan Dershowitz, Gerald Lefcourt, Roy Black and Kenneth Starr - have been +negotiating a deal with federal prosecutors who are probing, among other things, whether the grayhaired money manager paid West Palm Beach girls for sex or transported them across state lines." +Ex. 92 at -501. +113. In a June 17, 2013 internal risk assessment matrix, JPMorgan acknowledged allegations +that Epstein "supposedly bought his way to a lesser sentencing" and "paid a whole series of girls +to stay quiet." Ex. 93 at -344 (Name Risk tab). +114. +On September 24, 2007, Epstein agreed to plead guilty to two prostitution charges in state +court, including the solicitation of a minor to engage in prostitution, in exchange for a federal nonprosecution agreement ("NPA") providing him with immunity from federal child sex-trafficking +charges. Ex. 94 at -010-011. +115. +JPMorgan's due diligence on Epstein in October 2007 contained a news article discussing +Epstein's plea deal. Ex. 95 at -527; Ex. 63 at -652. +116. +On July 1, 2008, Keating, +, Sheridan, and Waters received a July 1, 2008 NYT article +titled "Financier Starts Sentence in Prostitution Case." The article reported: "But then the United +States attorney's office in Miami became involved. Last summer, Mr. Epstein got an ultimatum: +27 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 28 of 148 +plead guilty to a charge that would require him to register as a sex offender, or the government +would charge him with sexual tourism, according to people who were briefed on the discussions. +David Weinstein, an attorney in the government's Miami office, declined to discuss the specifics +of the case. But he did address the subject of Mr. Epstein's means and prominent legal team, and +dismissed a proposal by Mr. Epstein's lawyers—who opposed the application of the federal +statutes in the case that he be confined to his house in Palm Beach for a probationary period." +Ex. 96 at -954. +117. +On July 15, 2008, I +circulated to Verdon, Dalessio, McCleerey, Waters, Sheridan, and +(all Private Bank personnel) "for the 2:00 pm EST Rapid Response Meeting on Jeffrey +Epstein" an article titled "Rich Man Fought the Law - and He Mostly Won" and dated July 7, +2008. The article stated: "But that plea deal ... does not account for all of the girls, one as young +as 14, who alleged that Epstein sexually abused them. The slow, dissatisfying resolution of the +case sends a message to the public that there's a different system of justice for the wealthy who +hire high-powered lawyers .... The plea deal also drops a federal investigation of Epstein." Ex. +97 at -028. +118. The NPA stated that "the US Attorney's Office and the Federal Bureau of Investigation +have conducted their own investigation in Epstein's background and any offenses that may have +been committed by Epstein against the United States from in or around 2001 through in or around +September 2007, including ... knowingly, in and affecting interstate and foreign commerce, +recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained +the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. +§1591(c)(1); in violation of Title 19, United States Code, Section 1591(a)(1) and 2 ...." Ex. 94 at +-010-011. +28 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 29 of 148 +119. The NPA stated: "The United States shall provide Epstein's attorneys with a list of +individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255 .... If any of the +individuals referred to [above] elects to file suit pursuant to 18 U.S.C. § 2255 ... Epstein waives +his right to contest liability and also waives his right to contest damages ... and agrees to waive +any other claim for damages ...." Ex. 94 at -013. +120. The non-prosecution agreement identified +and +as potential +co-conspirators of Epstein. Ex. 94 at -014. +121. The non-prosecution agreement identified Lesley Groff as a potential co-conspirator of +Epstein. Ex. 94 at -014. +122. On September 9, 2010, +emailed McCleerey, copying Dalessio, stating: "Epstein +signed a federal non-prosecution agreement under which he would not be charged with related +federal crimes if he successfully served out his time and abided by the conditions under the state +charges. He also waived his right to contest liability and damages in civil lawsuits by 33 minor +girls identified by the non-prosecution agreement." Ex. 98 at -703. +123. +Steve Cutler testified, I know at a certain point I understood that there was a federal nonpros agreement" and that sometime before 2011, "I think we would have seen the non-pros +agreement." Ex. 99 at 150:4-6; 264:10-265:2. +124. On March 15, 2011, Jonathan +(then General Counsel Investment Bank) e-mailed +Cutler: "Spoke with Jay [Lefkowitz]. He represented Epstein in state plea/fed NPA process .... +Believes any pre-plea conduct is subsumed within plea/NPA." Ex. 100 at -278. +125. On October 19, 2007, Dalessio (Private Bank Risk Management) emailed Verdon (then +General Counsel Private Bank), copying McCleerey (Private Bank Risk Management) and Waters +(Managing Director AWM), Subject Epstein. Dalessio stated: "Anne [Verdon], Lisa asked me to +29 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 30 of 148 +send to you a list of PB entities in Epstein relationship with current balances .... Notable activity +in Epstein personal account: Cash withdrawals - CTRs filed --> 2007 ytd $400,000 (10 $40,000 +withdrawals), 2006 $914,796 (18 $40,000 withdrawals, 1 $60,000, 1 $30,000, 1 $25,000) 2007 +transaction activity>=$50,000." Ex. 63 at -651. +126. Dalessio further stated in his email: "One of the accounts in the Epstein relationship is for +his 'girlfriend / model' - +- funds into her account are transfers from Epstein - +3/19/07 for $25,000, 6/8/07 from $50,000. See attached article. The two others mentioned in the +article, +Lare not PB clients. Thely! do appear to have Retail credit +cards +- active, +- revoked)." Ex. 63 at -651 (emphasis added). +127. Dalessio attached to his email a document "Epstein 2007 transactions.xls.zip" which +included millions of dollars in payments from Epstein accounts at JPMorgan to Epstein's lawyers +and their law firms, including Alan Dershowitz, Gerald Lefcourt, Roy Black (Black Srebnick), and +Jay Lefkowitz (Kirkland & Ellis). Ex. 63 at -655. It also included twenty payments from Epstein +accounts for $100,000. Id. at 655. +128. On October 6, 2007, the New York Post reported: "THE owners of MC2 models are +denying industry speculation that massage maven Jeffrey Epstein is a secret financial backer of +the agency being run by scandal-scarred Jean-Luc Brunel, who was once accused of taking +advantage of underage models. Epstein, who this week agreed to plead guilty to soliciting underage +prostitutes at his Florida mansion in a deal that will send him to prison for about 18 months, +reportedly gave 'millions' to start MC2, which opened in October 2005 with offices in New York, +Miami and Tel Aviv. One of the girls Epstein, 54, was accused of soliciting massages from was +described in court documents as being just 14. 'E equals MC squared ... get it, like the equation? +E equals Epstein. He just thinks everyone is too dumb to figure it out,' said a model industry +30 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 31 of 148 +insider. 'He's a desperate old man that fantasizes and takes advantage of young girls.' .... MC2 +president Jeffrey Fuller confirmed Brunel was a partner in the company, but denied any working +relationship with either Epstein or | +'We have no relationship business-wise with Gerald +. Jeffrey Epstein has no ownership or involvement in our company and never has. Jean-Luc +Brunel and I are the only two partners and owners of MC2 Model Management,' Fuller said. +Epstein's rep said he was not involved in the agency. 'He has no business relationship with them,' +said Howard Rubenstein." Ex. 101 at -593. +129. JPMorgan admits that in 2005 JPMorgan approved a $1 million Stand By Letter of Credit +("SBLC") in Epstein's name to support a loan from Mellon United National to MC2 Model +Management, LLC. Ex. 39 at Resp. 66. +130. JPMorgan admits that a S1 million letter of credit in Epstein's name to backstop a loan +from Mellon United National to MC2 Model Management, LLC was subject to annual review. Ex. +39 at Resp. 67. +131. JPMorgan admits that it renewed the SBLC in Epstein's name to support a loan from +Mellon United National to MC2 Model Management, LLC until March 2011. Ex. 39 at Resp. 68. +132. On October 25, 2007, +emails Mary l +, subject: "Re: Jeffrey Epstein +new LOC" and states in response to +request to open a new line of credit for Epstein: "we +do still have an existing $IMM LC that we issued a few years ago ... supporting the Modeling +Agency's loan to Mellon." Ex. 102 at -962-63. +133. +31 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 32 of 148 +Ex. +103 at - 155. +134. In a July 31, 2010 email, Erdoes tells Staley, describing a July 31, 2010 NY Post article: +"The feds many not be quite done with (JE). Having just completed 13 months in a fl jail for +solicing[sic] prost [sic] from a minor, he now might be under investig [sic] for other possible +crimes, inclduing [sic] whether there's any evidence of child trafficking. E has settled several +lawsuits by teens who say they were lured to his palm beach mansion for massages or sx [sic]. The +us AG in fl wouldn't comment. E's lawyer, jack goldberger, says he know nothing of any probe, +and 'they are not and should not be any pending criminal investigations."" Ex. 104 at -251. +135. +The July 31, 2010 NY Post article "Jeffrey Epstein may face child trafficking probe" +states: +The Feds may not be quite done with Jeffrey Epstein. Having just completed 13 +months in a Florida jail for soliciting prostitution from a minor, he now might be +under investigation for other possible crimes, including whether there's any +evidence of child trafficking, reports The Daily Beast. Epstein has settled several +lawsuits by teens who say they were lured to his Palm Beach mansion for massages +or sex. The US attorney general in Florida wouldn't comment. Epstein's +lawyer, Jack Goldberger, says he knew nothing of any probe and, "There are not +and should not be any pending criminal investigations." +Ex. 90 at -814. +136. The July 29, 2010 Daily Beast article cited in the NY Post article states: "The Justice +Department is investigating Jeffrey Epstein for child trafficking ... and has widened the scope of +its probe to include a famous modeling agency." "Federal investigators continue to investigate +Epstein's activities, to see whether there is evidence of child trafficking—a far more serious charge +than the two in his non-prosecution agreement, the arrangement between Epstein and the +Department of Justice allowing him to plead guilty to lower level state crimes. Trafficking can +carry a 20-year sentence." "The FBI is also investigating Epstein's friend Jean Lue Brunel, whose +32 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 33 of 148 +MC2 modeling agency appears to have been a source of girls from overseas who ended up on +Epstein's private jets." Ex. 105 at -902-903. +137. JPMorgan admits that in 2010, certain of its employees received, reviewed, or read a +Newstex Web Blog, Jezebel, article ("2010 Newstex article") identifying "MC2" as "the modeling +agency owned by Jean Lue Brunel." Ex. 39 at Resp. 70. +138. The 2010 Newstex article states: +a. +"Jeffrey Epstein, the billionaire financier who the FBI believes molested around 40 +underaged girls" Ex. 106 at 596. +Buying a 14-year old Yugoslavian girl named +to keep her as his "sex slave" Id. +from her parents in order +C. +Paying women to bring him "economically desperate" teenagers to give him +massages "that often led to sexual contact" Id. +d. +Receiving two 12-year old L +girls as a "birthday present" Id. +e. +f. +g. +h. +i. +j. +and that Epstein, Maxwell, Brunel, Alfredo Rodriguez, and +agency to "lure minor children ... mostly girls under the age of 17 ... to engage +in sexual play for money" Id. +References that the FBI is investigating MC2 and Brunel for "possibly engaging in +child sex trafficking" Id. +Mentions Epstein's plea of soliciting sex with a minor and settling a dozen civil +lawsuits from victims Id. +"These same civil complaints allege that young girls from South America, Europe, +and the former Soviet republics ... were recruited for Epstein's sexual pleasure" +Id. +"Brunel, along with numerous young models, was a frequent passenger on +Epstein's private jet, according to flight manifests" Id. +"The agency owner also allegedly received $1 million from Epstein in 2005, when +he founded MC2 .... [but] denied any such payment from the billionaire pervert in +2007, when rumors started swirling" Id. +33 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 34 of 148 +k. +"Whether the money was a secret investment in MC2, or a payment for Brunel's +service as a procurer, is unknown" Id. +139. A DDR regarding Epstein approved by Morris (then banker), Sheridan (then overseeing +Morris); and Keating (then CEO U.S. Private Bank) stated: "As of 3/4/2011: Numerous articles +detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating +in child trafficking and molesting underage girls. Jeffrey Epstein is required to register as a sex +offender. Jeffrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding +solicitation for an undisclosed amount. MC2 Model Management received $1 million from Epstein +in 2005. It is unknown if the money was given as a secret investment or payment for services as a +procurer. Jean Luc Brunel, owner of MC2 Model Management and Jeffrey Epstein engaged in +racketeering that involved luring in minor children for sexual play for money. In addition, Brunel +was a frequent passenger on Epstein's private jet and often visited Epstein in jail. MC2 Model +Management was issued a citation by the Florida Business and Professional Regulation for acting +as a talent agent without a license. MC2 Model Management LLC has two outstanding federal tax +liens totaling $593,789 ($443,728 + $150,061)." Ex. 31 at -574. Global Security & Investigations, +Due Diligence Unit circulated "A Red Dot Memo for Jeffrey Epstein" containing the same +information that was circulated to Morris, +Dalessio, and +among others, in early +March 2011. Ex. 107 at -499-500. +140. +Ex. 9 +9,206. +" Id. 9 206. +141. JPMorgan's own due diligence process also required that it research and review civil and +other lawsuits that may be filed by or against clients. Ex. 32 at 42:20-24. +34 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 35 of 148 +142. +In 2007, news reports stated Epstein was "bracing for a slew of lawsuits from as many as +40 young women who came to his Palm Beach mansion for massage sessions." Ex. 63 at -652. +143. +Ex. 108 at - 685. +144. +Ex. 109 at -686. +145. The February 7, 2008 New York Post article stated that "the teen -identified only as 'Jane +Doe No. 2' - says she was lured to Epstein's Palm Beach mansion and then sexually assaulted in +his massage room .... He then paid her $200 ...." Ex. 110 at 1. The article further states: "... +Jane Doe No. 1 ... says she was 14 when she went to Epstein's home to give him a massage and +wound up getting sexually assaulted by him" and that Epstein is "currently only facing criminal +charges related to Jane Doe No. 1." Id. at 1-2. +146. On June 30, 2008, Epstein pled guilty to felony solicitation of prostitution and procurement +of a minor to engage in prostitution on June 30, 2008 and was "sentenced to 18 months in jail" and +"required to register as a sex offender." Def. JPMorgan Chase Bank, N.A.'s Answer Second Am. +Compl. ("Answer") 1 38 +147. +the victim was a 14-year-old girl. Ex. 109 at -686; Ex. 110 at 1-2. +148. +Ex. 2 at -196; Ex. 3 at -523. +149. In 2011, Langford communicated to Cutler "concern" about retaining Epstein as a client. +Cutler testified: "Those concerns are heightened, if you will, by the human trafficking initiative +that we're doing, given that he was convicted of these crimes." Ex. 99 at 343:12-24. +35 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 36 of 148 +150. +Ex. 55 at -475. +151. +The August 5, 2008 AML Operations Human Trafficking Overview states that "nearly +two-thirds of the women trafficked for prostitution worldwide come from Eastern Europe" and +"former Eastern bloc countries such as Albania, Moldova, Romania, Bulgaria, Russia, Belarus and +Ukraine have been identified as major trafficking source countries for women and children." Ex. +44 at -053. +152. In 2010, additional "news stories ... connects Jeffrey Epstein to human trafficking." Ex. +112 at -262. +153. On November 8, 2010, Dalessio emails Morris and | +, with a ce to McCleerey, Subject: +Excerpt from recent articles. Dalessio writes: "See below new allegations of an investigation +related to child trafficking - are you still comfortable with this client who is now a registered sex +offender?" Ex. 90 at -814. Dalessio attaches excerpts from four articles: +1. +The Palm Beach Post 8/1/10 "Epstein may be under new sex crime scrutiny from +feds": "Epstein ... may be under investigation for other sex crimes, including child +trafficking ... According to the news website The Daily Beast, the feds are also +checking whether a modeling agency run by a friend of the Wall Street Investor +Epstein fed his appetite for underage foreign girls. Epstein was known to fly young +women from Eastern Europe to Palm Beach, where they'd massage him, among +other services." Id. +NY Post 7/31/10 "Epstein Probe": "The Feds may not be quite done with Jeffrey +Epstein .... [H]e now might be under investigation for other possible crimes, +including whether there's any evidence of child trafficking, reports The Daily +36 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 37 of 148 +Beast. Epstein has settled several lawsuits by teens who say they were lured to his +Palm Beach mansion for massages or sex." Id. +3. +Palm Beach Daily News 7/18/10 "House arrest nears home stretch for Epstein": +"Epstein has settled more than two dozen lawsuits and claims against him by teenagers who say they were lured to his Palm Beach mansion to give him sexually +charged massages and/or sex in exchange for money ... A secret deal with federal +prosecutors revealed Epstein could have been charged with multiple federal counts +of sexual exploitation of minors, resulting in much harsher penalties. But the feds +deferred to two state charges that got him an 18-month sentence." Id. at -814-815. +4. +Palm Beach Daily News 9/19/10 article "Woman sues Epstein for $50 M, alleging +abuse as teen": +"alleges repeated sexual abuse by Epstein" and that "she was +coerced into prostitution as a minor by Epstein, assisted by his employee +alleges Epstein has transferred and is transferring his assets overseas +and elsewhere to conceal them from her and to prevent +from obtaining those +assets in any judgment she may receive against him." Id. at -815. +154. +The JPMC Corporate AML Compliance Human Trafficking Finance: Nature, Scope and +Control Project, November 2010, states that one of the results achieved from the program was that +JPMorgan "Led effort to draw industry attention to human trafficking as an AML-related issue" +and notes multiple industry presentations given by JPMorgan related to human trafficking issues +and/or its human trafficking project findings. Ex. 71 at -975, -977-78. On December 21 2010, Ryan +writes to DeLuca: "My fear is will all our touting of good will on the HT work, if anyone should +ever say yet we bank Epstein, a known child sleaze." DeLuca responds: "That is what I was +thinking when I read this. I'Il call you." Ex. 113 at -018. +37 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 38 of 148 +155. "HT" in Ryan's email refers to a project "within investigations related to human trafficking +and certain typology work that they were looking to dig through to identify human trafficking." +Ex. 36 at 56:14-57:6. +156. On December 22, 2010, DeLuca writes Langford again and states: "This will be raised to +the Rapid Response team (Catherine Keating) after the first of the year. McCleerey agrees this +customer should go." Ex. 114 at -738. +157. On December 23, 2010, DeLuca writes Langford and states: "... I sent you an e-mail +yesterday on that scum Epstein. That looks good to. I reminded McCleerey that he listened to 2 +days of HT at the forum and this account could be problematic in several ways." Langford +responds: "Good. Let me know if McCleerey waffles on Epstein. No patience for this." Ex. 115 at +-777. +158. On January 4, 2011, Dalessio e-mails Morris, with a ce to +and MoCleerey, +Subject: Rapid Response meeting this Thursday, stating: "See attached draft document for the +Rapid Response meeting this Thursday [sic] We were asked by the firms AML Compliance +Director, William Langford, to re-evaluate our sponsorship of Epstein and request re-approval +from Steve Cutler if we wanted to retain." Morris responds: "I thought we decided this was not +necessary." Dalessio responds: "william langford requested that we responsor this client in light +of the new allegations of human trafficking which the firm has been actively assisting law +enforcement in uncovering others engaged in this practice." Ex. 116 at -967. +159. +On January 5, 2011, Ryan wrote to DeLuca: "BTW, 4 tomorrow is the rapid response +meeting on Epstein, the sleazy PB client." DeLuca responded the next day: "This is the guy who +likes young girls, correct? Hope they do not cave!" Ex. 117 at -062; Ex. 36 at 68:11-69:18. +38 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 39 of 148 +160. By "sleazy PB client," Ryan was referring to the allegations against Epstein of sexual +misconduct with children. Ex. 36 at 68:11-19. +161. On January 7, 2011, Ryan emails DeLuca, copying Middlemiss, writing, "Epstein was +released in July from house arrest and the Palm Beach Post carried two articles saying that DOJ +may be investigating for child trafficking via a modeling agency he is part owner in." Ex. 118 at +-066_R; Ex. 36 at 88:24-90:2. +162. Ryan testified: "So, Phil was of the mindset, as was I, that [Epstein] had to go." Ex. 36 at +70:19-71:3. +163. Langford testified: "We were pushing it. I had asked for this to be redone, to push again, +to say it's time that we exit Epstein." Ex. 119 at 278:17-21. +164. Langford testified that by the end of 2010 or early 2011, it was his view that "we should +exit Jeffrey Epstein as a client." Ex. 119 at 58:18-59:11. +165. DeLuca testified: "Maryanne [Ryan] was all over this, and like myself and William +[Langford], Maryanne wanted to see this client gone, the relationship terminated." Ex. 120 at +204:22-205:1. +166. On January 10, 2011, DeLuca emails Nichols, copying Langford, regarding Jeffrey +Epstein: "He is alleged to be involved in human trafficking of young girls and law enforcement is +allegedly investigating his involvement in this activity. ... AML Operations went to a PB risk +meeting late last week requesting we exit this relationship." Ex. 70 at - 748_R. +167. On March 12, 2013, Ryan emails DeLuca, Subject: High Profile, telling him: "Here are the +ones [accounts] I think should be closed where the LOB has disagreed and signed off to keep.... +PB customer Jeffrey Edward Epstein is an American financier and science and education +philanthropist, who is a convicted sex offender." Ex. 121 at -272. +39 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 40 of 148 +168. +JPMorgan admits that Erdoes was involved in decision making with respect to maintaining +Epstein as a customer of JPMorgan. Ex. 28 at Resp. 8. +169. In 2008, JPMorgan acquired Bear Stearns. Ex. 122 at 1; Ex. 123 at 285:8-286:2. +170. JPMorgan knew that Epstein conducted his brokerage business at Bear Stearns. Ex. 124 at +-175. +171. +Ex. 125 at -076. +172. After Bear Stearns was acquired by JPMorgan, Arthur Middlemiss assumed a similar role +with JPMorgan AML compliance, working with Langford. Ex. 126 at 1; Ex. 120 at 155:21-158:6. +173. While at Bear Stearns, Middlemiss was the AML Officer responsible for responding to a +2007 subpoena by the federal prosecutors investigating Epstein for federal sex crimes. Ex. 125 at +-076. +174. On January 10, 2011, Ryan e-mails Langford, DeLuca, and Nichols, Subject: Re: Jeffrey +Epstein: "Seems JPMC never was served a subpoena, which I find odd since we were his #1 bank +and actually Bear got one in 07. Rich is getting me the AUSA correspondence and we will compare +their ask of Bear (something about $1000 and $100,000 transactions were of interest to them)[.]" +Ex. 127 at - 192. +175. +Ex. 128 at -247. +Ex. 129 at -248, - 251-52; Ex. 125 at +-075. +40 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 41 of 148 +176. +Ex. 129 at - 251. +Id. +177. +Ex. 125 at -075. +Id. at -076. +178. +In 2007, JPMorgan knew, as part of its investigation of Epstein at that time, that it had +made twenty transfers out of Epstein's accounts in the amount of $100,000 from January 2, 2007 +to October 12, 2007. Ex. 63 at -655-60. +179. On August 27, 2006, Staley emails Erdoes: "Last night went to the Huggy Bear concert. +The age difference between husbands and wifes [sic] would have fit in well with Jeffrey. What a +joke." Erdoes responds, " +|, and what I meant to tell you about last night was they [sic] were a +few people laughing about Jeffrey. One of the guys ran a unit of +Apparently +has +8 assistants, one is more beautiful than the other (even though he's gay). Anyway, lots of +comparisons to JE." Ex. 130 at -337. +180. +41 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 42 of 148 +Ex. 131 at -627. The article discussed "alleged financier-perv* billionaire Jeffrey Epstein, +of whom it is alleged that he retained a procurer of underage girls." Ex. 132 at 1. +181. In May 2008, Erdoes writes to +: "This has turned into a cheezy broker fest ... +totally not cool, the only cool people are here at glenn's table-same as bat mitzvah!" +responds: "Epstein there with miley cyrus?" Ex. 133 at -475. +182. In May 2008, Miley Cyrus was 15 and starring in "Hannah Montana" on the Disney +Channel. Ex. 134 at 2 +183. +On February 7, 2011, Ryan also said to Langford: "... wanted to catch up on Epstein as +he was featured ripped from the headline story on Law and Order SVU this week." Ex. 135 at +-044; Ex. 36 at 145:21-148:2. +184. Ryan testified, "That entire series [Law and Order SVU] was based on real life stories, and +it's never difficult to figure out, since I am a New Yorker, I knew exactly what this particular +episode was on, and so I sent it to William so that he could see.... I saw it - happened to see it, +made sure I told William that a customer might have been the implied story that was out in the +news." Ex. 36 at 147:4-148:2. +185. Ryan testified that she wrote to Langford: "I typed SVU and his name and there is a Gawker +story, Law & Order commerates [sic] JE taste for teen hookers." Ex. 135 at -044; Ex. 36 at 148:21- +149:2. +186. +The Gawker story states: "Last night, for instance, Dick +Law & Order: SVU aired +a 'ripped from the headlines' episode that seemed to be aimed directly at Epstein. The villain was +'Jordan Hayes,' a 'billionaire pervert flying in underage girls for sex" on his private jet. His parties +make the society page, he's friends with 'a former president,' and Hayes almost gets away with +42 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 43 of 148 +the statutory rape of a young girl before our heroes uncover scores of underage girls he had +sexually abused." Ex. 136 at 1. +187. The Law & Order episode and the Gawker story made Ryan "more anxious to get Jeffrey +Epstein out of the bank." Ex. 36 at 149:5-11. Ryan further testified "that all of these facts should +be escalated to the business to make an informed decision about getting Epstein out of the bank." +Id. at 149:17-21. Ryan was of the opinion that Epstein should be out of the bank. Id. at 149:20-21. +188. +On November 29, 2011, Ryan e-mails DeLuca an article, "FBI Set to Reopen Epstein Case +Based on Testimony of +" The article states: "The FBI is reportedly preparing to +launch a new inquiry into Epstein after one of his under-age erotic masseuses, +made a string of disturbing allegations about her role. U.S. detectives are said to be furious that +Epstein, 58, escaped with only 13 months in jail for child sex offences [sic] after he struck a plea +bargain with prosecutors. The deal protected him from further prosecution for offences in Florida. +But the significance of +claims that under-age girls were moved abroad for sex is +that she paves the way for the FBI to prosecute him for offences [sic| committed outside Florida +under the Trafficking Victims Protection Act." Ex. 137 at 689 (emphasis added). +189. On June 17, 2013, in a "Lync" chat from DeLuca with Jessica Gomel, who reported to +DeLuca, DeLuca repeated the contents of the article, including that "the significance of +claims that under-age girls were moved abroad for sex is that she paves the way for +the FBI to prosecute him for offences (sic] committed outside Florida under the Trafficking +Victims Protection Act." Ex. 138 at -936 (emphasis added). +190. +In September 2012, David Brigstocke (then CFO of JPMorgan AWM) writes to Erdoes +regarding +house: "The size of the Union Club. In fact it used to be a club. Reminded +43 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 44 of 148 +me of JE's house, except it was more tasteful, and fewer nymphettes. More like the Frick. Art +was fabulous. D." Erdoes responds: "Wow." Ex 139 at -203 (emphasis added). +191. Staley was the senior person at JPMorgan with a business relationship with Epstein. Ex. +39 at Resp. 204. +192. JPMorgan admits that its employees consulted with Staley regarding Epstein's account +activities. Ex. 39 at Resp. 144. +193. JPMorgan admits that Staley communicated with Epstein through his JPMorgan email +account jes.staley@jpmorgan.com. Ex. 39 at Resps. 161, 162. +194. JPMorgan employees were instructed to only use their email accounts "for business +purposes." Ex. 39 at Resp. 163. +195. JPMorgan admits that Epstein sent Staley photographs of women on Staley's JPMorgan's +email address. Ex. 39 at Resp. 164. +196. JPMorgan admits that more than 1,200 email messages were sent between Staley and +Epstein over Staley's work account. Ex. 39 at Resp. 165. +197. JPMorgan admits that Staley sent an email from his work account that referenced "Snow +" Ex. 39 at Resp. 166. +198. On July 9, 2010, Staley e-mailed Epstein, "That was fun. Say hi to Snow | +" Epstein +responded, "what character would you like next." Staley responded, "Beauty and the Beast...." +Epstein responded, "well one side is available." Ex. 140 at -669. +199. +On August 30, 2009, Epstein emailed Staley, "how long London? Do you need anything +there?" Staley responded, "Yep." Ex. 141 at -171. +200. +On September 2, 2009, Epstein emailed +staying at the berkeley hotel in London tonight." Ex. 142 at -773. +"jes staley is +44 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 45 of 148 +201. On December 20, 2009, Epstein emailed Staley a blank email with only an attachment, +which "appears to be a modeling photo": +Ex. 143 at -791-92; Ex. 144 at -005. +202. +On December 5, 2009, Epstein emailed Staley, "you were with larry, [sic] and I had to put +up with ...." with the following attachment: +45 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 46 of 148 +Ex. 145 at -715-16; Ex. 144 at -005. +Ex. 146 at +-718. +203. On June 16, 2010, Staley wrote to Epstein "is she free tonight?" Epstein replied, "call me." +Staley replied, "I'm with A." Ex. 144 at -998. +204. Staley testified he met +at Epstein's townhouse. Ex. 46 at 343:22-346:8. +205. +Staley testified he met Lesley Groff at Epstein's townhouse. Ex. 46 at 343:22-346:8. +206. +Staley testified he met +at Epstein's townhouse. Ex. 46 at 343:22-346:8. +207. +Staley testified +Ex. 46 at 433:9-440:8. +46 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 47 of 148 +208. +JPMorgan admits that Staley submitted, and JPMorgan reimbursed, the costs associated +with expense reports reflecting purported meetings with Epstein. Ex. 39 at Resps. 168, 169. +209. +JPMorgan admits that certain of its employees knew that Staley had visited Epstein while +he was incarcerated and still a JPMorgan client. Ex. 39 at Resp. 175. +210. +JPMorgan admits that Staley visited Epstein at Epstein's New York property while Epstein +was a client of JPMorgan. Ex. 39 at Resp. 176. +211. +JPMorgan admits that certain of its employees learned that Staley visited Little Saint James +while Epstein was a client of JPMorgan. Ex. 39 at Resp. 177. +212. JPMorgan admits that it gave Staley a bonus every year between 2001 and 2012. Ex. 39 at +Resp. 197. +213. JPMorgan admits that Staley's bonus was related to his performance and performance of +the business under his supervision, which may have included the revenue and business that they +generated. Ex. 39 at Resp. 198. +JPMorgan Participated in Epstein's Sex-Trafficking Venture +214. On July 6, 2020, the New York State Department of Financial Services entered into a +Consent Order with Deutsche Bank imposing a $150 million penalty in connection to Deutsche +Bank's relationship with Jeffrey Epstein. Ex. 147; Ex. 148; Ex. 99 at 457:10-466:2. Regarding the +Consent Order, Superintendent Lacewell said: "despite knowing Mr. Epstein's terrible criminal +history, the Bank inexcusably failed to detect or prevent millions of dollars of suspicious +transactions." Ex. 147; Ex. 148; Ex. 99 at 457:10-466:2. The bank "processed hundreds of +transactions totaling millions of dollars" including: +• payments to individuals who were publicly alleged to have been Mr. Epstein's +co-conspirators in sexually abusing young women; +47 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 48 of 148 +• settlement payments totaling over $7 million, as well as dozens of payments to +law firms totaling over $6 million for what appear to have been the legal +expenses of Mr. Epstein and his co-conspirators; +• payments to Russian models, payments for women's school tuition, hotel and +rent expenses, and (consistent with public allegations of prior wrongdoing) +payments directly to numerous women with Eastern European surnames; and +• periodic suspicious cash withdrawals — in total, more than $800,000 over +approximately four years. +Ex. 147; Ex. 148; Ex. 99 at 457:10-466:2. +215. In 2005, JPMorgan made two separate $25,000 payments from Epstein's JPMorgan +accounts to +Ex. 56 at 34, 36 and Figure 9.3 (copied below).? +' Figure 9.3 is a summary of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Butterfly Trust's JPMorgan account ending in 2810 +48 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 49 of 148 +Figure 9.3: Direct Payments to +2006 +2007 +2008 +2009 +Date +2005 +1/4/2005 +$25,000.00 +1/5/2005 +$25,000.00 +1/24/2008 +3/19/2008 +4/16/2009 +4/17/2009 +5/13/2009 +6/4/2009 +6/19/2009 +7/30/2009 +8/17/2009 +8/24/2009 +9/16/2009 +10/1/2009 +11/18/2009 +12/4/2009 +1/4/2010 +2/4/2010 +3/4/2010 +4/5/2010 +4/7/2010 +5/4/2010 +6/4/2010 +8/31/2010 +3/10/2011 +3/24/2011 +8/16/2011 +11/16/2011 +3/16/2012 +10/4/2012 +4/8/2013 +8/21/2013 +Total +2010 +2011 +2012 +2013 +Grand Total +$3,055.00 +$131,000.00 +$500.00 +$14,000.00 +$4,000.00 +$6,000.00 +$4,000.00 +S1.025.00 +$4,000.00 +$5,000.00 +$4,000.00 +S13,000.00 +$4,000.00 +$4,000.00 +$4,000.00 +$4,000.00 +$4,000.00 +$4,000.00 +$2,604.62 +$4,000.00 +$4,000.00 +$2,104.17 +$6,000.00 +S300,000.00 +$12,252.60 +$6,105.75 +$3.294.43 +$9,800.00 +$100,000.00 +$15,000.00 +$50,000.00 +$0.00 +$0.00 $134,055.00 S63,525.00 +S334,708.79 $18,358.35 S13,094.43 S115,000.00 S728,741.57 +216. From August 2006 through August 2013, JPMorgan handled $678,741.57 in payments +from Epstein's JPMorgan accounts to +Ex. 56 at 34, 36 and Figure 9.3. +217. +In August 2013, JPMorgan handled a payment of $15,000 from Epstein's JPMorgan +account to +Ex. 56 at 34, 36 and Figure 9.3. +49 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 50 of 148 +218. +From August 2006 through January 2013, JPMorgan handled $607,804.30 in payments +from Epstein's JPMorgan accounts to +below).° +•. Ex. 56 at 34-35 and Figure 9.2 (copied +Figure 9.2: Direct Payments to +2005 +2006 +2007 +2008 +2009| +Date +2003 +11/3/2003|5500.00 +3/9/2004 +4/8/2004 +422/2004 +428/2004 +6/1/2004 +8/5/2004 +10/19/2004 +11/22/2004 +12/1/2004 +1:4/2005 +1/19/2005 +4/12/2005 +4/26/2005 +7/19/2005 +8/15/2005 +8/25/2005 +10/11/2005 +10/24/2005 +1.4/2006 +2/3/2006 +3/2/2006 +4/10/2006 +4/28/2006 +7/18/2006 +9/6/2006 +103/2006 +12/18/2006 +3/19/2007 +6/8/2007 +9/25/2007 +1/24/2008 +7/3/2008 +9/3/2008 +7/8/2009 +12/7/2009 +2004 +51,166.00 +52,000,00 +$1,517.82 +53,000.00 +[S10,000.00 +55,000.00 +S10,000.00 +52,168.29 +51,713.45 +2010 +2011 +2012 +2013 Grand Total +$25,000.00 +$3,155.56 +$778.76 +S10,000.00 +53,339.96 +$480.00 +S10,000.00 +55,000.00 +S10,000.00 +510,000.00 +$11,000.00 +$6,786.00 +$15,000.00 +$7,362.50 +$5,000.00 +$25,000.00 +$1,025.00 +51.724.30 +$25,000.00| +$50,000.00 +[$100,000.00 +$3,055.00 +$2,000.00 +S100,000.00 +$50,000.00 +$10,000.00 +510,000.00 +$10,000.00 +$25,000.00 + +S20.000.00 +30000 +S10,000.00 +Total +|5500.00 536,565.56 567,754.28 SK2,97.80 $175000.00 S105,055.00 | 560,000.00 S100,000.00 590.000.00 | $40,000.00 |$10,000.00 5767,772.64 +& Figure 9.2 is a summary of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Butterfly Trust's JPMorgan account ending in 2810 +50 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 51 of 148 +219. In 2004, 2005, and 2006, JPMorgan handled $36,565.56, $67,754.28, and $82,897.80, +respectively, in payments from Epstein's JPMorgan accounts to +Ex. 56 at 34- +35 and Figure 9.2. +220. +Ex. 149 +221. From October 1999 through July 2006, JPMorgan handled $25,146,955.30 in payments +from Epstein's JPMorgan accounts to Ghislaine Maxwell. Ex. 56 at 45-46 and Figure 15 (copied +below).? +Figure 15: Direct Payments to Ghislaine Maxwell +Date +1999 +10/19/1999$18,300,000.00 +9/18/2002 +2/27/2003 +5/6/2003 +6/20/2003 +11/4/2004 +11/18/2004 +4/27/2005 +5/20/2005 +7/22/2005 +7/25/2005 +1128/2006 +4/23/2009 +Total +2002 +2003 +2004 +2005 +2006 +2009 +Grand Total +$18,300,000.00 +$5,000,000.00 +$5,000,000.00 +$325,000.00 +$250,000.00 +$93,037.97 +$325,000.00 +$250,000.00 +$93,037.97 +S225,000.00 +$34,867.33 +$225,000.00 +$34,867.33 +$205,000.00 +$139,050.00 +$200,000.00 +$375,000.00 +$205,000.00 +S139,050.00 +$200,000.00 +S375,000.00 +$13,750.00 +$13,750.00 +$100,000.00 +$100,000.00 +S18,300,000.00 +$5,000,000.00 | S668,037.97 +S259,867.33 +$919,050.00 S13,750.00 +| $100,000.00 $25,260,705.30 +222. From August 2006 through April 2009, JPMorgan handled $113,750 in payments from +Epstein's JPMorgan accounts to Maxwell. Ex. 56 at 45-46 and Figure 15. +223. In addition, JPMorgan received a S7.4 million wire from Epstein's Mellon Bank account +to Maxwell's JPMorgan account to purchase a helicopter. On June 15, 2007, JPMorgan received +° Figure 15 is a summary of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Epstein's JPMorgan account ending in 1001 (Ex. 58); +Financial Trust's (owned by Epstein) JPMorgan account ending in 0001 (Ex. 59); Financial Trust's +(owned by Epstein) JPMorgan account ending in 5001 (Ex. 60). +51 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 52 of 148 +a $7.4 million wire to Maxwell's JPMorgan account ending in 6312 from Epstein's Mellon Bank +account. Ex. 150 at -025 (June 2007 account statement from Ghislaine Maxwell's JPMorgan +account ending in #6312 showing a $7.4 million wire from Epstein's Mellon Bank account). On +the same day, Maxwell transferred those same funds to Air Ghislaine, Inc.'s JPMorgan account +ending in 4324. Ex. 151 at -878 (June 2007 account statement from Air Ghislaine, Inc.'s JPMorgan +account ending in 4324). Then on June 18, 2007, $7,352,825.00 was transferred to Sikorsky +Aircraft as a down payment for the purchase of a l +helicopter - Sikorsky S76C. Id. According +to the Aviation Database, as of June 27, 2007, the helicopter with tail number N908GM was +registered to Air Ghislaine, Inc. Ex. 56, Amador Exhibit G (aircraft registrations). +224. From 2003-2013, JPMorgan handled $3,132,070.88 in payments to girls or women, +including many girls or women with Eastern European names, from Epstein's JPMorgan accounts. +Ex. 56 at 30-33 and Figure 9 (copied below).'° +Figure 9: Direct Payments to Women from the Epstein Accounts +Payee Name +Total Payment Amount +$15,000.00 +$5,000.00 +$13,656.00 +$5,000.00 +S7,026.00 +$3,000.00 +S64,599.86 +$5,000.00 +$8,468.00 +$2,400.00 +10 Figure 9 is a summary of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Epstein's JPMorgan account ending in 0663 (Ex. 152); +Financial Trust's JPMorgan account ending in 5001 (Ex. 60); The C.O.U.Q. Foundation's +JPMorgan account ending in 1565 (Ex. 153); Butterfly Trust's account ending in 2810 (Ex. 64). +52 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 53 of 148 +Payee Name +Total Payment Amount +$400.00 +$500.00 +$4,000.00 +$58,000.00 +$8,000.00 +$5,000.00 +$20,000.00 +$19,000.00 +$36,049.30 +$22,500.00 +$113,500.00 +$5,007.13 +$1,000.00 +$396.44 +$500.00 +$3,675.00 +$12,110.00 +$550.00 +$200.00 +$4,901.00 +$3,341.68 +$116,399.86 +$500.00 +$1,550.00 +$750.00 +$12,500.00 +$9,000.00 +$211,441.25 +$5,000.00 +$12,528.67 +S728.741.57 +$7,750.00 +$5,000.00 +$80,550.00 +53 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 54 of 148 +Payee Name +Total +Total Payment Amount +$115,000.00 +$50,000.00 +$8,073.75 +$108,500.00 +$767,772.64 +$1,000.00 +$1,495.00 +$500.00 +$2,700.00 +$15,000.00 +$5,000.00 +$1,100.00 +$79,773.51 +$10,000.00 +$1,540.00 +$81,000.00 +$21,739.73 +$4,000.00 +$1,320.00 +$3,000.00 +$27,743.00 +$23,000.00 +$4,200.00 +$2,000.00 +S10,140.00 +$3,500.00 +$1,650.00 +$8,000.00 +$300.00 +$5,000.00 +$38,031.49 +$500.00 +S3,132,070.88 +54 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 55 of 148 +225. +"These charts contain summaries of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Epstein's JPMorgan account ending in 0663 (Ex. 152); +Financial Trust's JPMorgan account ending in 5001 (Ex. 60); The C.O.U.Q. Foundation's +JPMorgan account ending in 1565 (Ex. 153); Butterfly Trust's account ending in 2810) (Ex. 64). +55 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 56 of 148 +56 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 57 of 148 +57 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 58 of 148 +58 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 59 of 148 +59 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 60 of 148 +60 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 61 of 148 +226. +12 +12 This chart contains summaries of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Epstein's JPMorgan account ending in 0663 (Ex. 152); +Financial Trust's JPMorgan account ending in 5001 (Ex. 60); The C.O.U.Q. Foundation's +JPMorgan account ending in 1565 (Ex. 153); Butterfly Trust's account ending in 2810 (Ex. 64). +61 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 62 of 148 +62 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 63 of 148 +63 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 64 of 148 +64 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 65 of 148 +65 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 66 of 148 +66 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 67 of 148 +67 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 68 of 148 +68 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 69 of 148 +227. +13 This chart contains summaries of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Epstein's JPMorgan account ending in 0663 (Ex. 152); +Financial Trust's JPMorgan account ending in 5001 (Ex. 60); The C.O.U.Q. Foundation's +JPMorgan account ending in 1565 (Ex. 153); Butterfly Trust's account ending in 2810 (Ex. 64). +69 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 70 of 148 +70 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 71 of 148 +71 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 72 of 148 +72 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 73 of 148 +73 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 74 of 148 +74 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 75 of 148 +228. +14 This chart contains summaries of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Epstein's JPMorgan account ending in 0663 (Ex. 152); +Financial Trust's JPMorgan account ending in 5001 (Ex. 60); The C.O.U.Q. Foundation's +JPMorgan account ending in 1565 (Ex. 153); Butterfly Trust's account ending in 2810 (Ex. 64). +75 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 76 of 148 +229. +15 +230. JPMorgan sent several of the payments by foreign wire to girls or women including +-located +in Belarus, Lithuania, and Russia. Ex. 56 at 37-38 and Figure 10 (copied below).' +Figure 10: Foreign Wire Transactions from the Epstein Accounts +Date +Beneficiary Bank +Location +Beneficiary +12/1/2008 +Alfa Bank +Moscow, Russia +12/1/2008 +VTB Bank +Moscow, Russia +1/8/2009 +SEB Vilniaus +Bankas +Lithuania +9/8/2009 +VTB Bank +Moscow, Russia +11/4/2010 +ZAO +Raiffeisenbank +Moscow, Russia +8/21/2012 +ZAO +Raiffeisenbank +Moscow, Russia +1/14/2013 +| Joint Stok Company | Minsky, Belarus +Amount +$3,000.00 +$2,000.00 +$2,000.00 +$292.00 +$2,840.00 +$2,000.00 +$10,000.00 +15 These charts identify and summarize relevant transactions from JPM-SDNYLIT-00921097 (Ex. +149). +16 Figure 10 is a summary of wire instructions from Epstein's JPMorgan accounts (Ex. 154). +76 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 77 of 148 +10/15/2013 | Joint Stok Company | Minsky, Belarus +$20,000.00 +231. From 2004-2013, JPMorgan handled $211,411.25 in payments to +from +Epstein's JPMorgan accounts. Ex. 56, Amador Exhibit F (chart showing breakdown of each direct +payment Epstein made to girls or women from his JPMorgan accounts). +232. JPMorgan also handled $158,958.34 in indirect payments from Epstein's JPMorgan +accounts for the benefit of girls or women. Ex. 56 at 38-40 and Figure 11 (copied below).' +Figure 11: Indirect Payments for the benefit Women from the Epstein Accounts +Amount +Steven D. Kaplan, DMD +Total +$1,260.00 +$1,260.00 +Spanish American Institute +Total +$840.00 +$840.00 +International Center of Photography +Total +$1,290.00 +$1,290.00 +Castle Worldwide Inc. +Pacific College of Oriental +Medicine +$250.00 +$21,245.86 +" Figure 11 is a summary of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Epstein's JPMorgan account ending in 0663 (Ex. 152); +and Enhanced Education's (owned by Epstein) JPMorgan account ending in 4810 (Ex. 155). +77 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 78 of 148 +Steven D. Kaplan, DMD +Total +Amount +$5,700.00 +$27,195.86 +Laguardia College +The World's Community College +Total +$2,425.85 +$4,135.85 +$6,561.70 +New York Film Academy +Steven R. Erle, MD, PC +Total +$6,040.00 +$450.00 +$6,490.00 +Bloomingdales +Express +I C Systems +Target +Victoria's Secret +Total +$532.77 +$380.87 +$329.00 +$352.10 +$211.04 +$1,805.78 +Alan Barnett DLP, LLC +The International Culinary Center L +Total +$10,400.00 +$42,000.00 +$52,400.00 +78 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 79 of 148 +Amount +Samuel C. Klagsbrun M.D. +Total +$2,000.00 +$2,000.00 +ATP USA, Inc. +Total +$26,000.00 +$26,000.00 +New York Film Academy +Total +S3,500.00 +$3,500.00 +Alliance Nursing +Dr. David Price +Dr. Gerald Imber +Dr. Jane Recant +Office Based Surgery Care +Total +$2,275.00 +$412.00 +$20,000.00 +$2,000.00 +$1,500.00 +$26,187.00 +Fashion Institute of Technology +Total +$2,020.00 +$2,020.00 +ALCC American Language +$1,408.00 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 80 of 148 +Amount +$1,408.00 +$158,958.3 +4 +Grand Total +233. JPMorgan also handled $5,600 in legal fees from Epstein's JPMorgan accounts for the +benefit of three women- +Ex. 56 at 40-41 +and Figure 12 (copied below).' +Date +1/30/2009 +1/11/2012 +Figure 12: Legal Fees Payments for Women from the Epstein Accounts +Check # +Payee +2691 Vincent A. Fuller, Jr., Esq. +3359 +M. Arda Beskardes, Esq. +Amount +$4,500.00 +$600.00 +Memo line: +8/21/2012 +Total +3412 | M. Arda Beskardes, Esq. +$500.00 +$5,600.00 +Smaller Dollar and "Gift" Payments to Girls or Women and $100,000 Payments +234. +Ex. 156(2012 Jeffrey E. +Epstein Gift Tax Return).' +20 +18 Figure 12 is a summary of information from account statements for Epstein's JPMorgan account +ending in 0663 (Ex. 152) +9 Epstein's 2012 Gift Tax Return is the only gift tax return the USVI was able to locate. +20 Figures 14 and 14.1 are summaries of information from Epstein's 2012 Gift Tax Return (Ex. +156). +80 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 81 of 148 +81 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 82 of 148 +82 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 83 of 148 +83 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 84 of 148 +235. +21 These charts contain summaries of information from the following documents: account +statements from Epstein's JPMorgan account ending in 0438 (Ex. 57); account statements from +Epstein's JPMorgan account ending in 0663 (Ex. 152); JPMorgan's internal documents (Ex. 63). +84 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 85 of 148 +85 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 86 of 148 +86 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 87 of 148 +236. +22 These charts contain summaries of information contained in account statements from Epstein's +JPMorgan account ending in 0438 (Ex. 57). +87 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 88 of 148 +88 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 89 of 148 +237. +23 These charts contain summaries of information from the account statements of Epstein's +JPMorgan account ending in 0438 (Ex. 57). +89 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 90 of 148 +238. +From September 2006 through December 2006, JPMorgan handled $883,750.00 in +payments from Epstein's accounts to Alan Dershowitz, Roy Black, Gerald Lefcourt, and Jack +Goldberger (relevant transactions identified and summarized in the chart below). 24 +239. From January 2007 through September 2007, JPMorgan handled $3,386,884.26 in +payments from Epstein's accounts to Alan Dershowitz, Roy Black, Gerald Lefcourt, Jack +Goldberger, and Kirkland & Ellis (Jay Lefkowitz) (relevant transactions identified and +summarized in the chart below), 25 +24 This chart contains summaries of information from Epstein's JPMorgan account ending in 0438 +(EXis chart contains summaries of information from Epstein 's JP Morgan account ending in 0438 +(Ex. 57). The Government's calculation of legal fees to these lawyers matches the same calculation +in JPMorgan's own summaries (Ex. 63). +90 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 91 of 148 +91 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 92 of 148 +240. +From 2006 through 2013, JPMorgan handled $50,909,656.04 in payments from Epstein's +JPMorgan accounts to various law firms, including $9,505,547.91 in payments from January 2006 +through September 24, 2007; $5,597,358.02 in payments from September 25, 2007 through June +30, 2008; and $35,806,750.11 from July 1, 2008 through December 2013 (relevant transactions +identified and summarized in the chart below).? +26 This chart contains summaries of information from the following account statements: Epstein's +JPMorgan account ending in 0438 (Ex. 57); Epstein's JPMorgan account ending in 0663 (Ex. 152). +92 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 93 of 148 +93 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 94 of 148 +94 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 95 of 148 +95 + + +Case 1:22-cV-10904-JSR Document 221 Filed 07/24/23 Page 96 of 148 +96 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 97 of 148 +97 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 98 of 148 +98 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 99 of 148 +99 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 100 of 148 +100 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 101 of 148 +101 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 102 of 148 +102J + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 103 of 148 +103 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 104 of 148 +104 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 105 of 148 +105 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 106 of 148 +106 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 107 of 148 +107 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 108 of 148 +241. JPMorgan Private Bank's Client Cash Transaction Guidelines states: "The receipt of large +cash deposits and disbursements of cash withdrawals for other than client casual spending needs +to be discouraged. It is the primary responsibility of the Banker to obtain explanations on the +source of the cash and acceptability of the intended use of the case, and to assess the plausibility +of these explanations for large cash transactions." Ex. 157 at -224. +242. From September 2003 through November 2013, JPMorgan recorded cash withdrawals +from Epstein's JPMorgan accounts totaling $5,018,472. Ex. 56 at 24-26 and Figure 8 (copied +below).? +Figure 8: CTRs Relating to Epstein Accounts By Year +Epstein +#0663 +Hyperion +#4332 +NYSG +#3130 +116 East 65'h +St LLC#4235 +Year +2003 +2004 +2005 +2006 +2007 +2008 +Epstein +#0438 +$175,310 +$840,000 +$901,337 +$935,265 +$520,000 +$460,000 +$3,000 +$3,000 +$6,000 +$9,000 +Total +$175,310 +$840,000 +$904,337 +$938,265 +$526,000 +$469,000 +27 Figure 8 is a summary of information from currency transaction reports filed by JPMorgan (Ex. +79). +108 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 109 of 148 +Year +2009 +2010 +2011 +2012 +2013 +Total +Epstein +#0438 +$100,011 +$223,397 +$200,000 +Epstein +#0663 +$60,000 +$30,000 +Hyperion +#4332 +NYSG +#3130 +116 East 65th +St LLC#4235 +$5,000 +Total +$4,355,320 +$90,000 +$60,000 +$290,000 +$197,152 +$547,152 +$21,000 +$5,000 +$165,011 +$253,397 +$260,000 +$290,000 +$197,152 +$5,018,472 +243. From 2006 through 2013, JPMorgan recorded $3,098,825 in cash withdrawals from +Epstein's JPMorgan accounts. Ex. 56 at 24-26 and Figure 8. +244. From 2003 to 2007, JPMorgan recorded $3,383,912 in cash withdrawals from Epstein's +JPMorgan accounts. Ex. 56 at 24-26 and Figure 8. +245. From 2005 to 2006, JPMorgan recorded S1,842,602 in cash withdrawals from Epstein's +JPMorgan accounts. Ex. 56 at 24-26 and Figure 8. +246. From August 2006 through June 2008, JPMorgan recorded $1,134,000 in cash withdrawals +from Epstein's JPMorgan accounts (relevant transactions identified and summarized in the chart +below).28 +Transaction +Date +8/10/2006 +8/24/2006 +9/7/2006 +9/21/2006 +Acet# +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Amount +$60,000.00 +28 This chart identifies and summarizes currency transaction reports filed by JPMorgan (Ex. 79). +109 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 110 of 148 +Transaction +Date +10/19/2006 +11/10/2006 +11/20/2006 +12/15/2006 +1/18/2007 +2/20/2007 +3/1/2007 +4/5/2007 +4/5/2007 +5/2/2007 +6/11/2007 +7/10/2007 +7/10/2007 +8/2/2007 +9/4/2007 +9/19/2007 +10/24/2007 +11/27/2007 +Acet# +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +NYSG +#3130 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +NYSG +#3130 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Amount +$25,000.00 +$3,000.00 +S40,000.00 +$3,000.00 +110 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 111 of 148 +Transaction +Date +12/14/2007 +1/7/2008 +2/13/2008 +2/13/2008 +3/5/2008 +4/1/2008 +4/24/2008 +5/21/2008 +Acet# +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +NYSG +#3130 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Amount +$3,000.00 +6/16/2008 +Grand Total +$1,134,000.00 +247. From August 2006 through November 2013, JPMorgan recorded $2,485,560.00 in cash +withdrawals from Epstein's JPMorgan accounts (relevant transactions identified and summarized +in the chart below)." +8/10/2006 +8/24/2006 +9/7/2006 +9/21/2006 +10/19/2006 +Acet# +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Amount +$60,000.00 +29 This chart identifies and summarizes currency transaction reports filed by JPMorgan (Ex. 79). +111 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 112 of 148 +11/10/2006 +11/20/2006 +12/15/2006 +1/18/2007 +2/20/2007 +3/1/2007 +4/5/2007 +4/5/2007 +5/2/2007 +6/11/2007 +7/10/2007 +7/10/2007 +8/2/2007 +9/4/2007 +9/19/2007 +10/24/2007 +11/27/2007 +12/14/2007 +1/7/2008 +2/13/2008 +Acet# +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +NYSG +#3130 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +NYSG +#3130 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +112 +Amount +$25,000.00 +S40,000.00 +S40,000.00 +S40,000.00 +$3,000.00 +$3,000.00 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 113 of 148 +2/13/2008 +3/5/2008 +4/1/2008 +4/24/2008 +5/21/2008 +6/16/2008 +7/10/2008 +7/10/2008 +8/22/2008 +9/10/2008 +10/2/2008 +10/7/2008 +11/13/2008 +12/11/2008 +12/11/2008 +1/13/2009 +3/5/2009 +3/30/2009 +6/17/2009 +8/20/2009 +Acet# +NYSG +#3130 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +NYSG +#3130 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +NYSG +#3130 +Epstein +#0438 +Epstein +#0663 +Epstein +#0438 +Epstein +#0663 +Epstein +#0438 +113 +Amount +$3,000.00 +S40,000.00 +$20,000.00 +$3,000.00 +$20,000.00 +$20,000.00 +$20,000.00 +$20,000.00 +$3,000.00 +$20,011.00 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 114 of 148 +11/19/2009 +11/19/2009 +3/2/2010 +4/1/2010 +4/21/2010 +7/19/2010 +7/23/2010 +8/19/2010 +9/27/2010 +10/29/2010 +12/30/2010 +2/14/2011 +4/12/2011 +5/27/2011 +7/8/2011 +8/5/2011 +10/6/2011 +12/13/2011 +2/21/2012 +Acet# +Epstein +#0438 +116 East 65th St LLC +#4235 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0663 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Amount +$20,000.00 +$5,000.00 +$20,000.00 +$20,000.00 +$13,397.00 +S40,000.00 +S40,000.00 +114 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 115 of 148 +3/19/2012 +5/29/2012 +7/9/2012 +7/31/2012 +9/10/2012 +9/28/2012 +10/23/2012 +12/7/2012 +2/28/2013 +6/4/2013 +8/1/2013 +Acet# +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +11/1/2013 +Grand Total +Amount +$20,000.00 +$97,152.00 +$2,485,560.00 +248. +From September 2008 through November 2013, JPMorgan recorded $1,308,560 in cash +withdrawals from Epstein's JPMorgan accounts (relevant transactions identified and summarized +in the chart below). 30 +9/10/2008 +10/2/2008 +Acct# +Epstein +#0438 +Epstein +#0438 +Total Cash +$20,000.00 +30 This chart identifies and summarizes currency transaction reports filed by JPMorgan (Ex. 79). +115 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 116 of 148 +10/7/2008 +11/13/2008 +12/11/2008 +12/11/2008 +1/13/2009 +3/5/2009 +3/30/2009 +6/17/2009 +8/20/2009 +11/19/2009 +11/19/2009 +3/2/2010 +4/1/2010 +4/21/2010 +7/19/2010 +7/23/2010 +8/19/2010 +9/27/2010 +Acet# +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +NYSGR +#3130 +Epstein +#0438 +Epstein +#0663 +Epstein +#0438 +Epstein +#0663 +Epstein +#0438 +Epstein +#0438 +116 East 65th St +LLC +#4235 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Total Cash +$20,000.00 +$20,000.00 +$3,000.00 +$20,011.00 +$20,000.00 +$5,000.00 +$20,000.00 +$20,000.00 +S13,397.00 +116 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 117 of 148 +10/29/2010 +12/30/2010 +2/14/2011 +4/12/2011 +5/27/2011 +7/8/2011 +8/5/2011 +10/6/2011 +12/13/2011 +2/21/2012 +3/19/2012 +5/29/2012 +7/9/2012 +7/31/2012 +9/10/2012 +9/28/2012 +10/23/2012 +12/7/2012 +2/28/2013 +Acet# +Epstein +#0663 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Epstein +#0438 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +117 +Total Cash +S40,000.00 + + +Case 1:22-CV-10904-JSR Document 221 Filed 07/24/23 Page 118 of 148 +6/4/2013 +8/1/2013 +Acet# +Hyperion +#4332 +Hyperion +#4332 +Hyperion +#4332 +Total Cash +$20,000.00 +11/1/2013 +Grand Total +$97,152.00 +$1,308,560.00 +249. From August 2013 through November 2013, JPMorgan recorded $117,152 in cash +withdrawals from Epstein's JPMorgan accounts (relevant transactions identified and summarized +in the chart below). 3! +8/1/2013 +Acet# +Hyperion +#4332 +Hyperion +#4332 +Total Cash +$20,000.00 +11/1/2013 +Grand Total +$97,152.00 +$117,152.00 +250. +-206-210. +Ex. 158 at - 133-134, +Id. at - 134. +Ex. 159 at -001- +002, - 175-182. T +Id. at -001. +3' This table identifies and summarizes currency transaction reports filed by JPMorgan (Ex. 79). +118 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 119 of 148 +JPMorgan Benefited from Participation in Epstein's Sex-Trafficking Venture +251. +JPMorgan first opened an account for Epstein in 1985. Ex. 39 at Resp. I. +252. +JPMorgan admits that it earned fees and revenue from providing banking services to +Epstein. Ex. 39 at Resp. 7. +253. +One of the factors impacting bonuses for JPMorgan Private Bankers was the revenues that +clients brought into the bank. Ex. 160 at 46:11-18; 48:4-49:18. +254. +In 2003, Epstein brought in over $8.1 million in revenue to the Private Bank. Ex. 161 at - +088. +255. Epstein's $8.1 million in revenue in 2003 was the most investor revenue for JPMorgan +Wealth Management. Ex. 161 at -088. +256. Epstein's $8.1 million in revenue in 2003 was nearly double the amount of JPMorgan +Wealth Management's second-highest client. Ex. 161 at -088. +257. In 2003, "Jeffrey Epstein, through the trading of his accounts and that [sic] of +generates one of the largest annual revenue flows of private clients in the private bank." +Ex. 162 at -098. In 2004, Epstein's JPMorgan Banker considered the Epstein/Wexner relationship +a "crucial relationship to the private bank." Ex. 163 at -030. +258. +Leading up to Epstein's indictment in 2006, he was one of JPMorgan's "very big clients." +Ex. 164 at - 615.; Ex. 46 at 85:9-86:18. +259. In October 2006, Epstein's JPMorgan accounts totaled approximately $32 million. Ex. 76 +at -953. +260. At the October 2006 Rapid Response Team meeting, "[a]fter internal discussion with Jes +Staley, Mary Erdoes, Catherine Keating, John Duffy and Mary +it was decided that we will +119 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 120 of 148 +keep Mr. Epstein solely as a banking client and on a "reactive', client service basis." Ex. 39 at +Resp. 44 (citing JPM-SDNYLIT-00127953 (Ex. 76)). +261. Kevin McCleerey testified that these conditions were imposed to "mitigatel] the risk" +presented by Epstein by capping "the number of accounts and relationships with him." Ex. 35 at +119:2-120:5. +262. In October 2007, JPMorgan continued doing "business as usual with Epstein's office." Ex. +102 at -963. +263. At the time, Mary Erdoes wanted to "move forward based on our earlier decision to +continue doing business" with Epstein. Ex. 102 at -962; Ex. 32 at 264:16-265:2; 273:24-274:22. +264. By July 2008, Epstein's JPMorgan accounts had increased to total approximately $121.5 +million. Ex. 165 at 944; Ex. 32 at 309:8-311:3. +265. On August 28, 2008, Mary +emails Marcus Sheridan, subject: "Re: "09 plan" and +said: "Also, I would count Epstein's assets as a probable outflow for "08 ($120mm or so?) as I +can't imagine it will stay (pending Dimon review)." Ex. 301 at -706_R. +266. On September 3, 2008, Epstein's JPMorgan accounts had a PCN Market Value of +$156,218,451.45. Ex. 166 at -758; Ex. 39 at Resp. 3. +267. JPMorgan admits that in October 2010 Epstein was one of JPMorgan's top 20 clients in +the Closely Held Business Group. Ex. 39 at Resp. 4. +268. +Ex. 167 at -654. +269. +270. +Ex. 167 at -654. +Ex. 167 at -654. +120 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 121 of 148 +271. By 2011, Epstein was JPMorgan Private Bank's "GIO's biggest revenue producer." Ex. +168 at - 977. +272. By July 2013, Epstein was still actively trading through the GIO. Ex. 169 at -230. +273. At the time, Epstein's Banker (Justin Nelson) described Epstein as "one of the most active +and sophisticated investors on the GIO desk." Ex. 169 at -230. +274. In September 2013, JPMorgan noted the impact of exiting Epstein roughly equated to "- +S0.5MM YoY revenue decrease in 2013. In 2014 it will be roughly a -$2MM revenue impact." +Ex. 170 at -016. JPMorgan further noted, "He currently has $176MM with us and actually has +TCP flows of +$72MM this year." Id. +275. In or about the year 2000, Douglas "Sandy" Warner, then CEO of JPMorgan, said to Staley +(then Head of Private Bank), "...[Y]ou should meet meet [sic] Epstein. He's one of the most +connected people I know of in New York." Ex. 46 at 45:18-47:4. +276. JPMorgan admits Epstein introduced and referred potential clients to JPMorgan Private +Bank. Ex. 39 at Resps. 5, 6. +277. Epstein referred a number of ultra-high net worth clients to JPMorgan over the years. Ex. +48 at Resp. 17; Ex. 46 at 86:19-23. +278. One of the factors impacting bonuses for JPMorgan Private Bankers was new client +acquisition. Ex. 171 at 83:18-84:4. +279. +One of the objectives that was instilled in JPMorgan Private Bankers was to acquire new +clients. Epstein referred Bill Gates as a client to JPMorgan. Ex. 46 at 88:3-4. +280. +281. +Epstein referred Sergey Brin as a client to JPMorgan. Ex. 46 at 87:2-4. +Epstein referred Google LLC as a client to JPMorgan. Ex. 46 at 87:5-6. +121 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 122 of 148 +282. Epstein referred the Sultan of Dubai, Sultan Ahmed bin Sulayem as a client to JPMorgan. +Ex. 46 at 87:7-8. +283. Epstein referred Mort Zuckerman as a client to JPMorgan. Ex. 46 at 87:15-16. +284. Epstein referred +as a client to JPMorgan. Ex. 46 at 87:17-18. +285. Epstein referred David Gergen as a client to JPMorgan. Ex. 46 at 88:8-9. +286. Epstein referred Boris Nikolic as a client to JPMorgan. Ex. 46 at 88:10-11; Ex. 160 at +17:13-18:4. +287. Boris Nikolic was a medical advisor, who ran a venture fund. Ex. 160 at 17:13-18:4. +288. Boris Nikolic was "somehow related to Bill Gates." Ex. 160 at 17:13-18:4. +289. Epstein referred Larry Summers as a client to JPMorgan. Ex. 46 at 88:12-13. +290. Epstein referred +Pritzker, chairman and CEO of the Pritzker Organization, as a +client or for additional activities or funds to JPMorgan. Ex. 172 at Resp. 49; Ex. 46 at 310:19- +311:4. +291. Epstein facilitated meetings between Staley and Ehud Barak. Ex. 46 at 89:11-16. +292. In January 2008, Epstein facilitated an introduction between JPMorgan executives and +Ehud Barak, and Staley directed his assistant to arrange the meeting through Jamie Dimon's office. +Ex. 173 at -152. +293. +Epstein facilitated meetings between Staley and Peter Mandelson. Ex. 46 at 90:20-24. +294. +Lord Peter Mandelson was a senior member of the British Government. Ex. 144 at -009. +295. +On June 5, 2009, Epstein wrote to Staley, "well, [sic] for all intends [sic] and purposes +peter mandelson is now deputy prime minister." Ex. 174 at -959; Ex. 144 at -009; Ex. 175 at 6. +122 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 123 of 148 +296. +On June 17, 2009, Epstein wrote to Staley, "peter will be staying at 71 st over weekend, do +you want to organize either you, or you and Jamie,, [sic] quietly,, [sic] up to you." Ex. 176 at -005; +Ex. 144 at -009; Ex. 175 at 6. +297. In January 2009, Epstein wrote to Staley, "david gergen is coming to see me today.. [sic] +we should talk before twelve." Ex. 177 at -763; Ex. 144 at -006; Ex. 175 at 4. +298. David Gergen is a former adviser to Presidents Nixon, +,, Reagan, and Clinton. Ex. 144 +at -006. +299. Epstein facilitated meetings between JPMorgan employees and Prince Andrew. Ex. 46 at +96:13-16. +300. On April 15, 2010, Epstein wrote to Prince Andrew the +of York, tdoy@rlwgp.com, +"jes staley will be in London on thurs the 22.. [sic] i think you should meet if you are in town.. +[sic]." Ex. 178 at -534; Ex. 144 at -011; Ex. 175 at 6. +301. On May 18, 2010, Epstein wrote to Staley, "anadrew [sic] will try to see you on your trip +to london." Ex. 179 at -970; Ex. 144 at -011; Ex. 175 at 6. +302. On September 2, 2010, Lesley Groff wrote to Epstein, "Jes Staley's office called saying +last night Jes met up with Prince Andrew and Tim +"Ex. 180 at -703; Ex. 144 at -011; Ex. +175 at 7. +303. +LId. +Ex. 181 at -071. +Id. +123 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 124 of 148 +304. +On December 22, 2010, Prince Andrew wrote to Staley, "Wishing you a very happy +Christmas and New Year. Sorry to have missed you this week.... Hope to catch up sometime +after the New Year. I will be at Davos as usual." Ex. 182 at -808; Ex. 144 at -011; Ex. 175 at 7. +305. +In November 2013, Prince Andrew hosted Jamie Dimon for dinner and performances at +Buckingham Palace. Ex. 183 at -462-63. +306. Epstein facilitated meetings between Staley and Bill Gates. Ex. 46 at 92:20-23. +307. Epstein introduced his JPMorgan banker (Paul Morris) to Andrew Farkas. Ex. 160 at 15:23- +17:12. +308. Andrew Farkas is a major real estate investor who founded Island Capital Group. Ex. 144 +at -006. +309. Epstein introduced JPMorgan to David Mitchell, a real estate developer. Ex. 160 at 14:20- +15:5. +310. Epstein referred Robert Lee Burch IT, former CEO of Jonathan Engineered Solutions and +member of A.W. +advisory board, as a client to JPMorgan. Ex. 184 at -986; Ex. 39 at Resp. +29. +311. In 2003, Epstein's JPMorgan Private Banker ( +several managers, including Glenn +312. +) noted that Epstein "helped us source +and Steve Saltzman." Ex. 185 at -893. +Ex. +186 at - 184_R. +313. +124 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 125 of 148 +Ex. 187 at - 559. +314. +Ex. 188 at -001-003; Ex. 189 at -008. +315. Sergey Brin became a client of JPMorgan's San Francisco Private Bank in 2004. Ex. 190 +at - 710. +316. Staley referred Brin to Robert +Francisco. Ex. 189 at -001; Ex. 190 at -709. +317. +JPMorgan Banker/Managing Director in San +Ex. 191 at - 185. +318. +Ex. +192 at - 515. +319. +Ex. 193 at -516. +320. +125 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 126 of 148 +Ex. 194 at -517. +321. +Ex. 195 at -519. +On October 26, 2006, Ann Borowiec emailed Jes Staley, "Catherine spoke to me about the +need to have a NY team for Jeffrey Epstein, as the advisor to the Google founders." Ex. 196 at - +322. +356. +323. +Ex. 197 at -520. +324. +Ex. 198 at -522. +325. +Ex. 199 at - 590. +126 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 127 of 148 +326. +Ex. 200 at -423. +327. +Ex. 201 at -152. +328. +Ex. 202 at - 668. +Ex. 203 at -670. +329. +Ex. 204 at -67l. +330. +Ex. 205 at -720. +331. In July 2014, JPMorgan noted "It]he overall Brin relationship is one of the largest in the +Private Bank, of +$4BN." Ex. 190 at -710. +127 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 128 of 148 +332. Brin and the CEO, CFO, and CIO of his family office, Bayshore Global, met with Mary +Erdoes, Kelly Coffey, John Duffy and other JPMorgan regional executives. Ex. 190 at -709. +333. +Ex. 61 at -033. +334. +Ex. 61 at -033. +335. +Ex. 206 at +-037; Ex. 207 at 1. +Ex. 206 at +-037. +336. Sultan Ahmed bin Sulayem, was a senior United Arab Emirates official involved in +ownership of the Dubai Ports. Ex. 144 at -009. +337. On December 7, 2009, Epstein wrote to Staley, "if you can have a one on one off the record +with sultan , [sic] he will meet you." Ex. 208 at -724; Ex. 144 at -012; Ex. 175 at 7. +338. +On December 8, 2009, Epstein wrote to Staley, "no to china /ports yet.. [sic] sultan will +meet you privately to give you guidance. ..." Ex. 209 at -897; Ex. 144 at -012; Ex. 175 at 7. +339. On December 8, 2009, Epstein wrote to Sultan bin Sulayem, copying Staley, "sultan , [sic] +jes is free thurs,, [sic] from 5-10 p.m. where and when,, [sic] only the two of you please." Ex. 210 +at -727; Ex. 144 at - 012; Ex. 175 at 7. +128 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 129 of 148 +340. +On December 9, 2009, Epstein wrote to Staley, "sultan is laying the groundwork for you +to establish a serious presence.. [sic] jpm reputation in the region is poor." Ex. 211 at -729; Ex. +144 at -012; Ex. 175 at 7. +341. Epstein's client, +_Black, was a customer of JPMorgan Private Bank. Ex. 39 at Resp. +192.; Ex. 212 at -010; Ex. 160 at 38:4-41:13. +342. One of Epstein's JPMorgan Bankers testified, ' +Black had a very significant net worth +and he was a CEO of a large investment firm, and I looked at him as a priority prospect." Ex. 160 +at 53:15-54:2. +343. Epstein occasionally brought opportunities to JPMorgan for them to "deepen" their +relationship with +Black. Ex. 171 at 46:9-15. +344. In July 2012, Epstein sought a loan through JPMorgan on behalf of | +purchase. Ex. 213 at -569; Ex. 160 at 173:8-21. +Black for an art +345. +Ex. 214 at -112. +346. +Ex. 215 at -892. +347. +Ex. 216 at -912. +129 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 130 of 148 +348. +Ex. 217 at -423. +349. +Ex. 218 at -646. +350. +On March 23, 2011, Roy Navon wrote Jacob Frenkel and Staley, "Against all odds, we +have been granted a meeting with Prime Minister Netanyahu." Staley forwarded the email from +Navon to Epstein and said, "Thanks." Epstein responded to Staley, "surprisee [sic] surprise." Ex. +219 at -841; Ex. 144 at -008; Ex. 175 at 6. +351. On April 10, 2011, Epstein wrote to Staley, "I will be back tomorow. [sic] Karim Wade +son of the senegalese president and one of the most important players in africa, will be at the house +this week, i think you will enjoy him." Ex. 220 at -260; Ex. 144 at -008; Ex. 175 at 6. +352. On September 16, 2011, Epstein wrote to Staley, "co founder of facebook , [sic] and +founder of spotify, sean +, [sic] will be at the house for dinner on sunday —come." Ex. 221 +at -368; Ex. 144 at -009; Ex. 175 at 6. +353. +Ex. 222 at Resp. S. +354. +In August 2013, after JPMorgan informed Epstein of the decision to exit him from the +bank, Duffy and Erdoes decided it was okay to continue working with Epstein as long as it was +through his client accounts. Ex. 212 at -010; Ex. 171 at 174:19-175:23. +355. +JPMorgan continued to work with Epstein on accounts for +Black, CEO of Apollo, a +private equity group. Ex. 223 at -344; Ex. 224 at -434-35; Ex. 225 at -511; Ex. 226 at -218-19; Ex. +171 at 45:8-13. +130 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 131 of 148 +356. +Duffy gave Epstein's JPMorgan Banker (Nelson) permission to continue a relationship +with Epstein as a potential source of referrals. Ex. 171 at 172:2-175:9. +357. Nelson maintained a relationship with Epstein after he was terminated as a client. Ex. 171 +at 43:6-24. +358. Nelson met with Epstein 8 to10 times after Epstein was terminated. Ex. 171 at 177:12-18. +359. JPMorgan admits that Mary +met with Epstein at his Manhattan townhouse two or +three times between 2000 and before Epstein's arrest in 2006. JPMorgan admits that Mary +also met with Epstein at his Manhattan townhouse once in 2011 and once in the summer of 2013. +Ex. 227 at Resp. 21. +360. +Ex. 228 at -644. +361. +Ex. 229 at -300. +362. +Ex. 230 at -592. +363. +131 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 132 of 148 +Ex. 231 at -975. +364. +Ex. 232 at -177. +365. +366. JPMorgan admits Epstein was involved in the establishment of a customer relationship +with Kathryn Ruemmler. Ex. 234 at Resp. 3. +367. +Ex. 235 at -394. +368. +Ex. 236 at -392. +369. +Ex. 237 at 467. +370. +Ex. 238 at -063. +371. Epstein was close friends with Glenn L +, the billionaire co-founder of Highbridge, and +godfather to one of _ +children. Ex. 239 | 3; Ex. 240 at -164; Ex. 123 at 173:19-74:1. +132 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 133 of 148 +372. Epstein advised JPMorgan regarding the acquisition. Ex. 241 at 590; Ex. 242 at -149-50. +373. Epstein also advised Highbridge regarding the acquisition. Ex. 241 at -590; Ex. 242 at - +149-50 +374. +On June 16, 2004, James Von Moltke emailed Jes Staley and David Brigstocke with the +subject line, "Thoughts on the 6/15/04 meeting with Highbridge," stating, "The good news is that +we did not leave any money on the table and that, based on the 9-11x multiple range we discussed +with Dimon et al... They should be encouraged to go ahead with the Dimon and Coulter lunch. . +.. This would be a good part of a follow-up discussion, ideally with you and prior to the +Dimon/Coulter meeting. ... We continue to be concerned about the role Jeffrey Epstein is or is +not playing. One concern that we have is that Jeffrey has been educating Glenn & Henry about our +structure and valuation thoughts..." Ex. 242 at - 149-50. +375. On January 14, 2004, the New York Times reported that JPMorgan had agreed to acquire +Bank One and stated: "The combined company will be headed by William B. +60, who +is currently the chairman and chief executive of J.P. +Chase. James Dimon, 47, the +chairman and chief executive of Bank One, will become president and chief operating officer of +the combined company. He is to succeed Mr. +as chief executive in 2006, although Mr. +will remain as chairman." Ex. 243 at 1. +376. +133 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 134 of 148 +Ex. 244 at -985, -987, -996, -998. +377. +Ex. 245 at -780. +378. JPMorgan admits that | +& Swieca Holdings, Inc. paid Financial Trust Company, Inc. +a fee related to JPMorgan's acquisition of a majority interest in Highbridge Capital Management +in 2004. Ex. 39 at Resp. 9. +379. +Ex. 246 +at -246-47. +380. Highbridge managed $7 billion in assets at the time JPMorgan acquired the majority +interest. Ex. 247 at 1. +381. On June 11, 2009, JPMorgan completed its purchase of Highbridge and touted it as "one +of the largest and most significant strategic alliances in the hedge fund industry." Ex. 248 at 1. +382. +At the October 2006 Rapid Response meeting, the Private Bank imposed a condition on +Epstein's accounts—he could remain a "banking" but not an investment client. Ex. 76 at -953. +383. +At the time, Epstein's brokerage business was at Bear Stearns, not JPMorgan. Ex. 124 at - +175; Ex. 249 at - 787. +134 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 135 of 148 +384. +Ex. 32 at 97:3-100:1. +385. +386. +JPMorgan considered him "problematic" from an investment standpoint. Ex. 250 at -254; +Ex. 167 at -654. By 2011, Epstein was the Private +Bank's investment arm's "biggest revenue producer." Ex. 168 at -977. +Ex. 251 at -223. +387. +On March 16, 2008, JPMorgan purchased Bear Stearns. Ex. 122 at 1. +388. The purchase kept Bear Stearns, which was heavily in mortgage-backed securities +investments, from bankruptcy following the housing market crash that led to the 2008 Great +Recession. Ex. 122 at 1. +389. +Ex. 252 at 1-2. +390. In August 2009, Epstein sued Bear Stearns for "fraudulently overstating] the value of Bear +Stearns' mortgages, mortgage-backed and asset-backed securities and other derivative financial +instruments, the adequacy of its liquidity and capital reserves, and the quality of Bear Stearns' risk +management." Ex. 253 9| 15. +391. +On July 19, 2011, JPMorgan offered Epstein a proposal to settle his High Grade Fund and +Bear Stearns claims together for S21 million. Ex. 254 at -561. The following day, Cutler responded, +"This is not an honorable person in any way. He should not be a client." Id. +392. +On July 21, 2011, Cutler wrote to Erdoes regarding a settlement offer to Epstein, "I would +like to put it and HIM behind us. Not a person we should do business with - period." Ex. 255 at - +958 +_R. +135 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 136 of 148 +393. On August 4, 2011, JPMorgan met for a fourth Rapid Response Meeting regarding Epstein +and concluded that "Duffy to reach out to Jes Staley and advise that we exit while things are a bit +settled." Ex. 256 at 31. +394. On April 8, 2011, Nina Shenker emailed Kevin McCleerey with the subject, "Rapid +Response." Shenker wrote, "[!]f you could break down between ddas, brokerage and fund holdings +and others [sic] categories. So that we can understand the process for offboarding the account." +Ex. 257 at -025. Kevin McCleerey responded with the attachment, "Rapid Response Team - +Jeffrey Espstein [sic] 3r Mtg - Jan 2011 - March 2011 update-doc.zip." Employees were working +to collect information to "understand the process for offboarding the account." Id. at -025. +395. In July 2011, when Epstein approved the settlement, Nina Shenker, then GC to the Private +Bank, wrote to Erdoes, "Steve [Cutler] at conclusion of JE approval [of Bear Stearns settlement], +asked when we are offboarding JE. I reminded him that we have the other matter outstanding." +Ex. 258 at -982; Ex. 99 at 268:12-272:24. +396. +Ex. 259 at - 106. +397. +_Ex. 252 at 1-2; Ex. 260 at -610. +398. +Ex. 261 at -948_R. +399. +Ex. 262 at -561. +136 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 137 of 148 +400. +Ex +262 at -560. +401. "The Talented Mr. Epstein" states: "in his early 20s [Epstein] got a job teaching physics +and math at Dalton, the elite Manhattan private school. While there he began tutoring the son of +Bear Stearns chairman Ace Greenberg and was friendly with a daughter of Greenberg's. Soon he +went to Bear Stearns, where, under the mentorship of both Greenberg and current Bear Stearns +C.E.O. James Cayne, he did well enough to become a limited partner—a rung beneath full partner." +Ex. 49 at 5. +402. In August 2010, Alan "Ace" Greenberg, who was now at JPMorgan, wanted to continue to +do business with Epstein so he went to Cutler for an exception to the felon policy. Ex. 263 at 910- +11. +403. In his deposition, Jes Staley agreed that Greenberg was "a fairly important person" with +"heft" at JPMorgan around 2010. Ex. 46 at 173:13-24. +404. Beginning in 2011, Staley and Erdoes had "regular communication with Jeffrey Epstein +relating to certain strategic initiatives and business proposals." Ex. 144 at -012; Ex. 175 at 1. +405. +Ex. 302 at -555-56; Ex. 303 at - 548-49. +406. +JPMorgan admits that Epstein and JPMorgan personnel discussed a potential donor advised +fund relating to The Bill and Melinda Gates Foundation and Bill Gates. Ex. 39 at Resp. 14. +407. On February 6, 2011, Epstein wrote to Staley regarding a potential donor advised fund for +The Bill and Melinda Gates Foundation, "you could tie it initially just to the gates program, [sic] +miinimum [sic] gift. 100 million. it could then be opend [sic] up later. IT will be the largest +137 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 138 of 148 +foundation in the world .... done right its [sic] 100 billion dollars in 2 years.... Farming the +investments to a highbridge is no brainer. ... It will be the most sort [sic] after board in the +country." Ex. 264 at -591; Ex. 144 at -012; Ex. 175 at 7. +408. +In August 2011, Epstein wrote to Staley and Erdoes regarding +noting it will be a "very HIGH profile" opportunity and recommending it require a minimum $100 +million donation. Ex. 265 at -652; Ex. 144 at -013; Ex. 175 at 7. +409. +Ex. 266 at -924. +410. +Ex. 267 at -666. +411. +Ex. 268 at -028. +412. +JPMorgan admits it had communication with Epstein about a fee for Epstein in connection +with a proposed donor advised fund. Ex. 39 at Resp. 15. +413. +138 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 139 of 148 +Ex. 269 at -931-32. +414. +On April 27, 2009, Epstein emailed Staley, " +can meet have dinner lunch a weekend +[sic] with any of the following seth Lloyd mit quantum computing.. [sic]| +gell-man, santafe institute quarks , [sic] brian +Columbia -string theory,, [sic] leonard Susskind ,, [sic] +strings theory, +Krause,, [sic] origins institute phoenix Arizona.. [sic] lee smolin perimeter +institute, loop quantum gravity , [sic] she can see the large adron [sic] collider in switzerland. +private tour." Ex. 270 at -844; Ex. 144 at -004; Ex. 175 at 4. +415. +Ex. 144 at -004. +416. +On September 24, 2010, Staley forwarded an email chain between him, +and Staley's wife, +regarding a professor at Columbia to Epstein, +"can u [sic] get to this professor at Columbia?" Ex. 271 at -121; Ex. 144 at -004; Ex. 175 at 4. On +September 25, 2010, Epstein responded, 'in a snap." Id. +417. +On December 12, 2008, Erdoes wrote to Staley regarding Bernie Madoff, "... glenn and I +have been going back and forth all night. This is terrible. Just terrible. +has over lb. Nicole +has another client with 1b. We have HUNDREDS of clients with some. The ny/palm beach +community will be in shock. Can you call JE to get scoop from down there?" Ex. 272 at -627. +139 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 140 of 148 +418. On April 7, 2023, in a CNN interview Jamie Dimon, in response to a question about +whether "JPMorgan should have acted more quickly after Epstein pleaded guilty to one of these +charges in 2008" said "Hindsight is a fabulous giff." Ex. 273 at 21. +419. In the same CNN interview, Jamie Dimon was asked, "[the U.S. Virgin Islands is] alleging +that your bank helped facilitate payments to Epstein's victims and benefited from human +trafficking while ignoring warnings. Do those allegations have merit?" Dimon responded, "[W]e +have some of the best lawyers in the world compliance, out of the DOJ, out of SEC important +divisions who review all of these things and make decisions at the time based on what they know, +as best as they know." Ex. 273 at 20. +JPMorgan Obstructed Enforcement of the TVPA +420. +Shaun O'Neill, former Special Agent with the Federal Bureau of Investigations ("FBI"), +states that "the FBI relies on financial institutions as a key partner to ... obtain the information +necessary to answer the questions of who, what, when, where, and why." Ex. 274 at 17. The +information in JPMorgan's possession "warranted a constant stream of information from JPMC to +the FBI about Epstein's ongoing suspicious activity ... Human trafficking is an ongoing crime, +with harm incurred every day that the crime continues." Id. at 18. "It shocks the conscience that it +was not until Epstein's death in prison that JPMC suddenly recognized Epstein's prior banking +transactions as +Id. at 25. O'Neill further states that "When it became public that +Jeffrey Epstein had been arrested and that he had used cash to commit his sexual crimes against +children, JPMC's| +crimes that it was investigating against Epstein." Id. Further, +impaired the government's ability to prosecute the +"the sheer amount of cash being dispersed," +"more than $3 million was paid by Epstein to women, many of whom had Eastern European +140 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 141 of 148 +surnames," and Epstein's loan to modeling agency MC2—"Epstein would have been federally +charged at a much earlier date." Id. at 18-25. "Had the FBI been notified of this +banking +activity all being related to Epstein ... [Epstein] would not have been able to continue his criminal +activity from 2008 onward." Id. at 20-21. +421. +Ex. 275 at -683. +422. +Ex. 276 at -422. +423. +In 2019, Brunel was arrested and charged with rape of minors and sexual harassment and +was under investigation for human trafficking. Ex. 277. +424. +Ex. 69 at -545-550. +Ex. 69 at -545. +141 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 142 of 148 +Facts Concerning Epstein's Registration as a Sex Offender in the Virgin Islands +425. +Shani Pinney, coordinator for the sex offender registry, and former Attorney General +Vincent Frazer both testified that they were not responsible for and did not enable Epstein's crimes. +Ex. 278 at 266:17-268:8; Ex. 280 at 12:9-21, 455:24-456:20. +426. Epstein never failed to register as a sex offender. Ex. 280 at 85:2-87:2; 442:15-17. +427. Shani Pinney, coordinator for the sexual offender registry, testified that news reports were +not sufficient basis to initiate an investigation because they did not contain the requisite "concrete +allegations" of wrongdoing. Ex. 280 at 12:9-21; 415:1-20; 446:5-447:9; 447:16-449:1. +428. Former Attorney General Denise +similarly testified that she couldn't rely on "news +reports," "rumor" or "innuendo" to initiate an investigation into Epstein. Ex. 282 at 167:3-170:3. +429. As witnesses testified, absent an actual complaint from a victim or eyewitness evidence +brought to the Department of Justice's attention, the Department could not initiate investigations. +Ex. 280 at 415:1-20; 446:5-447:9; 447:16-449:1; Ex. 282 at 167:3-170:3. +430. Ms. Pinney and Attorney | +both confirmed they received no concrete complaints of +misconduct by Epstein. Ex. 280 at 206:6-208:17; Ex. 282 at 164:3-167:2. +431. Upon assuming her role as Attorney General, Attorney +inquired of various agencies +to confirm whether they had received any complaints regarding Epstein. She found no evidence +that any complaints had been received. Ex. 282 at 164:3-167:2. +432. +The Virgin Islands Department of Justice performed address verification checks (also +called "sweeps") roughly annually in conjunction with U.S. Marshalls. Ex. 280 at 52:1-54:12, +105:20-106:3, 398:18-400:12. +433. +The address checks are not warrants; government officials do not possess the ability to +enter a sex offender's property or conduct a search. Ex. 280 at 49:21-50:25; 440:1-441:3. +142 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 143 of 148 +434. In certain years, the U.S. Marshalls and Virgin Islands officials did not proceed beyond +Epstein's dock. If an offender refused entry, the government officials performing the check did +not possess authorization to enter. Ex. 280 at 43:7-46:24, 47:12-48:11, 49:4-50:25. +435. +Ms. Pinney testified that she conferred with the federal government concerning this +practice and was told that it was similar to a situation where a landowner has placed a gate at the +border to his property. The officials were not permitted to proceed beyond that gate without a +warrant. Ex. 280 at 108:5-110:23. +436. It was not improper or unusual for the Government to confirm addresses at a sex offender's +place of employment, as was done one year with Epstein. Ex. 280 at 409:7-410:4; 438:15-439:20. +437. In 2012, the Virgin Islands Legislature amended its sex offender laws, in part to obtain +federal funding for its sex offender unit. Ex. 278 at 79:12-80:10, 119:9-121:12; Ex. 280 at 125:21- +126:6. +438. The U.S. Government approved all changes to the Virgin Islands sex offender laws in +advance. Ex. 278 at 122:1-9; Ex. 280 at 306:22-307:12, 452:21-453:4. +439. Although Epstein's attorneys sought to coordinate with legislators concerning proposed +changes to the Virgin Islands laws, the Legislature ultimately rejected Epstein's proposed changes. +Ex. 278 at 160:12-165:1; 262:10-264:4. +440. Epstein applied for and received a waiver in 2012 of his travel notification requirements +pursuant to these statutory provisions. Ex. 278 at 11:13-13:23, 187:16-188:15, 189:18-190:24, +192:4-10, 193:14-24; Ex. 279 at 12480-12491. +441. +Then-Attorney General Vincent Frazer testified that he relied on representations of +Epstein's 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 +143 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 144 of 148 +would arise from the waiver. Ex. 278 at 190:8-24, 191:3-12, 193:14-24, 250:11-255:13; Ex. 281 +at 12246-12250, 12263-65. +442. Epstein's 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. 278 at 251:16-255:13; Ex. 281 at 12246- +12250, 12270. +443. 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. 280 at 363:3-365:12. +444. Travel notifications are not authorizations or requests; the Government had no ability to +restrict Epstein's travel. Ex. 278 at 135:6-17, 200:14-201:4. +445. Entry into the Virgin Islands from overseas is controlled by federal authorities, not the +Virgin Islands Government. Ex. 278 at 209:23-210:5, 265:13-268:8. +Facts Concerning Tax Benefits Granted to Epstein's Companies +446. The EDC granted tax incentives to two of Epstein's companies: Financial Trust Company +and Southern Trust Company. Ex. 283 at 29:10-19, 34:2-10, 42:3-21; Exs. 284-286. +447. The first grant of benefits to an Epstein-owned company occurred in 1999 to Financial +Trust Company. Ex. 283 at 29:10-19; Ex. 284. +448. +In 2009, Financial Trust applied for and received an extension of benefits. Ex. 283 at 34:2- +10; Ex. 285. +144 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 145 of 148 +449. Epstein formed a new company—Southern Trust-which applied for and received tax +benefits in 2012. Ex. 283 at 42:3-21; Ex. 286. +450. +Each time that Financial Trust or Southern Trust sought benefits, the companies submitted +applications for the benefits. Ex. 287 at 42:3-21; Exs. 288-289. +451. 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 opportunity to +present their case and answer questions. Ex. 287 at 42:3-21, 67:15-69:7, 169:21-170:2; Ex. 288- +290; Ex. 291 at 29:12-20; Ex. 292. +452. 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. 287 at +22:18-23:10, 42:3-21; Exs. 288-289. +453. Epstein's Florida conviction was not a sufficient basis for revocation of benefits at that +time because there was no evidence available to the EDC that Epstein's solicitation of a minor for +prostitution in Florida was "connected with the operation" of Epstein's USVI businesses. Ex. 287 +at 157:6-24, 159:10-15, 170:3-172:3. +454. The EDC did not have access to Epstein's companies' daily financial transactions, and was +not aware of any connection between his conduct and the operations of his business. Ex. 287 at +61:4-24, 148:11-149:7, 157:6-24, 159:10-15, 170:3-172:3; Ex. 283 at 53:22-54:4, 55:9-21; Ex. 291 +at 295:25-297:18. +455. +Indeed, the EDC reached out to Epstein's attorney in January 2015 to inquire whether +media reporting regarding allegations of misconduct had any connection to the business of +Epstein's Southern Trust Company. His attorney responded to confirm "[w]e do not believe that +145 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 146 of 148 +these media discussions will have any impact on the business activities of STC." Ex. 287 at 172:17- +174:10; Exs. 293-294. +456. Margarita +, a witness with more than 30 years' experience at the EDC, testified +that the cost-benefit ratios provided to board members cannot be analyzed in isolation because the +ratio "doesn't give the full picture to anyone" and "can be misleading." Ex. 287 at 78:25-79:21, +80:23-81:13. Governor Albert Bryan testified that the ratios were not intended for "smaller +financial firms" like Epstein's companies. Ex. 291 at 47:22-49:6. +457. +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. 287 at 81:14-83:2. +Governor Bryan agreed testifying that "the government didn't give up anything" because "half of +some is better than all of none." Ex. 290 at 49:7-23. +458. The ratio further ignores ancillary benefits that accrue to the Territory from the presence +of high net-worth individuals, who engage in economic activity unrelated to their businesses that +benefits the Territory. Ex. 290 at 48:18-49:6, 50:5-51:13, 297:23-298:17. +459. During a March 2009 public hearing, Epstein's attorney explained that a denial of an +extension would likely cause "a responsible business person ... to seriously consider relocating +the business" if another territory offered similar benefits. Ex. 295 at 40:20-41:3; Ex. 296. +460. +Thus, the EDC could not assume that it would collect Epstein's tax revenue if the benefits +were not extended. Ex. 290 at 49:7-23 +461. +The EDC did not treat Epstein differently than any other beneficiary. Ex. 290 at 280:3-17. +146 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 147 of 148 +Facts Concerning Cecile de Jongh's Employment with Epstein +462. Cecile de Jongh became First Lady when her husband was elected Governor. She testified +that "there's 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. +297 at 17:12-21:19. +463. During the time her husband was Governor, Ms. de Jongh was widely known and +recognized to be employed by Epstein's businesses and acting on their behalf. Ex. 287 at 130:12- +14; Ex. 298 at 6:12-9:11, 10:10-23, 11:21-13:3; Ex. 299 at 49:4-21. +464. Her employment with Epstein had been widely reported and numerous witnesses +confirmed their familiarity with her employment. Ex. 287 at 130:12-14; Ex. 298 at 6:12-9:11, +10:10-23, 11:21-13:3; Ex. 299 at 49:4-21; Ex. 291 at 14:21-15:17; Ex. 283 at 36:12-37:2. +465. Ms. de Jongh had no contact with personnel at the Department of Justice responsible for +sex offender registration and monitoring. Ex. 280 at 158:7-12, 179:20-24. +466. Decisions concerning whether or not to grant tax benefits were first made by the board +members of the EDC. Ex. 287 at 22:18-23:10, 27:25-28:6. +467. 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's recommendation in the first +place. Ex. 287 at 22:18-23:10, 27:25-28:6. +468. Ms. de Jongh vigorously denied knowing about or facilitating Epstein's crimes in the +Virgin Islands. Ex. 297 at 33:17-39:8, 133:10-134:2, 212:24-213:18, 217:11-220:6. +469. With respect to efforts to establish an English as a Second Language class, Ms. de Jongh +testified that she was not aware any of the women were potential trafficking victims. Ex. 297 at +131:16-132:16, 136:10-137:1. +147 + + +Case 1:22-cv-10904-JSR Document 221 Filed 07/24/23 Page 148 of 148 +470. +The documents also make clear that the University merely agreed to offer an alreadyexisting class to individuals. Ex. 297 at 129:11-14; Ex. 300. +Dated: July 24, 2023 +ARIEL | +L. ESQ. +ATTORNEY GENERAL +Is/ Mimi Liu +MIMI LIU +Admitted Pro Hac Vice +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +mliu@motleyrice.com +VENETIA VELAZQUEZ +Admitted Pro Hac Vice +Acting Chief, Civil Division +Virgin Islands Department of Justice +Office of the Attorney General +213 Estate La Reine, RR1 Box 6151 +Kingshill, St. Croix +U.S. Virgin Islands 00850 +Tel: (340) 773-0295 ext. 202481 +venetia.velazquez(@doj.vi.gov +LINDA +| (Admitted Pro Hac Vice) +DAVID I. ACKERMAN +PAIGE BOGGS (Admitted Pro Hac Vice) +Motley Rice LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Isinger@motleyrice.com +dackerman@motleyrice.com +pboggs@motleyrice.com +Attorneys for Plaintiff Government of the +United States Virgin Islands +148 \ No newline at end of file diff --git a/vision-fixhub/court-05/6a7f3f929d0f8e97f8dc0ec0fa147a868a96608338a962a183170f46540345ca.receipt.json b/vision-fixhub/court-05/6a7f3f929d0f8e97f8dc0ec0fa147a868a96608338a962a183170f46540345ca.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d12a50844d521c02da55c09330cba76500ee0943 --- /dev/null +++ b/vision-fixhub/court-05/6a7f3f929d0f8e97f8dc0ec0fa147a868a96608338a962a183170f46540345ca.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -3268, + "dataset": "marble-joined", + "doc_id": "6a7f3f929d0f8e97f8dc0ec0fa147a868a96608338a962a183170f46540345ca", + "engine": "marble-apple-vision", + "event_count": 158, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "f7483a45fcf20d0084043b4ef2701e0e6b77cb095fcf00acdf781078f099b5e8", + "output_sha256": "d4c94c3f08fce1f3d929ebda2f77edf767173831e56f296ea8915210500371ba", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6a8f8a130af9709012b0cf05d2bc79d9a2bd8d03bbf8a97652e6a0be6b40ef90.md b/vision-fixhub/court-05/6a8f8a130af9709012b0cf05d2bc79d9a2bd8d03bbf8a97652e6a0be6b40ef90.md new file mode 100644 index 0000000000000000000000000000000000000000..4aa92a87c819a3cd6f741ce5aed80e521a41c7a0 --- /dev/null +++ b/vision-fixhub/court-05/6a8f8a130af9709012b0cf05d2bc79d9a2bd8d03bbf8a97652e6a0be6b40ef90.md @@ -0,0 +1,17 @@ +Case 1:22-cV-10904-JSR Document 284-36 Filed 08/14/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 284-36 Filed 08/14/23 Page 2 of 2 +Date: 10/18/2017 12:22:55 AM +From: "Cecile de Jongh" +To: "Lesley Groff" +Subject: Slight Change of Plans +Good evening Lesley. +We just got a call from American Airlines and they have switched us to leaving on Saturday, October 21st instead of Friday the 20th. Is it alright for us to stay one +more day in the apartment? +With warmregards, +Cecile +Sent frommy iPhone and misspellings courtesy of iPhone. + +ESTATE_JPM060812 diff --git a/vision-fixhub/court-05/6a8f8a130af9709012b0cf05d2bc79d9a2bd8d03bbf8a97652e6a0be6b40ef90.receipt.json b/vision-fixhub/court-05/6a8f8a130af9709012b0cf05d2bc79d9a2bd8d03bbf8a97652e6a0be6b40ef90.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..39482dfd926924659cb4581ff392b28fcadcdf09 --- /dev/null +++ b/vision-fixhub/court-05/6a8f8a130af9709012b0cf05d2bc79d9a2bd8d03bbf8a97652e6a0be6b40ef90.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "6a8f8a130af9709012b0cf05d2bc79d9a2bd8d03bbf8a97652e6a0be6b40ef90", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "c1f4a9d7d10b52fd5e46308fec0aaafcfa2d76cabdb5a50538e8973f568bd57b", + "output_sha256": "3ec978d0f965fbf5f1839deebf37f18a5360a660f4cd25d417b40a456953fb60", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6ab750dc8377ac7f180ce6629d0076a077148953c2d58532771ac7f004890229.md b/vision-fixhub/court-05/6ab750dc8377ac7f180ce6629d0076a077148953c2d58532771ac7f004890229.md new file mode 100644 index 0000000000000000000000000000000000000000..46cf8436bb8e11ce345b8b6790e7bf17873e874f --- /dev/null +++ b/vision-fixhub/court-05/6ab750dc8377ac7f180ce6629d0076a077148953c2d58532771ac7f004890229.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 311-31 Filed 08/25/23 + + +Filed Under Seal diff --git a/vision-fixhub/court-05/6ab750dc8377ac7f180ce6629d0076a077148953c2d58532771ac7f004890229.receipt.json b/vision-fixhub/court-05/6ab750dc8377ac7f180ce6629d0076a077148953c2d58532771ac7f004890229.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..64a690988eb410def90020d0aa4e9cc929a5e5f6 --- /dev/null +++ b/vision-fixhub/court-05/6ab750dc8377ac7f180ce6629d0076a077148953c2d58532771ac7f004890229.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "6ab750dc8377ac7f180ce6629d0076a077148953c2d58532771ac7f004890229", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "442fb29b823028b66c9697bd88767030097d8ca6bea3d52629e10d04578c1b36", + "output_sha256": "ac320ca8e3522a021f36ab942c6516aa027a8ef48d7de6691d4ad9a25d139f61", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6ac5737926f402753d276f23d4691aa3d87e0f1f8b23612ea3a8d5d62006f0e1.md b/vision-fixhub/court-05/6ac5737926f402753d276f23d4691aa3d87e0f1f8b23612ea3a8d5d62006f0e1.md new file mode 100644 index 0000000000000000000000000000000000000000..98393243fe24daa11106006c37ea5a73b55d86a0 --- /dev/null +++ b/vision-fixhub/court-05/6ac5737926f402753d276f23d4691aa3d87e0f1f8b23612ea3a8d5d62006f0e1.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 243-14 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/6ac5737926f402753d276f23d4691aa3d87e0f1f8b23612ea3a8d5d62006f0e1.receipt.json b/vision-fixhub/court-05/6ac5737926f402753d276f23d4691aa3d87e0f1f8b23612ea3a8d5d62006f0e1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..13e185c46bd8ef4a3cf030aae19dba89be5284cf --- /dev/null +++ b/vision-fixhub/court-05/6ac5737926f402753d276f23d4691aa3d87e0f1f8b23612ea3a8d5d62006f0e1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "6ac5737926f402753d276f23d4691aa3d87e0f1f8b23612ea3a8d5d62006f0e1", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "01d24c7c9d169b5be0041f63e3d37389ed8b3094e63484b6e840ca1df0df4a46", + "output_sha256": "307530af2bdd97322d2e9fdab9473fa2206f3a54261e8299817dc427b0687a91", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6af65c3cda055f827c81cb33d10a64aa32ce079f1fc65970d58c0f41fe50b7e9.md b/vision-fixhub/court-05/6af65c3cda055f827c81cb33d10a64aa32ce079f1fc65970d58c0f41fe50b7e9.md new file mode 100644 index 0000000000000000000000000000000000000000..05fd1364f23a4757120eba492ac5869e2d07f78a --- /dev/null +++ b/vision-fixhub/court-05/6af65c3cda055f827c81cb33d10a64aa32ce079f1fc65970d58c0f41fe50b7e9.md @@ -0,0 +1,289 @@ +Case 1:22-cV-10904-JSR Document 268-56 Filed 08/07/23 Page 1 of 6 + + + +Case 1:22-cV-10904-JSR Document 268-56 Filed 08/07/23 Page 2 of 6 +1 +2 +3 +4 +5 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +VS. +JPMORGAN CHASE BANK, N.A., +Defendant. +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +No. 22-cv-10904-JSR +v. +JAMES EDWARD STALEY, +Third-Party Defendant. +THE ORAL DEPOSITION OF SANDRA BESS was taken on +the 18th day of May, 2023 at the Ritz-Carlton Hotel, +6900 Great Bay, Nazareth, Charlotte Amalie, St. +U.S. Virgin Islands, between the hours of 8:43 a.m. and +11:53 a.m. pursuant to Notice and Federal Rules of Civil +Procedure. +Reported by: +DESIREE D. +Registered Merit Reporter +I Reporting Services +St. +P.O. Box 307501 +•, Virgin Islands +(340) 714-0269 + + +Case 1:22-cV-10904-JSR Document 268-56 Filed 08/07/23 Page 3 of 6 +15 +1 +2 +3 +4 +5 +done for the period. +I see. So if there were a renewal coming +up and there was no recent compliance report, you +would prepare a summary of their compliance? +MR. ACKERMAN: Objection to form. +(By Mr. Neiman:) Is that fair? You can +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +e. +answer. +A. +Yes, sir. +All right. Now, these compliance reports +that you prepare for a particular certificate holder, +how often would you put together a compliance report? +A. +A compliance report should be done +annually, but because the agency had some backlog as +we termed it, sometimes the report would take +probably three years before completion, five years +before completion, and sometimes you'd have one +that's done on an annual basis. +Would it be unusual for a company to not +get a compliance report until nine years after they +started as a certificate holder? Would that be +unusual? +A. +It is -- should not be unusual 7but it +maybe has happened in one or two cases. +Okay. So not the normal practice but might +have happened one or two times. + + +Case 1:22-cV-10904-JSR Document 268-56 Filed 08/07/23 Page 4 of 6 +22 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +A. +From the annual report. +2. Okay. So, you get the information provided +by the certificate holder? +A. +Yes, sir. +All right. +And what do you do to audit +whether the income information and tax information +provided by the certificate holder is accurate? +MR. ACKERMAN: Objection to form. +THE WITNESS: Excuse me one +second. So we verify it. So I 1o0k -- +I would look at the presentation and +what was presented at the back and +ensure that the numbers total, and then +that's the information I would use. +(By Mr. Neiman:) Okay. So, you would make +sure that what's in the cover sheet of the annual +report matches what the company has provided to you in +the support behind the cover sheet? +A. +Yes, sir. +And would you look at any third-party +sources or just the information the company provided +in terms of verifying their income and the tax +benefit? +A. +Only if it's unclear, and I would need to +veri - go a little further to clarify the + + +Case 1:22-cV-10904-JSR Document 268-56 Filed 08/07/23 Page 5 of 6 +23 +1 +2 +3 +4 +5 +information provided. +Okay. But as long as what was provided +appear to support the numbers on the cover sheet, that +will be the end of your analysis? +MR. ACKERMAN: Object to form. +Vague. +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE WITNESS: Typically, it would +be. +e. +(By Mr. Neiman:) Okay. Now, is any part +of your job as a compliance officer reviewing the +character of the people who are the owners of the +companies receiving tax benefits? +A. +No, sir. +Is there anybody at the Economic +Development Authority who has that responsibility? +A. +To the best of my knowledge, that would +come prior to -- I -- to me receiving the certificate +as a compliance officer, it would usually come from +the application side -- application division. +Okay. And what if -- withdrawn. +Is there anything that is done to see if +any character issues have arisen since the +application process? +A. +None that I know of. +Now, are you familiar with a person named + + +Case 1:22-cV-10904-JSR Document 268-56 Filed 08/07/23 Page 6 of 6 +36 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Okay. Did you do any unannounced visits to +the Financial Trust Company as best as you can recall? +A. As best as I can recall, I probably would +have done one or two. +Okay. Tell me about the one or two +unannounced visits that you recall. +A. +Nothing that I can specifically recall, +but I would show up at the door, identify myself, and +then ask to see the compliance person -- the person +that I relayed to, speak to on the email, on the +phone, or anyone else if that person is not there. +Who was the person or people at the +Financial Trust Company that you dealt with? +A. +Cecile de Jongh. +Okay. And who is Cecile de Jongh? +A. +The office manager at the Financial Trust +and Southern Trust. +And during the time that you were +interacting with her as a compliance officer, was she +also the First Lady of the Virgin Islands? +A. +Yes, sir. +So, her husband was the governor? +A. +Yes, sir. +Okay. Did the fact that she was married to +the governor affect how you interacted with her in any diff --git a/vision-fixhub/court-05/6af65c3cda055f827c81cb33d10a64aa32ce079f1fc65970d58c0f41fe50b7e9.receipt.json b/vision-fixhub/court-05/6af65c3cda055f827c81cb33d10a64aa32ce079f1fc65970d58c0f41fe50b7e9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..66177c233dbb4e588cc5ff52c7943048e7391541 --- /dev/null +++ b/vision-fixhub/court-05/6af65c3cda055f827c81cb33d10a64aa32ce079f1fc65970d58c0f41fe50b7e9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -83, + "dataset": "marble-joined", + "doc_id": "6af65c3cda055f827c81cb33d10a64aa32ce079f1fc65970d58c0f41fe50b7e9", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "877583d90f1a37d84c82c0ebd4d4ed5212ea63ab02b14e5e7a709f225722ae70", + "output_sha256": "5dd3bc5f8e202e7b6ee28be4dc76bd6077a28dce511b55ab9b7fc0e38cbc2ede", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6b197366adae76c7fad13fa09af78ef56414f8cd044ab5b0edb4fbe2611380ee.md b/vision-fixhub/court-05/6b197366adae76c7fad13fa09af78ef56414f8cd044ab5b0edb4fbe2611380ee.md new file mode 100644 index 0000000000000000000000000000000000000000..516a16fe50b0090f544a3a19fbffa90afa5365a8 --- /dev/null +++ b/vision-fixhub/court-05/6b197366adae76c7fad13fa09af78ef56414f8cd044ab5b0edb4fbe2611380ee.md @@ -0,0 +1,219 @@ +Case 1:22-cV-10904-JSR Document 263-68 Filed 08/07/23 Page 1 of 4 + +FILED UNDER SEAL + + +Case 1:22-cv-10904-JSR Document 263-68 Filed 08/07/23 Page 2 of 4 +Page 1 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-- +-- +-- +- - - - - - - +JANE +DOE 1, individually and on +behalf of all others similarly +situated, +- - x +Plaintiff, +Case No. +-against- +1:22-cv-10018-JSR +DEUTSCHE BANK AKTEINGESELLSCHAFT, et al., +Defendants. +- x +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +----- +- x +JANE DOE 1, individually and on +behalf of all others +similarly +situated, +JP +Plaintiff, +-against- +Civil Action No. +1:22-Cv-10019-JSR +CHASE BANK, N.A. +Defendants. +- - + +Videotaped oral deposition of PAUL +MORRIS, taken pursuant to subpoena, was +held +REMOTELY, commencing April 18, +2023, +9:00 a.m., on the above date, +before +Leslie Fagin, a Court Reporter +and Notary Public in the State of New +York. +MAGNA LEGAL SERVICES +(866) 624-6221 + + +Case 1:22-cV-10904-JSR Document 263-68 Filed 08/07/23 Page 3 of 4 +Page 337 +1 +P. Morris - Confidential +2 +and questions +about that. And I recall our +3 +CEO spoke to Epstein and, you know, got +4 +answers on that. +5 +6 +Do you remember what Jeffrey +Epstein's answers were for the cash +7 +8 +withdrawals in 2012 from Hyperion Air? +A. +I believe they were for -- his +9 answer was they were for fuel. +10 +11 +l. Did you ever attempt to determine +whether the cash was actually used for the +19:14:44 +19:14:52 +19:14:58 +19:15:00 +19:15:01 +19:15:05 +19:15:11 +19:15:16 +19:15:18 +19:15:22 +12 payment of fuel? +19:15:31 +13 +MR. BOUCHOUX: +Objection to form. +19:15:36 +14 +A. I did not. +19:15:38 +15 +e. Did it ever concern you that +19:15:41 +16 perhaps the cash was being withdrawn for the +19:15:47 +17 +payment related to sexual abuse or sex +19:15:51 +18 trafficking? +19:15:55 +19 +MR. BOUCHOUX: +Objection to form. +19:15:56 +20 +A. +It never occurred to me that that's +19:16:00 +21 +what was happening. +22 +e. +23 +around you at JP +Io your knowledge, did anyone +ever indicate that +19:16:02 +19:16:05 +19:16:07 +24 +25 +they suspected that the cash withdrawals were +19:16:11 +being used or could be used for sexual abuse +19:16:17 + + +Case 1:22-CV-10904-JSR Document 263-68 Filed 08/07/23 Page 4 of 4 +Page 338 +1 +P. Morris - Confidential +2 +O I +sex trafficking? +19:16:20 +3 +MR. BOUCHOUX: Objection to form. +19:16:23 +4 +A. Absolutely not, never heard that. +19:16:25 +5 +Same +question +at Deutsche Bank, did +19:16:28 +6 +anyone around you ever suggest that the cash +7 +withdrawal +activity from Jeffrey Epstein's +8 +accounts +was potentially being used by him to +9 sexually abuse or sex traffic? +10 +A. Absolutely not, I never heard that. +11 +e. Do you recall from time to time at +12 +13 +JP +being sent negative news articles +about Jeffrey Epstein connected to human +14 +15 +16 +trafficking? +MS. BEBCHICK: Objection. +A. I recall getting the negative news +17 +stories from time to time, but I don't recall +18 them being about trafficking. +19 +l. Did you ever speak with Steven +Cutler about Jeffrey Epstein? +20 +21 +A. +No, never spoke to him. +22 +Q. +Did you ever attend any rapid +23 +response meeting that was called as a +24 +consequence of any negative news articles +19:16:34 +19:16:39 +19:16:42 +19:16:48 +19:16:52 +19:17:01 +19:17:04 +19:17:07 +19:17:09 +19:17:12 +19:17:15 +19:17:20 +19:17:24 +25 +related to Jeffrey Epstein? +19:17:47 +19:17:51 +19:17:52 +19:18:02 +19:18:06 +19:18:08 +19:18:12 \ No newline at end of file diff --git a/vision-fixhub/court-05/6b197366adae76c7fad13fa09af78ef56414f8cd044ab5b0edb4fbe2611380ee.receipt.json b/vision-fixhub/court-05/6b197366adae76c7fad13fa09af78ef56414f8cd044ab5b0edb4fbe2611380ee.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7882b62ab4bbfd2c95830951584743527262969d --- /dev/null +++ b/vision-fixhub/court-05/6b197366adae76c7fad13fa09af78ef56414f8cd044ab5b0edb4fbe2611380ee.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -174, + "dataset": "marble-joined", + "doc_id": "6b197366adae76c7fad13fa09af78ef56414f8cd044ab5b0edb4fbe2611380ee", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "d1be5596c32fc58eec8fe1adab80be035e93720e4997d3717ab5566d7013d0fb", + "output_sha256": "5d3cdf5183260e8f24fa0cc46f4edff1586e16f2f55c85d22f1b834f19e48d3e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6b2be091353f26305d73cfdb14e142a8094b7eccdb0d5e923e0861e7b8e00f3d.md b/vision-fixhub/court-05/6b2be091353f26305d73cfdb14e142a8094b7eccdb0d5e923e0861e7b8e00f3d.md new file mode 100644 index 0000000000000000000000000000000000000000..a3aa8d8f3ba031e868c73adc388771c639e98c6a --- /dev/null +++ b/vision-fixhub/court-05/6b2be091353f26305d73cfdb14e142a8094b7eccdb0d5e923e0861e7b8e00f3d.md @@ -0,0 +1,129 @@ +Case 1:22-cV-10904-JSR Document 239-18 Filed 07/25/23 Page 1 of 9 + + + +Case 1:22-cV-10904-JSR Document 239-18 Filed 07/25/23 Page 2 of 9 +From: +Sent: +To: +Burnside, +6/17/2013 7:50:10 PM +Gomel, Jessica L [jessica.l.gomel@jpmchase.com]; Dyer, John W [john.w.dyer@jpmchase.com]; Seba, Rick +[rick.seba@jpmchase.com]; Ryan,Maryanne X [maryanne.x.ryan@jpmchase.com]; Alaniz, Richard +[richard.alanizjr@jpmchase.com]; Vossel, Caryn A [caryn.a.vossel@jpmchase.com]; Robinette, Jerry +[jerry.robinette@jpmchase.com]; Bookheimer, Brian D [brian.d.bookheimer@jpmorgan.com] +CC: +Subject: +DeLuca, Phillip A [phillip.a.deluca@jpmchase.com] +RE: Discussion draft of De-risk matrix - June 10 +Attachments: AML Investigations de-risk survey June 17 draft.xisx +Here is a revised version with "names" received to date. +From: Burnside, +Sent: Monday, June 17, 2013 8:03 AM +To: Gomel, Jessica L; Dyer, John W; Seba, Rick; Ryan, Maryanne X; Alaniz, Richard; Vossel, Caryn A; Robinette, Jerry; +Bookheimer, Brian D +Cc: DeLuca, Phillip A +Subject: FW: Discussion draft of De-risk matrix - June 10 +Phil has been asked to provide "names" for the de-risk process today. +Can you please send any names you have in the attached spread sheet. +Thanks +Tom +From: Burnside, +Sent: Thursday, June 13, 2013 12:15 PM +To: DeLuca, Phillip A +Cc: Gomel, Jessica L; Dyer, John W; Seba, Rick; Ryan, Maryanne X; Alaniz, Richard; Vossel, Caryn A; Robinette, Jerry; +Bookheimer, Brian D +Subject: RE: Discussion draft of De-risk matrix - June 10 +Here is most recent matrix. +Please note that I added a new Tab for the "Name Risk" customers. Please complete with any nominations and send to +me. +From: Burnside, +Sent: Thursday, June 13, 2013 8:14 AM +To: DeLuca, Phillip A +Cc: Gomel, Jessica L; Dyer, John W; Seba, Rick; Ryan, Maryanne X; Alaniz, Richard; Vossel, Caryn A; Robinette, Jerry; +Bookheimer, Brian D +Subject: RE: Discussion draft of De-risk matrix - June 10 +We are still in process of discussing de-risk matrix with team, but we need to give a status update to Cindy (see e-mail +below) +I attach a proposed deck and hope that we can discuss at least briefly during 9:00 call. +DeLuca Deposition + +23 +334640-CAK +04/19/2023 + +JPM-SDNYLIT-00194342 + + +Case 1:22-cV-10904-JSR Document 239-18 Filed 07/25/23 Page 3 of 9 +From: DeLuca, Phillip A +Sent: Thursday. June 13, 2013 6:51 AM +To: Burnside, +Subject: FW: Discussion draft of De-risk matrix - June 10 +Tom, +I will need the slides that we discussed by Mid day today. In addition Please send the most recent version of the +attached encompassing the risk ranking that we discussed in our Monday afternoon call +If John is not yet available we can leave a placeholder and work around him. I am to meet with Cindy later in the day. +Thanks, +Phil +From: Burnside, +Sent: Monday, June 10, 2013 2:52 PM +To: DeLuca, Phillip A; Dyer, John W; Gomel, Jessica L; Seba, Rick; Ryan, Maryanne X; Alaniz, Richard; Robinette, Jerry +Subject: Discussion draft of De-risk matrix - June 10 +Here is a discussion draft of the de-risk survey (with preliminary indexing) that I would like to discuss on +today's call. + +JPM-SDNYLIT-00194343 + + +Case 1:22-cv-10904-JSR Document 239-18 Filed 07/25/23 + +Document Produced in +Native Format + +JPM-SDNYLIT-00194344 + + +Case 1:22-cv-10904-JSR Document 239-18 Filed 07/25/23 Page 5 of 9 +JFM-SDNYLIT-00184344 (1) +Prosesal + + +Case 1:22-cv-10904-JSR Document 239-18 Filed 07/25/23 Page 6 of 9 +JPM-SONYLIT-00194344 (9) +Proposal + + +Case 1:22-cv-10904-JSR Document 239-18 +Filed 07/25/23 Page 7 of 9 +JPM-SDNYLIT-00194344 (1) +Proposal + + +Case 1:22-cv-10904-JSR Document 239-18 Filed 07/25/23 Page 8 of 9 +JPM-SDNYLIT-001S4344 (1) +Proposa + + +Case 1:22-CV-10904-JSR Document 239-18 Filed 07/25/23 Page 9 of 9 +Tracking +number +LOB +Name +ECI +Reason +2 +PB +Jeffrey Epstein +He was a convicted sex offender and supposedly bought his way to a lesser sentencing. He paid a whole series of girts to stay +quiet.The FBI is reportedly preparing to launch a new inquiry into Epstein after one of his under-age erolic masseuses, +(made a string of disturbing allegations about her role. +U.S. detectives are said to be furious that Epstein, 58, escaped with only 13 months in jail for child sex offences after he struck a +9710670708 Plea bargain with prosecutors. +The deal protected him from further prosecution for oflences in Florida. But the significance of Miss +claims that under-age +girls were moved abroad for sex is that she paves the way for the FBl to prosecute him for offences committed cutside Flonda +under the Trafficking Victims Protection Act. +PB did not want to keep him but due to his relationship with the old head of the PB (Jes Staley) they were over ruled +JPM-SDNYLIT-00194344 +Name risk diff --git a/vision-fixhub/court-05/6b2be091353f26305d73cfdb14e142a8094b7eccdb0d5e923e0861e7b8e00f3d.receipt.json b/vision-fixhub/court-05/6b2be091353f26305d73cfdb14e142a8094b7eccdb0d5e923e0861e7b8e00f3d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0eacccc7776bb7431b169df4a95408a5ecacd065 --- /dev/null +++ b/vision-fixhub/court-05/6b2be091353f26305d73cfdb14e142a8094b7eccdb0d5e923e0861e7b8e00f3d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -172, + "dataset": "marble-joined", + "doc_id": "6b2be091353f26305d73cfdb14e142a8094b7eccdb0d5e923e0861e7b8e00f3d", + "engine": "marble-apple-vision", + "event_count": 15, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "6041d01f10ea7b854858c65f4017f5f87d9738aff22b44ca250756b0568fd33e", + "output_sha256": "2487121785b4b0754afc39b9b57fda54b020395d222b379251248a223afcffe1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6b364286bbd41570cc965f8eeb97e60d00aad001c19839c348965fbae7575afe.md b/vision-fixhub/court-05/6b364286bbd41570cc965f8eeb97e60d00aad001c19839c348965fbae7575afe.md new file mode 100644 index 0000000000000000000000000000000000000000..20245f295fb053b7f0db0099b8c8fc8ce110f706 --- /dev/null +++ b/vision-fixhub/court-05/6b364286bbd41570cc965f8eeb97e60d00aad001c19839c348965fbae7575afe.md @@ -0,0 +1,37 @@ +Casse1122201D9904155R Document 2223 FreekD01173223 Faagel10622 +IN THE UNITED STATES DISTRICT COURT FOR +THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiffs, +Case No. 22-cv-10904-JSR +[PROPOSED| ORDER FOR +ADMISSION PRO HAC VICE +V. +JPMORGAN CHASE BANK, N.A.., +Defendant. +The motion of Felicia Ellsworth for admission to practice pro hac vice in the abovecaptioned action is granted. +Applicant has declared that she is a member in good standing of the bar of the state of +Massachusetts, and that her contact information is as follows: +Wilmer Cutler Pickering +Hale and Dorr LLP +60 State Street +Boston, +02109 +Tel.: (617) 526-6687 +Felicia.Ellsworth@wilmerhale.com +Applicant having requested admission pro hac vice to appear for all purposes as counsel +for Defendant JPMorgan Chase Bank, N.A. in the above-captioned action, +IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the +above-captioned case in the United States District Court for the Southern District of New York. +All attorneys appearing before this Court are subject to the Local Rules of this Court, +including the Rules governing discipline of attorneys. + + +Cassel1222e0v1 D9904155R Docoumeet 2223 FfleekD01173223 Feage220022 +Dated: 1/17/23 +-, 2023 +New York, NY +Jed S. Rakolf +The Honorable Jed S. Rakoff +United States District Judge diff --git a/vision-fixhub/court-05/6b364286bbd41570cc965f8eeb97e60d00aad001c19839c348965fbae7575afe.receipt.json b/vision-fixhub/court-05/6b364286bbd41570cc965f8eeb97e60d00aad001c19839c348965fbae7575afe.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a6f85b04510991da2c8bca39f4e239be1d6a567d --- /dev/null +++ b/vision-fixhub/court-05/6b364286bbd41570cc965f8eeb97e60d00aad001c19839c348965fbae7575afe.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "6b364286bbd41570cc965f8eeb97e60d00aad001c19839c348965fbae7575afe", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "8e3d068146b6e077bc2a76f23e2ae423172f1735f21684d6921d7d0c423fcdbe", + "output_sha256": "92e1a6aed43d82cba117c62d588ca4c9eb5f2d7870d672c25586c26129394bcb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6b4573fa2c20934f2c86b010f54da483ca7f7286ae78d9ac09b6e2d0485bcfc1.md b/vision-fixhub/court-05/6b4573fa2c20934f2c86b010f54da483ca7f7286ae78d9ac09b6e2d0485bcfc1.md new file mode 100644 index 0000000000000000000000000000000000000000..9c953c9e5d2e0979b99e105bf919a801d62d4e5e --- /dev/null +++ b/vision-fixhub/court-05/6b4573fa2c20934f2c86b010f54da483ca7f7286ae78d9ac09b6e2d0485bcfc1.md @@ -0,0 +1,61 @@ +Case 1:22-cV-10904-JSR Document 240-17 Filed 07/25/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 240-17 Filed 07/25/23 Page 2 of 3 +From: +Sent: +To: +Subject: +Deluca, Phillip A [/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=PHILLIP.A.DELUCA] +1/6/2011 12:10:49 PM +Ryan, Maryanne X [maryanne.x.ryan@jpmchase.com] +RE: 2011 Conferences +This is the guy who likes young girls, correct? +Hope that they do not cave!! +From: Ryan, Maryanne X +Sent: Wednesday, January 05, 2011 8:20 PM +To: DeLuca, Phillip A +Subject: Re: 2011 Conferences +Can't wait. BTW, 4 tomorrow is the rapid response meeting on Epstein, the sleazy PB client. +From: DeLuca, Phillip A +To: Ryan, Maryanne X +Sent: Wed Jan 05 19:40:34 2011 +Subject: Re: 2011 Conferences +Let's talk tomorrow. I had an interesting conversation w/Truax +From: Ryan, Maryanne X +To: DeLuca, Phillip A +Sent: Wed Jan 05 18:43:33 2011 +Subject: Re: 2011 Conferences +Will do. Sorry about the one on one. I have one last phone interview tomorrow and then serious decisions. Today the +person told me how Rich told her that his dept has shrunk from 13 to 6 blah blah blah. Why that ever was part of the +interpretation is interesting. +From: DeLuca, Phillip A +To: Ryan, Maryanne X +Sent: Wed Jan 05 15:42:23 2011 +Subject: RE: 2011 Conferences +I think we can do that +Can you price it out in a request memo and I'll get it approved. +BTW We missed our 1 x 1 today +From: Ryan, Maryanne X +Sent: Wednesday, January 05, 2011 2:00 PM +To: Deluca, Phillip A +Subject: 2011 Conferences +Phil- + + +Ryan b +5.2423 +JPM-SDNYLIT-00194062 + + +Case 1:22-cv-10904-JSR Document 240-17 Filed 07/25/23 Page 3 of 3 +Where do you think we stand on conferences this year. This is one I have never been to but I see W is +moderating. Instead of the ML Alert conference, could this be a possibility? +Regards, +Maryanne Ryan, Vice President, AML Operations | JPMorgan Chase Bank, N.A. | Legal and Compliance Department | ED 194 +Floor 4, Iselin, NJ 08830-2710 | 8 W: 732.452.8071 +| Avenue South, + +JPM-SDNYLIT-00194063 diff --git a/vision-fixhub/court-05/6b4573fa2c20934f2c86b010f54da483ca7f7286ae78d9ac09b6e2d0485bcfc1.receipt.json b/vision-fixhub/court-05/6b4573fa2c20934f2c86b010f54da483ca7f7286ae78d9ac09b6e2d0485bcfc1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8d7659500645df4ebfe64fa54ab31ad558ee0a3d --- /dev/null +++ b/vision-fixhub/court-05/6b4573fa2c20934f2c86b010f54da483ca7f7286ae78d9ac09b6e2d0485bcfc1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -78, + "dataset": "marble-joined", + "doc_id": "6b4573fa2c20934f2c86b010f54da483ca7f7286ae78d9ac09b6e2d0485bcfc1", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "75b31bac33e28c09f6885f5cb1defc52a25beaa717f934e108507ddf6dfa62e2", + "output_sha256": "08402837467145392ea7e67e069789713cdfd8857b00ea9b7beba1423520ce27", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6b5325cbaa6f9451caede127bd43a5742ce79cf3ad33ab2008dcd76f2dcdba6f.md b/vision-fixhub/court-05/6b5325cbaa6f9451caede127bd43a5742ce79cf3ad33ab2008dcd76f2dcdba6f.md new file mode 100644 index 0000000000000000000000000000000000000000..946234ab9e3685162f1974a9c1147010384254f2 --- /dev/null +++ b/vision-fixhub/court-05/6b5325cbaa6f9451caede127bd43a5742ce79cf3ad33ab2008dcd76f2dcdba6f.md @@ -0,0 +1,466 @@ +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 1 of 11 + + + +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 2 of 11 +AO 88B (Rev. 12/13) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action +UNITED STATES DISTRICT COURT +for the +Southern District of New York +Government of the United States Virgin Islands +Plaintiff +V. +JPMorgan Chase Bank, N.A. +Defendant +Civil Action No. +1:22-cv-10904-JSR +SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS +OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION +LARRY PAGE +To: +(Name of person to whom this subpoena is directed) +• Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following +documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the +material: See attached Exhibit A +Place: Motley Rice LLC +c/o Litigation Services +3510 Unocal Place, Suite 115, Santa Rosa, CA 95403 +Date and Time: +04/28/2023 5:00 pm +O Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or +other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party +may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it. +Place: +Date and Time: +The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance; +Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(c) and (g), relating to your duty to +respond to this subpoena and the potential consequences of not doing so. +Date: +04/11/2023 +CLERK OF COURT +OR +Signature of Clerk or Deputy Clerk +Is/Linda +Attorney's signature +The name, address, e-mail address, and telephone number of the attorney representing (name of party) +Plaintiff, the Government of the United States Virgin Islands +., who issues or requests this subpoena, are: +Linda l +1. Motley Rice LLC, 401 9th Street NW, Suite 630, Washington, DC 20004, (202) 386-9626, +Isinger@motleyrice.com +Notice to the person who issues or requests this subpoena +A notice and a copy of the subpoena must be served on each party in this case before it is served on the person to whom +it is directed. Fed. R. Civ. P. 45(a)(4). + + +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 3 of 11 +AO 88B (Rev. 12/13) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2) +Civil Action No. 1:22-cv-10904-JSR +PROOF OF SERVICE +(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) +I received this subpoena for (name of individual and title, if any) +on (date) +7 I served the subpoena by delivering a copy to the named person as follows: +on (date) +; or +7 I returned the subpoena unexecuted because: +Inless the subpoena was issued on behalf of the United States, or one of' its officers or agents, I have also +endered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount c +$ +My fees are $ +for travel and S +for services, for a total of S +0.00 +I declare under penalty of perjury that this information is true. +Date: +Server's signature +Printed name and title +Server's address +Additional information regarding attempted service, etc.: + + +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 4 of 11 +AO 88B (Rev. 12/13) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action(Page 3) +Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13) +(c) Place of Compliance. +(1) For a Trial, Hearing, or Deposition. A subpoena may command a +person to attend a trial, hearing, or deposition only as follows: +(A) within 100 miles of where the person resides, is employed, or +regularly transacts business in person; or +(B) within the state where the person resides, is employed, or regularly +transacts business in person, if the person +(i) is a party or a party's officer; or +(il) is commanded to attend a trial and would not incur substantial +expense. +(ii) disclosing an unretained expert's opinion or information that does +not describe specitic occurrences in dispute and results from the expert's +study that was not requested by a party. +(C) Specifying Conditions as an Alternative. In the circumstances +described in Rule 45(d)(3)(B), the court may, instead of quashing or +modifying a subpoena, order appearance or production under specified +conditions if the serving party: +(i) shows a substantial need for the testimony or material that cannot be +otherwise met without undue hardship; and +(ii) ensures that the subpoenaed person will be reasonably compensated. +(2) For Other Discovery. A subpoena may command: +(A) production of documents, electronically stored information, or +tangible things at a place within 100 miles of where the person resides, is +employed, or regularly transacts business in person; and +(B) inspection of premises at the premises to be inspected. +(d) Protecting a Person Subject to a Subpoena; Enforcement. +(1) Avoiding Undue Burden or Expense; Sanctions, A party or attorney +responsible for issuing and serving a subpoena must take reasonable steps +to avoid imposing undue burden or expense on a person subject to the +subpoena. The court for the district where compliance is required must +enforce this duty and impose an appropriate sanction which may include +lost earnings and reasonable attorney's fees on a party or attorney who +(2) Command to Produce Materials or Permit Inspection. +(A) Appearance Not Required. A person commanded to produce +documents, electronically stored information, or tangible things, or to +permit the inspection of premises, need not appear in person at the place of +production or inspection unless also commanded to appear for a deposition, +hearing, or trial. +(B) Objections. A person commanded to produce documents or tangible +things or to permit inspection may serve on the party or attorney designated +in the subpoena a written objection to inspecting, copying, testing, or +sampling any or all of the materials or to inspecting the premises or to +producing electronically stored information in the form or forms requested. +The objection must be served before the earlier of the time specified for +compliance or 14 days after the subpoena is served. If an objection is made, +the following rules apply: +(i) At any time, on notice to the commanded person, the serving party +may move the court for the district where compliance is required for an +order compelling production or inspection. +(il) These acts may be required only as directed in the order, and the +order must protect a person who is neither a party nor a party's officer from +significant expense resulting from compliance. +(3) Qwashing or Modifying a Subpoena. +(A) When Required. On timely motion, the court for the district where +compliance is required must quash or modify a subpoena that: +(i) fails to allow a reasonable time to comply; +(i) requires a person to comply beyond the geographical limit +pecified in Rule 45(c); +(lil) requires disclosure of privileged or other protected matter, if no +exception or waiver applies; or +(iv) subjects a person to undue burden. +(B) When Permitted. To protect a person subject to or affected by a +subpoena, the court for the district where compliance is required may, on +motion, quash or modify the subpoena if it requires: +(i) disclosing a trade secret or other confidential research, +development, or commercial information; or +(e) Duties in Responding to a Subpoena. +(1) Producing Documents or Electronically Stored Information. These +procedures apply to producing documents or electronically stored +information: +(A) Documents. A person responding to a subpoena to produce documents +must produce them as they are kept in the ordinary course of business or +must organize and label them to correspond to the categories in the demand. +(B) Form for Producing Electronically Stored Information Not Specified. +If a subpoena does not specify a form for producing electronically stored +information, the person responding must produce it in a form or forms in +(C) Electronically Stored Information Produced in Only One Form. The +person responding need not produce the same electronically stored +information in more than one form. +(D) Inaccessible Electronically Stored Information. The person +responding need not provide discovery of clectronically stored information +from sources that the person identifies as not reasonably accessible because +of undue burden or cost. On motion to compel discovery or for a protective +order, the person responding must show that the information is not +reasonably accessible because of undue burden or cost. If that showing is +made, the court may nonetheless order discovery from such sources if the +requesting party shows good cause, considering the limitations of Rule +26(b)(2)(C). The court may specify conditions for the discovery. +(2) Claiming Privilege or Protection. +(A) Information Withheld. A person withholding subpoenaed information +under a claim that it is privileged or subject to protection as trial-preparation +material must: +(i) expressly make the claim; and +(il) describe the nature of the withheld documents, communications, or +tangible things in a manner that, without revealing information itself +privileged or protected, will enable the parties to assess the claim. +(B) Information Produced. If information produced in response to a +subpoena is subject to a claim of privilege or of protection as +trial-preparation material, the person making the claim may notify any party +that received the information of the claim and the basis for it. After being +notified, a party must promptly return, sequester, or destroy the specified +information and any copies it has; must not use or disclose the information +until the claim is resolved; must take reasonable steps to retrieve the +information if the party disclosed it before being notified; and may promptly +present the information under seal to the court for the district where +compliance is required for a determination of the claim. The person who +produced the information must preserve the information until the claim is +resolved. +(g) Contempt. +The court for the district where compliance is required—and also, after a +motion is transferred, the issuing court may hold in contempt a person +who, having been served, fails without adequate excuse to obey the +subpoena or an order related to it. +For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013). + + +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 5 of 11 +Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR + +Definitions +Unless otherwise specified, the documents specified below are required to be produced for the +time period commencing January 1, 2002 and continuing through the present. Where +production of account data is provided in electronic format or media the preferred software +format to incorporate the data into is Microsoft Excel. +As used herein, the following terms are defined as indicated: +1. "All/Each." The term "all" and "each" shall be construed as all and each. +2. "And/Or." The connectives "and" and "or" shall be construed either disjunctively or +conjunctively as necessary to bring within the scope of the discovery request all +responses that might otherwise be construed to be outside of its scope. +3. "Communication" means the transmittal of information (in the form of facts, ideas, +inquiries or otherwise). +4. The terms "Document" or "Documents" are defined to be synonymous and equal in scope +to the usage of these terms in Federal Rule of Civil Procedure 34(a), including, without +limitation, any written, drawn, printed, typed, photographed or other graphic or +electronically or computerized recorded data or compilations of any kind or nature +prepared or received by, or in the possession, custody or control of the answering party, +its agents, servants, employees or other representatives. Originals, drafts and all nonidentical copies are separate documents within the meaning of this term. +5. The term "identify" when used with reference to a person, means to give, to the extent +known, the person's full name, present or last known address, and when referring to a +natural person, additionally, the present or last known place of employment. Once a +person has been identified in accordance with this subparagraph, only the name of that +person need to be listed in response to subsequent discovery requesting the identification +of that person. +6. The term "identify" when used with reference to documents, means to give, to the extent + + +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 6 of 11 +Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +known, the (i) type of document; (ii) general subject matter; (iii) date of the document; +and (iv) author(s), addressee(s) and recipients). +7. The term "identify" when used with reference to an oral communication, discussion, +conversation or any other oral statement, shall mean to describe in detail the substance of +each such communication, discussion, conversation or statement, state the date of such +communication, discussion, conversation or statement, the place where such +communication, discussion, conversation or statement was held and identify each person +present for such communication, discussion, conversation or statement. +8. "Referring to", "relating to", "reflecting", "regarding" or "with respect to" mean, without +limitation the concepts: pertain to, deal with, concern, reflect, record, report, constitute, +contain, mention, describe, discuss, analyze, evaluate, estimate, study, survey, project, +assess, support, modify, contradict, criticize, summarize, comment, or otherwise involve, +in whole or in part. +9. "You" and "Your" shall mean Larry Page. These terms also shall be deemed to include +all agents and other persons acting or authorized to act on his behalf. +10. "Employee" includes, but is not limited to, all current or former salaried employees, +hourly employees, independent contractors, and individuals performing work as +temporary employees, for the entity referred to in the request. +11. "Epstein" shall mean Jeffrey E. Epstein, as well as all agents and other persons acting or +authorized to act on his behalf, including but not limited to Darren K. Indyke, Richard D. +Kahn, Bella Klein, Lesley Groff, and Daphne Wallace. +12. "JPMorgan" shall mean the Defendant, JPMorgan Chase Bank, N.A., its officers, +directors, employees, partners, representatives, agents, corporate parent, subsidiaries, +affiliates, divisions, predecessors or successors-in-interest, or any other person operating +in any representative capacity on its behalf. +2 + + +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 7 of 11 +Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +IL. +Instructions +1. When providing Your responses, indicate the Request to which each Document or answer +responds in the metadata field, RequestNo. +2. Documents produced pursuant to these Requests shall be produced as they are kept in the +ordinary course of business. +3. For each Document that You produce, produce the current version together with all earlier +editions or predecessor Documents during the relevant time period, even though the title +of earlier Documents may differ from current versions. Format for Documents produced +electronically: +a. +b. +c. +d. +e. +f. +g. +Data shall be produced in single page TIFFs at a 300 DPI resolution which +are named for the +Number of the page. There shall be no more than +1000 images per folder. +numbers, confidentiality designations, and +redactions shall be burned into the TIFF image file so as not to unreasonably +obstruct any information on the page. +Document Unitization. Each page of a Document shall be electronically +converted into an image as described above. If a Document is more than +one page, the unitization of the Document and any attachments and/or +affixed notes shall be maintained as it existed in the original when creating +the image file and appropriately designated in the load files. The +corresponding parent/attachment relationships, to the extent possible, shall +be provided in the load files furnished with each production. +Include Document level text files containing optical character recognition +("OCR") or extracted text named with the +Number of the first page +of the Document. +Include data load files containing all of the metadata +(both system and +application - see list below) from the original Native Documents with +extension.dat for Concordance. +Include the database field name in the first line of the metadata file, in such +a manner that it is clear how the metadata is organized in the file. +Include an image loadfile for Concordance - such as opt. +All hidden text (e.g., track changes, hidden columns, comments, notes, etc.) +shall be expanded, extracted, and rendered in the TIFF file. +3 + + +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 8 of 11 +Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +h. +i. +J. +k. +Documents created in Excel (spreadsheets), CSV files, Access (databases), +and audio and video media files shall be produced in Native format. The +extractable metadata and text shall be produced in the same manner as other +Documents that originated in electronic form (as described herein) to the +extent that metadata exists or is reasonably accessible. +Email attachments and embedded files or links shall be mapped to their +parent. +Produce all attachments to responsive Documents attached to the responsive +Documents. +De-duplicate prior to production. To the extent that exact duplicate +Documents (based on MD5 or SHA-1 hash values at the Document level) +reside within a party's data set, each party is only required to produce a +single copy of a responsive Document, so long as there is a data field that +identifies each custodian who had a copy. In addition, Documents may be +le-duplicated in such a way as to eliminate earlier or incomplete chains o +mails, and produce only the most complete iteration of an email chain s +long as there is a data field that identifies each custodian who had a copy. +REQUIRED METADATA +BEGDOC +BEGATTACH +ATTCOUNT +CUSTODIAN +FROM +CC +FILESIZE +DATERECD +DATESENT +ENDDOC +ENDATTACH +ATTACH +AUTHOR +TO +BCC +PGCOUNT +TIMERECD +TIMESENT +4 + + +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 9 of 11 +Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +CRTDATE +CRTTIME +LASTMODDATE +LASTMODTIME +LASTACCDATE +LASTACCTIME +TITLE +SUBJECT +EMAILSUBJECT +FILENAME +FILEEXT +MDSHASH +ORGANIZATION +FULLPATH +RECORD_TYPE +VERSION +VOLUME +COMMENT +PRINTEDDATE +ENTRYID +ATTLST +ITEMTYPE +PSTINSIDEPATH +ITEMCREATIONTIME +REQATTANDEES +REMINDERTIME +REPLYTIME +APPOINTMENTSTARTDATE +APPOINTMENTDURATIONTIME +APPOINTMENTCONTACT +CATEGORY +KEYWORDS +MANAGER +LASTAUTHOR +ENCRYPTED +FAMILYDATE +NATIVELINK +TEXTPATH +REQUESTNO +4. Format for hard copies of Documents produced in response to this Request: +a. +Re-type the question or request to which the Documents respond and firmly +5 + + +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 10 of 11 +Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +b. +attach the Documents to the re-typed request; +Number all Documents consecutively, consistently with the numbers used +for the Documents produced electronically. +5. Unless otherwise indicated, the relevant time period for this Request for Production of +Documents is January 1, 2002 to the present. +6. If no Documents responsive to a particular request exist, so state. +7. As to any Document which no longer exists but which You are aware existed at one time, +identify such Document with as much particularity as possible, and in addition, identify +the last known location of the Document, the reason the Document is no longer in +existence, and the person responsible for the Document's disposition. +8. For information that You withhold on the basis of privilege, provide a descriptive list of +each Document stating the grounds for Your refusal and providing the following +information: the name or title of the Document; a description of the nature and subject +matter of the Document sufficient to enable a meaningful challenge to the assertion of +privilege; the date, author(s), sender(s), and recipients) of the Document; and the nature +of the privilege. +9. These requests shall be deemed continuing in character so as to require prompt +supplemental responses if additional Documents called for herein are obtained, discovered, +or become known to You between the time of responding to the Requests and the final +disposition of this action. +10. Social Security numbers may be redacted from documents to the extent required by +applicable law. +6 + + +Ill. +Case 1:22-cv-10904-JSR Document 132-2 Filed 05/04/23 Page 11 of 11 +Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +Requests for the Production of Documents +1. All Documents reflecting or regarding Communications between You and JPMorgan +regarding Epstein or Epstein's role with respect to Your accounts, transactions, or financial +management. +2. All Documents reflecting or regarding Communications between You and Epstein +regarding JPMorgan and/or Your accounts, transactions, or relationship at JPMorgan. +3. All Documents concerning Communications or meetings between You, Epstein, and/or +JPMorgan regarding Your accounts, transactions, or relationship at JPMorgan. +4. All Documents reflecting or regarding fees You paid to Epstein and/or JPMorgan in +connection with Your accounts, transactions, or relationship at JPMorgan. +5. All Documents reflecting or regarding Epstein's involvement in human trafficking and/or +his procurement of girls or women for commercial sex. +7 diff --git a/vision-fixhub/court-05/6b5325cbaa6f9451caede127bd43a5742ce79cf3ad33ab2008dcd76f2dcdba6f.receipt.json b/vision-fixhub/court-05/6b5325cbaa6f9451caede127bd43a5742ce79cf3ad33ab2008dcd76f2dcdba6f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8a0d102a2c94ed47c43f234e2f7935847f92fbc6 --- /dev/null +++ b/vision-fixhub/court-05/6b5325cbaa6f9451caede127bd43a5742ce79cf3ad33ab2008dcd76f2dcdba6f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -152, + "dataset": "marble-joined", + "doc_id": "6b5325cbaa6f9451caede127bd43a5742ce79cf3ad33ab2008dcd76f2dcdba6f", + "engine": "marble-apple-vision", + "event_count": 14, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "84a7100018b993d1d28e30353d73dac436e39d477d078d0b90ef81563324b9c1", + "output_sha256": "b8fb7548fc4dfb992b49a7153109baa6db60cfe3d9f54d469604aa3cd2fe4a0e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6b5711d2e58bc677e01cc6ec754c7d2c03a796644d9e2cd8acc638603640b1d5.md b/vision-fixhub/court-05/6b5711d2e58bc677e01cc6ec754c7d2c03a796644d9e2cd8acc638603640b1d5.md new file mode 100644 index 0000000000000000000000000000000000000000..d9c8759e5244cbad7984e5b734b863a46c85a5e8 --- /dev/null +++ b/vision-fixhub/court-05/6b5711d2e58bc677e01cc6ec754c7d2c03a796644d9e2cd8acc638603640b1d5.md @@ -0,0 +1,62 @@ +Case 1:22-cV-10904-JSR Document 285-61 Filed 08/15/23 Page 1 of 5 + + + +Case 1:22-cV-10904-JSR Document 285-61 Filed 08/15/23 Page 2 of 5 +Ann - +Update to my Nov. 14 memo: +1. +New clients I have brought to JPM: +A. +B. +C. +D. +E. +G. +2. +Potential new clients I have brought or am about to bring to JPM (updates). +A. + +JPM-SDNYLIT-00449669 + + +Case 1:22-cv-10904-JSR Document 285-61 Filed 08/15/23 Page 3 of 5 +B. +C. +D. +E. +Special Situations: +Let poet Convinstions you have fad you cantee neal up a it i of co +Also, as you know, carlier today, Jeff called me to say he has asked two potential new +clients in 200M range (Nick Ribis and Ben Jacobson) to call me directly. +JPM Meetings/Pitches have been helping other NJ team members with for +clients/prospects, etc. +First: update re 8 listed on prior memo: +A. +B. +Others not on original list: + + +Case 1:22-cv-10904-JSR Document 285-61 Filed 08/15/23 Page 4 of 5 +3. +4. +5. +6. +8. +10. +12. +13. +11. Howard Rubenstein, others - see Jeffrey Epstein/special situations +14. +15. +16. +17. +18. +19. + +JPM-SDNYLIT-00449671 + +Case 1:22-cV-10904-JSR Document 285-61 Filed 08/15/23 Page 5 of 5 +Not sure this is a complete list, but should be reasonably complete. + +JPM-SDNYLIT-00449672 \ No newline at end of file diff --git a/vision-fixhub/court-05/6b5711d2e58bc677e01cc6ec754c7d2c03a796644d9e2cd8acc638603640b1d5.receipt.json b/vision-fixhub/court-05/6b5711d2e58bc677e01cc6ec754c7d2c03a796644d9e2cd8acc638603640b1d5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d918ca380819702352d399fd295f0b8b77113851 --- /dev/null +++ b/vision-fixhub/court-05/6b5711d2e58bc677e01cc6ec754c7d2c03a796644d9e2cd8acc638603640b1d5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -83, + "dataset": "marble-joined", + "doc_id": "6b5711d2e58bc677e01cc6ec754c7d2c03a796644d9e2cd8acc638603640b1d5", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "1decb01c1dcd55ea6c888b4eb881db6369b69b99b67b13d2b1dd803f09f0bc92", + "output_sha256": "1280cb023733f073bdb5cd8a2b1781f533a62b2a6aa2cf8a5172b94225cdd6a6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6ba1409a32d540c904ae7e5048693a332c17574c978349567e1120f6b5cebad3.md b/vision-fixhub/court-05/6ba1409a32d540c904ae7e5048693a332c17574c978349567e1120f6b5cebad3.md new file mode 100644 index 0000000000000000000000000000000000000000..a9ad8e18323ada8c8c251630e42ba1a7ea7f6ad3 --- /dev/null +++ b/vision-fixhub/court-05/6ba1409a32d540c904ae7e5048693a332c17574c978349567e1120f6b5cebad3.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 158-48 Filed 05/23/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6ba1409a32d540c904ae7e5048693a332c17574c978349567e1120f6b5cebad3.receipt.json b/vision-fixhub/court-05/6ba1409a32d540c904ae7e5048693a332c17574c978349567e1120f6b5cebad3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2d9de30c285d9073c111390522d936062d166429 --- /dev/null +++ b/vision-fixhub/court-05/6ba1409a32d540c904ae7e5048693a332c17574c978349567e1120f6b5cebad3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "6ba1409a32d540c904ae7e5048693a332c17574c978349567e1120f6b5cebad3", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "e50a1da9150d6fb630c36eab6271b83d6ce65a1606cb062477ded53897ce7cd3", + "output_sha256": "1fd6eaf22a3e2043e6825750fb858ea7bc9566c5a91812e4d91310192d6b2515", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6ba6b3dafbe7ac9c5a08bd36499286814fd8532bc94a2b67c1bff51aae223c12.md b/vision-fixhub/court-05/6ba6b3dafbe7ac9c5a08bd36499286814fd8532bc94a2b67c1bff51aae223c12.md new file mode 100644 index 0000000000000000000000000000000000000000..ca425ec15291cf00b32ae56eefdfed83f304d5cb --- /dev/null +++ b/vision-fixhub/court-05/6ba6b3dafbe7ac9c5a08bd36499286814fd8532bc94a2b67c1bff51aae223c12.md @@ -0,0 +1,46 @@ +Cassel1222c0v1D9904JS5R Doccuneet 11 B373 Ffldel054085283 Faggel10022 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-cv-10904-JSR +[PROPOSED| ORDER +GRANTING MOTION FOR +ADMISSION PRO HAC VICE +JPMORGAN CHASE BANK, N.A., +Defendant / +Third-Party Plaintiff +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +V. +JAMES EDWARD STALEY, +Third-Party Defendant. +The motion of Eden Schiffmann for admission to practice pro hac vice in the abovecaptioned action is GRANTED. Applicant has declared that he is a member in good standing of +the bars of the District of Columbia and Maryland and that his contact information is as follows: +Applicant's Name: +Eden Schifffmann +Firm Name: +& Connolly LLP +Address: +680 Maine Avenue, S.W. +City/State/Zip: +Telephone/Fax: +Email: +Washington, D.C. 20024 +(202) 434-5977 / (202) 434-5029 +ESchiffmann@wc.com + + +Cassel1222c0v1D9904JS5R Doccuneet 11 B373 Ffldel054085283 Fagge220022 +Applicant having requested admission pro hac vice to appear for all purposes as counsel +for Third-Party Defendant James Edward Staley in the above-captioned action; +IT IS HEREBY ORDERED that Applicant Eden Schiffmann is admitted to practice pro +hac vice in the above-captioned action in the United States District Court for the Southern +District of New York. All attorneys appearing before this Court are subject to the Local Rules of +this Court, including the Rules governing discipline of attorneys. +Dated: 5/8/2023 +jed S. Rakof +lonofable Jed S. Rakol +United States District Judge diff --git a/vision-fixhub/court-05/6ba6b3dafbe7ac9c5a08bd36499286814fd8532bc94a2b67c1bff51aae223c12.receipt.json b/vision-fixhub/court-05/6ba6b3dafbe7ac9c5a08bd36499286814fd8532bc94a2b67c1bff51aae223c12.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1b91622321416236f73e645aac4706edf86b54fa --- /dev/null +++ b/vision-fixhub/court-05/6ba6b3dafbe7ac9c5a08bd36499286814fd8532bc94a2b67c1bff51aae223c12.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -26, + "dataset": "marble-joined", + "doc_id": "6ba6b3dafbe7ac9c5a08bd36499286814fd8532bc94a2b67c1bff51aae223c12", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "1bb8c66a9198c0a2a4e068b50a9b634843b4cd34fa772a53f8f7066aae60b5ba", + "output_sha256": "24b7976d717016a630be354cee7456884995fa20abf4d5a1ed857cd8c70ee5ea", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6bac5ce6f417574caa12b6852fe58ecef43bcadd0d68eb529f73c33febced037.md b/vision-fixhub/court-05/6bac5ce6f417574caa12b6852fe58ecef43bcadd0d68eb529f73c33febced037.md new file mode 100644 index 0000000000000000000000000000000000000000..6fc634ffa0781a67da069f767f6b2490febc0fff --- /dev/null +++ b/vision-fixhub/court-05/6bac5ce6f417574caa12b6852fe58ecef43bcadd0d68eb529f73c33febced037.md @@ -0,0 +1,14386 @@ +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-x +UNITED STATES OF AMERICA, +V. +GHISLAINE MAXWELL, + +2834 +20 CR 330 (AJN) +Defendant. +-x +Before: +HON. ALISON J. NATHAN, +Jury Trial +New York, N.Y. +December 20, 2021 +8:40 a.m. +District Judge +APPEARANCES +DAMIAN WILLIAMS +Jnited States Attorney for the +louthern District of New Yorl +BY: +Assistant United States Attorneys +HADDON MORGAN AND FOREMAN +Attorneys for Defendant +BY: JEFFREY S. PAGLIUCA +LAURA A. MENNINGER +-and- +BOBBI C. STERNHEIM +COHEN & GRESSER +BY: CHRISTIAN R. EVERDELL +Also Present: +FBI +NYPD +Paralegal, U.s. Attorney's Office +AParaldbe, Haddon Morgan and Foreman + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 + +2835 +THE COURT: Preliminary matters to take up, counsel? +Not from the government, your Honor. +MS. MENNINGER: Not from the defense, your Honor. +THE COURT: Let me just confirm that we have to be +docketed or had been docketed all admitted exhibits with the +tailored redactions proposed. +MR. +: Your Honor, the pursuant to the Court's +order that they've been made public through the United States +Attorney's Office's press office, so the exhibits for both +parties are publicly available. +THE COURT: There was one that the letter indicated +the defense would propose a more tailored redaction that was -- +MR. EVERDELL: Is that AF-1, your Honor? +THE COURT: AF-1. +MR. EVERDELL: There is AF-1R, which is the publicly +available version that's going to be made public. +THE COURT: Great. And we've sorted the availability +for the public of the visual portion of the closing to be in +redacted form shortly after the completions of closing. +MS. MENNINGER: Yes, your Honor. I'm not sure whether +we will be able to take out the slides that have the sensitive +materials within two hours. I hope to be able to just redact +the part that's - but I'm not sure we'll have enough time to +check it. With the Court's permission, we"ll tender the one +that has none of the sensitive slides and then replace them + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2836 +with redacted ones as soon as we can and confirm it with the +government. +THE COURT: I think that caution is worth it, but +balanced against the need to provide public access to what will +occur in court with appropriate tailored redactions. +Anything else to take up? +Not from the government, your Honor. +MS. MENNINGER: Your Honor, can I just confirm the +timing which -- +THE COURT: That's a great point. I thought through +it a little bit more and what we've done is we've ordered an +early - taking Ms. Sternheim up on her suggestion, the +government will go and Ms. +in your absence, they committed +you to an hour. +: I guess I'll have to talk even more quickly +than I normally do. +MS. STERNHEIM: Judge, if I can share, the first trial +I had before Judge Motley, she did that to 17 lawyers who +started ripping pages out. +THE COURT: Ms. | +, does it look like two? +: Somewhere between two and two and a half +hours, your Honor. +THE COURT: It won't be more than two and a half. +: Of course, your Honor. +THE COURT: And Ms. Menninger. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKCmax1 + +2837 +MS. MENNINGER: Yes. +THE COURT: It won't be more than two and a half? +MS. MENNINGER: It will what? +THE COURT: Not be more than two and a half? +MS. MENNINGER: Correct, your Honor. +THE COURT: All right. So here's what we're going to +do: The government will go straight through, we'll then break +and I will have the jurors' lunch -- an early lunch at that +point. It will be short, 20 to 30 minutes. We come back, the +defense goes all the way through. We take a short comfort +break, ten minutes, and then government rebuttal and my charge +and begin deliberations if we have time. +I had told the jury to prepare to stay until 6:00 in +case we needed that to get through what we need to do, that +remains true. As is my practice, what I'll tell them is they +can let us know when they would like to leave for the evening, +if they're in agreement to continue their deliberations until +they indicate to us that they're ready to call it a night. +MS. MENNINGER: And then does your Honor have the +practice of counsel being within a certain - +THE COURT: +|. MENNINGER: —- in the building or what's your +Honor's preference? +THE COURT: Look, we need to be able to -- +MS. MENNINGER: Yes. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2838 +THE COURT: So, I +should be able to get you +back here within a few minutes. +MR. EVERDELL: Your Honor, on the logistics about +read-backs, we provided the government with a proposed set of +redacted transcripts which I think they still need to review, +it was late last night, but we'll get that approved. So in +case there are read-backs, we'll have a preset redacted +transcript. +THE COURT: Okay. And I know you're working with +on finalizing the exhibit list. There were a few +items missing. She'll get you the new version with the +additions once we've checked them and then, presumably, at the +lunch break, I'll get verification from both sides that the +list is complete and accurate. +Okay? +MR. +: Yes, your Honor. +THE COURT: And then exhibits going back to the jury, +I had asked the parties to confer on how they'd like to handle +that. Where are we on that? +MR. +: Yes, your Honor, with exception of the +physical exhibits, the parties are going to create a flash +drive with exhibits from both parties and indices for those +exhibits, which will be available for the jury. +THE COURT: So not paper, just the flash drives and +then physical exhibits are not going back? +MR. +: With the exception of the physical + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 +Page 6 of 257 2839 +exhibits which can't be loaded to the flash drive, I think they +are going back to the jury. +MS. MENNINGER: Right. That's right. +THE COURT: So it will be a flash drive and the +physical exhibits and that's it. And you've gotten that, the +flash drive. Everybody's looked at it so you can confirm you +know what's going back? +MR. +: The parties agreed on what should be on +the flash drive and it's been created. I don't think the +defense has had an opportunity to look at it yet. +THE COURT: Who's handling this, Ms. Menninger? +MR. EVERDELL: I will be handling it, your Honor. +THE COURT: Let's be ready again at the lunch break to +just confirm on the record that that's ready to go. +Let me check if I have anything else. I don't think +so. The box is turned. Okay. All right. We'll wait for our +jurors and let my staff know if you need me for anything before +we get underway. +(Recess) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2840 +THE COURT: All right. We have our jury. +Anything to raise before we bring them in? +: Not from the government, your Honor. +MS. STERNHEIM: No, your Honor. Thank you. +THE COURT: Thank you. +Ms. +, you can take your place at the podium. +Thank you, your Honor. +THE COURT: And bring in the jury. +(Jury present) +THE COURT: Good morning, members of the jury. Thank +you so much for your timeliness. It's good to see everyone. +As I indicated, we are at the summation or closing +argument phase of the trial. Here's how we'll do the schedule: +The government, Ms. +will present the closing +argument for the government. +She's going to go through and +finish her argument. We'll then break early for lunch. It +will be a short lunch, and then we'11 come back -- 20 to 30 +minutes for the lunch break. We'll come back. +Ms. Menninger will present the closing argument on +behalf of the defense. We'll take a short break at that point. +We'll come back. Rebuttal closings by the government, and +instructions from me. So that's the schedule for the day, just +to give you a sense of where we are. +With that, I ask you to please give your full +attention to Ms. +on behalf of the government. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2841 +Ghislaine Maxwell was dangerous. She was a +grown woman who preyed on vulnerable kids, young girls from +struggling families. +She targeted a girl whose father had just +died. She targeted a girl whose mother was an alcoholic. She +targeted a girl with a single mom who was struggling to raise +her daughters. +Maxwell was a sophisticated predator who knew +exactly what she was doing. She ran the same playbook again +and again and again. She manipulated her victims and she +groomed them for sexual abuse. She caused deep and lasting +harm to young girls. It is time to hold her accountable. +over the last few weeks, you've seen and heard a lot +of evidence. You've heard from witnesses from all walks of +life. You heard powerful testimony from women who told you +about traumatizing events from their childhoods. You heard +from people they talked to years ago about those events who +corroborated their testimony. You heard from law enforcement +officers who searched the properties where these crimes +happened. You heard from employees who worked for Maxwell and +Epstein. +In addition to those witnesses, you've seen documents, +phone messages, FedEx records, a household manual, and a little +black book with victim names. You also saw bank records +showing the $30 million that Jeffrey Epstein paid to Ghislaine +Maxwell. +Ladies and gentlemen, this summation is our + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX2 +Page 9 of 257 2842 +opportunity to explain how all of that evidence fits together, +because the proof is in. It's clear, it's consistent, and it +points to only one conclusion: Maxwell is guilty. +So today, I want to talk to you about eight different +reasons that you know Maxwell is guilty. After that, I'1l +discuss the charges in this case, and then I'll address some of +the arguments the defense has made to you throughout this +trial. +So let's start with the eight reasons that you know +Maxwell is guilty. +The first reason that you know Maxwell knew exactly +what she was doing when she recruited and groomed young girls +for abuse is that Maxwell and Epstein were partners. They were +partners in crime who sexually exploited young girls together. +So let's talk about the relationship between Maxwell and +Epstein and how it shows you that Maxwell committed these +crimes together with Jeffrey Epstein. +The evidence at this trial showed you that Maxwell was +Jeffrey Epstein's right hand. For many years they were in a +romantic relationship; they were partners. In 2002, Maxwell +wrote this essay; it's Government Exhibit 422. Now, you know +that Maxwell wrote this essay because you saw the metadata that +showed that the author of this document was G. Max, the +defendant. And the document was on a computer that was +registered to Maxwell. Here's that metadata. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 10 of 257 2843 +So in this essay, here's how Maxwell described her +relationship with Jeffrey Epstein: Jeffrey and Ghislaine have +been together, a couple, for the last eleven years. They are, +contrary to what many people think, rarely apart. I almost +always see them together. Jeffrey and Ghislaine complement +each other really well, and I cannot remember one without the +other. On top of being great partners, they are also the best +of friends. +A couple for eleven years. Great partners. Rarely +apart. Best of friends. Does that sound like a personal +assistant compartmentalized from Jeffrey Epstein's life? Of +course not. What Maxwell described in this essay is the +relationship that you heard throughout this entire trial. +Close partners who operated together. And, ladies and +gentlemen, when you're with someone for eleven years, you know +what they like. Epstein liked underage girls. He liked to +touch underage girls. Maxwell knew it. +Make no mistake. Maxwell was crucial to the whole +scheme. Epstein could not have done this alone. A single +middle-aged man who invites a teenage girl to visit his ranch, +to come to his house, to fly to New York, is creepy. That sets +off alarm bells. But when that man is accompanied by a posh, +smiling, respectable, age-appropriate woman, that's when +everything starts to seem legitimate. And when that woman +encourages those girls to massage that man, when she acts like + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 11 of 257 2844 +it's totally normal for the man to touch those girls, it lures +them into a trap. It allows the man to silence the alarm bells +and get away with molesting those girls. +Maxwell was the key to the whole operation. +At this trial, you saw photographs that showed how +close Maxwell and Epstein were over a span of many, many years. +And the relationship that you saw in those photos was the same +relationship that Maxwell described in an essay. They were +close. They were partners. They were rarely apart. Let's +take a look at some of those. +You saw many photos for the many years that Maxwell +and Epstein were partners. And what you're looking at here is +a couple. Arms around each other, doting looks on their faces. +Here are three more photographs. As you look through these, +notice that they are getting older. Their haircuts change; +time appears to be passing. But it's the same relationship the +whole way through. Cheek-to-cheek, arms wrapped around each +other. +Here are three more. These photographs show you what +their relationship was really like. They were incredibly close +for many years. +I want to show you two more photographs. That's +Government Exhibit 313 and 342. On the left, you're looking at +Maxwell and Epstein swimming naked together in a pool. They +are not alone; someone else is taking the picture. They're + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +laughing. On the right, that's Maxwell massaging Epstein's +foot with her breasts. +She's smiling. A third person is +taking the photograph. +What you're looking at in these two photographs are +two people with a sexual relationship. They were partners. +And throughout this trial, you heard witnesses tell you how +Maxwell made this kind of sexual behavior feel normal and +casual. That's exactly what you're looking at in these +photographs. +Now, being the right hand to a multimillionaire came +with serious benefits to Maxwell. As his partner, she had +access to enormous wealth and she lived his luxury lifestyle. +She spent her weeks flying around on Epstein's private jet from +his mansion on the Upper East Side, to his ranch in New Mexico, +to his villa in Palm Beach, to his apartment in Paris, and to +his private island in the U.S. Virgin Islands. Together, they +moved in a social circle of rich and famous people. +Now, Maxwell was not just Epstein's partner; you +learned that she was the lady of the house. You heard from +Juan Alessi, the house manager in Palm Beach, who told you all +about Maxwell's place in that household from the early 1990s, +until Alessi left in December of 2002. Here's Alessi's +testimony about that. +Juan Alessi told you that the day Maxwell came to the +house, she took over right away; and she told Alessi that she +2845 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 13 of 257 2846 +was going to be the lady of the house. And what Alessi told +you about Maxwell is backed up by the household manual, that +document full of rules that you saw at trial. Those were rules +that Maxwell put in place. You know she put those rules in +place. Alessi testified that Maxwell gave him this manual. +During Juan Alessi's testimony, you saw many pages +from this manual, and you saw all the sections that talked +about Maxwell and Epstein: What to serve them for breakfast, +how to arrange their desks, where to put their stationery. I'm +not going to go through all of those pages with you now, but +here's just one example. This section tells employees to make +sure to set out two different sizes of Maxwell's notepads, one +marked "Lady Ghislaine." +Now, you can read through that entire manual when you +deliberate, but you're just going to find two names throughout +that whole household manual, it's Maxwell and Epstein's guests, +Maxwell and Epstein's phone directories, Maxwell and Epstein's +breakfast preferences, Maxwell and Epstein's phone messages, +Maxwell and Epstein's phone lines, Maxwell and Epstein's +residence. These were Maxwell and Epstein's rules. This +manual was clear. She was the lady of the house. +And no matter how hard the defense has tried to +suggest throughout this trial that Maxwell was just an +employee, that she didn't know what was going on, this document +tells you otherwise. This manual makes crystal clear who + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 14 of 257 2847 +mattered in that household in Palm Beach. It was Maxwell and +Epstein together. +Of course, Maxwell knew what was going on in +that house. +She had a firm grip on everything that was +happening there. +She was Epstein's partner. +Now, the household manual isn't the only document that +you saw at this trial that showed you that Maxwell had a firm +grip on that household and that she knew everything that was +going on there. I want you to take a look at Government +Exhibit 420. This document is dated in 2002. And the metadata +tells you that it was written by, you guessed it, G. Max. This +document shows you that Maxwell wrote out a detailed list of 13 +different oils and lotions for massages in Palm Beach. She was +intimately involved in all of the details of Epstein's +so-called massages. +In fact, even the sex toys in the massage room had to +be returned to a basket in Maxwell's bathroom closet. That's +what Mr. Alessi had to do. Here's his testimony about that. +He told you about having to wash off dildos after the massages +and how he would return them to a basket in Maxwell's closet, +because that's where they were kept. Again and again, the +evidence at this trial showed you how closely Maxwell was +involved in Epstein's so-called massages. She managed all of +the details right down to the lotions and the oils. She was in +on the whole thing. +So we were talking about the household manual. What + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 15 of 257 2848 +else does the household manual tell you? You remember the +disturbing warning in that manual. Here it is: Remember that +you see nothing, hear nothing, say nothing, except to answer a +question directed at you. Respect their privacy. +You learned that this powerful warning to employees +was effective. +Here's Mr. Alessi's testimony about that. He +explained that this rule was a kind of warning that he was +supposed to be blind, deaf, and dumb, to say nothing of their +lives. +Ladies and gentlemen, now that you've sat through this +entire trial, you know exactly why Maxwell told workers in the +house to see nothing, hear nothing, and say nothing. It's +because she was Epstein's partner in crime. And in that house, +behind closed doors, Maxwell and Epstein were committing +horrifying crimes. +That brings us to the second reason. The second +reason that you know that Maxwell is guilty is that she ran the +same playbook over and over and over again as she exploited +young girls. The similarities between what happened to Jane +and +and +and +are incredibly powerful evidence +of the defendant's guilt. So I want to talk to you about the +playbook that Maxwell ran again and again and again. +Before we talk about this, remember that you heard +from Dr. Rocchio, an expert psychologist who specializes in +treating victims of sexual abuse for the trauma they suffered + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 16 of 257 2849 +as a result of their childhood experiences. She told you that +childhood sexual abuse typically occurs in an established +relationship by a perpetrator who's known to the victim. Dr. +Rocchio explained to you that perpetrators are able to abuse +kids by using a series of techniques called grooming. She +walked you through the stages of grooming. Here they are: +Identifying and selecting the child. +Obtaining access and isolating the child. +Engaging in manipulation in order to build trust and +attachment. +Desensitizing the child to physical touch and sexual +content. +And finally, maintaining control over the child to +continue abuse and decrease the likelihood that the victim will +report. +So let's talk through the ways that Maxwell and +Epstein ran this exact playbook. +First, the ways that they selected these girls tells +you that they were targeting vulnerable kids. It is not an +accident that Jane and | +and +and +all came from +single-mother households. It is not an accident that all of +their families were struggling in different ways. What that +tells you is that Maxwell and Epstein selected these girls +carefully. +When Jane was 14, her father had just died and her + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 17 of 257 2850 +family was struggling financially. She didn't have her own bed +to sleep in. Things were really tough at home. She had big +dreams of working in the arts one day. She was talented. +When +was 16, she lived with her mother who was +supporting her daughters by herself on a limited income. +was hoping to go to a good college. +When +was 17, she lived with her mother who had +been sick. Things were difficult at home and +was alone a +lot. And she was dazzled by this impressive woman who made her +feel special. +When +mom who was an alcoholic. +was 14, she lived with her mom, a single +She had previously been sexually +abused by family members and she told Maxwell about that. +Make no mistake. +Selecting these girls was predatory +behavior. Maxwell and Epstein picked vulnerable girls. They +found kids who needed something. They were exploiting that +need. +So what was the next stage of the playbook? It was +isolating the girls. Maxwell and Epstein got them alone in +Epstein's enormous houses, alone on trips to Epstein's +sprawling ranch, his mansion on the Upper East Side. They got +them alone in massage rooms. They were away from their +parents. +Remember how Jane told you that her mother was never +invited when she would spend time with Maxwell and Epstein? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2851 +That was by design. It was Maxwell's design. Maxwell was +hanging out with these girls alone, isolating them and +befriending them. +And remember how +mom told you that Epstein +called her to invite +to New Mexico? Remember how +mom explained that Epstein said about 20 to 25 girls would be +there and so would his wife, Ghislaine. And remember how +told you that when she got to New Mexico, she found herself +alone with Maxwell and Epstein? They were isolating these +girls for a reason. +Then came the next step in the playbook: Making these +girls feel special, giving them gifts, making friends, giving +them money, promising to help with their futures, promises like +sending +on a trip to Thailand or helping to pay for +Jane's voice lessons and tuition. They were building a +relationship. They were building trust for what was going to +come next. +Once the girls were manipulated this way, Maxwell +helped Epstein normalize sexual situations and sexual touching. +For +, it started with Maxwell telling her how to massage +Epstein's feet. And it escalated to Maxwell touching +breasts in a so-called massage. +For +too it started with +Maxwell asking her to rub Epstein's feet. For Jane it started +with Maxwell being topless by the pool, and then Maxwell +talking about boyfriends and sex with Jane. And it escalated + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2852 +to sexualized massages. Again and again throughout this trial, +you heard about how these girls were asked to perform +sexualized massages on Jeffrey Epstein. +While we're talking about physical touch, let me just +pause here and point out that +and Jane all +testified that Maxwell touched their breasts. They all had +very specific memories about that. +Here's +testimony about that: You remember +that she told you about Maxwell coming into the massage room +when +was naked. Maxwell touched +breasts and +told her that she had a good body. Jane told you about Maxwell +touching her breasts too during sexual encounters with Maxwell +and Epstein during so-called massages. +Maxwell did it to +, too. Here's her testimony +about that. Here's what she said about how that made her feel: +I was very uncomfortable and fearful and wanted to get +off the table, that massage table, and wanted it to be over +with. +Ladies and gentlemen, Maxwell touched these girls' +bodies. Three different women told you about Maxwell touching +their breasts when they were kids in massage rooms on massage +tables and in the context of so-called massages. It's not an +accident. It happened again and again and again. It is +powerful evidence of Maxwell's guilt. +And the woman they all described to you when they took + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2853 +that stand, when they talked about their memories of her, +ladies and gentlemen, they were describing the same woman. Not +just her name and her physical appearance, but what she was +like. These girls knew her. They knew Maxwell. Charming, +sophisticated, engaging, impressive. A woman who moved in a +social circle that was intimidating. These witnesses were +describing the same woman, Ghislaine Maxwell. They knew her. +The relationships that Maxwell cultivated with these +girls were essential to the scheme. Those relationships helped +Maxwell and Epstein maintain control of these girls for years. +Jane didn't become Epstein's so-called goddaughter by accident. +Maxwell helped establish a close relationship that became a +cover for sexual abuse. +The patterns you saw throughout this trial, the +playbook that Maxwell ran for years, is just one of the many +ways that you know that Maxwell is guilty. +I want to talk to you now about what Maxwell and +Epstein did to Jane. That's the third way that you know that +Maxwell is guilty. +This is Jane. Jane turned 14 years old in the summer +of 1994, when she met Maxwell at a summer camp for kids. +Maxwell and Epstein told her that Epstein was a wealthy donor +who gave scholarships. But you learned that meeting Maxwell +and Epstein at summer camp was the beginning of years of sexual +abuse. What Jane told you about meeting Maxwell in summer camp + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2854 +in 1994 is backed up by documents. So let's talk about it. +Here's Jane's application to Interlochen for the +summer of 1994. She weighed 90 pounds and she just finished +the seventh grade. There can't be any question that Jane was +at Interlochen that summer. And there also cannot be any +question that Maxwell was there that summer, too. +Let's take a look at the flight records. They show +you that on August 18th, 1994, Jeffrey Epstein flew to Traverse +City, Michigan. That's where Interlochen is. And sure enough, +two days later, on the 20th, Maxwell was on the flight home +with him. She's right there in the flight records, "GM." +She's listed on it as a passenger on the plane ride home. +These flight records prove to you that Maxwell was there that +summer. That's when she met Jane. That's how it all started. +You also know that Epstein and Maxwell were there in +August of 1994 because Epstein had donated a scholarship lodge. +Here's the letter you saw from Interlochen; it's dated February +1994. And they are thanking Epstein for donating the money to +build a scholarship lodge. Government Exhibit 745 is a +photograph of that lodge. +And most importantly, you know that Maxwell was at +Interlochen that summer because Maxwell got a letter from +Interlochen in December 1994, just months after she'd met Jane +at camp. The folks at Interlochen were writing Maxwell to tell +her that they found an envelope while they were cleaning the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 22 of 257 2855 +Epstein lodge and they wanted to return it to her. So when +Jane told you about meeting Maxwell and Epstein at summer camp +in 1994, you know that's the truth. +What Jane didn't know that summer, but what you +learned at this trial, is that Maxwell and Epstein were +targeting her for sexual abuse. By the time she started +spending time with Maxwell and Epstein in Palm Beach, she was +an 8th grader. She was in middle school. Epstein told Jane's +mother that he would help Jane; that he gave scholarships. +That was the cover. +But once Maxwell and Epstein started spending time +with Jane alone, they started grooming her for abuse right +away. Jane described how Maxwell acted like she was an older +sister figure; how she went to the movies with Maxwell and +Epstein. They took her shopping. They bought her +underwear. Epstein gave her money. She saw Maxwell topless by +the pool. And by the way, you know that's true because now +you've seen Maxwell topless by the pool too. +Jane told you about how Maxwell would chitchat with +her, talking about school and then about boyfriends and sex. +There was a purpose for all of this. Maxwell and Epstein were +setting the stage for what was going to come next. +Jane told you about how one day after this initial +grooming, Epstein walked her down to the pool house. He pulled +her onto his lap and started masturbating on her. Here's her + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 23 of 257 2856 +testimony about that: She was frozen in fear. She had never +seen a penis before. It was horrifying. +What did Maxwell do next? She started teaching Jane +how to massage Epstein. Here's her testimony about that: +Maxwell would show her how Jeffrey likes to be massaged. And +you know what happened next: Fully ramping up, breaking down +barriers, making it all seem okay. Maxwell and Epstein started +sexually abusing Jane during these so-called massages. +Maxwell played an essential role in these abusive +massages. As Jane told you, Maxwell was the person most +frequently in the room when Epstein molested her. Along with +Epstein, Maxwell gave Jane instructions on how to massage +Epstein. Here's her testimony about that: Showing you, you +know, what he likes; what -- you know, what men, what women +like, sort of touching on breasts and touching his penis. +And while all of this was happening, while Jane was +being abused, Maxwell was right there acting casually and +behaving like all of this was normal. She was doing that +because she was trying to normalize sexual abuse. +Here's Jane's testimony about that: It seemed very +casual, like it was -- like it was very normal, like it was not +a big deal. She's describing how Maxwell would act during +those massages. +She said, It made me feel confused because that did +not feel normal to me. I'd never seen anything like this or + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 24 of 257 2857 +felt any of this and it was very embarrassing. You know, it's +all these mixed emotions. +When you're 14, you have no idea +what's going on. +Ladies and gentlemen, none of this was normal. It was +not okay. It was deeply disturbing. They were molesting an +underage girl. That's what Maxwell did. And Jane told you +about all the ways in which she was sexually abused during +these so-called massages. You saw in her face how hard it was +for her to talk to you about that. It was hard to hear. +She told you about having to touch Epstein's penis, +how Epstein touched her vagina and used vibrators; how he put a +back massager on her vagina, even when she said it hurt. She +told you that Maxwell touched her breasts, that there were +hands everywhere. She also told you that Maxwell and Epstein +would sometimes involve her in horrifying group encounters with +other women. +The sexual abuse didn't just happen in Florida. You +learned that Maxwell and Epstein started taking Jane on trips +to Epstein's house in New York. She flew to New York on +commercial flights, but also in the private jet. Ask +yourselves, does it seem normal to you that two adults were +spending their weekends on trips with a 14-year-old girl? +Absolutely not. There was nothing normal about that. And your +common sense tells you they weren't bringing her to New York +for some kind of scholarship or mentoring program. They were + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE l +Page 25 of 257 2858 +bringing her to New York to be molested, and that is exactly +what happened. +And by the way, you know that Maxwell and Epstein +weren't simply charitable, wealthy people who were just trying +to help young girls. There are real ways, official ways, that +you can help and mentor young people, but that's not what they +did at all. There wasn't some scholarship foundation, there +certainly weren't any scholarship boys. There were no +applications or legitimate selection criteria. Io qualify, you +just had to be a pretty, young, vulnerable girl. That's who +they were targeting. +Jane told you about those trips with Maxwell and +Epstein to New York when she was 14 and 15 and 16. She told +you about the abuse that happened there. He would use +vibrators on me. He would put his fingers in my vagina. He +would start to masturbate and he would ask me to straddle his +face. He would ask me to, like, squeeze his nipples really +hard while he came. +Let's talk about the house in New York where that +happened. Here's the massage room in New York. As you look at +these photos - we're going to look at two -- let me read to +you from the transcript what Jane testified about this room. +And you're going to see she's describing this very same massage +room. Here's what she said: It was off the +bathroom. +Notice the bathroom on the left. And it looked like it was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 26 of 257 2859 +maybe supposed to be like a giant walk-in closet. And it was +very dark. There was a +• built-in bookcase on the right-hand +side, and there was a stereo system and there was, like, music +playing. And I don't know if it was painted dark, but -- or +maybe that was the lighting, but it sort of had this red mood. +And then there was just a giant black massage table in the +middle of it. +Ladies and gentlemen, you know that Jane has been in +this massage room because it looks exactly like she remembered. +During the years that Maxwell and Epstein abused Jane, +she was literally growing up in front of their eyes. She +turned 15 and 16 and 17. This went on for years. They +maintained a coercive relationship with her into her early +twenties. +Now, I've already talked about some of the ways that +Jane's testimony was corroborated. I want to talk to you now +about the many other ways that Jane's testimony is backed up by +all of the other evidence in this case. +First, you heard from Juan Alessi, who remembered +Jane. Here's his testimony about that. He remembered that she +looked about 14 or 15, and that she spent time with Maxwell and +Epstein at the house. Here's his testimony about that: Alessi +remembered the school that Jane went to because he would be +sent to pick her up there sometimes. He also remembered +driving Jane to the airport with Maxwell and Epstein. Here's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | +Page 27 of 257 2860 +part of his testimony about that. You know that Jane traveled +with Maxwell and Epstein because Jane told you that. But you +also know it because Alessi told you about that. And you know +it because the flight records show it too. +So let's take a look at Government Exhibit 662. So in +the flight records, you learned that the pilots didn't always +see the passengers or learn their names; sometimes they just +wrote one female or one passenger. Here's an example from +January of 1995. And, of course, you know that Maxwell and +Epstein wouldn't have been eager to have a pilot log the name +of the kid they were bringing on trips. They wouldn't be eager +to introduce her to the pilots until she got older. +But Jane is listed on several flights in these +records. Here's the first one where her name appears. It's +November 1996, when Jane was just 16 years old. Here she is on +a flight from Palm Beach to Teterboro Airport. That's the +airport they would use when they were flying to New York. +What you're looking at is cold, hard proof that Jane +was an underage girl being transported to New York. And while +Maxwell isn't listed on the flight log for the flight there, +you know she was there because you look -- if you look at the +second entry right below that, she's on the flight log leaving +New York the very next flight. That's how you know that +Maxwell was in New York too. She's right there. +Here's the next flight where Jane's name appears. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 28 of 257 2861 +It's May 1997. A flight from Teterboro to New Mexico. They +were traveling from New York to New Mexico. On the day of this +flight, Jane +was still just 16 years old. The flight log here +shows just Maxwell, Epstein, and Jane. And Jane told you about +going on a trip alone to New Mexico with just Maxwell and +Epstein. Why on earth were Maxwell and Epstein flying alone to +New Mexico with a 16-year-old girl? They were doing it for the +same reason they did that to +ladies and +gentlemen. That's the playbook. +Let's take a look at just one more flight. And +remember, these aren't the only trips that Jane took; they are +just the ones that happen to be captured in the flight logs +when she flew on the jet. +So here is Jane in April 1998 flying with Maxwell and +Epstein from Palm Beach to Teterboro, a trip to New York when +Jane was 17. And by the way, remember when defense counsel +showed you pictures of an older woman with Jane's first name, +who worked as a personal assistant, and they suggested to you +that maybe that's the Jane on these flight logs? That's the +photo they showed you. Ladies and gentlemen, that was +completely misleading. +The pilots told you that there were only ever two +passengers with that first name, and they met the second +person, the person in this photo, years later. And you heard +testimony from someone from the DMV to show you that this adult + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 29 of 257 2862 +woman in that picture was 11 old when these flights took off. +She obviously wasn't working as a personal assistant when she +was 11. It's not her. It's Jane on those flight logs. You +know the girl on those flights was Jane. +In addition to all of that corroboration, you've also +heard testimony from Matt, who dated Jane for several years in +the mid 2000s. He told you that he had conversations with Jane +more than a decade before this case. And what Jane told him +back then is consistent with what she told you at this trial. +She told Matt that she had a godfather named Jeffrey Epstein +who paid for things when she was growing up. It started when +she was 14, and she had to do things she didn't want to do. +She told him it involved massage and that there was a woman who +made her feel comfortable. +Here are two portions of Matt's testimony: She said +that it started at 14. There was a woman in the house who made +her feel comfortable. You know that woman is Maxwell, because +when Matt learned that Maxwell had been arrested in this case, +he called Jane and asked her, Is that the woman you told me +about all of those years ago? And Jane told him that it was. +Now, Jane didn't tell Matt all of the details; she just told +him the money wasn't free. And Matt told you about how when +Jane would talk about this, she was -- and I'm quoting from the +transcript - ashamed, embarrassed, horrified. +Jane couldn't share all of the details with Matt; it + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 30 of 257 2863 +took her a long time to be able to do that. You heard expert +testimony at this trial from Dr. Rocchio who told you about +just how common that is. Dr. Rocchio has spent literally +decades treating real-world patients for trauma caused by +sexual abuse. She's an expert. And she told you that it's +actually uncommon for kids to disclose that they've been abused +when it happens. +Here's her testimony about that. In fact, as Dr. +Rocchio told you, victims are less likely to tell, and they are +more likely to delay telling the closer they are to the +perpetrator. +And you heard about how Maxwell was like a big sister +to Jane; how Epstein was Jane's so-called godfather. It was +this close relationship that made it hard for Jane to talk +about the abuse, especially given everything that you learned +about what was going on at home for Jane and what her mother +was like. +Remember how Matt told you he was there when Jane +confronted her mother years later? Here's his testimony about +that. Jane told her mother that she -- that the money was not +free, and that there was no way she couldn't have known that it +wasn't free. +At this trial, you heard expert testimony from Dr. +Rocchio about how it's hard for victims of childhood sexual +abuse to tell someone that they've been abused. And when they + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 31 of 257 2864 +do tell, here's what Dr. Rocchio explained to you. She said, +Disclosure is a process that unfolds over time. So individuals +will typically begin the disclosure maybe by alluding to what's +happened in a general sense or the gist of what's happened. +Let me pause here and say that's exactly what happened +with Matt. +She's alluding to what happened, giving the gist of +it, but not all the details. It's just too hard. +Here's the rest of her testimony. And then it's only +over time they will begin to talk more specifically about what +has happened. And even in therapy, oftentimes disclosure of +the most intimate or difficult details is something that's very +hard and individuals are very reluctant to do. Dr. Rocchio has +explained to you that's what happens in these cases, and she's +an expert in the psychology of sexual trauma. +Now, the defense cross-examined Jane about why she +didn't immediately tell someone about the abuse she suffered +when she was 14 and 15 and 16, as if that would have been easy. +And, in fact, when the defense points out that Jane wasn't able +to tell people what really happened to her, they're actually +pointing to what makes this a textbook case of child sexual +abuse. +How else do you know that Jane told you the truth? +It's because her testimony is corroborated by the testimony of +and +and +, whose experiences were strikingly +similar, as we've already discussed. It's not a coincidence. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +LCKVMAX2 + +2865 +You can consider all of the witnesses' testimony as +corroborating testimony as you consider what happened to each +one of them. +Let me just say one last thing about Jane. Defense +counsel asked Jane in cross-examination whether she remembered +some of the first names of people who were present for group +sexualized encounters. +She remembered five names: +Eva, and +And keep in mind, she was a +kid, right; it's not like she's taking people's IDs in the room +when she's being sexually assaulted, but that's what she can +remember. +The defense seized on two of those names, Eva and +Here's the transcript where they asked about this on +cross. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +: So in the defense case, they happened to +find two people with the first names, +and Ava, and +they brought them down to court to try to discredit Jane. But +here's the thing, Jane never testified that +and +Eva Dubin were in the room when she was abused. She did not +say that. +2866 +Defense counsel asked her about a +and an Eva. +They expressly did not ask Jane if she knew those people's last +names. They didn't show Jane pictures of Eva Dubin or +to see if those were the people she was referencing. +They left it really vague on purpose. But trying to discredit +Jane this way makes no sense. +those aren't the only +Your common sense tells you that +and Evas in the whole wide +world. +And you can take a look at excerpts from Government +Exhibit 52. That's the black contact book. Remember, there +were pages from Epstein and Maxwell's contact book, and we're +going to talk more about this book later. But you're going to +see this book had another Eva in it and three +Of +course there were other | +and Evas out there and other +people with those names in Epstein's life. Calling these women +to testify was completely meaningless and it was a total +sideshow. Don't be distracted by that. It was meaningless. +Ladies and gentlemen, the evidence tells you that Jane +told you the truth at this trial because you could see and hear + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 34 of 257 2867 +her yourself. You met Jane. It was powerful testimony and it +was difficult to hear, but you know from your direct +observations that she was telling you the truth. +You also know it was true because her testimony was +extensively corroborated by Alessi, by Matt, and by documents +like the flight records, school records, and camp records. And +you know it because you recognize the same playbook they ran +with Jane when you compare it with what Epstein and Maxwell did +with the other witnesses at this trial, and the lengths the +defense went to, to try to discredit Jane, just tells you how +devastating her testimony was. It proves Maxwell is guilty. +Jane was a kid in middle school. She was sexually +exploited by Ghislaine Maxwell and Jeffrey Epstein. If you +believe Jane's testimony, the defendant is guilty on counts One +through Four of the indictment. +I want to talk to you now about +is +The fourth reason that you know that Maxwell is guilty +told you about meeting +Jeffrey Epstein in New York in December 1995. She was 16 years +old. Epstein said that he was taking an interest in her as a +student and he talked to l +about college. Then Epstein +took her to the movies with her sister, +During that +movie, he held +hand and rubbed her arm. He hid it from +1, but he was rubbing +arm during the movie. He was +trying to desensitize +to his touch. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 35 of 257 2868 +Here's part of +teenage diary entry about the +trip to the movies. It tells you a few things. First, this +diary tells you that this isn't a new story. It's right there +in her teenage diary, her high school diary from 1986. And +what you saw in +diary was just how confusing this +experience was for a teenage girl. This diary entry was a +perfect illustration about how kids being groomed for sexual +abuse wrestled with understanding that confusing experience. +wrote about how she went back and forth about how this +was weird, and you can see her in her diary struggling to +rationalize what is obviously inappropriate behavior, because +this adult was being nice to her, he had made promises, he was +important to her sister's career, and he held a position of +trust. That's exactly how grooming works. +I want you to notice one thing more about this diary. +You'll notice towards the bottom that +wrote down, the one +thing that kind of weirded me out about it was that he let go +of my hand when he was talking to +told you about +how in the movie theater when Epstein was touching her, he had +to hide it from +- I want you to remember that, because +we're going to talk about it in a few minutes. +Now, Maxwell wasn't there for the trip to New York, +but you know that she was absolutely there for what happened +next, as she and Epstein tried to escalate things with +In the spring of 1996 when +was 16, she flew all + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 36 of 257 2869 +by herself to New Mexico to stay with Maxwell and Epstein. She +thought it had to do with a potential scholarship, and so did +her mother, who took the witness stand and told you that she +remembered +going on this trip with Maxwell and Epstein, +and that she thought it was a trip for multiple scholarship +students who would be chaperoned by Ghislaine Maxwell. But +when +got to New Mexico, she was alone. She was alone +with Epstein and Maxwell. She was alone with them, with no +chaperone, no other students. She was alone with two sexual +predators. +Over the course of the weekend, Maxwell engaged in +textbook grooming behavior with +First, Maxwell starting +chatting her up, asking her about her life. She was charming +her. Then Maxwell took +on a shopping trip. They bought +her boots and Maxwell picked out a hair product for +What came next? Maxwell and Epstein took +to a +movie theater where Epstein began holding +hand and +rubbing her foot and her arm. He was doing the same thing he +had done in New York, but now he was doing it openly. He was +doing it openly because this time he was doing it with Maxwell, +and he didn't have to hide it from Maxwell because she was in +on the whole thing. +So what did +tell you about next? Well, Maxwell +started rationing things up to the next level. Here's her +testimony about that. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 37 of 257 2870 +It was decided that I would learn how to give Epstein +a foot massage. Maxwell wanted to show me how to rub his feet, +and so that was something I should learn how to do. And so she +sat and held one of his feet and instructed me to hold his +other foot and showed me how to rub it. Maxwell started to +teach +how to give Epstein a foot massage. +Now, did Maxwell know that Epstein liked foot +massages? Of course she did. You saw that photo of Maxwell +massaging Epstein's feet with her breasts. +Ladies and gentlemen, your common sense tells you, it +is not normal for an adult woman to teach a 16-year-old girl to +rub a middle-aged man's feet. That is not part of some +mentoring program, it's not part of a scholarship entry +program. You know exactly what that was about, and when +Maxwell did it, she knew exactly what she was doing, she was +trying to get +to touch Epstein. They were confusing her +boundaries. They were moving the line slowly and gradually for +what would come next. +This was classic grooming behavior. It's what Maxwell +did to Jane and it's also, by the way, what Maxwell did to +So let's take a moment to look at +testimony about +that. +told you that when Maxwell introduced her to +Epstein, she said, why don't you give his feet a little squeeze +to show him how strong you are. Why was Maxwell asking these + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 38 of 257 2871 +teenage girls to touch Epstein's feet? It's obvious. She was +trying to get these girls to touch Jeffrey Epstein. She was +trying to normalize touch. She was doing it because she was a +predator. +For +things didn't stop with foot massages. +Maxwell pushed things further. +told you about how +Maxwell insisted on giving +a massage, and during that +massage, Maxwell folded down the sheet, exposing +breasts, and began touching her breasts. +Ladies and gentlemen, there are a lot of things you +can say about a woman in her 30s groping the breasts of a +16-year-old girl, but a therapeutic massage is not one of them. +That's not on a list of spa treatments anywhere. What Maxwell +was doing was the same thing that she did to other girls - she +was introducing touch, she was normalizing sexualized massages, +she was breaking down barriers, she was moving the line +forward, slowly, but surely. +And what happened next is exactly what Maxwell was +trying to set up. Towards the end of the trip, Epstein came +into +room and got into her bed saying that he wanted to +cuddle. A man in his 40s was in her bed. He wrapped his arms +around her and pressed his body against her. Just imagine how +terrifying that would be for a 16-year-old girl. She's alone +on a ranch in the middle of nowhere, and the adults in charge +are the woman who groped her breasts and the man who's now in + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 39 of 257 2872 +her bed trying to cuddle her. +You learned that +got away. She got out of bed +and she hid in her bathroom. What Maxwell and Epstein were +trying to do, what they successfully did with other girls, it +didn't work on +And +told you that, after that, on +the last day, Maxwell suddenly seemed very disinterested in +her. +Ladies and gentlemen, Maxwell lost interest in +because her scheme didn't work. When +wouldn't cuddle +with Epstein, when they couldn't take things further, Maxwell +dropped the act. She didn't have to pretend to be charming +anymore because she didn't have any use for +anymore, and +that was the end of the trip. After that, +never spoke to +Maxwell or Epstein again. She went to her junior prom and then +she spent the summer in Thailand on a trip that Epstein had +paid for. +And by the way, I +• and +and her high school boyfriend, +mom all remember that +went to +Thailand that summer. +During the defense case, the defense called someone to +testify about border patrol records, but don't let any spotty +border records from the 1990s distract you for a minute. She +obviously went to Thailand that summer. We're looking at a +photograph of it right here. +When +got home from Thailand, her mother had +asked her what had happened in New Mexico, she wanted to know + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 40 of 257 2873 +what had happened on that trip. +Here's Janice Swain's testimony about that. She told +you that +said, I don't want to talk about it, I'm just +not going to let it ruin my life. +But not long after this happened, +told her high +school boyfriend what Maxwell and Epstein had done. She told +him about meeting Maxwell on the trip to New Mexico. +You heard from +at this trial. Here's +his testimony about what [ +told him. She said that Maxwell +was very charming, very pretty, she greeted her when she +arrived, and I remember that they had a day around town where +Maxwell took her shopping. He even remembered that +said +that Maxwell had bought her cowboy boots. But most +importantly, +told him that Maxwell had given her a +massage and touched her breasts. +Here's his testimony about that. He remembered what +told him, that Maxwell had touched her, that she had +touched her breasts during the massage, and in 2006, +told +the FBI the same thing. +Here's her testimony about that. She told them about +Maxwell in 2006 - 15 years ago. That's one of the many ways +that you know that +• is telling the truth. She has been +consistently describing since the 1990s what Maxwell did to +her, and what Maxwell did to +| is powerful evidence of her +guilt. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2874 +I want to talk to you now about what Maxwell and +Epstein did to +• That's the fifth way that you know +Maxwell is guilty. +This is +when she was a teenage girl. +met Maxwell through a girl she knew named +So +I'm going to start by talking to about +This is Government Exhibit 113 and 114. That's +This is the same girl that Juan Alessi remembered. +He told you about how he was driving to Mar-a-Lago one day. He +was driving Maxwell one day by Mar-a-Lago, and Maxwell saw this +girl and told him to pull over. Maxwell got out of the car and +went to go talk to that girl. +Here's his testimony. She told me to stop - John, +stop - and I stopped the car and she opened the door and she +went towards this girl as she was coming down the ramp. +She +went to go talk to this girl. And sure enough, he saw +at the house later that day. When she arrived, Alessi brought +her to see Maxwell. After that, he remembered that +started coming to the house and spending time with Maxwell and +Epstein. He told you about that. +We'll talk more in a moment about +but I want +to be very clear that the +that +told +you about is the very same +that Juan Alessi +told you about. It's the same girl that Maxwell pulled over to +talk to. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2875 +Now +testified that when she was about 14, +told her about a way to make money giving a massage to +a wealthy man. They went over to that man's house in Palm +Beach and met Maxwell there. +Here's her testimony about that. +said this +was her friend, +| and Maxwell responded, you can bring +her upstairs and show her what to do. You know exactly what +Maxwell meant, sexual contact was about to happen in the +massage room, and that's exactly what happened next. +and +got undressed and started +massaging Epstein in the massage room, and then +and +Epstein started having sex in front of +in the massage +room. +sat on the couch in the massage room while it +happened. +This is the massage room. That's the couch on the +left. On the walls on the left, there were nude drawings. +Ladies and gentlemen, this was not a place for a therapeutic +massages, it is a place where Maxwell and Epstein's victims +were sexually abused. +You take a look at the drawings on the left, here is a +zoom-in from the search video, there are the drawings. And +while we're talking about this space where things happened, I +want to pause here and show you the entrance to the master +bedroom in the Palm Beach house close by the massage room. +You're going to notice a large photo of a young girl pulling + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2876 +her underwear down, and when you see that, you'll understand +what Maxwell understood, that Maxwell understood what was +happening in that house. +The first visit for +to this house was the +beginning of years of sexual abuse. +told you about how +Maxwell would call her to set up appointment times for these +so-called massages, and sometimes +would call, too. +Here's her testimony about that. She told you that +Maxwell would call and set up appointment times. She said for +the first year or two, Maxwell would call, and then +call after that point. And you know that's true because +would +said that twice when she gave deposition testimony +under oath in 2009. +Here's the first one. +This is +deposition testimony from 2009. +"Q. In fact, Mr. Epstein himself did not contact you on each +occasion and request you to come, did he? +"A. No. He would have +or Maxwell call me." +Here's the second one. +"2. And on these occasions that you called to see if you could +go over there and give him a massage, did you talk to him or +did you talk to others at his house? +"A. I talked to +or Maxwell. I've also talked to -- I +don't know if it's a cook or someone else that was there that +took phone messages." + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2877 +She said it twice. +In 2009, +testified under oath that Maxwell +called her to schedule sexualized massages. And you know all +of this is true because you have heard testimony from Sean, +boyfriend at the time, who told you that +started making money by going over to Jeffrey Epstein's house. +He remembered that happening a couple weeks after he met +in 2001 when +was just 14 years old. +He also remembered that +told him that she +interacted with Maxwell inside of Epstein's house. Here's his +testimony about that. Sean even remembered how +couldn't pronounce Maxwell's first name. +When +went to that house, she had conversations +with Maxwell. Maxwell asked her if she'd ever used sex toys, +and she said no. Maxwell asked her about her plans for the +future. They talked about personal things in +life. +told Maxwell about her upbringing and her home life, +that her mother was an alcoholic and that +had been +molested by her grandfather when she was younger. +Maxwell also talked to +about travel. Maxwell +told her that she +invited her to travel with them, and +couldn't, that she was too young, she didn't have a passport, +and her mother wouldn't let her go. It should come as no +surprise to you, ladies and gentlemen, that Maxwell asked this +young girl to travel with them, because that's what Maxwell and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +Epstein had been doing for years at this point - trips with +Jane when she was 14, 15, 16; spending a weekend in New Mexico +with +when she was 16. +And we're about to talk in a few minutes about just +how many flight records there are that show that +flew with Maxwell and Epstein when she was 17 years +old. This was Maxwell's playbook for years, and she tried to +get +to travel, too. +What happened to +in the years that she was +abused in that house in Palm Beach is hard to talk about. You +remember her testimony. She told you about being paid to give +sexualized massages to Epstein, how he touched her breasts, put +a vibrator on her vagina, and how every massage ended with +Epstein ejaculating. Ladies and gentlemen, that's what +happened to Jane, too. It's one of the many ways that you know +that +is telling the truth. +Now, remember when +told you that Epstein sent +her packages, that he sent her lingerie? You know that's true +because you saw FedEx records that proved that Epstein sent her +packages. +2878 +This is Government Exhibit 803. It's a record of a +package sent to +| in October of 2002, when she was 15. +It's a package from New York from Epstein's office, and it +wasn't the only package. Here's another, Government Exhibit +801. Again, +was 15. And here's another, Government + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 46 of 257 2879 +Exhibit 802. Again, +was 15. +told you that she +got packages from Epstein from New York, and she did. You can +see that here in black and white. That's Government Exhibits +801, 802, and 803. +Who else was sending packages from Epstein's office +from this very same time period? Maxwell. She used the same +account to send packages. +You see Maxwell's name on each of +these FedEx account invoices. Maxwell was a part of the +operation just like +told you. +You also learned about phone messages that +left in the Palm Beach house on those message pads. Those +phone messages corroborate +testimony. They prove to +you that she was there. +So let's talk about two of them. +First, this is Government Exhibit 608. +testified that this was her mother's phone number. She wrote +it down so she wouldn't have to say it out loud at trial, and +we marked it as an exhibit. That same phone number is all over +the message pads from the Palm Beach house, phone message after +message. +This is Government Exhibit 1-B. It's the same phone +number, and that's +full name, first and last. It's +from 2004. And remember, we were just looking at FedEx records +from 2002. What's the message here? That she wants to work +for Epstein today. What you were looking at is a phone message + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2880 +from an underage girl who needs money and is being exploited. +This is Government Exhibit 3-E. It's the same phone +number and that's +full name. What's the message? +It's that +wants to work. Just like +told you, she +brought other friends to the house to give massages. +Ladies and gentlemen, +testimony was +extensively corroborated in this case. +Her name is on FedEx +records and phone messages. She has been on the record since +2009 about Maxwell calling her for appointments. And her +exboyfriend, Sean, confirmed that +went to that house to +make money for years and that she interacted with Maxwell at +that house. +You know that +told you the truth. That's what +the evidence tells you. Her testimony was backed up by the +other evidence in this case and it was corroborated by what +and +and Jane told you about Maxwell and how she +operated for years. What +told you is powerful evidence +that Maxwell was conspiring with Epstein to abuse underage +girls. Maxwell sent a teenage girl into a massage room with an +adult man. She knew exactly what she was doing. If you +believe +testimony, the defendant is guilty on counts +One, Three, Five, and Six. And I'll talk about those counts +later on. +That brings us to reason six. The sixth way that you +know Maxwell is guilty is because Maxwell and Epstein kept a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2881 +little black book with their victims' names in it. It is a +powerfully incriminating document. +So I want to start by going back to the household +manual. And what the manual shows you is that Maxwell and +Epstein had a phone directory, and they kept several copies of +it in the house. +There was a copy in the pool area, there was +a copy in their cars, there was a copy of it in the master +bedroom, and most importantly, there was a copy right on +Maxwell's desk. +Here's the part of the manual that tells you that. +There was a copy on her desk. And they're not just any +directories. In the manual, they're the JE and GM telephone +directories. Jeffrey Epstein and Ghislaine Maxwell. When Juan +Alessi testified, he was asked about a little black book and he +testified that he recognized it as one of those books. +So let's take a look at Government Exhibit 52-G, which +is a page from that book. Here it is. So the section on this +page is titled "Massage Florida." I'm going to highlight a few +specific entries in a moment, but first let's just start with +the basics. You'll notice just how many names there are. Who +needs that many masseuses? That's the first sign that +something is off here. And a second thing that you're going to +notice is that all of the names here are female. +The third thing that you're going to notice is that +there are notes next to some of the names, things like mom, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 49 of 257 2882 +dad, or parents. Use your common sense, ladies and gentlemen. +When you contact a professional masseuse, you don't need to +call her mom or dad. Just looking at this page tells you that +none of this was legitimate. These were millionaires who could +hire the top massage therapists in the whole world, but Maxwell +had a book with dozens of entries in a massage section that +makes absolutely clear that these were not real massages by +professional masseuses. In fact, this book makes clear that +some of the entries were for kids. +So let's talk about one of those entries. The entry +here on the left is +parents. I want you to take a +look at the phone number, ladies and gentlemen. You've seen it +somewhere else at this trial, and here it is. This is +Government Exhibit 823. It's the employment record for | +birth certificate, so you +know that +dad. He was an employee at +Mar-a-Lago, which, as Juan Alessi testified, is the place where +Maxwell met +Take a look at the phone number +listed for +on this document. It's the same number +on Government Exhibit 52-G, the contact book. +And +is also, by the way, on flight records +with Maxwell when she was 17 years old. Let's take a look, and +as we do, you're going to see the initials "G.M." for Ghislaine +Maxwell on every single one. +Here's the first one. Iwo flights, JE, GM, ET, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +JE, GM, AT, +It's from 2000. She was 17 +years old. Here's another page. JE, GM, +ET, +Here's another, JE, GM, ET, +There is another +one, JE, +GM, ET, +• This is 2001 when +was 17. They were flying around with a 17-year-old +2883 +girl. +But back to the black book, there is more to talk +about. Remember Sean, +boyfriend? There is an entry +for him, too, under an entry for +boyfriend's +house. That entry has +first and last name. That +same phone number that you're looking at here is on three +messages from the message pads, and here they are. It's +Government Exhibits 2-U, 2-P, and 2-0. And if you take a 100k +at the date on the two messages on the left, they're from 2003 +when +was 16. There's the phone number. It's the same. +In fact, the message in the middle is from just a month past +16th birthday. There is more. There is an entry in +here for +with her full name. That number is on phone +messages from 2003, too. Here they are. One says +two +say +I, but you know it's the same person, you know it's +because the phone number is the same. +Who else is in this book? Remember how Sean told you +that he would bring a 16-year-old girl named +to the +house with +? It's this girl in the photograph with +She's the one right next to +That's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 51 of 257 2884 +birth certificate. Sean told you this is the girl. +And sure enough, there are two entries under massage for +friend. Here they are. +Again, remember how you learned that, by this point, +things operated like a pyramid scheme. +brought +brought | +and other girls. One girl +would bring another, who would bring another. +Ladies and gentlemen, this book, Maxwell's book, it +proves to you that Maxwell is guilty. What you'll see in this +book corroborates the witnesses who testified at this trial. +She had victim names written in a little black book. This +document is powerful evidence of the defendant's knowledge and +intent. These were not real massages. What was happening was +sexual abuse with underage girls. Maxwell knew it, she was +part of it, she was responsible for it, and the fact that she +had a little black book with her victims' names in it proves to +you that she is guilty. +That brings us to the seventh reason that you know +Maxwell is guilty. It's the money. Now, we've already talked +about Epstein's luxurious lifestyle and all of the perks that +Maxwell got from being his partner in crime, but it wasn't just +getting to live in the mansions and flying on the private jets, +maxwell got millions of dollars from Epstein. You learned that +between 1999 and 2007, Jeffrey Epstein gave Maxwell about $30 +million, and you know exactly what that money was for. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 52 of 257 2885 +First, in 1999, Epstein sent Maxwell $18.3 million. +$18.3 million - here's the transaction. And then, in 2002, +Epstein paid Maxwell $5 million - here's the transaction. And +last but not least, in 2007, Epstein paid Maxwell $7.4 million. +$18.3 million, $5 million, $7.4 million. It's a total of +$30.7 million. +At this point, you got to ask yourselves, what was +Maxwell doing for Epstein that was worth more than $30 million? +Your common sense tells you that you don't give someone +$30 million unless they're giving you exactly what you want, +and what Epstein wanted was to touch underage girls. When +Maxwell took that money, she knew what it was for and now you +do, too. It was payment for committing terrible crimes with +Jeffrey Epstein. +That brings us to reason number 8 that you know that +Maxwell is guilty. When you zoom out and look at the big +picture, the timeline over the years, it's obvious that Maxwell +spent a decade aiding and abetting Jeffrey Epstein's crimes, +that they were coconspirators, partners crime. +Let's talk about the timeline the big picture. +In 1994, Maxwell met Jane. In that same year, Maxwell +and Epstein started sexually abusing Jane, and that often +happened in the context of massages. That same year, in 1994, +Maxwell met +1, too, and Epstein initiated sexual contact +with +also in the context of massages, massages in which + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 53 of 257 2886 +Maxwell delivered +to Epstein. +In 1995 and 1996, Maxwell was still in contact with +encouraging +to travel to see her and Epstein, and in +that same period, Maxwell was traveling with Jane, still +exploiting Jane, in Palm Beach, in New York, and in New Mexico. +And in the spring of 1996, +went to New +Mexico where Maxwell groomed her for sexual abuse, where +Maxwell massaged +breasts. +In 1999, Epstein sent Maxwell $18.3 million, and the +abuse continued. +Maxwell recruited +at Mar-a-Lago. In +2000, +was 17 years old and flying with Maxwell +and Epstein on Epstein's private jet. And in 2001, +was still 17 and still flying on the jet with Maxwell +and Epstein. They were flying around with a teenage girl. +In 2001, +brought +to the Palm Beach +house. +was 14 years old. That's when +met +Maxwell and Epstein, and that was the beginning of the pyramid +scheme of abuse, the scheme that no longer required Maxwell to +personally find young girls for Epstein, girls like +incentivized by extra cash were now bringing their friends, +girls who needed money. +And one year later in 2002, Epstein paid Maxwell +$5 million. +In 2002, 2003, and 2004, +was sexually abused + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2887 +in Epstein's Palm Beach massage room. Maxwell called to +schedule some of the appointments. +was 15, 16, and 17 +years old. +Remember how the defense tried to suggest to you that +because Maxwell had started dating some other guy named Ted +Waitt around 2004, she was no longer around Epstein. You know +that's not true and here's why. You saw that household manual, +Government Exhibit 606, that was dated in February of 2005, the +manual that outlined what Epstein and Maxwell demanded in the +Palm Beach house. She was still the lady of the house. And in +2005, the Palm Beach Police Department searched Epstein's +house. And what did the police notice during their search? +They found a desk with Ghislaine Maxwell's stationery on top. +And in 2007, two years later, Epstein paid Maxwell +$7.4 million. +When you take a step back and you look at this +timeline and think about the big picture, it is crystal clear +that Maxwell knew about and was deeply involved in Epstein's +sexual abuse of children. +Take a moment and just reflect on how deeply strange +this whole situation was. For years, Maxwell took trips on +Epstein's private planes with Epstein and teenage girls. For +years, Maxwell was right by Epstein's side as numerous teenage +girls came to visit him inside his homes. There were teenage +boys, by the way. For years, Maxwell watched a parade of these + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 55 of 257 2888 +girls come to massage him. For years, she kept a list in her +little black book with dozens of female names, definitely no +boys. For years, Maxwell lived in houses with Epstein that +were decorated with nude females, including sexualized pictures +of girls. For years, Maxwell slept in a bedroom in Palm Beach +that had two bathrooms attached to it, one filled with nude +drawings and stocked with a massage table and all the different +types of massage oils and lotions that Epstein liked, and the +other, Maxwell's bathroom where the dildo was stored. And over +those years, Epstein paid Maxwell millions and millions of +dollars. Ladies and gentlemen, look at the big picture and use +your common sense. She knew, she was complicit, she is guilty. +Ladies and gentlemen, that's eight reasons why you +know the defendant is guilty. Let's turn and talk about the +charges against the defendant. +Here are the six counts. I'm going to talk through +them briefly, but I want you to keep in mind that Judge Nathan +will give you detailed instructions about the law, and you +should listen closely when she does. What Judge Nathan says +about the law controls here. +First, I want to talk to you about something called +aiding and abetting. For counts Iwo, Four, and Six, which +we're going to discuss in just a moment, Maxwell is guilty if +she committed those crimes herself, but you can also find her +guilty under an aiding and abetting theory. In other words, if + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 56 of 257 2889 +you find that Epstein committed these crimes and that Maxwell +assisted him, she is just as guilty as if she had committed +those acts herself. And we talked about the overwhelming +evidence that Maxwell aided and abetted these crimes. She was +an essential accomplice, complicit in an extensive scheme to +abuse young girls. +So let's talk first about Count Iwo, which is +enticement to engage in an illegal sexual activity. This count +is about Jane and how Maxwell and Epstein enticed her to travel +in interstate commerce, in other words, to go across state +lines to New York to be abused. +The first element of that crime is that the defendant +knowingly persuaded, or induced, or enticed, or coerced Jane to +travel in interstate commerce. In other words, did the +defendant in some way cause Jane to travel across state lines. +You know that Maxwell induced Jane to travel because +Jane told you about traveling with Maxwell to New York. Jane +flew on commercial flights and also on the private jets. She +told you about how Maxwell assisted with her travel +arrangements, and Juan Alessi confirmed this, because he +remembered driving Jane with Maxwell, Epstein, and Jane right +up to the plane. He watched them board together. +Ladies and gentlemen, Jane didn't end up in New York +by accident, it was a direct result of Maxwell's actions, +aiding and abetting Epstein as part of an ongoing pattern of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 57 of 257 2890 +abuse. +You also know that Maxwell enticed Jane to New York +because Jane told you about the pattern of her relationship +with Maxwell and Epstein. She told you that Epstein gave her +money and gifts and paid for school. That money wasn't free, +and part of the cause was getting Jane on the plane with them +to go to New York where she was sexually abused. That is +inducement, that is enticement, that is coercion. +The second element is that Jane traveled in interstate +commerce. We've already discussed how you know that Jane +traveled from New York from out of state. You know that from +Jane's testimony, from Juan Alessi's testimony, and from the +flight records. +The third element is that the defendant intended that +Jane would engage in sexual activity for which any person can +be charged with a criminal offense under New York law, and +you're going to learn that it's a crime to engage in sexual +contact with a kid under 17 who is too young to consent. And +the evidence shows you that Maxwell absolutely intended that +Jane would be abused in New York. That was the whole point of +bringing her there, so that Epstein could have access to Jane. +They weren't traveling for mentorship or scholarships, they +weren't traveling with an underage girl because they were +friends, they were getting her to travel so that she could be +molested and that's exactly what happened. The evidence shows + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 58 of 257 2891 +you that the defendant is guilty on Count Two. +Now let's talk about Count Four, it's transportation +of an individual under age 17 to engage in illegal sexual +activity. And again, this count is about Jane. +The first element is that the defendant knowingly +transported Jane in interstate commerce. +Here we're talking +about the travel itself. The last count we looked at was about +enticement to travel, this one is about the travel itself. +We've already talked about how Jane was transported to New +York, and for this count, all that's required is that the +defendant was actively engaged, either personally or through an +agent, in making travel arrangements, or that she aided and +abetted Epstein. +THE COURT: Ms. I +,, closer to the mic, please. +: Thank you, your Honor. +Maxwell did not need to physically transport Jane +herself or even be present for transportation, but again, Jane +told you that Maxwell helped with her travel arrangements and +that Maxwell was on flights with Jane. Juan Alessi confirmed +that. The flight records confirm that. +The second element here is that the defendant +transported Jane with the intent that Jane would engage in +sexual activity for which any person can be charged with a +criminal offense under New York law. We've already talked +about this one and how the evidence conclusively proves that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 59 of 257/ +2892 +Maxwell intended for Jane to be sexually abused on these trips. +I want to emphasize here that there is no requirement +that abuse in New York actually happened or that the defendant +was the one who committed the abuse. The crime is transporting +Jane with the intent that she will be abused. +Ladies and gentlemen, when Maxwell was helping arrange +travel for Jane, when she got on that plane with Jane, Maxwell +knew exactly what she was doing, and she knew exactly what +Epstein was going to do to Jane. The crime happened the moment +they crossed state lines. And to be very clear, when Epstein +flew Jane to New York and Maxwell aided and abetted him, that's +enough, too. +The last element is that the defendant knew Jane was +less than 17 years old. And you know that the defendant knew +that Jane was under 17, ladies and gentlemen, she met her at a +summer camp for kids. She was too young to drive. Maxwell +knew this girl for years, when she was 14 and 15 and 16. She +would talk to Jane where they would spend time together. +Maxwell absolutely knew that she was under 17. +And through all these elements, when we're talking +about the defendant's knowledge and intent, I want you to think +about | +She told you about how the defendant asked her to +deliver tea to Epstein wearing a schoolgirl outfit. That is +striking evidence that Maxwell knew Jeffrey Epstein had a +sexual preference for schoolgirls. And after +delivered + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2893 +tea in that schoolgirl outfit and Epstein initiated sexual +contact with +later that day, Maxwell asked | +if she +had fun. Maxwell told +that she was a good girl. +also told you about how Maxwell complained about +Epstein's need to have sex three times a day, how Maxwell was +constantly looking for someone to give him blowjobs. That +makes it crystal clear exactly what Maxwell intended when she +was taking Jane on these trips. Jane was there to satisfy +Epstein's constant need for sexual gratification. The evidence +proves to you that Maxwell is guilty on Count Four. +Now let's talk about Count Six, it's sex trafficking +an individual under age 18. This count is about +The first element is that the defendant knowingly +recruited, enticed, harbored, transported, provided, or +obtained +You heard about how the defendant called +for massage appointments with Epstein. She was +recruiting, enticing, providing, and obtaining +every +single time she did that. +The second element is that the defendant knew that +was under age 18. Ladies and gentlemen, +was a +14-year-old girl. She came to the house over and over again +and interacted with Maxwell. She talked about her home life, +she told Maxwell she was too young to travel, that her mother +wouldn't let her go on trips. She was a girl who had just +dropped out of middle school. There just can't be any question + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2894 +that Maxwell knew +was underage. +And we're talking about the counts one by one, but I +want to step back and ask you to keep in mind, you don't have +to set aside all of the evidence you heard in this case when +you examine each count, it's the opposite. The pattern +throughout the case tells you that the defendant knew these +girls were under age and she knew that they were going to be +molested. You should consider all of that evidence as you +examine each count. +The third element of Count Six is that the defendant +knew +would be caused to engage in a commercial sex act. +And here, a commercial sex act just means a sex act in exchange +for money. That's what happened to +She was paid +hundreds of dollars every time that she was abused. Sometimes +Maxwell handed over the cash herself. +And we've been talking all morning about the +overwhelming evidence that Maxwell knew these girls would be +sexually abused in those so-called massages. She absolutely +knew. +Finally, there is a fourth element here. In +interstate commerce here means something a little different +than the first two counts we talked about. We're not talking +about travel across state lines. +Instead, we're talking about +an effect on interstate commerce. +So when +got packages from New York, when she + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2895 +was abused on a massage table that was manufactured in +California, that proves that there was at least a minimal +effect on interstate commerce, which is all that's required for +this count. +Finally, there are three conspiracy counts that charge +Maxwell with conspiring with Epstein to commit the three crimes +that we just talked about. +I expect Judge Nathan will instruct +you that a conspiracy just means an agreement to break the law. +The crime is the agreement and taking some step to carry it +out. So the question for you here is, did Maxwell agree with +Epstein to commit these crimes. The conspiracy counts are +counts One, Three, and Five. +The first two conspiracy counts are from 1994 to 2004. +Those counts are about Jane, +• and +• Those counts +charge a conspiracy related to enticement and travel, as we've +just discussed. We've already talked about how Maxwell and +Epstein completed these crimes as to Jane. For the conspiracy +charges, even though +and +were not sexually abused +in New York, everything about the defendant's and Epstein's +interactions with those girls makes it clear that that is what +they both intended. Maxwell groomed both +and +as +part of a broader agreement with Epstein to provide him with +underage girls for abuse. You heard about all of the steps the +defendant took in those years in furtherance of that +conspiracy, how Maxwell traveled with Jane and groomed + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +for abuse after she had already visited Epstein in New York, +how the defendant asked +to travel, too. This went on +for years. +Count Five is the sex trafficking conspiracy count +which spans from 2000 to 2004, and this count relates to +and +You heard about the steps the defendant +took in those years with | +and +She was taking +steps to traffic girls for sex, recruiting +Mar-a-Lago, transporting | +at +sending +to other states with Epstein, +up to the Palm Beach massage room on her first +visit, calling +for massage appointments in Florida so +that she could engage in commercial sex acts. The defendant +took so many steps in furtherance of the conspiracies charged +in the indictment, the evidence about that was overwhelming, it +went on for years. +But let me say this, because it's very important. For +each of the conspiracy counts, to find the defendant guilty, +you only have to find that she did it once, that there existed +one moment in time in all of those years where she agreed to do +this, and that Maxwell or Epstein took some step to carry out +the agreement. That's it. If you find that one moment +happened, the defendant is guilty. +Let me say one last thing about the law. For each of +the counts, I expect Judge Nathan will instruct you about +something called venue. We're required to prove that it's more +2896 + + +Case 1:20-cr-00330-PAE | +Summation - Ms. l +Page 64 of 257 2897 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +likely than not that just one act in furtherance of the crimes +took place here in the Southern District of New York. There +just cannot be any question about that. +For the first four counts, you heard about Jane's +trips to Manhattan, which is in the Southern District of New +York. +For counts One and Three, you also heard about +trip to Manhattan. And for counts Five and Six, you saw the +packages sent from Manhattan, you heard about Maxwell calling +to schedule sexualized massages when Maxwell was in New +York. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +Filed 08/10/22 Page 65 of 257 2898 +That's more than enough for venue on each +count. +So that's all that I'm going to say about the law. +We've proved to you that the defendant has committed all six +crimes charged in the indictment. +I want to switch gears and talk to you about one last +topic. I want to talk to you about the arguments the defense +has made to you at this trial. Now, before I get into this, +let me be clear that Maxwell has no burden to put on a defense +or to put on any witnesses or evidence on her behalf. The +government has the burden of proof beyond a reasonable doubt. +We embrace that burden and we've carried it. But in this case, +Maxwell chose to cross-examine witnesses, to make arguments, +and to call witnesses. You can -- and should -- scrutinize +that carefully. +In her opening statement, defense counsel said +something to you about Maxwell being blamed for something a man +did. Let me be very clear. The evidence at this trial showed +you that Ghislaine Maxwell made her own choices. She committed +crimes hand-in-hand with Jeffrey Epstein. She was a grown +woman who knew exactly what she was doing. And now she's +sitting here in this courtroom being held accountable for +breaking the law. That's what this trial is about. That's +what the evidence tells you. +And at the beginning of this trial, defense counsel + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +Page 66 of 257 2899 +said to you that this case was about manipulation, money, and +memory. And you know what? Defense counsel was exactly right, +but not in the way she meant. Not at all. +This case was absolutely about manipulation. You +learned about how Maxwell manipulated young girls, making them +believe that she was their friend, making them feel special, +all so they could be molested by a middle-aged man. And you +heard from Dr. Rocchio, an expert psychologist, and you learned +about how perpetrators manipulate their victims in a process +called grooming. The evidence in this case overwhelmingly +shows you that that's exactly what Maxwell did to these girls. +And make no mistake, this trial was absolutely about +money. The evidence showed you that Maxwell and Epstein were a +wealthy couple who used their privilege to prey on kids from +struggling families. +Let me stop and say this: I want you to think about +the few $100 that +got every time that she was sexually +abused. And I want you to think about the $30 million that +Ghislaine Maxwell got from Jeffrey Epstein. This case is about +the way that Ghislaine Maxwell and Jeffrey Epstein exploited +kids from struggling families. So when defense counsel talks +to you about money, just think about that. +This trial was also about memory. When the witnesses +took that witness stand, they told you about searing memories +of childhood sexual abuse, traumatic memories that they've + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +Filed 08/10/22 Page 67 of 257 2900 +carried with them for years. That is what the evidence at this +trial showed you. +Next, the defense has tried to argue to you that +Maxwell, that maybe she was just too busy to commit these +crimes. So let's talk about that. +The employees you heard from at this trial told you +that Maxwell had all kinds of people who worked for her. She +had personal assistants who she interviewed in the back of a +limo, a woman to walk her dog. But despite all of this, the +defense tried to argue that maybe Maxwell was so busy managing +all of the details of Epstein's life, that maybe she wasn't +involved in these crimes; that maybe she was so busy ordering +sand to be delivered to Epstein's private island, that she just +didn't know what was going on right in front of her. That's +the argument. +The argument that Maxwell did not know what was going +on is flatly contradicted by the evidence in this case. +Maxwell participated in the abuse; of course she knew what was +happening. And in the moments where she wasn't in the room, +she absolutely knew what was going on. The argument that +Maxwel1 didn't know what was happening in the houses that she +managed and lived in with the man she was sleeping with, what +was going on with young girls she met in person and interacted +with frequently, that argument is absolutely absurd and you +should reject it completely. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +Page 68 of 257 2901 +So next, the defense has repeatedly attacked Jane, +and +I, claiming that they are liars or that +their memories are faulty or maybe it's both. They argued both +to you during this trial. They are doing that because the +testimony of the witnesses in this case is devastating evidence +of Maxwell's guilt; because if you believe them, Maxwell is +guilty. +You are the finders of the fact. You're the judges of +the truth. And your common sense tells you that only one of +three things can be true about +., Jane, +, and +Either they are all misremembering the same thing, or they're +outright lying, or they're telling the truth. +So I want to talk through those one-by-one. +First, the defense has suggested to you that perhaps +Jane and +and +and +are all talking about fake +memories. But that's what they testified about, that they are +getting it wrong; that their memories are faulty. Four women +have testified at this trial about Maxwell. They all describe +the same woman, the same playbook. They didn't imagine what +happened to them. Your common sense tells you that just cannot +be true. They are not all somehow suffering from the same mass +delusion. +And while time has passed, they told you very clearly +that they remember being exploited by Maxwell and Epstein. +Your common sense tells you that being molested is not + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +LCKVMAX4 +Page 69 of 257 2902 +something that you forget ever. You remember an adult woman +groping your breasts. You remember a middle-aged man touching +your vagina. You remember feeling scared and frozen and +trapped and confused. Your common sense tells you these women +know what happened to them in their own lives. They know it. +These are powerful memories of trauma, and they've carried +these haunting memories with them for years. +But when the defense talks about memory, they want to +talk about experiments, experiments that Professor Loftus +performed in a lab, experiments like the one where she tried to +convince people that they saw Bugs Bunny at Disneyland; +experiments where she told people that a stop sign was a yield +sign. Don't be distracted by that. +Loftus has made a career of being a witness for the +defense. And she said in her book by that name, she doesn't +even pretend to be an impartial expert. She admits she is an +advocate for the defense. And over the years, as she has +admitted, she has been paid by criminal defendants to testify +on their behalf. She's made a name for herself as a witness +for the defense in high-profile trials. And most importantly, +this case isn't about Bugs Bunny, it isn't about stop signs; +it's about sexual abuse, repeated sexual abuse of teenage +girls. Loftus told you, never done a study about that. +So all of that testimony she gave about implanted +memories or corrupted memories, it was totally irrelevant to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +Page 70 of 257 2903 +the facts of this case. And that's because those experiments +are nothing like what happened here. And Loftus was basically +forced to admit that on cross-examination. +Remember that study she described about telling people +that they were lost in a mall? Remember that she only was able +to trick 25 percent of the participants about that? +But, more importantly, another researcher then did a +follow-up study, and that researcher tried to implant two false +memories. She tried to implant the lost-in-the-mall story, and +also a story about an unpleasant bodily intrusion, a rectal +enema. Now, some people were tricked about getting lost in the +mall, but no one had a false memory about getting a rectal +enema. Why is that? Your common sense tells you that kind of +experience is the sort of thing you can't trick someone into +believing. You cannot suggest that. You can't make it up. A +rectal enema is the kind of thing you'd only remember if it +really happened, kind of like sexual abuse. +And again, Loftus basically had to admit this on +cross-examination. She said the core memory of trauma is +stronger than other types of memory. She admitted that. +People might forget some of the peripheral details, but the +core of the traumatic event, those memories are much stronger. +You don't need a paid expert to tell you that, ladies and +gentlemen. It's just common sense. You remember something +like this. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +Page 71 of 257 2904 +Her testimony was a total distraction. You saw the +witnesses yourself. They were not talking about one time that +they saw a fake car crash. They were telling you about how +they were sexually abused again and again and again. You heard +them tell you about their worst memories, and that's why this +is a case about memory- +As jurors, you understand how memory works from your +own lives, and that's how you know it just doesn't make any +sense to say that Jane and +and +and +all +imagined this, or that they're experiencing some kind of false +memory of something that never happened. Again and again at +this trial you saw the lengths the defense went to in order to +try to discredit the witnesses, because their testimony was +devastating evidence of Maxwell's guilt. +I want to talk about that for just a moment. Let's +talk about just two examples. +Remember that in a cross-examination of Jane, when the +defense repeatedly tried to suggest that Jane had said on her +application to Interlochen that nothing was difficult for her? +This is Defense Exhibit J-3. This went on for question after +question, as the defense tried to suggest that Jane was lying +about her difficult home life. Here it is. The defense +pointed her to the Interlochen application twice to suggest +this. Here's part of the transcript where that happened. +You wrote that. When asked about something difficult, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +_Page 72 of 257 2905 +nothing has been difficult for me; correct? +I guess I did. +But then you saw the actual application, the whole +thing. +What was that question really about? List two +difficult works performed in orchestra, band, or an ensemble +within the past year. And Jane answered: Nothing has been +difficult for me. +So what does that mean? The defense spent a long time +trying to discredit Jane with a line that was really about +orchestra music. Even Jane didn't realize she was being misled +this way until she was shown the question itself on redirect. +Here's another example: Remember how Jane was asked +about a legal document called an interrogatory? She told you +that she'd never seen this document before and she had no idea +what it was. And the defense suggested to you that this legal +document means that Jane said nobody else besides Epstein had +been involved in her abuse. There's this long question here. +But guess what: Here's the portion that the defendant +didn't show you and didn't read to you. It says, Maxwell +facilitated the sexual abuse of Jane and was frequently present +when the sexual abuse of Jane occurred. It's right there in +that same document. They didn't read that part to you; +instead, they plucked parts out of context to create a +misimpression. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +LCKVMAX4 +Filed 08/10/22 Page 73 of 257 2906 +Finally, I also expect the defense will make arguments +to you about property records in London. Those all came in by +stipulation on Friday. They'll say that Maxwell didn't live at +44 Kinnerton Street in 1994, when +met her; and that she +lived -- that Maxwell lived in another house nearby in London. +But that's just another distraction and here's why: +Maxwell herself testified under oath in a 2019 +deposition, here it is, that she had lived at 44 Kinnerton +Street since 1992 or 1993. So either the defendant lived there +the whole time or she mixed up her two London houses and +did too. Either way, it just doesn't matter. +So next, the defense has argued to you that Jane and +and +and +are all lying. The defense has +asked you to believe that Jane and +and +and +that they are all lying for money. But none of that makes any +sense when you look at it closely. It doesn't make any sense +when you look at the evidence. +Now, all four women have testified that they submitted +claims to the Jeffrey Epstein Victim Compensation Program. +They were awarded millions of dollars. And that happened well +before this trial. Their civil lawsuits are over. Those cases +are done and the witnesses don't get anything out of testifying +at this trial. They were clear in their testimony. They have +no financial stake in the outcome of this trial. None. +And one of the other ways you know the witnesses + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +LCKVMAX4 +Filed 08/10/22 Page 74 of 257 +aren't making this up is that multiple other witnesses backed +up what they told you. Think about all of the other witnesses +in this case. +Juan Alessi, +Janice Swain, and +the witnesses called Matt and Shawn. Think about all the ways +their testimony was backed up by documents, all of the other +evidence +in the case. +Your common sense tells you the witnesses are not +lying and they just cannot be all misremembering the same +thing. That just leaves one conclusion: That Maxwell is +guilty and you should convict her. +Let me take a step back and say this: Ladies and +gentlemen, 1ook at the evidence together, all of the evidence, +and use your common sense. The evidence points to only one +conclusion: That Ghislaine Maxwell sexually exploited young +girls. She trafficked underage girls for sex. When you +consider all of the evidence and use your common sense, you +will reach the only verdict consistent with the evidence: +Maxwell is guilty. +THE COURT: All right. Thank you, Ms. +Members of the jury, we are going to take that break +for lunch. It will be a short break, 20 to 30 minutes. +is having it set up now. My law clerks are going +to assist you getting back. +I just want to pause one moment. I repeat this, even +though we're at the later stages of the case. No discussions +2907 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +LCKVMAX4 +Filed 08/10/22 Page 75 of 257 2908 +with each other or anyone else about the case. Wait until you +hear the remainder of the arguments to come, my instructions, +and you begin your deliberations. And continue to keep an open +mind until we get through all of the stages of the case. +Enjoy your brief lunch. We'll see you in 20 to 30 +minutes. Thank you. +(Jury not present) +THE COURT: Any matters to take up? +: No, your Honor. +MS. STERNHEIM: One brief matter, Judge. +THE COURT: Okay. +MS. STERNHEIM: And I preface this by saying that I +haven't had an opportunity to research it, but during the +closing argument, Ms. +indicated that because a massage +table came from California, that affects interstate commerce. +It is not my understanding that that is accurate. If that were +the case, then any dwelling that contained any property that +had come out of state would have affected interstate commerce. +There is no evidence that the table was purchased, when it was +purchased, and whether it was purchased in connection with the +offenses charged. It is unlike the cases where property is +stolen, and that property is for resale and affects interstate +commerce. This is not that situation, and I think that the +statement is incorrect. +THE COURT: Application? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +Filed 08/10/22 Page 76 of 257 +2909 +MS. STERNHEIM: One moment, please. +(Counsel conferred) +MS. STERNHEIM: Judge, if I may just from here, I +think our application would be a limiting instruction +correcting the misstatement. +THE COURT: Specifically? +MS. STERNHEIM: That the statement that the massage +table having been manufactured or sent from California is a +sufficient element to satisfy the interstate commerce clause of +Counts Five and Six. +MR. +: Your Honor, just reading from the +Court's charge, it affects interstate commerce to use products +that traveled in interstate commerce, that's exactly the +situation here. +THE COURT: You pulled away from the microphone. +MR. +: Just reading from the Court's charge, +it affects interstate commerce to use products that traveled in +interstate commerce, that is exactly what Ms. +said here. +And, of course, the massage table was used in the course of the +crime here. +MS. STERNHEIM: I'd also add that there was no +identification of that specific massage table as the one that +was used in connection with these offenses. +MR. +: At a minimum, your Honor, this is the +massage table seized in 2005. The jury can infer it was used + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +LCKVMAX4 +Filed 08/10/22 Page 77 of 257 2910 +in 2004 during the sex trafficking conspiracy. +THE COURT: All right. Overruled. +Anything else? +MR. PAGLIUCA: Yes, your Honor. +This relates to Exhibit 52, which are the pages from +the book that were admitted. The Court admitted those over our +hearsay objection with the limiting instruction. And the +government assured the Court, when the Court was making this +decision, that they weren't going to argue the truth of the +matter contained in any of the books. +And what we heard in closing argument was exactly +that, that there are names in the books. And you can then +infer from those names that those might be the people that were +being discussed by Jane as having the sexualized massages; that +they were reading the words mom, dad, phone numbers, and +suggesting that that's how Ms. Maxwell had to have known that +these individuals were minors. Again, that's the truth of the +matter asserted; it's not for the limited purpose that the +Court instructed the jury. +My request, your Honor, my application, first, is that +the Court declare a mistrial based on the misuse of that +evidence. If the Court is not inclined to do that, I believe +the Court should reinstruct the jurors about the limited +purpose, instruct the jurors that they can't infer what the +government was suggesting they could infer from that argument. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Filed 08/10/22 Page 78 of 257 2911 +LCKVMAX4 +And then we go from there. +I also object to the use of what I thought the Court +prohibited, which was the grooming-by-proxy argument, which was +re-raised in closing argument, suggesting that somehow Ms. +Maxwell was grooming these women for Mr. Epstein, which I +thought had been precluded. +THE COURT: That's easy to overrule. +My precise conclusion was the expert couldn't testify +to it in part because -- well, not in part. The expert +couldn't testify to it; but, of course, counsel could make +arguments along that regard from the facts in the evidence. +MR. PAGLIUCA: Understood, your Honor. +Those are my remarks and requests about the closing. +THE COURT: Exhibit 52. +: Yes, your Honor. +The government's arguments with respect to Government +Exhibit 52 were entirely consistent with the Court's ruling. +In particular, the arguments were about knowledge and intent, +how it would be obvious, looking at a document, that none of +this was legitimate, that they weren't real masseuses, things +like mom and dad, we have that effect. And when a document is +offered not for its truth, that is certainly a proper +inference. +When we compare the numbers in Government Exhibit 52 +against the message pads, the language was the number here is + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +Page 79 of 257 2912 +the same +number on this document. That's certainly permissible +and a matter of common sense. +We just showed two documents and +showed they were the same phone numbers. +What I didn't say is, This is +phone number, +you know, it's the real phone number. It was a common sense +inference between two phone numbers that were the same. +THE COURT: I deny the request for mistrial. I +overrule the objection. It is consistent with my -- both my +conclusion in allowing it with respect to the limited purpose +for which the document was entered as indicated in my limiting +instruction at the time. And for those reasons, the motion +is -- the application is denied. +Anything else? +MS. STERNHEIM: No, thank you. +: Not from the government, your Honor. +THE COURT: All right. See you in about 15 -- I want +to make sure everybody has enough time for a quick lunch, but +my plan is to resume in 20 minutes. Thank you. +(Luncheon recess) +MS. MENNINGER: We have technical difficulty, your +Honor. The screen is not working. +However, we're working on it. +THE COURT: Be seated please. +How about a laptop? +(Pause) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +LCKVMAX4 +Document 767 Filed 08/10/22 Page 80 of 257 +2913 +THE COURT: Let the record reflect my suggestion was +paper • +(Pause) +THE COURT: I'll ask +to line up the jury. +Ms. Menninger, are you ready now? +MS. MENNINGER: Yes. +We are now. +Thank you, your Honor. +THE COURT: Okay. +Bring in the jury. +Ms. Menninger, please do stay close to the mic +throughout, if you can. I know sometimes it starts that way +and then you back up. One backs up. +MS. MENNINGER: One does. +THE COURT: One does. Thank you. +MS. MENNINGER: One will try not to. +THE COURT: Thank you. Bring in the jury. +(Jury present) +THE COURT: Everyone may be seated. +All right. Thank you, members of the jury. I hope it +was a good -- even if speedy -- lunch. +I'll ask you to now please give your full attention to +Ms. Menninger, who will deliver the closing argument on behalf +of Ms. Maxwell. +Go ahead, Ms. Menninger. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2915 +MS. MENNINGER: Good afternoon. Ghislaine Maxwell is +an innocent woman wrongfully accused of crimes she did not +commit. The government has failed to prove any charges beyond +a reasonable doubt, and the just and only correct verdict in +this case is not guilty on each and every count. +The evidence presented at trial has established +exactly what we told you it would during openings, that the +stories relied on by the government are the product of +erroneous memories, manipulation, and money. But, in this +case, the order is reversed. The money brought the accusers to +the FBI with their personal injury lawyers sitting right there +next to them. The lawyers manipulated their stories and the +government accepted those stories at face value without ever +testing them or corroborating them or checking with other +witnesses to see if they were accurate. And suddenly, the +women recovered memories years later, they recovered memories +that Ghislaine was involved, that Ghislaine was there, that +Ghislaine is the culprit. +Just as we predicted in our opening statement, the +government spent a lot of time focusing you on Epstein, on his +character, on his lifestyle, on his flaws, and they certainly +proved to you that Epstein had abused his money and his power. +They proved to you that he was a +manipulator. That has +nothing to do with Ghislaine and everything to do with Jeffrey +Epstein. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 82 of 257 2916 +We are not here to defend Jeffrey Epstein, he is not +my client. +The government played you a montage of Epstein's +houses, his bank accounts, his artwork, his cars, his planes, +his helicopters, his bank accounts, his message pads, just like +a sensationalist tabloid would. His private island, his +photos, and those, +ladies and gentlemen, are for things that +Epstein did, things that Epstein had, and perhaps Epstein's +crimes, but as we told you in our opening, Ghislaine is not +Jeffrey Epstein. +The government in this case has now pivoted because +Epstein is not here and they said: Her, too; her, too. +Ghislaine was there, she must have known. They said, let me +show you a bunch of photos of them together, undated photos +from unknown times with unknown hairstyles. You've seen them +together. She must have known. Ladies and gentlemen of the +jury, you heard that the government seized somewhere near +38,000 photographs, and they brought you a handful of Jeffrey +Epstein and Ghislaine Maxwell together. Where are the other +37,960 photographs? Who were in those photographs? Was it +other girlfriends? Was it other women? Who was it? You don't +know. They didn't bring you those photos. +You saw in the drawers, where these photos were kept, +the binders. You saw the discs where they were kept. And they +brought you the most innocuous photos of a couple that once was +together, and they didn't even tell you when. This is proof of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +nothing. Do your former boyfriends or girlfriends still have +some photos of you somewhere in their drawer? Does that make +you a sex offender if they are? This is straight up +sensationalism, your Honor and ladies and gentlemen of the +jury. +2917 +Judge Nathan will instruct you at the end of this case +that you are to consider the evidence and you are also to +consider the lack of evidence presented to you by the +government to meet the highest standard of proof we have in our +system, proof beyond a reasonable doubt. Those two concepts +are equally important, the evidence and the lack of evidence. +What you heard, and more importantly, what you did not hear +over the last three weeks is going to convince you that the +only correct verdict is not guilty. +These accusers in this case had stories to tell about +Jeffrey Epstein and, decades later, they inserted Ghislaine +Maxwell into their narrative. There were FBI interviews, civil +complaints, depositions, interrogatories, settlements, all came +and went over those decades. +Jeffrey Epstein died and then +everyone lawyered up. Every one of the accusers got themselves +a lawyer before they first walked in, in September of 2019 in +connection with this case, to talk to the FBI. You don't need +a lawyer to go talk to the FBI unless you want to get money. +Those lawyers sat down with their clients, they met with them, +it's all shielded by privilege what they talked about, but we + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | + +2918 +know that the clients talked to each other. You heard that +from the witnesses. You know they emailed each other, you know +they met up after court appearances with Jeffrey Epstein, and +you heard, for example, about Jane's lawyer, Robert Glassman. +He told her, before this case was ever charged, that Glassman +stated before the government charged the case, Jane had +discussed whether to cooperate -- and reminding you, she didn't +want to cooperate before Epstein died, but he advised her that, +to cooperate, would quote, help her case, meaning her civil +case. +She hired Robert Glassman two weeks before she first +talked to the FBI in September of 2019. +So these women, with their lawyers, walked into the +U.S. Attorney's Office, they filed their civil lawsuits at the +same time, and the lawyers, like Boies Schiller, helped set up +the Epstein Victims Compensation Fund. +told you that. +On that fund application, it asked you, are you cooperating +with a criminal investigation, have you filed a civil suit, +because if you are, we'll just assume you're a real victim, +even though we, the fund, aren't going to ask you any questions +or put your story to the test. And all of these ladies had +lawyers, went to the FBI, and filed a civil suit and filed a +civil claim with the fund and they each took home millions, and +now they are stuck with the stories that they told. +That's the money piece. Now for the manipulation, a +manipulation of the truth and the evidence. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2919 +As we go through the stories of each of these accusers +and each of the witnesses, you need to keep your eye on the +thing that the government hasn't, how these stories have +changed dramatically over time. +, you heard, had a lawyer back in 2008, and she +started out giving a very clearcut story about Jeffrey Epstein +and also about a woman named +who she also sued. +She had no trouble articulating her claims. She had a lawyer, +she filed a lawsuit, a lawsuit that didn't mention, in 290 +paragraphs, Ghislaine Maxwell one time. +The same is true with Jane. She told stories about +Epstein. Initially, she said she wasn't sure that Maxwell was +ever in the room. And don't be fooled about this difficulty in +disclosing the details of it. She had two male lawyers. She +had no difficulty disclosing it to them before she ever met +with the government. And when she walked in to talk to the +government, she told them she wasn't sure if Maxwell was ever +in the room. But her lawyer told her it would help her with +her case if she cooperated with this prosecution, and so she +did, and the lawyers kept asking, the FBI kept asking, are you +sure that maybe the person who had a foreign accent was perhaps +Ghislaine Maxwell? Are you sure maybe he groped your breasts +instead of massaging your upper chest? Are you sure there +wasn't sexual abuse in New Mexico? Perhaps you met him when +you were only 14? Perhaps you didn't just meet Epstein then, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2920 +maybe you met Ghislaine Maxwell there, too? +Every last one of the government's interviews with +these accusers - and there were dozens you heard - was not +recorded. There is no transcript. There is no record of the +exact questions that were asked or who asked what questions or +whether the lawyers +suggested maybe their clients had something +more to add or another person to add, and that was by design so +none of us have a transcript of what actually took place in +these interviews with the FBI. +So it was left to us, the defense, to ask the hard +questions of these witnesses when they took the stand. And +it's not easy to ask someone, well, that's not exactly what you +said before, is it, when you told your story the first time, +you didn't mention Ghislaine, and you only added that later. +Why would you go decades without mentioning Ghislaine Maxwell +and suddenly when you have your personal injury lawyer, you add +her to the mix. The government never asked them, wait a +second, you said you were traveling with Epstein and Maxwell +when you were 14 and 15 years old. We have these flight logs, +there's not a single record of you traveling with them when you +were 14 or 15 years old. How could that be? Where did you +live when this was going on? There is two different addresses +and maybe we, the FBI, should go check out the house you were +living in. You said you were poor, is that true? Or, where +are your boots that you said they bought you? The tough + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2921 +questions weren't asked by the government, so they had to be +asked by us, and what you learn is that the truth was +manipulated and changed over time. +You also heard the manipulation of other storylines, +and I'll go through them, that Ghislaine is at the center of +all this, she's the right-hand woman, she's Cruella Devil and +the lady wears Prada all wrapped into one. This is a +manipulation of the truth as old as Hollywood, your Honor, and +ladies and gentlemen, and don't be fooled by it. +With the money on the line, the accusers' goal of +holding someone accountable for Jeffrey Epstein, who was dead +at the forefront, and the tape recorders turned off, the +accusers' memories started to shift. +Earlier, +said it was +now she's +says it was Ghislaine Maxwell. Before Jane said she met only +Epstein on a park bench at Interlochen, now she saw Ghislaine +walk by and then, +, by the time she got to trial, it was +Ghislaine who stopped and talked to her. Before it was, I have +no specific recollection of Ghislaine being in the room when it +happened. That became, I remember it being once or twice or +all the time. Before it was, I can't remember anything about a +sexualized foot massage. Now +hears Jeffrey moaning with +pleasure. +Professor Loftus explained to you that's not how +memory works. You don't acquire a memory, retain it, retrieve + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2922 +it with a few details, and then decades later, acquire new +details, acquire new people who were there. +That's called +post-event suggestion, and that's what happened in this case. +Each of these women had talked to numerous individuals, had +watched media, shared their stories, talked to their lawyers, +and we're talking about events that supposedly happened 25 +years ago. In Jane's own words, she said memory is not linear, +or how would I know, I was only 15. +Memories have been manipulated in aid of the money. +The government made a lot of promises to you on +opening, promises that they broke. The story of Jane didn't +pan out the way they opened. They told you she started +spending time alone with Epstein at his house as a 14-year-old, +but it turned out she told them years ago that when she first +started going, she went with her mother or her mother and her +brothers, exactly as Juan Alessi told you. And as Juan Alessi +and Larry Visoski told you, she wasn't 14 or 15 when she +started coming, she was older, a fully grown mature young +woman. +Ghislaine didn't target Jane as a predator, as the +government promised you. Jane's original story in 2015 to the +press is that she was sitting on a park bench when Jeffrey +Epstein came up and talked to her. Ghislaine didn't invite +Jane over for tea, she wasn't even there when she and her +mother went. Ghislaine didn't arrange for Jane to come to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 89 of 257 2923 +Epstein's house. She told you it was other people in Epstein's +office. And Ghislaine didn't encourage Jane to travel with +Epstein. You heard not one single word out of Jane's mouth +that Ghislaine encouraged or enticed her to travel anywhere. +The government's biggest promise that they repeated to +you over +and over again with respect to Jane is that she was, +quote, +sometimes in the room when it happened. But when Jane +got on the stand, she admitted, finally, that what she told the +government several times is she wasn't sure and had no +recollection that Ghislaine was ever in the room when Epstein +abused her. She said it in February 2020, and what she said on +the stand in front of you is, as you sit here today, you're not +sure whether you were ever in the room alone with Ghislaine and +Epstein, correct, and she said, no. +The government also promised you an array of +witnesses, another promise they broke. They said these +witnesses would back up the accusers' claims. They told you, +for example, that there were relatives from the victims that +you would hear from, and that those relatives would tell you +about the victims spending time with the defendant and Epstein +and traveling with them and receiving phone calls from them all +when they were between the ages of 14 and 17. +Let's break that down. +What relatives came to tell you about Jane spending +time with the defendant and Epstein? What relative was that? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2924 +You didn't hear from one. Jane said she went to Epstein's +house hundreds of times, once every week or two, for three +years. +She lived with a mother and two brothers, and no one, +not one relative came and got on that stand and told you that +she spent time with Ghislaine and Epstein from the ages of 14 +to 17. No relative of +came to tell you that. No +relative of +came to tell you that. Who are these +relatives that are going to come and tell you about the victims +spending time with the defendant and Epstein? +mom +came. +mom came and told you she only spoke to Epstein. +She never met or talked to Ghislaine Maxwell. She has no idea. +The government also said that these relatives would +come tell you about all the phone calls these females got. Did +you see those phone calls? Did you hear from those relatives? +Did you see a phone record? I didn't. These are broken +promises from the government in their opening. Lack of +evidence. +The government also told you that they were going to +tell you, you are going to hear from a bevy of employees who +would back up the accusers' stories, and again, the government +failed to deliver the goods. Instead, what you did you get? +You got some pilots. They told you the pilots would tell you +about flying some of the victims. +We did hear from pilots. +We heard from Larry Visoski, +who said he never saw a woman on a plane who looked under 20 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2925 +unless +she was there with her parents. He met Jane once. +He +remembered her striking eyes. He said she was fully mature +when he met her. +And by the way, does it make any sense to you that if +Epstein is showing off Jane, he keeps her undercover when she's +14 and 15 to put her on a flight log as a female and all of a +sudden, when she's 16, takes her up to introduce her to the +pilot? Does that make any sense based on the evidence that you +heard? No. No pilot came and told you they saw +on a +plane or +or +• And no flight logs show any of those +three women either. +What about the multiple promised Palm Beach employees +who would tell you about this culture of silence? They bombed +on this promise, too. There was no culture of silence. You +just got the sound of silence, ladies and gentlemen. You heard +from one employee from the Palm Beach house. You know there +were many, there were chefs, there were landscapers, there were +gardeners, there were assistants, assistants to assistants, and +you got a two-time burglar, obviously with an ax to grind +because you know he wasn't getting along with the boss. He had +a deeply flawed memory, Juan Alessi did. He couldn't remember +whether dates happened in '94 or 2000. He couldn't remember +the number of times he robbed a house. He couldn't remember +the ages of girls, whether they were 20 or 14. Where are all +these Palm Beach employees who are going to tell you about a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2926 +culture of silence? I didn't see them. +They told you you'd hear from law enforcement +witnesses and they promised photographs of the search of the +Palm Beach house, and that search in 2019 of the New York +mansion that would show that Epstein lived in mansions filled +with photographs of naked women with a massage room in each one +of those houses. +You didn't see a single massage room with +naked women in it. I didn't. You saw a closet with photos of +friends and family in Palm Beach where the massage table was +stored, but there were no nude photos in the New York +residence, there were no massage rooms in New Mexico. +said she saw a massage room in Ghislaine Maxwell's house in +London, but +said she was there and there was no +massage room there. So law enforcement witnesses failed to +deliver on that promise. And you might have also noticed the +government didn't even call to the stand the two case agents in +charge of this investigation. Why would that be? +The government promised you evidence from these +searches, a massage table, +a schoolgirl outfit, and nude +photographs. You saw the 20-year-old massage table sitting up +here in the courtroom. What did that tell you? You didn't see +a schoolgirl outfit, you didn't see all these nude photographs. +You saw some artistic drawings around a rich man's house. +You saw FedEx records that showed Ghislaine Maxwell +didn't send any underage girl anything. The same FedEx records + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 93 of 257 2927 +that had packages going to +I from others showed Ghislaine +sending things to her family. That proves no involvement of +Ghislaine Maxwell in this enterprise. +And you saw no phone records. The government promised +you a playbook. It's an old gimmick. You get an expert on the +stand to tell you the stages of grooming and then you try to +build your evidence around what they said. But here, again, +the evidence didn't back up the government's promise. Their +headline read, Ghislaine targets daughters of single struggling +moms. What did you get instead? +introduced her +sister to Jeffrey Epstein and told her that he might help pay +for her college. Where was Ghislaine targeting +in +that storyline? +Epstein met Jane alone at Interlochen camp. At least +that's the way she told it for years. Where is Ghislaine +targeting her? +I was introduced to Epstein by +not Ghislaine Maxwell. And +was dating Ghislaine +Maxwell's classmate from Oxford, that's who introduced her to +him. +They promised you that these girls would tell you +about all of these discussions of sexual topics that normalized +the behavior. What did you get instead? +talked to +about making money going over to massage an older man. +Ghislaine wasn't even there. +Jane recalls one joke about grandfathering in old + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 94 of 257 2928 +boyfriends, and +didn't say any sexual topics were +involved? +Where's the normalizing going on there? And by the +way, this story about normalizing and making it seem casual, +Jane told you when she was first abused she was taken alone +into a pool room -- pool house where Epstein masturbated on +her. +Ghislaine wasn't even there and she's trying to make it +seem like she thought that was normal because she got one joke +about boyfriends? Use your common sense. +Then again, there's that promise that you would learn +that sometimes Ghislaine was in the room when it happened, +except Jane can't actually remember any one of those times or +what happened during those times. +Finally, the government promised you a motive, and the +motive that they came up with was that Ghislaine, a happy, +educated, beautiful woman in her 30s would just start and end +her career as a facilitator of sexual abuse for one man, +Jeffrey Epstein, because they said he was a means to support +her lifestyle and she needed to stay in a lifestyle to which +she had become accustomed. That's why they claim she became a +facilitator of sexual abuse, and where was the evidence they +delivered to you about that? +First, it was clear Epstein was a manipulator of +everyone around him. He's having Juan Alessi take down photos +of Ghislaine when he brings other women to the house. He's +dating women behind her back. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 95 of 257 2929 +But in terms of Ghislaine Maxwell's lifestyle, do you +know what it was before she met Jeffrey Epstein? No, because +the government didn't tell you about that. Do you know what it +was after she left Jeffrey Epstein? No, because the government +didn't tell you about that. Do you know her financial +situation? Do you know whether she had luxury in her life? +You saw photos of her that they showed you wearing tartan or +hunting with dogs in the U.K., it looks from the pictures. So +maybe it was Jeffrey that needed Ghislaine and her connections +and not the other way around. +And does that motive even make sense for a woman in +her 30s, that she needs this lifestyle, so she's just willing +to drag 14-year-olds in for sexual abuse? Use your common +sense. +And if that's the case, your Honor and ladies and +gentlemen of the jury, then why wouldn't Eva +be telling +you the same thing? She dated Jeffrey Epstein for a decade. +She saw nothing abnormal. She let her kids hang around with +Jeffrey Epstein. She went on to marry a billionaire. +Not one witness came in to tell you that Ghislaine +Maxwell needed Jeffrey Epstein's lifestyle so bad she was +willing to perpetrate on young females. +I'm going to take some time now, after talking about +the promises the government did not keep to you in their +opening, and go through each one of these women's stories and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2930 +then I want to talk about the lack of evidence that +corroborated each one of their stories. +Let's start with Jane. +The government started their opening with, this is the +story of Jane, and it was just that, quite a story, like an +actress who forgot her lines. She was supposed to place +Ghislaine Maxwell in the middle of Epstein's sexual abuse ring, +but she doesn't actually have a clear recollection of anything +that Ghislaine did. Time and time again, she couldn't remember +whether Maxwell ever touched her, kissed her, or even was in +the room when Epstein was +supposedly abusing her. +When actually asked on the stand to retrieve memories +of whether Ghislaine Maxwell was in the room, they had to ask +her that specific question, were there times when Ghislaine was +in the room when it happened. She said yes to the government's +questions, but her body language said hesitation, I don't +remember it, I can't remember the details. Indeed, when I +asked her on the stand, as you sit here today, isn't it true +that you don't remember being alone in the room with Epstein +and Ghislaine, and she said, no. +In February 2020, they asked her if there were times +it was just her, Epstein, and Ghislaine in the room, and she +said she was not sure, she doesn't recall that now. I asked +her when she was talking to the government whether she ever +told them that she, Ghislaine, and Jeffrey were alone in the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2931 +room together, she was not sure that ever happened and she +doesn't recall that now, no. But now, as she sits on the +stand, she can't recall whether she was ever alone in the room. +And as we talked about in her interrogatory response, +she was asked in 2020 to identify all other persons, other than +Epstein, who had ever committed or attempted to commit sexual +misconduct. This is notable not only because she doesn't +identify Ghislaine, but she also doesn't identify all these +other women who were supposedly in these orgies with her when +she was 14 over a three-year period. She'd given names to the +government, like Eva and | +and +• but she doesn't +tell them here in her sworn pleading. +You've seen this before, but I just want to bring up +Jane's actual birthdate as we talk through some of the timeline +so you can remember when she was 14, 15, or 16, and I want to +talk about the story of Jane, the one that's actually backed by +documents and facts. +It is true that her father died when she was 13, which +is a tragedy and is sad. She went on to tell you, though, that +she was so stricken by poverty that she had no lunch money at +times, and she was homeless. That's not the way it looked to +the outside world. She's applying to go to an arts camp with +her two brothers every summer for three years. That arts camp +costs $4,000 per person, per summer, so $12,000 per year, all +three of them go all three years. They don't even apply for + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2932 +financial aid. +She went to public school. She was obviously talented +and performing well, and that sentiment was echoed in the +supporting materials to her applications, which you will have +with you in the deliberation room. That guidance counselor, +you know, the one that she supposedly had confided in the year +earlier, the one that she said she told about how she was +struggling with talking to her mom, that's the guidance +counselor that wrote her a letter of recommendation saying she +came from a loving and supportive family. +She received glowing reviews from people who were well +positioned in the community, a board member from the Palm Beach +school system who was formerly on the board of the professional +children's school where she ultimately went. +You see from her applications that she had two +different addresses, one that she lived in a house from '94 to +'95, and a third one in her application from 1996 when she was +16. She told you she lived in a two-bedroom house and she +moved into a three-bedroom house, and the three-bedroom house +was in a gated community in Bear Lake Estates. That's someone +who just described for you that she was destitute and homeless. +She recognized the street she lived on, but not the house with +her house number. +In 1995, she filled out the application again. And by +the way, this is in October of '94, she filled out the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Page 99 of 257 2933 +application for the summer of '95. Again, she doesn't mention +that Epstein is providing her any support or paying for her to +go. By this point, in her budding career, she has been in +commercials, she has been in a Broadway production of +and the Technicolor Dreamcoat on the touring group that came to +Palm Beach. She's got more prestigious letters of +recommendation, still no application for financial aid, still +no mention of Epstein. +And after her second year at Interlochen, we see her +customs and border protection records which show how many times +when she was a teen that she was traveling internationally. +This person who said she didn't have lunch money, she's going +to Italy for an international trip she told you about, a vocal +competition with her school. And she's going on an +international trip to Europe with her family to see other +family back there. +And in 1996, she applies for Interlochen again. And +on that one, they actually go so far as to ask her, in this +yellow highlighted area, not only are you applying for +financial aid, which she says no, but does the student expect +to be the recipient of any funds from any individual +specifically for attendance at Interlochen Arts Camp, and she +says no, while she came in here and told you that Epstein was +paying for her. +The government touted, touted the trips in August to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 100 of 257 2934 +Interlochen on the flight logs. And you should take a look at +those, +because Epstein went every year, pretty much, including +with Itzhak Perlman, a famous musician himself. And not only +did Epstein and Maxwell go to Interlochen in '94, they also +went in '96. And actually, they both went in 1996. And so, +while they claim the flight log from '94 establishes that Jane +met Epstein and Maxwell in '94, in fact, it's just as possible +that she met them in '96. And if she met them in '96, it +certainly makes a lot more sense given the rest of the +evidence, which we'll talk about now. +Because the next thing that happened is there is a +flight in November of 1996 which the government showed you, and +I'll show you again in a minute, that has Jane going on a +flight from Palm Beach, when she's 16, to New York. That's the +very first time someone with Jane's first name flies on a +flight, when she's 16, while she came and told you all that she +was flying repeatedly when she was 14 and 15, but there is no +records, miraculously, of those flights. +In March of 1997, Jane and her mother, when she's 16, +file a lawsuit against her voice teacher, her principal, and +her guidance counselor. That lawsuit went on for two years. +Jane said she remembered her teacher pulling her hair one time, +but she had no idea that her mother and she had sued her own +principal, guidance counselor, and voice teacher. Is that +credible, that a 16-year-old doesn't know she's in litigation + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 101 of 257 2935 +with the three most important people to her at her school? Is +that credible? It is not credible, I submit to you. +And if Jane is unable to tell her mother about sexual +abuse, but she's able to tell her mother that she got her hair +pulled one time and she gets a lawsuit out of it, what makes +her think her mother is not going to get her back. This sounds +like a whole lot of hindsight changing the stories around. +And where is her mother? Why didn't her mother come +to testify about this? +• I kept that lawsuit from Jane, I +didn't want her to know we were in a lawsuit for two years. +And by the way, if you're getting wads of cash from +Jeffrey Epstein every time you go over there, why do you need +to file a lawsuit? +There's a flight log entry with Jane's first name in +May of '97 that goes from New Jersey to New Mexico. She's +almost 17 at that point. And then in August of '97, she turns +17. Before that, though, while she's still 16, she takes +another international trip. She doesn't remember that trip +either when I asked her. She turns 17 in the fall of '97, The +Lion +is released. She told you originally her first trip +to New York was when The Lion +was released. It turns out +she was 17 when that happened. She got her dates wrong in a +case that's about dates and about travel. She got her dates +wrong by three years. And then in January of '98, she goes to +Europe again with her family. You can see the cities that she + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 102 of 257 2936 +goes to when you look at these flight logs because they're on +there. This destitute, homeless, penniless Jane. +In May of '98, she says she's singing to Mike Wallace +for his birthday, his 80th birthday, and she estimated she was +15 or 16 years old, but it turns out he turned 80 when she was +17, almost 18 years old. So she got that date wrong by a few +years, as well. +Upon graduation, she left for LA, but before that, she +went to high school, and this is the only document from 1998 +when she's 18 that shows Mr. Epstein paying for anything for +her. High school, not Interlochen. She attends the +professional school and when she goes off to LA, she writes +back to Epstein, as you see on these photos, Jeffrey, thanks +for rocking my world, you're the best, love, Jane. She said +her mom made her send that photo, but again, you didn't hear +from her mom. +She continues to fly on Epstein's planes when she's 19 +and 20 and 21. I asked her about those flights that were paid +for by the Shoppers Travel witness you saw, and she didn't +remember that she kept taking flights on his dime when she was +20 and 21. +And then you will see and hear from on the flight +logs, in a moment, that she said she was on numerous flights +with famous people. You may recall she said she flew with +Prince Andrew, for example, and Mark Epstein, and Epstein's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2937 +mom, that there is not a single flight log entry with her +flying with those famous people. And we'll get back to her +memory being tainted by those flight logs in a second. +Let's talk about her memory. She demonstrated a very +poor and inconsistent memory about things that if were true, +she would have +remembered. Her memory is the underpinning of +this entire case, because the government has to prove to you +beyond a reasonable doubt that she was traveling, enticed to +travel, encouraged to travel, transported while she was under +the age of 17 in order to find Ghislaine Maxwell guilty of +counts One through Four. +And the government overlooks each one of these +significant memory gaps. They try to tell you, and I expect on +rebuttal Ms. +will tell you, she was too scared to +disclose the facts about what happened to her. Of, you know, +we overlooked that she's telling her male lawyers all these +facts for purposes of her civil suit. They brought up they had +to reduce the number of people in the room so she would feel +comfortable enough talking to them about it. You could judge +for yourself, her lack of discomfort and talking about it on +the stand. +But what she said in December of 2019 and in February +of 2020 was, I don't feel comfortable talking about this right +now. She said, I have no specific recollection of that or I +don't remember. If she doesn't remember something, the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2938 +government didn't confront her about it. The one time they +did, they brought up the lack of memory about The Lion | +date, and that certainly backfired. And so what they did was +say, okay, we'll just assume that wasn't your first trip to New +York, because your dates don't match, and then they stop +looking for other evidence that would corroborate her claims, +like, where are you on these flight logs. +Her lapses of memory pervade this case, and as +Dr. Loftus told you, very traumatic things one is unlikely to +forget, the where it happened, the who was there, the when it +happened, the how it happened, those would be core parts of her +story. +So, for example, a core part of her story would be +when and where was the first time you were sexually abused. +That's not something you forget. +She told you that it was when +she was in a pool house in Florida, and she told you about +that. But remarkably, back in December of 2019, that's not +what she told the government. She said the first time she +experienced abuse was when she was about 14 years old in New +York. She met Epstein to take headshots and that is when he +masturbated. Those are two totally different stories, in a +pool house in Florida or in New York when you go to get your +photos taken. When I asked her about it, she said the FBI got +it wrong, I didn't write any of this, I've never read this +document before. What is beyond dispute, because the FBI agent + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2939 +came in and told you that that is what she told them back in +2019, and that's a core detail you're not likely to forget if +it's true. +Let's take another example, whether there was ever +abuse in New Mexico. Jane told you, told the government +repeatedly, she had no specific recollection of abuse in New +Mexico. +So what did the government do? They kept asking her +over and over again - remember, they're trying to prosecute a +case about transportation and enticement to cross state lines - +are you sure there was no evidence? There was no abuse in New +Mexico? I have no memory of abuse in New Mexico. Are you +sure? Maybe there was some abuse in New Mexico? And finally, +after they asked her four times, she suddenly got back a memory +of abuse in New Mexico that she testified to here on the stand, +that she said someone came to get her, she doesn't know who, +and that her heart sank when she was taken to Epstein's room +for the abuse. That's not how memory works. That's +suggestion. +And clearly, for purposes of this case, the most +important thing is what did Ghislaine know about what was going +on, if anything, between Jane and Jeffrey Epstein. Was she +ever in the room as the government told you over and over? And +when I asked her, she does not recall if she was ever alone in +the room with Ghislaine and Jeffrey for any of the abuse. +And not only does she not remember being in the room + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2940 +specifically, she's not sure -- you heard the government say +their stories were all remarkably similar because they each had +their breasts touched. In the trial testimony, she told you +she was not sure that Maxwell ever touched her during these +encounters. She does not have a recollection, she said in +December of 2019, if Ghislaine touched her during these +encounters. At trial, she said she doesn't remember that, but +it's written here and the government notes, she's not sure +Maxwell ever kissed her. +She also, the government told you in their closing, +that Ghislaine was giving her directions about how to massage +Jeffrey Epstein, but that's not what she said on the stand. +She said she doesn't recall Ghislaine ever giving her a talk +about how to massage Jeffrey. +And what other things does she say she doesn't know +that Ghislaine ever saw? Never saw this oral sex she said she +had to perform in the orgy, she said she never saw hand jobs, +she said he never used sex toys on her, she said Ghislaine +never saw her have intercourse, and, in fact, she has no memory +of Ghislaine being present when Epstein engaged in sexual +contact with her. She told me, I don't remember. +If she doesn't remember ever being alone in the room +with him, then she also doesn't remember the story that she +told you on direct about the first time with Ghislaine. And +that's also what she confirmed to me on the stand, she had no + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2941 +specific memory of the first time with Ghislaine until she got +up on the stand and told you one. +So the government kept asking her, was Ghislaine ever +in the room when it happened. I asked her, how many times, and +she said I don't know -- I'm sorry. The government asked her +how many times, and she said I don't know. Was it once, no. +Was it twice, no. How many times, I don't know, but more than +twice. That's the evidence they want you to convict Ghislaine +Maxwell on? I don't know? I don't remember? +She also told you the thing that happened more +frequently was being in these group sexualized massages, and +because that involves other witnesses, you have a right to +evidence about this. She said that this group sex massages - +she called them orgies - happened frequently, and that Epstein +would just summon people up to a room and they would all follow +him up there. And she said she was a 14-year-old girl when +these orgies were going on in his house, and she wasn't sure +how often Ghislaine was ever present for these orgies, but she +gave other names. +Apparently none of these other women thought it was +unusual that a 14-year-old was in an orgy with them and they +didn't call the police or report it, but naturally, being the +FBI when they got names of these other women, they ran right +out to try to corroborate those stories and be like, hey, +sounds like maybe you were in a group orgy with a 14-year-old + + + +2942 +back in the '90s, can we talk about that. No. No, they didn't +do that. +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Jane told about a woman named +She gave a +description. She was blond and pretty. She said +married a racecar driver and +joined in these sexual +massages. +And then she told the government about a woman named +Eva, correct, she did not use a last name, but Eva. And this +wasn't just some disconnected Eva that showed up in an address +book from some unknown time in the future, jane said that Eva +joined in with +She joined in with +• Those were +your words, yes, Eva joined in with +So where would Jane have gotten these names, +and Eva, if the massage didn't really happen and she was trying +to come up with some names? Well, let's look. Sure enough, on +her very first flight log entry that has her name on it from +November of 1996, she's on a flight with +and Eva. What +are the odds that the very first flight she takes is with two +women who she claims are on a group sexualized massage? +Let's look at Eva. Eva is flying with her child and +her nanny. She told you on the stand that she just had a baby. +Do you think that Dr. Eva +that you just saw on the stand +with a child and a nanny who's on a flight with +she +joined in with +was in a group sexualized massage. Eva +told you she knows +was a professional masseuse. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | + +2943 +They know each other. This isn't some Eva that the +government's now gone back and scrambled and found a name in an +address book. +The next group of people she talks about is +She +remembers +was British and she was in the group sexualized +massages, and there was a woman named +And now the +government wants to suggest that +is some random +and we don't know who +is, and +could +be any old +and look at this address book with +old +name. There is +everywhere. +But Jane told you from the stand it wasn't just any +I it's the M +that she hung out with her and +So it's +friend, +and she said it was +friend, +1, that she hung out with. And you heard +on the stand say that's the +I'm the +that hung out with +. I don't know any other +that +• hung out with. And no, we weren't involved in any group +sexualized massages. I'm a housewife. +What you see here is a pattern, you see a pattern of +Jane picking names out of people she knew she met in Epstein's +world at some point in time. The receptionist, the first +person you see when you come into his office, and she came in +there with her mom. That's the one now she remembers she was +in a group sexualized massage with or a person she saw in the +flight log with another person in a flight log. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2944 +Did the government show Jane photos of any of these +women that they got in their address book now and say, hey, is +this the one you were in a group sexualized massage with, they +haven't done it, they haven't done it since they got those +names two years ago. +And just because I point out a few big problems with +the big parts of the story, don't be confused, Jane's story is +wrong, wrong, wrong on many, many points. She gave you a +description of the Palm Beach house. She said this massage +room that she went to hundreds of times, +hundreds of times was +in the massage room that was off the master bathroom, and that +the house itself had creepy looking animals. +We all sat +through the floor plan discussion that went on and on, and you +know what, there's not a massage room off the master bathroom. +The master bathroom was the +massage room. So if she had been +there hundreds of times, do you think she would have gotten +that wrong? +She said it had a light beachy feel. It was light +because it was off the master bathroom and it had like a beachy +feel. What was in the room, I don't think I saw anything past +the massage table. You recall a massage room that was attached +to the bathroom, correct, that's my memory, yes. We saw the +room attached to the bathroom, it's a closet. We saw the floor +plan. There is no massage room off the master bathroom. And +we saw the bathroom, which is hardly a light beachy feel with + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 | + +2945 +its white marble. +She was asked about the New York house. +Now, by the way, on the floor plans, as Juan Alessi +told you - and you'll have these exhibits back with you in the +deliberation room - this whole entire room has floor plans that +were major reconstruction being planned in 1994 with walls +being torn down. +She never told you about any reconstruction +or being there during reconstruction or Epstein moving out, as +Larry Visoski told you he moved out for six to eight months for +the renovation, she didn't remember any of that. +What about the New York house? She did talk about the +room being dark, an old building and lots of stones, but she +also told you artwork, paintings of orgies, creepy animal head +things. And you know the government didn't show her any +photographs to try to match up her memory with any of those +photos. +And the government staff members from the New York +house to come in and say, yeah, that was a little weird when a +14-year-old was staying here alone at our house. Not one. All +this staff that you know is there, their chef, the doorman, the +assistants to assistants. +You did hear, however, from +in Epstein's office and she kept the calendar for the +who worked +apartments that Epstein had and he lent out to guests. And +told you she specifically booked Jane and her mother + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 112 of 257 2946 +and her brothers to stay in those apartments. Nothing about +Jane staying in Epstein's house. +And the same is true with the Santa Fe property. She +told you she stayed in this big grand house, a big, big +structure, +big house. +told you she was there at roughly +the same time and there was no big ranch. It was a small +residence. Larry Visoski told you that big ranch wasn't built +until the late '90s, and guess what, there is a flight 1og +entry showing that Jane went there when she was 21 when the big +house was there. That's when Jane went to Santa Fe. She +didn't remember her other trips, her trips abroad. +We know her memory was contaminated post-event because +she was talking to her family members, her exboyfriend, Matt. +She was reading the news, she hired a lawyer to cancel all the +news about her, not to report this claim. +She was reading the +news and now she's incorporating all of those facts into her +head and trying to make some kind of sense out of it. +She has deliberately, however, attempted to move the +timeline back to make herself younger when she was with +Epstein. +She did that, first, by telling the government that +she was in the same house for three years when she met Epstein +until the time she moved to New York. She was in the same +house. She lived in the same house. It was in a gated +community in Bear Lake Estates, the same house, a three-bedroom + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2947 +house, but that house doesn't show that she was homeless, so +now she doesn't remember saying that, what she said to the FBI. +She said it might be a typo. Does that sound like something +the FBI can write a typo about, I lived in the same house in +Bear Lake Estates in a gated community? That's a really big +typo. And the Interlochen records show she didn't move there +until she was 16, and the flight records show that she could +have met Epstein in 1996. +She got the date wrong for Mike Wallace's birthday. +She told you she met Donald Trump when she was driven +there in a green car by Jeffrey Epstein before any of the abuse +happened, and you heard from Larry Visoski that Mr. Epstein +didn't get that car until the later '90s. +She's tried to explain why her mom's not here +essentially by telling you her mom was mean and oppressive, but +that doesn't square with what happened with her lawsuit and the +glowing recommendation of her guidance counselor who talked +about how great her family was and loving and supportive. And +you'll look at her grades. Her grades stayed the same all the +way through before she met Epstein until after she met Epstein. +She didn't miss a beat when she says all this is going on. +But most importantly, she's trying to insert Ghislaine +into this story well after the fact, and she's doing that +because she got this personal injury lawyer, Mr. Glassman, and +she promised -- he promised her that it would help her case if + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2948 +she participated with the government, so she did and she got +$5 million. +No one corroborates her story. There were people +everywhere - brothers, mother, friends from high school. And +she's just secretly flying all over the country, no one knows, +no one remembers her going to a commercial airport, there is no +record of her going on any commercial flights. That's just a +coverup for the fact that she's not on flight records until +she's older. None of her flight memories check out. The +people she said she flew with were not on those planes. +Let's turn to +is a psychologist who primarily works as +a therapist. Before +testified, the Court gave you this +instruction, I instruct you that the alleged physical contact +says occurred with Mr. Epstein and Ms. Maxwell in New +Mexico was not, quote, illegal sexual activity, end quote, as +the government has charged in the indictment. So what she told +you is not illegal conduct as charged in the indictment, +despite the fact that the government wants you to think that +this shows a pattern of targeting of young women. +What you heard is that +sister, +is the +one that introduced her to Epstein, that Epstein purchased a +ticket for +to come to New York as a gift to her sister +who was working with Epstein, and while she was in New York, +she spent 99 percent of her time with her sister doing + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2949 +sisterly-type things. They went to see a play, they went to +the Blue +Man Group, they went to the Met, they went to a New +Year's party, they went to thrift stores, and she got a dress. +There were two instances she met Epstein while she was +in New York, and during those events, she and her sister sat +had in his office across a desk and discussed her college +applications. +She told you she thought Epstein's home was +under renovation at the time, and she told you that there was +no sexual activity that occurred whatsoever in that home. She +told you Ghislaine Maxwell was not in the home, never came to +the home, no physical contact happened in the home, she wasn't +present, she wasn't there, and she didn't see anything that had +to do with Ghislaine Maxwell while she was in New York. So how +did Ghislaine target her somehow to come into New York to see +her sister? Where is Ghislaine Maxwell's role in any of that? +The second contact she had was in the movie theater +when they went to see a movie, she said she remembers was +called Five Monkeys. There isn't a movie called Five Monkeys, +there is a movie called 12 Monkeys, but that's what she +remembers. And while she was in Five Monkeys, Epstein caressed +her hand and held her hand, and as creepy as this is, what she +told the Victims Compensation Fund was that him holding her +hand was sexual abuse. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 116 of 257 2950 +MS. MENNINGER: She was awarded one and a half million +dollars for that. +But there's no dispute Ghislaine Maxwell had nothing +to do with getting her to New York, and nothing to do with +touching her in a movie theater. And there's no dispute that +the reason she went to New York was to see her sister. So the +purpose of her trip was to see her sister. +Ghislaine wasn't at the movies. +She didn't meet +Ghislaine during the trip. She didn't fly her to the trip, she +didn't arrange for the travel, she didn't call her mother +before she traveled, she didn't encourage her to travel to New +York. She never even, as you know and I know, heard of +Ghislaine Maxwell when she went on that trip to New York. +Ghislaine was simply nowhere around. +And so Ghislaine couldn't have been making her feel +more comfortable or normalizing sexual talk. She wasn't even +there, as +diaries confirm. Ghislaine is never +mentioned in those diaries. Even though we don't have all of +the diaries, she's clear that there is no mention in any entry +of any journal about Ghislaine Maxwell. And that's true from +the journal you saw some photos of, and that's true for the +ones she didn't show you. +She admitted that reviewing those journals helps her +remember things that happened in hindsight. She said her +memories are colored by hindsight, and that what happened to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 117 of 257 2951 +her later affects how she perceives what happened to her in New +York, like the sexualized hand-holding. +She doesn't know how the trip to New Mexico was +planned, but she's clear that Ghislaine is not the one who +called her. And her mother is clear that Ghislaine never +called her. So what Epstein did, Epstein, who's hiding things +from women around him, including Ghislaine, is the one that +called +mom. +You know that Ghislaine had no role in any of her +travel because she told you that. And she also told you her +original purpose or the original thought behind this trip to +New Mexico was that her sister was going to be there. That's +what she told the government in 2006. She's conveniently +forgotten that in the last 15 years. But what she told them in +2006 is her sister was supposed to accompany her on that trip. +She said she doesn't know whether Ghislaine saw +Epstein trying to hold her hand in the movie theater; she just +thought it was more blatant. She talked about the foot +massages. But she told the government in May of 2020, she +didn't remember those foot massages being sexualized. +She testified that Ghislaine gave her a massage; she +wasn't sure if she was topless or had her underwear on, excuse +me. But what she told you from the stand is that Ghislaine +massaged her chest and upper breast; and she confirmed for you +that that is where your pectoral muscles are. That's where she + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 118 of 257 2952 +got the massage. But then she turned around a month later and +told the victims' compensation fund that that was groping her +breast. +Ghislaine never touched her nipples or never touched +around her nipple area. But on her victims' compensation fund, +she told them that was groping her breast, and that's exactly +the language that Ms. +adopted here today. +You heard about an incident where she says that +Epstein entered her room and Ghislaine was not in that room +when it happened. Epstein was not in the room when she got the +massage. And she told the compensation fund that she was +sexually abused in the movie theater. She told them her +breasts were groped. She told them that she had Mr. Epstein's +genitals pressed against her; and she, for that story, got one +and a half million dollars. +But what is the evidence about what Ghislaine Maxwell +knew about this trip? Originally, +was supposed to go on +the trip. And so Ghislaine had no role in planning the trip, +aiding, abetting the trip, conspiring to make the trip happen. +We only know that Epstein called +mom and talked to her +about Ghislaine being there. +Imagine for a minute that you're Ghislaine Maxwell, +and you fly out to Santa Fe because you're going to meet with +some architects and plan the building of a new house. And all +of a sudden, some high school student shows up, was supposed to +come with her sister for some kind of trip, and then the sister + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2953 +is not there, and you have no idea what's going on. Imagine +that. +What are you going to do? Are you going to take them on +a tour of the ranch, spend a significant amount of time taking +them horseback riding, helping her get cowboy boots so she can +go horseback riding, talk to her about school? This isn't +Ghislaine Maxwell targeting someone. This is +showing up +at the ranch without Ghislaine's knowledge. +told you about reconstructing her memory of when +this trip occurred. She said it was in April of '96, and she +said she thinks that because she thinks she saw Primal Fear, +which came out in 1996. She researched that on the internet. +And then she talked to her friends about how prom was later +that year. And it happened before she went to prom, so she's +pretty sure it happened in April of '96. I mean, she's a +doctor. She knows how to go back and research things and put +it together. And she reconstructed that memory. +But when you look at the flight logs, she told you +also it was a weekend trip, mind you, and her mother confirmed +it was a weekend trip. But when you 1ook in April of 1996, +there is no weekend in April of 1996 that Ghislaine Maxwell and +Jeffrey Epstein are in New Mexico. It doesn't fit. There is a +March trip where just Jeffrey is in -- goes to Santa Fe for +like a day, and then there's a trip in the middle of May where +they both go to Santa Fe, but that's in the middle of the week. +There's no weekend trips in April or May of 1996. Okay. So it + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2954 +doesn't work. She tried her best to reconstruct the time. +She's wrong. That's just the way it is. +So if we had her +journals, we might know, but we don't. +So then if you look a year later, in April of 1997, +there is a trip where Jeffrey and Ghislaine go about that time +of year together to New Mexico in March or April of 1997. +is 17, almost 18 years old. And there is a flight +1og that shows them going at that time. So maybe she just got +it wrong by a year, meaning she's 17 when she went there. +She also says that trip to New Mexico happened right +before she went to Thailand. So naturally, one would look at +her border patrol records and figure out when did she go to +Thailand, because that would help us figure out when she +actually went. So when you look at those records, it shows her +very first trip out of the country and coming back into the +country was in July of '97, not in '96, when she was 18. +And you see she's coming back through a city called +Düsseldorf in Germany, which is not Thailand, I understand +that. But then you remember I asked her mom, Weren't you in +Germany when she was in Thailand? And she said, Yes, I was. +So +flies back from Thailand to Germany, where her mother +is, and then they fly back together when she's a senior, not a +junior, in 1997, and not 1996. That's what the documents show. +And don't let the government tell you these records -- +I mean, the government is going to tell you that their own + + +1 +2 +3 +4 +5 +Page 121 of 257 2955 +Customs and Border Patrol records are not accurate. +Okay. Well, that's kind of silly. +But if you look at Jane's records that come in the +same exhibit number, you'll see that they go back to January of +'96. So the records go back that far. There just isn't a +record of +going to Thailand in 1996. And so the +government didn't bring you the Customs and Border Patrol +records. +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +And finally, I want to consider one other piece about +story. She's saying that she wore -- she was bought +these boots by the people who sexually abused her; Epstein +bought her these boots. And she said that she kept them in the +closet, and then the government didn't ask for them in 2006, +excuse me. And you'll have the boots with you back in the jury +Ioom, and you can see for yourselves how worn those boots are. +And so when the government finally got those boots in +June of 2021, even though they'd met with her repeatedly, and +she never told them anything about wearing these boots, she +just said they bought her these boots, and then when they +finally got them and looked at them and saw that she's been +wearing boots from the people that she says sexually abused +her, she came up with a new story, and that story was that she +resided to reclaim the boots. And that's the story she told +for the first time right before trial and what she told you on +the stand. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 122 of 257 2956 +Again, the government promised you relatives who were +going to come corroborate these stories. Where was +sister? +Where were the people at the ranch? Where +was the chef? Where's the rest of her diaries? +What you got was a photograph of the front and back of +a diary, and you got photographs of several of the pages from +the diary. What you didn't get was the rest of the diary. You +don't even get to take the diary back into the room with you. +And she told you that she had diaries from Thailand. Why +didn't she share those diaries? Why didn't she give this diary +to the government? +Also, +is the one who explained a lot of the +intersection of these lawyers and the witnesses. She told you +she first met with the Boies Schiller firm when they were +representing +and she was going to be a +witness. And then she hired them. And she told you that Jane, +who told you she had talked to +lawyers, Brad +and Brad +was here in the courtroom when +was +testifying, Jane talked to him as well. And then Jack Scarola, +who represents +and brought her to the government, he +also talked to the same other witnesses, and they all talked to +their family members and saw the media. That's the +contamination of memory that we were talking about. +Finally, with respect to +story and the money +piece, she told the FBI that all of this was not sexualized + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 123 of 257 2957 +when she talked to them in May of 2006, and then again in May +of 2020. But then the Epstein Victims' Compensation Fund +opened, her lawyers had helped set it up on June 25th of 2020, +and the very next day she was first in line with her +application to get the money in saying that it all was +sexualized. +Let's talk about +I'm not really sure why +testified here because, +once again, the judge instructed you that any sexual conduct +she says occurred was not illegal activity. And you may not +convict Ms. Maxwell on the basis of +testimony regarding +any sexual contact that she says she had with Mr. Epstein. +Again, the government told you that Ghislaine Maxwell +targeted a woman who had a single parent, and her mother was +sick, I think they said. That's not what she told you. She +told you she had a wealthy stepfather who lived -- had his own +plane. She lived in the South of France before moving to +Ghislaine's -- close to Ghislaine's home in the Tony section of +London known as Belgravia. She admitted to being fiercely +ambitious, spending 90 percent of her time thinking about her +next move. And when she was 17 and in Paris, she met +Ghislaine, who was with an Oxford classmate of hers, of +Ghislaine's. She was dating him. So she was dating a man that +was Ghislaine's age at the time that Ghislaine met her. +And then she said, basically, she wanted to be + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2958 +Ghislaine. +told you, I was quite excited to be friends +with her. +And she was friends with a man I was dating. And +she seemed very exciting; and she seemed everything that I +wanted to be. +So +traded up from the one prominent gentleman to +the next, Jeffrey Epstein. +told you about her life in +this time period where she was abusing cocaine and sleeping +pills and alcohol for more than ten years. She was an +international model, she was in a movie with a prominent +English actor. She had a relationship with Epstein that +spanned decades. She was a billboard model, a lingerie model, +she was in tabloid magazines. She helped set up a man in a +tabloid magazine for asking him to get drugs in a conversation +that was recorded. That's the kind of information that +shared with you about her life. +And whatever she did Epstein was above the age of +consent. She maintained contact with Epstein into her +thirties. He was in prison, and she was writing and sending +him emails offering to send him pictures while he was in +prison, while she was in her thirties. Use your common sense. +Is that someone who was abused by Epstein? +She signed those emails, and these are Exhibits K-8 +and K-10. Best love always, +When confronted with a 2011 email she sent to Epstein +asking if she could stay at his place, she told you that she + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2959 +felt compelled to contact him. She emailed Epstein for +decades, and there's not one single proof of her ever +contacting or being in touch with Ghislaine. +At the time she met with the government, her lawyer +provided a U visa form and asked if they could help with it. +A +U visa is for people who are exceptional. And she said that +she is exceptional. She's a music therapist. And she was +starting a foundation, which opened right before Epstein +died - after Epstein died, excuse me, and closed right after +she got her $3.25 million from the fund. +She claims she was using a fake name during this trial +because of her child. But she had used her real name in +repeated media appearances and publicly in court about Epstein +after her -- after his death. +What Professor Loftus tells us about post-event +information and suggestiveness would suggest that +made her +own choices to engage with Epstein when she was over the age of +consent. And she made her own choice to blame Ghislaine. And +her memory is affected by a decade or more of substance abuse. +What I really want to emphasize about +though is +that she told you she met Ghislaine Maxwell at Ghislaine +Maxwell's home in London, and the address is 44 Kinnerton +Street. And she said that she met her in 1994. In order to be +awarded money from the victims' comp fund, you had to be 17 or +younger. So it was important to her story that she say that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 126 of 257 2960 +she met Ghislaine in 1994, when she was younger than 17. And +SO +was firm that that's the address she went to, the house +with the red door. It's actually Government Exhibit 702. So +when you see that house, you'll know that's the one that i +was talking about. It's across from something called The Nags +Head Pub. +But the problem is Ghislaine Maxwell didn't own that +home until 1997, not 1994. She owned that home when +was +20 years old, not 16 years old, not 17 years old. You will see +those exhibits, A-5 -- and A-5 refers you to MG-12 and MG-1. +And what these show is that Ghislaine Maxwell owned a home, +another home, at 69 Stanhope Mews; and that she sold that home, +and then she bought the next home at 44 Kinnerton Street. And +the purchase of that home, purchased from another family, +occurred in March of 1997, when +was 20 years old. So the +entire story about going to that home and there being a massage +room in that roam at Kinnerton Street is just wrong. If it +happened at all, it happened three years after +happened. +said it +Now, the government showed you an offhand remark made +in another property dispute from 2019 that Ghislaine Maxwel1 +gave under oath when it was talking about a totally different +property. And they asked her in 2019, When did you start +living at Kinnerton Street? And she said, 92, '93. She didn't +have any documents in front of her. And she's talking about a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 127 of 257 2961 +totally different property. The property records show when she +owned the home, and they showed that +story is wrong, +something the government didn't want you to see. I still don't +know what +story brings to this prosecution. +Let's talk about +talked to two FBI agents in 2007, Agents +Kuyrkendall and Richards. And you saw Special Agent Richards, +he testified here last week. And he told you that he's trained +at Quantico on how to interview people; and when he talks to +people, he's taking down notes carefully; and he's writing down +what they say; and he's not limiting them in what they can talk +about; and that all these agents review their notes for +accuracy, and they check their other agents' notes, and they +are all making sure that what they are writing down is accurate +because, who knows, 14 years later, you might have to get on a +witness stand and talk about what someone told you in an +interview, right. So you've got to be pretty careful when you +work for the FBI and you're taking notes. +So he said he met with +happened. And +and asked her what +told him a whole long list of things +that happened. +And she told Special Agent Richards that she was +recruited by +told her how +much money she would make. +brought her +inside. She saw a lady inside who had an unknown accent. She + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 128 of 257 2962 +told you that she knows what a British accent was. And she +didn't identify this person as Ghislaine back in 2007. And it +was +who instructed her how to massage Epstein. And +and Epstein had sex while +watched. And Epstein +paid +And +and +left. And +looked up Epstein's number in a phone book. And she called +Epstein. And either Epstein or +would call her, she +said. +And on the second visit, the chef asked her if she was +hungry. And she was greeted by someone named +• And +is the one that placed towels on the massage table. And +called to tell her about concert tickets. And Epstein sent her +gifts. And +took pictures of her. +That's her story from 2007. Not one mention of +Ghislaine or Maxwell or Maxwell calling her or Maxwell trying +to touch her breasts. I mean, that would be something you +would tell the FBI who was there investigating you -- +investigating a sex assault inquiry, right? She didn't mention +anything about Maxwell or Maxwell touching her breast. +And one year later, she files not one, but two civil +lawsuits. And exactly like her statement to Mr. -- Special +Agent Richards, she has lawyers, they draft up these long +lawsuits. And not one thing in those civil lawsuits, that go +on for 70 pages and 209 paragraphs, is there one mention of +Maxwell or Ghislaine. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2963 +Twelve years ago she was asked under oath to answer +questions about who was involved in the trafficking of her or +the sexual abuse of her. And she had lawyers who helped her +answer those questions. +And again, she didn't say anything +about Ghislaine Maxwell. And then she even updated her answers +again. +So she's looking at her answers to make sure that they +are accurate. And once again, she does not mention anything +about Maxwell. +She had a third opportunity to talk about who was +involved in this operation at the Epstein home. She gave a +deposition. And the deposition went on for hours. And she was +asked in that deposition, Are all of the things in your civil +complaint accurate? Do they include everything? Are they +complete? Are they true? +And she said, Yes, they are. +Not one mention of Ghislaine Maxwell in hours of +deposition testimony back in 2009. She may have mentioned that +Maxwell answered the phone once. But guess what? The +government grabbed all of those message pads which they talked +to you about, and there are message pads and there are message +pads, and you will get all these message pads back in the jury +deliberation room. And you will see there's not one single +message for Ghislaine Maxwell having to do with +She's +calling for Epstein. +And look at the name on GX-2T in the upper right-hand + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 130 of 257 2964 +corner. It's a French woman taking a message for Mr. Epstein +about +a French woman with an accent. We're talking +about the 2000s now. So one might imagine that there are phone +records. There might be phone records about all of these phone +calls, right? But there's not. There's not a single phone +record showing any calls from Ghislaine Maxwell's cell phone to +or from +to Ghislaine Maxwell. +And then +doesn't talk to anyone between -- in +the government between 2007 and 2020, okay. She gets a +settlement with Epstein, several hundred thousand dollars, that +money gets used up, and then she doesn't talk to anyone about +Maxwell. +And so then in 2019, her lawyer, civil lawyer, Jack +Scarola, calls up the government and says, Hey, let me put you +in touch with my client, because he's no dummy. And he knows +Epstein is dead; and he knows Epstein left behind a pile of +cash. +So she responds through her lawyer in July 2020, right +after the victims' compensation fund was opened. And that's +when her lawyer puts her in touch with the government, because +again, it helps you with your claim if you're cooperating in a +prosecution. +And in those 12 years when she wasn't saying anything +before about Ghislaine Maxwell, all through 2007, eight, and +nine, she didn't say anything about Ghislaine being there, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 131 of 257 2965 +introducing her, taking her upstairs, anything like that. She +gave +extensive testimony about it. And it happened shortly in +time after the events. +She didn't say anything about Ghislaine +Maxwell. She had a therapist, Susan Pope, she met with for +years. +She didn't tell her therapist about Ghislaine Maxwell. +She didn't tell the other doctor that she met with. +And soon after she files these lawsuits, she starts +mentioning Ghislaine. And that's the story that you heard from +the stand. For the first time in 17 years, all of a sudden, +her too; Ghislaine Maxwell's involved too. And she gets +several million dollars. +Is that the kind of evidence you would rely on in a +matter of importance to yourself? +She told you that she saw a photograph of Ghislaine +pregnant. There's no evidence that Ghislaine was ever +pregnant. No one so Ghislaine Maxwell pregnant, and there's no +photograph of Ghislaine Maxwell being pregnant. But that's +what +told you, that she saw a photograph of her +pregnant. +Money. The first time that Maxwell is accused of +anything by +is during this victims' compensation fund, +where she ultimately got $2.8 million. The government argues +that +has no financial incentive to stick with her story +here, but that's not supported by the facts. The new story is +the one she told the fund. And the fund tells you, if you + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2966 +don't tell the truth, they can prosecute you. So it's much +easier to just stick with her story here to keep the cash she's +already gotten. +17 years later, now claims that Ghislaine +Maxwell called her. There's not one phone record showing you +that. j +She claims that Ghislaine sent her things. There's not +one FedEx record telling you that. The message pads don't show +any contact between Ghislaine and Epstein. She wasn't taking +messages for +Evelyn was. And they show that +was calling and her calls were not being returned. There would +be evidence if her story were true. +Let's talk about Shawn, her boyfriend, with his felony +convictions. He says that their visits happened in 2002 and +2003, not 2001 or 2004. He testified in response to questions +by the government that +never talked about Ghislaine. +They never talked about Maxwell. +tried to minimize her drug abuse. But Shawn +told you that they were abusing -- let me find it, sorry -- +were abusing marijuana, cocaine, ecstasy and other pills during +that time period. According to Shawn, he and +shared a +phone, and he identified three callers. +It would either be Epstein or +calling; +correct? +Correct. Yes. +He knew it was +because +told him she was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2967 +calling on behalf of Epstein, right? And he claimed to +remember some of what he thought was a French accent. +And in that meeting, he identified +and then +another European with an accent that wasn't British that you +couldn't identify; correct? +Correct. +He met with the government five times. And in a fifth +meeting, he said he couldn't identify the accent. The truth of +the matter is Shawn never talked to Ghislaine Maxwell and never +heard her voice. +I want to turn to the other witnesses that came and +testified here. +The government talked to you about Dr. Rocchio, the +ultimate victim apologist who tried to explain away why these +accusers continued to have contact, including traveling with +Epstein or offering to send photos to him in jail 30 years +later. And to Dr. Rocchio, that's just proof that they are +victims. She's not trained as a treating therapist to question +accusers' accounts. She's not a lawyer or a judge or a juror. +She's a treating therapist. +The government has spent a lot of time and money on +Dr. Rocchio talking to you about grooming. There was no +evidence that Ghislaine Maxwell groomed anyone. +was +recruited by someone else. +time in her life. +met Ghislaine Maxwell one +I was a sophisticated adult above the age + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2968 +of consent who was dating a man Ghislaine Maxwell's age. And +Jane came from a prominent musical family with supportive +brothers and sisters and a mom and two older siblings as well. +She had a singing and acting career, and there's no evidence +whatsoever that Ghislaine Maxwell's chitchat with her, as she +called it, was grooming. +The government brought you these pilots. But the +pilots said they didn't see anyone underage. And nothing ever +once hinted to them that there was sexual activity going on +with underage girls. You heard Larry Visoski talk about how he +left his daughters -- he was happy to have his daughters go +horseback riding with Ghislaine Maxwell all the time. You +heard from the FedEx records custodian, Tracy Chapell was her +name. And again, she told you that there were no packages from +Ghislaine Maxwell to +or any other underage girls. +The government only showed you a few that went to +but she had gathered hundreds, and we provided with +you the rest of those, which just show that Ghislaine Maxwell +sent FedExes to her family. Not one of the accusers got a +package from Ghislaine Maxwell. +The government brought you some law enforcement +specialists. +Maguire said she searched the 71st Street +residence and located hundreds of hard drives and tons of +photographs. Kimberly Meder said she scoured those 40,000 +photos, and all they came up with were some old + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2969 +girlfriend/boyfriend looking photos of Ghislaine and Jeffrey. +Stephen Flatley. Let's take a minute on Stephen +Flatley. He's the computer forensic guy. And he's the one +that pulled the metadata that the government just showed you on +their closing. And they are trying to argue that these +documents, +because they came from a computer that was loaded up +originally by Ghislaine Maxwell, that she wrote every document +on that computer. +You know what's easy as can be, doesn't take +the FBI to do it? You just pull up the dates of that metadata +when those documents were created, and you look and see from +the flight logs where Ghislaine Maxwell was when those +documents were created. And she's in about four or five +different places. So whoever had that desktop computer Stephen +Flatley told you about wasn't carrying it with them on +airplanes. +And if other people could use that Ghislaine Maxwell +computer, what on earth makes the government think that +Ghislaine Maxwell was writing an essay about herself in the +third person with Jeffrey Epstein? You don't know about that +document. Not one single person told you what that document +is, where it came from. You got some metadata from a computer +that's clearly being used by a number of different people, +because Ghislaine Maxwell is not in the house when documents +are being created. But the FBI didn't put that together for +you. They want to just say, This is Ghislaine Maxwell's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2970 +document because it's got her name in the metadata. Please. +They've got a list of massage oils. Ghislaine Maxwell +wasn't in town when that list of massage oils was created. +They've got a household manual that wasn't on Ghislaine +Maxwell's computer, by the way. No one's explained where that +thing came from, but it's dated in 2005. There's an email +between Ghislaine Maxwell and another woman talking about the +household manual and also about what a terrible job Juan Alessi +was doing. That's the one email off of those hundreds of hard +drives you saw and the pictures, one email the government +brought you for a ten-year conspiracy, complaining about Juan +Alessi's job performance. What a smoking gun. +The Palm Beach detectives came and they told you about +their walk-through at the Palm Beach house, the one that showed +the massage room, which was really the +bedroom -- +bathroom, excuse me. There is no creepy animals that she +talked about or orgy paintings on the wall. They brought you +the massage table which proved nothing to you. +They showed you that photo up close of the girl with +her pants being pulled down that was on the wall. Go back and +compare that with the other photos. That's the same girl that +Eva +identified as her daughter in the other photos in the +house, okay. This isn't child pornography. This is a photo +that was given to Jeffrey Epstein by Eva +of his +goddaughter. Photo doesn't prove anything. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 137 of 257 2971 +They talked to you about sex toys that were found on a +shelf in a guest room closet. +Then there's +What does that prove to you? +The government wants +to try to claim that +was also a victim. +Where is +Why didn't +come and get on the stand and tell you that she was a +victim? +Use your common sense. If she could corroborate +you think they might have had her come in and do that? +What the government just told you is that Ghislaine +Maxwell basically picked her up off the side of the road. +That's not what you heard. Juan Alessi told you he -- +Ghislaine Maxwell went to get a treatment at the spa at +Mar-a-Lago, and +came out wearing a +uniform, as though she worked there. And Juan Alessi also told +you and said in a deposition in 2009, she was a masseuse. He +understood her to be a masseuse. This isn't picking up a girl +off the side of the road. +And 1ook at the records, okay. We put in +school records. She was going to Survivor Charter +School from 2001 to 2002. She was 18 years old. That's where +introduced +Shawn says he met her. And in 2002 is when +to Epstein, when she was 18 years old. So +the one who's taking underage girls to meet Epstein, not +Ghislaine Maxwell. +is +presence on a flight log when she was 17, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 138 of 257 2972 +rather than 18, tells you nothing about what she did or didn't +do. And if the government had proof to back up +claims, they could have brought it to you and put her on the +stand. +As I said at the beginning, the government has really +struggled to explain why an Oxford-educated, proper English +woman would suddenly agree to facilitate sex abuse of minors. +And they told you it was to maintain her jet-setter lifestyle. +They've also suggested at least three other reasons. +One is this culture of silence theory, which is +dependent entirely on Juan Alessi and the mysterious household +manual. Now, Juan Alessi told you he threw that manual away +and never used it, so we don't actually have a single employee +who came and testified that they used this household manual. +The pilots didn't use it. The office people told you they were +never given directions like that and didn't know about it. No +one was told not to look anybody in the eye. +Larry Visoski did tell you he signed a nondisclosure +agreement. He told you that was common for people of wealth; +that he had signed it for other people of wealth because they +don't want them -- their pilots writing about the famous people +who are flying on their planes, like Bill Clinton or Donald +Trump or Senator John Glenn or any of the other famous people +who you will see on the flight logs. Nondisclosures aren't to +hide illicit sexual activity; and not one witness told you that + + + +2973 +it was. +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Secondly, the government makes a big show of these big +dollar transfers. +And they claim it's the finances; that +Ghislaine Maxwell was basically being purchased to facilitate +sexual abuse because she got big dollar transfers of money that +you can see from bank statements. +That is some thin testimony. +What they are asking you to do is to speculate. And +speculation is not evidence. Putting up a bank statement that +shows transfers tells you nothing about what was going on and, +in fact, it's not even clear that Ghislaine Maxwell knew that +these transfers were being made in her name. +You saw evidence that Epstein bought a helicopter, and +he owned it through a company called Air Ghislaine. Dave +Rodgers told you that's totally common for wealthy people to +own their private planes through companies, because it limits +their liability. And that's exactly what the $7.4 million +would have corresponded with, because the bank records show it +was Air Ghislaine. It's not like Epstein put all his assets in +Ghislaine's name. Larry Visoski told you that he put +several -- that Epstein put several of the cars in Palm Beach +under Larry Visoski's name. +You also heard that Epstein was generous with a number +of people. He donated to numerous charities. He was a sponsor +of the arts and individual artists. He gave money to build a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 140 of 257 2974 +lodge at Interlochen. He paid for his employees' kids to go to +college. +He gave Larry Visoski 40 acres of land on a ranch +free of charge so he could build a house there. He didn't ask +anything in return for this generosity. Education was +important to him, and he did it for a number of employees. +Everyone knew that Epstein was doing this. The +employees knew about the tuition payments. Everyone knew he +was building a lodge at Interlochen that was handicap +accessible. So to everyone, including Ghislaine, it looked +like Epstein wanted to use his money to further the ambitions +and education of those around him. +As far as these bank records, where they showed you +these big numbers, and Ms. +just argued that's essentially +buying off a sex abuse case, you saw that for all those +records, the person who signed for the accounts was Harry +told you was Epstein's accountant. He +Beller, who +was signing all the checks. Beller had control over the +account, and he's the one signing for the accounts. +Who knows what that money was for. Did anyone from +the bank tell you what that money was for? Certainly no one +from JPMorgan did. What about all these other people around +Epstein who made the wire transfers or paid for it? Did they +come and testify? +The government wants you to speculate over and over, +and they want to put up big dollar signs and make you believe + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 141 of 257 2975 +that that turns someone into a sex abuser. +THE COURT: Ms. Menninger, we're just going to take a +real quick stretch break. +MS. MENNINGER: Sure. +THE COURT: Anyone who wants to stretch +• MENNINGER: You heard from the government that +Ghislaine was Epstein's right-hand woman; that she controlled +everything in his life; she knew everything, she saw +everything, she did everything, she's to blame for his sins. +That's not what the evidence showed you at all. +Everyone knew that Jeffrey was keeping secrets from +Ghislaine, except Ghislaine. The pilots knew it when they were +flying Epstein with other women. Her own assistant, +was +sending flowers to other women for Mr. Epstein. Mr. Alessi +told you that when Epstein was coming with other women, he was +ordered to take the photos down off the walls of Ghislaine. +We can see the flight logs -- you'll see the flight +logs and the testimony of other witnesses like Dr. +• Larry Visoski, that Mr. Epstein had many other +women in his life: Frances Jardine, +Sherry +and who knows how many more. There are trips over and +over on those flight logs with these women and without +Ghislaine going to Palm Beach. +Check out the flight logs for yourself. +Someone like Jeffrey Epstein is always trying to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22( + +2976 +control the people around them. He used his position to +manipulate people and play them off against one another. +Juan Alessi told you -- despite their one quote the +government showed you about Ghislaine being the lady of the +house when she first started, that, in 2016, Mr. Alessi +testified it was Epstein who was his direct supervisor. And if +Epstein was in the house, he would never go to Ghislaine, he +would go directly to Epstein. +And let's talk a little bit about Mr. Alessi. +Mr. Alessi worked for Epstein for many years. But you +can tell from the one email exchange, Government Exhibit 424, +between Ghislaine and +that Mr. Alessi was not +doing a very good job. In fact, I think she called it a truly +awful job. So we know the two of them weren't getting along. +But does being a tough boss make you an enforcer of a +code of silence? Mr. Alessi is simply not credible. He said +he didn't follow the household manual, which is dated years +later. He threw it away. Not one employee told you they +followed this household manual. +He's also the one that the government tried to get in +this little black address book from, right? He's the one. He +said he recognized it; it looked like the one he had seen. He +has no idea what year it's from. He doesn't know how accurate +it is; that people get added every year and taken away every +year. So somehow in 2021, a black address book shows up on the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2977 +stand with some names in it, and not one single person says +that that black address book is from the time we're talking +about and not Epstein's own address book from years later after +Ghislaine had nothing to do with it. Not one. If all these +employees are around the house all the time seeing these +address books laying everywhere, where are those employees and +where are all those address books? So Juan Alessi is the sole +guardian who can tell you about this black address book from +which the government wants to build their case. +What do we know about Mr. Alessi? +During his direct examination, the government asked +him about his burglary of Jeffrey Epstein's home. And he +turned on the stand and he looked at you in the eye and he +said, I will tell the truth. And then he proceeded to not tell +you the truth. He told you a story that he concocted to make +himself look better. He told you that he broke into Epstein's +home one time to try to help someone because he was out of +money. But he told the police back in 2003 that he broke in to +steal a gun. +He told you he stole the money because he needed it, +but then he told you he owned multiple rental properties. He +told you he broke in once. But the truth was, as he told the +police in 2003, he broke in twice. He went in, stole some +money, and then he came back a few weeks later and stole some +more money. So the man who turned and looked you in the eye + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 144 of 257 2978 +and said, I will tell you the truth, turned and didn't tell the +truth. You cannot trust this man's word, certainly not as +proof beyond a reasonable doubt, of anything. +And on top of that, his memory is all over the place. +He told different stories at different times. He couldn't +remember if he met someone in '94 or '99. He has no business +being the one corroborating witness for Jane. But even there, +he testified that he met her later in '98 or '99, when she +would have been 18 or 19. +He told you that he picked her up a few times, not the +hundreds of times she claims. He thinks he drove her to the +airport once, not the dozens of times she claims. And who +drove her to the commercial airport or back? Was that her mom +we didn't hear from? He did tell you he'd worked in +construction, and that the plans that he was shown demonstrated +that there was renovation that was about to start taking place +in the summer of '94. +Mr. Alessi does not have credible or complete or +accurate information. You should not rely on him in reaching a +verdict. +I want to talk a little bit about the defense case. +As you know, we called Dr. Loftus to the stand. She's +a prominent memory scientist. And she gave us a user-friendly +class on how the brain works and how human memory works. +And I understand the government wants to minimize her + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2979 +significant body of research and work because she wrote one +book called Witness for the Defense. But you will have her CV +and you can look at her eminent qualifications and all of her +research on how people can develop memories of things that +didn't happen or remember things differently from the way they +actually were and how people can develop false memories. +And what she told you is that memory is malleable. +Memory weakens over time. And memory can be impacted and +corrupted by post-event contamination. She talked about times +when false memories can be planted in a person's mind, and that +the person could then become just as emotional about these +created memories as other individuals who truly had the +experiences. And contrary to what most people think, memory +doesn't work like a recording device; you can't just push play +and it all comes back later. +Memories can be impacted by post-event information +that comes from all different sources. Interviews that use +words that are suggestive. You'll recall that she talked about +the study where they used the word "smashed." How fast was the +car going when it smashed into the other car; and that people +gave much higher rates of speed when they heard that word, +because it was suggested to them that it was fast. +And then think back about how none of the interviews +of these accusers were recorded and we don't have transcripts +and we don't know the words that were used in those interviews. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 146 of 257 2980 +We know that the accusers talked to their lawyers; we +know that many talked to the media; we know that they saw the +media; we know that they talked to other accusers; we know that +they all had at least a plan of recovering money through their +lawsuits and the victims' compensation fund, and that works on +your memories. +She told you about the three different stages of +memories, and that one thing that can happen is what's called +autosuggestion. Basically, when people suggest things to +themselves, and then they start to remember things and they +start to draw inferences, and then they start to feel as if +those things are actual memories. But memories come from the +acquisition of the event, the retention of the information, and +the retrieval. And post-event +information can impact a memory +at any one of those stages. +If you're under the influence of drugs or alcohol at +the time you acquire the memory, that affects the quality of +the formation of the memory in the first place. The older a +memory gets, the more susceptible it is to post-event +information. A little bit can come in, the older the memory +is, and it can cause a contamination or a distortion or a +supplementation. And news media in whatever form can include +re-dramatization. +Sometimes there's pressure to provide more and more +details about some particular subject. I don't know. Like the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2981 +government asking you four times, Are you sure there was no +sexual abuse in New Mexico? Could that possibly be pressure to +give more information that sometimes leads to corrupt memories? +And she explained to you that memory is a constructive +process; that we often takes bits and pieces of experiences and +try to put them together to make sense, which is exactly what +told you she did when she figured out the April +1996 date and she happened to be wrong. +How vivid a memory seems does not make it more +accurate. She talked about false memories being planted in +people's minds. You remember things like being attacked by a +vicious animal or nearly drowning; and that people can have +rich false memories that have been planted in their minds. She +also talked about confidence malleability; that the more +confident a person gets if they receive confirming information +like from their lawyer or another accuser, then they go up in +their confidence. +Dr. Loftus has consulted with the Department of +Justice, the bosses of these prosecutors; the FBI, the people +who interviewed in this case; and the Secret Service. So to be +telling you that she's only a defense witness is simply not +true. And if the government had called her, she would have +told them the same information, it's just information they +didn't want to hear. +You remember the government asking questions of Dr. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 148 of 257 2982 +to try to suggest that maybe her memory wasn't so good +because of a medical condition. But she was quite firm in the +one thing, +she absolutely did not take part in sexual abuse +with Jane. +Science is science. And Dr. Loftus, Professor Loftus, +would say the same thing, no matter who called her to the +stand. You can look at her CV. You can't compare it to Dr. +Rocchio's, because Dr. Rocchio's is not in evidence. But Dr. +Rocchio told you she hasn't done any research. And you don't +even need an expert to tell you some basic facts. Memory fades +over time, manipulation can alter memories, and money is a +powerful manipulator. +Any claim to truth must be accompanied by the proof. +And here, these women are claiming to be telling you true +stories and true memories; but in many cases, if not most, they +are contradicted by the actual documents we have from the time +period. +I'm going to talk to you a little bit about the law, +as the government did. +As you heard, Ghislaine Maxwell is charged with six +counts, and you're going to have the opportunity to acquit her +of all of those. I'm going to walk you through this. +Counts One, Three, and Five are the ones that accuse +her of participating in a conspiracy. A conspiracy is an +agreement between two or more people to violate the law. It's + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2983 +not mere presence around someone else who is violating the law; +it's an agreement to help that person. It's different from an +actual violation yourself of the law. And Counts Iwo, Four, +and Six are the ones that charge her with actually being the +one to violate the law. So it's a little confusing, but these +come in pairs, as you see from the color coding. +One and Iwo are the conspiracy and the substantive +count for enticement or persuading someone under the age of 17 +to travel to engage in a legal sexual activity. Count One is +the conspiracy, Count Iwo is the substantive count. +The same is true for Counts Three and Four; they are +the substantive and the conspiracy counts for transportation. +And Five and Six are the same for sex trafficking. +It's very important that you understand that certain +counts relate to certain accusers. So, for example, Counts Two +and Four are entirely based on Jane. If you don't believe +Jane, you just acquit Ms. Maxwell right away of Counts Iwo and +Four. + + +Page 150 of 257 2984 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MS. MENNINGER: And Count Six only relates to +So if you don't believe +or if you have a reasonable +doubt about +adding Ghislaine to the story, you just +acquit her on that charge, as well. +And there are numerous reasons why you should have +substantial reasonable doubt in this case. +But before I get to that, let's talk about conspiracy. +Judge Nathan will explain to you that conspiracy is an +agreement to accomplish something unlawful, and the +government's theory is that Epstein and Maxwell agreed that +they would encourage or arrange for females under the age of 17 +to travel to New York to engage in sex acts with Epstein, and +New York law provides that an adult of someone under 17 cannot +legally consent to have sexual contact. +So, what did +and +and +have to +do with that violation of New York law? +Nothing. +never went to New York. She never traveled anywhere. Any +suggestion that she was asked to travel was something she added +in the last year after her first lawsuits were over and her +money was gone and she was adding Ghislaine Maxwell to the +case. +came to New York through no involvement of +Ghislaine Maxwell. As she told you, quite clearly on the stand +and after she went to New Mexico, nobody asked her to travel + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 151 of 257 2985 +anywhere. +While she went to New York the one time before New +Mexico, Ghislaine Maxwell wasn't there, had nothing to do with +it. And +as we've already told you, nothing illegal +happened with +Counts Five and Six, the sex trafficking counts, these +are the counts that relate to +Now, the government wants you to believe that because +Ghislaine Maxwell traveled to Palm Beach at some points in that +period and helped to manage Epstein's properties, she was the +one orchestrating massages, despite the fact that you've seen +no proof of that, no message pads, no phone records, nothing. +You've seen +was there. +The Judge is also going to explain to you that mere +presence is not enough -- mere presence at the scene of the +alleged crime does not, by itself, does not make someone a +member of the conspiracy. And she will also, I expect, +instruct you that knowledge without participation in the +unlawful plan is also not sufficient to convict. In other +words, you cannot conclude Ghislaine was a member of the +conspiracy simply because she visited Palm Beach in the 2000s, +nor can you convict her because you have some nagging sense +that she must have known. She must have known is not proof +beyond a reasonable doubt. +The law presumes, as you sit here today, as I stand +here today, that Ghislaine Maxwell is innocent of all the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2986 +charges against her. And Ms. Maxwell does not have to prove +her +innocence to you. You already know it to be true as you +sit there. It is the government's burden to prove each element +of each of these crimes beyond a reasonable doubt. Those of +you that have worked in regulatory jobs or banking or finance +will be familiar with regulations and how there are knit-picky +rules. The Judge is going to give you the law. That's the law +that you'll follow. You'll get those instructions and you need +to follow those rules, each one of them, very carefully, +because if the government has failed to prove any element of +any count beyond a reasonable doubt, no matter how silly or +small it might seem to you, the Judge will instruct you, you +have to acquit. You only convict if you find the burden of +proof has been met as to each element of each count. +Reasonable doubt is something I've talked a little bit +about and the Judge, I expect, will give you the instruction +that you see here. So I'm just trying to point out a couple of +pieces of it, but obviously you'll need to read the entire +instruction and listen to all of the Judge's instructions +because they're all important. But when you're weighing the +credibility of the witnesses that you've heard from and you're +evaluating whether the government has met its burden of proof +as to each element of each count, you are to weigh whether or +not the government has satisfied their proof beyond a +reasonable doubt. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2987 +And what does reasonable doubt mean? I expect the +Judge will instruct you reasonable doubt is a doubt based in +reason in arising out of the evidence in the case or the lack +of evidence. It is a doubt that a reasonable person has after +carefully weighing all of the evidence in the case or the lack +of evidence. +So every witness you didn't hear from, every +piece of document that you didn't see, every piece of evidence +that you didn't see, you can take that into account and decide +whether the government has met their awesome burden. In other +words, if you have such a doubt as would reasonably cause a +prudent person to hesitate to act in matters of importance in +his or her own affairs, then you have a reasonable doubt, and +in that circumstance, it is your duty to acquit Ms. Maxwell of +that charge. +What does that mean? It means something different to +every person. But what is a matter of importance in your own +affairs or someone else's own affairs? Is it whether to get +heart surgery? Is it whether to buy a house? What major +events in your own affairs do you need highly trustworthy +information to make a decision about? +And then ask whether the quality of the evidence, the +lack of the evidence, the evidence that you did get, the +evidence that you didn't get was of such a standard that you +would not hesitate to act in a matter of importance to +yourself. Would you hesitate to act in a matter of importance + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2988 +to yourself based on the word of +? +Would you hesitate +to act in a matter of importance to yourself based on the word +of Jane? Did they demonstrate to you that their stories were +credible? I submit to you that they did not. +All of these witnesses have changed their stories many +times. +Why? +Was it a lack of memory? Was it a motivation to +change their story? And each change of story should cause you +to hesitate to act, and should evidence, the lack of proof +beyond a reasonable doubt. +There are many reasons to hesitate and many reasons to +doubt. You have to use your common sense. Money is a powerful +motivating factor. The time that has elapsed has made it very +difficult for people to go back and reconstruct their memories, +and their memories are highly flawed. How easy is it for +someone to get on the stand and say, okay, well, I know I told +you many times that I don't remember her being in the room, but +now I do. It's pretty easy because no one is here to confront +her. Epstein is dead. No one can say that they're lying +except asking them questions and pointing out that their +stories are not accurate. +But Eva and +came in and they told you they +absolutely did not participate in sexual orgies that Jane said +they did. That should make you hesitate about all of Jane's +story. +swore many times to tell the truth, and all of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 155 of 257 2989 +her depositions and in her civil complaints and then she added +someone else decades later. That should make you hesitate. +They all changed their stories when the Epstein +Victims Compensation Fund was opened up. That should make you +hesitate. +Mr. Alessi turning and looking at you and saying he's +going to tell the truth and not telling the truth, that should +make you hesitate. +The lack of evidence should make you hesitate. Where +is one photograph of Ghislaine with any one of these accusers +or any underage girl? That +should make you hesitate. +What are all the rest of those photographs show? That +should make you hesitate. +The absence of one other employee to come in here +should make you hesitate. +The absence of relatives who were living in the house, +mother and brothers who supposedly saw their sister go over to +a middle-aged man's house hundreds of times at the ages of 14, +15, and 16, they didn't come here, and that should make you +hesitate. +No phone records, no thank you notes, no proof that +Epstein gave money to Interlochen for Jane, that should make +you hesitate. +Certainly, if it was a matter of importance to +yourself, because I assure you this a matter of great + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 156 of 257 2990 +importance to my client, Ghislaine Maxwell, that hesitation is +reasonable doubt. +As we have said from the beginning, Ghislaine Maxwell +is not Jeffrey Epstein. She's being tried here for being with +Jeffrey Epstein. Maybe that was the biggest mistake of her +life, but it was not a crime. +Please only consider the evidence against her, don't +be fooled by the government's smoke in mirrors and big fancy +houses and bank accounts. What was the evidence that pertains +to her? The evidence on the law, the burden of proof, justice, +demand that you acquit Ghislaine Maxwell of every single count +with which she is charged. +Thank you for your time. +THE COURT: Thank you, Ms. Menninger. +Members of the jury, we'll take our short break now, +and bearing in mind all my instructions, which continue to +apply. When we return, we'll have rebuttal by the government +and then I'll give you my charge. Enjoy your break. + + +Document 767 Filed 08/10/22 Page 157 of 257 +2991 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Jury not present) +THE COURT: Matters to take up? +MR. PAGLIUCA: No, your Honor. +THE COURT: Ms. +: Yes, your Honor. We would like to make an +application, if possible, could we do so when we return from +the break? I just want to confer with my colleagues on the +particulars of our application with respect to the defense +summation. We wanted to look at the transcript in particular. +THE COURT: Well, why don't you raise it and then +we'll take a short break? +MS.: Yes, your Honor. There were a number of +points during defense counsel's summations where they referred +to facts which are not in evidence and testified to things +which are not in evidence. And for that reason, we would +respectfully request that the Court give a curative +instruction, essentially in reminding the jurors that it's +their recollection of the evidence that controls and not what +the lawyers say. +I think, in particular, there is one example, I +believe Ms. Menninger read into the record an email from +which the Court expressly precluded and which is not in +evidence. +THE COURT: What exhibit? +MS. M: I don't have the number in front of me, but + + +Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 158 of 257 +2992 +they were the emails that Ms. Menninger referenced between +and Epstein. +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: Those came in redacted? +Yes, completely redacted without any +content. +MS. MENNINGER: Judge, it came in the testimony. The +emails themselves were redacted. +The content was part of the +testimony. +THE COURT: I think that's right. +: I don't believe the emails -- were offered, +were offered for the truth. That's one of the reasons we +wanted to check the transcript. +THE COURT: The curative instruction that you're +asking for is in the charge, precisely the words that you just +indicated, that it's, what's in evidence and not counsel's +arguments. The jury is going to get that. It's in the charge. +MS. : Yes, your Honor. Our concern was that there +were a number of items throughout the closing that were +mischaracterizations of testimony or inaccurate or references +to items that were not in evidence. That's why we're +requesting it now, although I understand the Court's point that +the jury will be charged this afternoon and that language is in +the charge. +The second issue that we wanted to raise is, as the +Court will recall from pretrial litigation, we moved to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 159 of 257 2993 +preclude any arguments to the jury that the defendant was a +substitute for Jeffrey Epstein. That's the exact argument that +Ms. Menninger advanced to the jury in closing, which the Court +precluded. +THE COURT: Not with respect to motivation for the +witness's testimony. There is a reason I gave -- for both +sides, you've both now done this, which is basically to reargue +sort of precisely the line that I crafted and ruled on in my +pretrial rulings. I have maintained those lines throughout +trial with a couple of exceptions where there was a little bit +of door opening and the like, but I don't have in mind, yes, +they made the argument that Epstein's death is a factor in the +motivation for the changing the stories, which is what I said +was -- to the extent that arguments go to the credibility of +witnesses, that's where I drew the line. +Yes, your Honor. I was referring to the +argument early in Ms. Menninger's summation about I took to +mean an argument that the government was substituting +Ms. Maxwell for Mr. Epstein. Again, we want to review the +transcript, but that's how we heard it. +There were also arguments throughout summation about +the victims doing that, which I understand the Court has ruled +on that there is a difference between those two, but we think +where that crosses the line is an argument where the government +is doing that. + + +Document 767 Filed 08/10/22 Page 160 of 257 2994 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +THE COURT: I don't recall hearing a crossing of the +line, but I'll step down and you can point me to language and, +again, they're about to get the instruction, so I'm not going +to give an instruction that's a repetition about what I'm about +to instruct them. We'll break for five. +(Recess) +THE COURT: Yes. +MR. +: Your Honor, with the benefit of the +break, the government has honed its request and basis for it. +said, we think there was several assertions +So, as Ms. +which were not in the record, but the clearest one perhaps is +Ms. Menninger's arguments about the way interviews were +conducted in this case. +The Court will recall we had extended discussion about +that when Special Agent Young was on the stand on Friday, +Ms. +asked a question and the Court said that if +Ms. +in fact, asked the question and got the answer, it +opened the door to evidence about how the interviews were +conducted. +THE COURT: It was referencing the cross examination +of the witnesses themselves regarding how they were questioned +in the interviews and the prior interviews. That was the +evidentiary basis for those comments. Overruled. +Anything else? +MR. +: Nothing else from the government, your + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 161 of 257 2995 +Honor. +THE COURT: Anything from the defense? +MS. STERNHEIM: No. +Thank you. +THE COURT: You can set up and we'll bring in the +jury. +Thank you, your Honor. +THE COURT: Counsel, you have ready the exhibits to go +back to the jury? +MR. +: Yes, your Honor. They've now been +reviewed by both sides, I assume, Mr. Everdell? +MR. EVERDELL: I just turned them over to the +government, so we've got everything ready. +THE COURT: I think you're still finalizing the +exhibit list, that's fine, because I want it to go being I'1l +mark it as a Court Exhibit once you've finalized it. +MR. EVERDELL: Yes, your Honor. +MR. +: Yes, your Honor. +THE COURT: 35, correct, Ms. +MS. I +: Yes, your Honor. + + +Document 767 Filed 08/10/22 Page 162 of 257 2996 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Jury present) +THE COURT: Everyone may be seated. Thank you, +members of the jury. We'll now hear a short rebuttal argument +by the government. +: Thank you, your Honor. +I want to start off by making one thing very clear, +this case is about that woman, it's about the children that she +targeted, the steps that she took to serve those children up to +be abused. It's about her own participation in that abuse when +she touched Jane's breasts and +breasts and +breasts. This case is about Ghislaine Maxwell, the crimes she +committed. +The defense just spent a whole lot of energy trying to +get you to think about anyone other than the defendant, trying +to get you to look away from the massive amount of evidence +that Ms. +walked you through this morning. +Now, to be clear, the defense doesn't have to do +anything at all at this trial. As Judge Nathan has instructed +you, the government bears the burden of proof and we embrace +that burden, but when the defense makes arguments like they +just did, it is perfectly appropriate for you to think about +whether those arguments make any sense at all and it is +perfectly appropriate for the government to respond to those +arguments. Here, the defense's theories just do not hold up. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 163 of 257 2997 +I'm not going to address all the stuff you just heard, I'm +going to focus primarily on the core of the defense's arguments +here, that you can't believe the four women you heard from, +Jane, +and +• Never mind that they +corroborate each other, never mind the mountain of evidence +that backs those four up, the defense is desperate for you not +to believe these women, so they're throwing up anything they +can think of at the wall to see if anything will stick, but if +you think about those arguments for just a little bit, you'll +see they don't hold any water. +Let's walk through them. +The defense tried to suggest that even if Jeffrey +Epstein did engage in sexual contact with Jane, +and +Maxwell didn't know about it. She just had no idea +that her boyfriend and best friend for more than a decade had a +thing for teenage girls. Ladies and gentlemen, that suggestion +is borderline laughable. Of course she knew. The defendant +ran every aspect of Jeffrey Epstein's life for the better part +of a decade. She traveled with him constantly. She shared a +bed with him, inside a bedroom they can't get to without +walking past a photo of a young girl pulling down her +underwear. She had a bathroom off of that +bedroom. She +referred to her homes as his home. She was the lady of the +house. So of course she knew what was going on. Of course she +knew that her boyfriend, when he was spending time with teenage + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 164 of 257 2998 +girls like Jane, like +like +like +she knew that he was doing it because he was attracted +to them, because he wanted to have sex with them. The +suggestion that she didn't know borders on the absurd. +Think about that Palm Beach house filled with +sexualized photos of girls around his desk, in the bedroom, in +the closet where the massage table was kept, and think about +that list of masseuses. Who needs that many masseuses? You +saw that list from Government Exhibit 52-G. And who needs that +many massages? Those were so obviously a ruse for sex. The +defendant clearly knew what was going on, and she was +complicit. She was in the room. So of course she knew. That +$30 million is not just house-manager, hold-my-money-for-me +money, it is, we-molested-kids-together money. The defendant +was a crucial part of this scheme. +Now the defense talked a lot about what you don't have +here, what's not in evidence in this case. See that for what +it is, a distraction. It's a desperate attempt to get you to +think about anything other than the powerful testimony you +heard during this trial from Jane, +h and +Just a few points on this particular argument. +First, Ms. Menninger talked a lot about where are the +photographs or where are the hard drives. I expect that Judge +Nathan is going to instruct you that the government is not +required to use any particular investigative techniques. What + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2999 +is before you is whether the evidence that you heard in this +courtroom proves the defendant's guilt beyond a reasonable +doubt, and it absolutely does. +Second, I expect that Judge Nathan will instruct you +that any witnesses who did not testify here were equally +available or equally unavailable to both sides, the government +and the defense. +So when Ms. Menninger stands up here and says +where is +, where is Jane's mom, where are the +employees, keep that in mind, it's just a distraction. +Third, your common sense tells you that the sexual +abuse of children is not the kind of crime that leaves paper +evidence. The victims are the evidence. Their testimony, +their consistent accounts of Maxwell and Epstein and how they +operated, that's how you know they were in those massage rooms. +People who prey on children do not leave behind documents +admitting to what they did. The defendant was not walking out +of those massage rooms writing a memo to herself saying, today +I touched Jane's breasts. But you do have powerful +corroboration from three different victims who each told you +compellingly similar accounts of their experiences, three +different victims who remember the defendant touching their +breasts, three different victims describing how the defendant +used massage as a technique to move into sexual abuse. +And by the way, you do have documents to back up their +testimony. Ms. +walked you through them. You've got the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +3000 +contact book, the message pads, the FedEx records, you have +evidence on top of the witnesses. +The defense spent most of their time attacking Jane, +and +, and now it's obvious why they did +that. Those four witnesses gave you the most damning testimony +in this trial. If you believe those women, then that's it, the +defendant is guilty. So of course the defendant is spewing out +anything they can think of to attack these women. +I'm not going to respond to every single sideshow that +Ms. Menninger tried to lead you down about each of these women, +but let me just address a few of the most obviously false ones. +First, there is literally no evidence in this record +of an age limit at the Epstein Victim Compensation Fund. +That's something Ms. Menninger just made up. There is nothing +in the record to say you have to be a particular age to put in +a claim to that fund. +Second, the suggestion that +was 17, not 16 when +she went to Santa Fe. Three different witnesses, +her +mother, and her high school boyfriend all remember that +took that Thailand trip the summer between her junior and her +senior year. +remembered she had just gotten +back when they started dating and that she went after they met +at junior prom. They didn't just make that up. +And remember, this trip to Santa Fe with +took +place close in time to the trip around Christmas time to New + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +3001 +York. Epstein wanted to get her back in his clutches as +quickly as he could, and he wanted his right-hand woman there +to help groom her. That's how you know it happened in '96. +And this thing about flight records, also a +distraction. If you want to take a look for yourself, go to +Government Exhibit 662 at page 40, look at the flight on March +29th, 1996. You'll see Jeffrey Epstein flying to Santa Fe, New +Mexico. The next flight is more than a week later, April 8th, +1996. Maxwell is on that next flight with Epstein. That span +of time of more than a week covers a weekend. Take a look at +that, ladies and gentlemen. +And third, Ms. Menninger talked a lot about Jane's +testimony on cross examination. And to give you an example of +some supposedly "aha" moment, she showed you a question that +she asked Jane that was written like a riddle. Remember that +question, it was, you don't recall Maxwell and Epstein being in +the room, correct, and Jane answered no. What that means is, +no, that's not correct. Ms. Menninger was trying to mislead +you about what the answer to that riddle-like question meant +just like she was trying to mislead you about what nothing has +ever been difficult for me meant on that Interlochen +application. Don't be distracted by that nonsense. +I want to walk through the main arguments at the core +of what the defense has said to you today about these +witnesses. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +3002 +First, the defense tries to argue that Jane, | +and +are all misremembering what happened to +them. +They concede that the sexual contact happened with +Epstein, but the theory is, Maxwell just had no part in it, +wasn't involved. So the theory is that all four of these women +had a massive false memory event that just happen to include +details of the defendant grooming them in the same way using +the same playbook. Your common sense tells you that didn't +happen. The defense's own expert, Professor Loftus, confirmed +that the core memories of trauma are solid. Peripheral details +make it a little fuzzy, but those main memories, those events +that are at the center are implanted. Some things you never +forget because they're seared into your brain forever. +You remember keen moments, moments that change your +life, like Jane remembering the defendant touching her breasts, +remembering the defendant touching her breasts, | +remembering the defendant touching her breasts, +remembering the defendant standing right next to her in the +doorway the first time she sees Jeffrey Epstein naked, frozen +with fear. +There was nothing peripheral about the defendant. She +was the core memory, she was essential to this scheme. And to +distract you from the remarkable clarity with which these women +remember those core details, the defense primarily points to +how Jane and +have described aspects of their + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +3003 +experiences differently over time. They mixed up details, +couldn't remember exactly when certain things took place. But +if you think about your own lives and your own memories, you +will see that difficulty remembering certain things doesn't +mean that they didn't happen, doesn't mean that you don't +remember the core. +Jane and +were both abused many, +many times over a period of years. The abuse became routine, +the same sickening process each time, these were recurring +events. +Now imagine you were asked to recall a recurring event +from years ago in your own lives. Say something like a +holiday, like Thanksgiving. There is a routine you follow each +year, the same food, the same people attend. That event stands +out in your mind because it's significant, it's a holiday, but +you won't necessarily remember the specific dinner conversation +you had each year. You're sure you had turkey because that +happened every time, but some details are just not going to +stand out to you because essentially the same thing happens +every year. +Now what might stand out is when a routine gets +broken. Say one year a neighbor came over to join who was +unexpected or you switched up salt and sugar and a pie got +totally ruined. You'll remember that different thing, but you +might not be able to remember which Thanksgiving that thing +happened. Did the neighbor come when I was 14, or 15, or 16? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 170 of 257 3004 +What year was it that I ruined that pie and it was salty? Just +because you can't remember exactly how old you were, which +Thanksgiving it was, does that mean it didn't happen? Of +course not. +The same is true of Jane and +• The abuse +stands out in their mind because it was formative, but it +happened so often that the details run together. They remember +certain things like when someone else was in the room or going +to get to see The Lion +during one of the trips, but those +can be hard to place in time because of how frequent and +similar their experiences +were. +Now, by contrast, +had a much smaller window of +interactions with Maxwell and Epstein. So for her, many more +details stand out very vividly. It's less like Thanksgiving +for her and more like a sweet 16 party, something unique that +only happens once, so it stands out much more clearly in every +detail. +For Jane and +even though some of those +peripheral details got jumbled, they have solid memories of the +core events. And you know from the defense's own expert that +when an event you're remembering is traumatic, not just some +holiday, the memory is going to be even stronger. +Like Jane, she remembers Maxwell being in the room. +The presence of a woman that she had looked up to like an older +sister during this horrifying sexual abuse is a traumatic core + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 171 of 257 3005 +event. And you know Jane was 14 when she met Maxwell and +Epstein. +She vividly remembers being 14 years old when that +abuse began. It was within a year of her father dying. That's +an anchoring way for her to hold onto that memory and know she +was 14. It's also what she told Matt a decade ago long before +this trial. And there +are documents to confirm she's right. +You saw the Interlochen records putting her and the defendant +and Epstein all at Interlochen the same summer of 1994. You +saw the flight records putting Maxwell and Epstein there that +summer. It is so clear that Jane was 14 when she met these +predators. +Now the defense tries to wiggle out of that by +suggesting that Jane's estimation that she was approximately 15 +on Mike Wallace's birthday somehow means that she got that date +wrong. Ladies and gentlemen, which would stand out more in +your mind, how old you were on Mike Wallace's birthday or how +old you were the first time a middle-aged man molested you? It +is obvious that Jane remembers these core events clearly, and +that is what matters. +And hypothetically, let's just say the defense was +right. Let's just say that she got the timing of her first +meeting wrong, that it was actually that last summer when she +turned 16 in 1996, and you know that she knew them by the time +she was 16 because you saw the flight records putting her on +those planes with defendant and Epstein going to New York when + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +3006 +she was 16. So the best argument the defense has is she was +16, not 14, when the abuse happened. That is not a defense. +It is still illegal. It is not a defense to say, +•, по, по, +no, she was 16, not 14, when I touched her breasts. It's still +a crime. +NOw +vividly remembers the first time +she met the defendant. You saw her correct defense counsel on +cross examination. Remember, he tried to skip over the part of +meeting her and she said no, no, you forgot about when I met +Maxwell. That first day was a scarring memory for +1, and +she remembers Maxwell as a fixture in her experiences at the +Palm Beach house, like the stuffing at Thanksgiving, there +every time. +The defense is very focused on the peripheral details +that got mixed up for +between her earlier statements +and her trial testimony more than a decade later. And they +harped a lot on her memory of seeing a photo of Maxwell +pregnant in the massage room. +Ladies and gentlemen, I'd encourage you to take a 100k +at Government Exhibits 286 and 287. Those show pictures that +were on the wall in the closet where the massage table was kept +in the Palm Beach +bathroom. You look at those and +you'll see that there appear to be three different pictures +that appear to show a pregnant woman in a two-piece swimsuit. +So what if +mistakenly thought that one of those showed + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 173 of 257 3007 +Maxwell? What do you think stands out in her memory more, who +the pregnant person in that picture was or the middle-aged man +who was masturbating and touching her breasts inside that room? +That is the definition of a peripheral detail. +And why is the defense focusing so much on these +peripheral details? Because they desperately want you to +ignore the fact that +has consistently remembered +Maxwell as one of the people involved in her experiences at +that house. They want you to forget that she mentioned Maxwell +not once, but twice in her 2009 deposition. Without prompting, +named Maxwell as one of the two people who would call +her to schedule these massages with Jeffrey Epstein. She named +her as one of the two people she would talk to when she called +herself begging to come over because she needed the money. And +told Sean that she met a woman named Maxwell, whose +first name she couldn't pronounce. +Now, back then there was no reason for +into more detail about what was happening with Maxwell, +to go +especially not in a lawsuit that was about +and Epstein. +But when she was asked more detailed questions, she remembered +the core events, and she'd already mentioned Maxwell, without +prompting, long before there could be anything to contaminate +her memory. +Next, the defense suggests that somehow these clear +memories of Maxwell got implanted into the brains of Jane and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 174 of 257 3008 +and +and +• The defense seems to suggest that +this implantation happened from the media, greedy civil +lawyers, and the FBI. None of those actually make sense and +not one has support in this record. +Starting with the media, you heard absolutely nothing +at this trial about any of these witnesses consuming media in +this case. You heard that Jane and +gave some interviews +themselves, you heard that +also gave an interview, but +there is no evidence that any of these different witnesses saw +each other's interviews, they weren't asked about it, they +didn't say they did. There is no evidence that any witness saw +each other's media or anything else about this case in the +news. This is a distraction. +Turning to the lawyers. There is not a shred of +evidence that a group of lawyers got together, made up a story +about Maxwell, and then implanted it into these witnesses' +minds. Remember, each witness had a different lawyer. So for +this theory to work, four different attorneys had to come up +with this story and they separately manipulate their clients +into perjuring themselves at a federal trial all so they could +get a cut of the Epstein Victim Compensation Fund. That makes +no sense for a bunch of different reasons. +For one thing, L +told you that her lawyer is pro +bono, working for free. She doesn't get a cut of whatever +gets from the fund, so why would she need to make up a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 175 of 257 3009 +story about the defendant? And it makes no sense for the other +lawyers to push this supposedly made up story about the +defendant when they've already gotten paid. Remember, the +payments have all been made, the lawyers got their money long +before this trial started. +And you know these lawyers didn't just implant the +defendant into these victims' minds. Jane, +and +all talked about Maxwell, remembered her as part of their +experiences a long, long time ago. They all included her in +their accounts before there was some supposed incentive for a +payday. +mentioned it to Dave +, her high school +boyfriend, and the FBI in 2006. She told both of them how +Maxwell touched her breasts during a massage. Jane told Matt, +her boyfriend from a decade ago, about the woman who would make +her feel comfortable in the room. +mentioned meeting +the woman with short black hair and an accent to the FBI in +2007. She mentioned Maxwell twice in her deposition, and she +told Sean that she saw Maxwell at the house at that time, way +before there was a compensation fund or any incentive to add in +Maxwell if it wasn't true. +And that timing is crucial here because it completely +guts the whole defense theory. The defense suggests that some +lawyers made everything up about Maxwell to get money, but even +if adding Maxwell in to get money could get you money, which is +not true, there is no universe in which that was the case when + + +Page 176 of 257 3010 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Epstein was alive. Before he died in 2019, Epstein was the big +fish, he's who you go after if you're going to make up a story. +So all of the things that these witnesses said about Maxwell +before 2019 were not part of some frame-job for the defendant. +Even under the defense theory there was zero reason to make up +her involvement when these disclosed years ago. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 177 of 257 3011 +Finally, there is this, frankly, desperate +suggestion that the FBI manipulated these witnesses; asked +leading questions to fit a narrative. +Let me be very clear here. There is not one shred of +evidence to support that in this case. Ms. Menninger seemed to +improvise, ad-libbed, made up, some theoretical questions that +she'd like to think that the FBI asked some of these witnesses +in their meetings with the government. But you didn't hear +anything about that on the witness stand or the exhibits in +this case. What you did hear was Special Agent Young. She +told you how she values being ethical. She told you it matters +to her that a victim's memory is her memory. +Not a single witness at this trial suggested for even +a moment that the FBI told them what to say. Remember, every +single witness who was asked told you flat out, the only thing +the governed asked of them was to tell the truth. And you know +that's what they did here. +Really the whole memory thing makes no sense at all. +There is no way that Jane, +and +just +misremembered the defendant's core role in abusing them. So +what does that leave the defense with? They are all liars. In +order for the defense to be right, for the defendant not to +have known about the abuse, for the defendant not to have +participated in it, witness after witness after witness must +have lied to you. Jane and +and +and +must + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +3012 +have just stacked lie on top of lie on top of lie. That +doesn't make any sense for a whole host of reasons. +First, if these women are lying, then that means all +of the witnesses who backed them up are lying too. The +ex-boyfriends, Matt, Dave, Shawn, they must be lying. Juan +Alessi must be lying. That's simply nonsensical for the +ex-boyfriends. +Matt, Dave, and Shawn have nothing to gain from +testifying here. They have no reason whatsoever to lie. No +motive. Why would they come here and lie to you? +The same goes for Juan Alessi. The defense spent a +lot of time trying to dirty Alessi up. You know why they did +that? It's because his testimony is incredibly powerful +evidence that backs up so much of what these other witnesses +say. But their arguments about him are really just silly. +They spent time talking about the money and the gun. +Remember, Mr. Alessi told you himself he stole money +from Jeffrey Epstein and he paid it back. Some police report +says that he was also looking for a gun. So what? Does that +mean that he would make up an entire story about the defendant? +No. And you know he told you the truth because he was +corroborated by other evidence. Flight records confirmed that +Jane and +flew on Epstein's planes when they were +minors, just like he told you. The pilots confirmed that Juan +Alessi drove passengers up to the tarmac, just like he told +you. The household manual showed you in black and white that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 179 of 257 3013 +Maxwell was exactly who Alessi said she was. And just like the +ex-boyfriends, +Alessi has no reason to lie to you. +Second. +Jane, +• and +have no motive +to lie at this trial. The defense's only explanation for why +they would perjure themselves on that stand is money. But the +facts just do not support that. Remember, the victim +compensation fund is finished; the civil cases are done. +There's nothing pending. These women have already received +millions of dollars. They are not getting a penny more. +Now, the defense tried to point you to this +stipulation about Jane's lawyer. I'd encourage you to take a +look at it. Look at the whole stipulation. You'll see it +doesn't change anything I've said. Jane's lawyer told the +prosecutor that he remembered telling Jane that testifying +would be the morally right thing to do and that it could help +her case. But to be clear, that conversation with that +prosecutor occurred in 2021, long after Jane's civil case was +settled, long after she already received her award from the +fund. So there was no case to help. Whatever the lawyer meant +by that, there is absolutely no evidence that Jane had any +financial incentive to testify at this trial. There's no money +to be had. You heard Jane, +and +each tell +you unequivocally they have no financial stake in the outcome +of this trial. This verdict will have zero impact on the money +they received. + + + +3014 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Third. If Jane, +, and +really +believed that making up a story about Maxwell would somehow +benefit them, you better believe they would have told much +better lies. +If they wanted to frame Maxwell, if they thought +doing so would somehow benefit her, they would put Maxwell in +way deeper. They would have said that Maxwell was in the room +every single time Jeffrey Epstein initiated sexual contact. +Jane, +and +would have said that Maxwell +participated in all kinds of sex acts: Intercourse, oral sex, +you name it. That's not what they did. +was so careful to make clear that the +Remember, +defendant touched the tops of her breasts, but not her nipples. +Jane was careful to explain that Maxwell wasn't always in the +room, and that the only physical contact she remembers is the +defendant touching her breasts. +described oral sex and intercourse involving +two other women, but with Maxwell it was just one time touching +her breasts. Her memory is that Maxwell mostly talked with +her, called to schedule appointments, invited her to travel. +And how about +She never put Maxwell in the room +for a single sex act. She just remembered Maxwell walking her +to the door and leading her into that sexualized massage. And +remember, she said she was 17 when this happened. If she was +going to lie about her age, why wouldn't she make herself +younger? 16, 15, 14. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 181 of 257 3015 +If these four witnesses wanted to dirty Maxwell up for +a huge payday, they would have told way better lies. +But, you know, let's just say the defense is right. +Let's say these women are lying. Given how consistent their +accounts are with each other and with the other witnesses in +this case, that would mean that at least eight people -- Jane, +Dave, Shawn, Matt, and Juan Alessi -- all +are part of a massive conspiracy to frame the defendant. And +then they just happened to be lucky enough that the FBI had +documents to back up what they said: Flight records, FedEx +records, message pads, contact book, household manual to back +up their lies. +Beyond how implausible such a massive conspiracy of +eight people to lie in a federal court is, the timing here +makes it impossible. Remember, the defense's theory is that +the incentive to frame Maxwell arose after Epstein died in +2019. So this supposed frame job was hatched in 2019, meaning +had to get in a time machine, go back to 2009 and +sprinkle in a couple references to Maxwell in her deposition. +And then +had to borrow that time machine, go back to +2006, and tell the FBI about how Maxwell touched her breast +during a massage. +did not happen. +Ladies and gentlemen, that's fiction. You know that +told the FBI about Maxwell because it +was the truth. +| described Maxwell in her deposition + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +3016 +because it was the truth. There is no massive conspiracy here +to frame +Ghislaine Maxwell. +Finally, if these four witnesses really believed that +lying and framing Maxwell would get them more money with the +compensation, there is no way they would have testified at this +trial. No way. They got million-dollar payouts already. The +plan worked. They got the money. Why on earth would they then +take the huge risk of perjuring themselves in a federal trial? +If all of this was just lies, made up to get money, why would +they push their luck after they already reached their goal? If +money is all they wanted, they would have walked away as soon +as the check cleared. +That's not what happened. These women put themselves +through the hell of testifying at this trial, even though they +have nothing to financially gain. They exposed the darkest, +most traumatizing events of their lives to the world at this +trial. They sat on that stand and went through excruciating +and humiliating cross-examination. Did that look fun? Why +would they put themselves through that when they already got +millions of dollars? Why would they let themselves be attacked +like that? You know why. They told you themselves and you +could see it on their faces. They did it for justice, for the +hope that the defendant would be held accountable for her role +in shattering their lives. +The defendant never thought that those teenage girls + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +3017 +would have the strength to report what happened to them. In +her eyes, they were just trash, beneath her. +Those girls would +never stand up to a power couple like Jeffrey Epstein and +Ghislaine Maxwell. And if they ever did, who would believe +them? +Who would believe Jane or +OI +or +over +Ghislaine Maxwell and Jeffrey Epstein, who rubbed shoulders +with presidents and celebrities and business leaders? +But the defendant didn't count on those teenage girls +growing up into the women who testified at this trial; women +who would be willing to take that stand and tell the truth +about what happened. The defendant didn't count on all four of +them coming forward in an avalanche of evidence. And the +defendant did not count on the witnesses -- Shawn, Matt, Dave +Alessi -- who would come forward and back those women up. And +she didn't count on you. +She didn't count on a jury who would +see past the nonsense that she tried to throw up, who would +look at the evidence clear-eyed and see her for the predator +that she is. +Ladies and gentlemen, you know what happened here. +Four incredibly brave women came forward and told you what +happened to them. They opened themselves up and shared their +horrifying experiences. Jane, +, they each +told you how the defendant played a pivotal role in the worst +events of their lives. They corroborated each other and were +further corroborated by the evidence in this case. There is no + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 184 of 257 3018 +Charge +reasonable doubt that the defendant participated in the sexual +abuse of underage girls. +Now it is time to hold her accountable. If you use +your common sense, stay focused on the evidence, and follow +Judge Nathan's instructions on the law, then you will reach the +only verdict that is consistent with the evidence, the verdict +that justice demands: The defendant is guilty. +THE COURT: All right. Thank you, Ms. +We will hand out the jury instructions to members of +the jury who may read along while I read it to you. +Please wait till I direct you. +All right. Counsel, are you ready for me to read the +charge? +MR. +Yes, your Honor. +MS. STERNHEIM: Yes. +THE COURT: Okay. Members of the jury, you may read +along or not, as you like. I'm going to read you the jury +instructions. Instructions begin on page 5, which is after the +table of contents. +Instruction No. 1. Role of the Court. +You've now heard all of the evidence in the case, as +well as the final arguments of the lawyers for the parties. My +duty at this point is to instruct you as to the law. And it's +your duty to accept these instructions of law and apply them to +the facts as you determine them. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 185 of 257 +Charge +3019 +On these legal matters, you must take the law as I +give it to you. Regardless of any opinion that you may have as +to what the law may be or ought to be, it would violate your +sworn duty to base a verdict upon any view of the law than that +which I give you. If an attorney or anyone else at trial has +stated a legal principle different from any that I state to you +my instructions, it's my instructions that you must follow. +You should not single out any instruction alone +stating the law, but you should consider my instructions as a +whole when you retire to deliberate in the jury room. You may +take a copy of these instructions with you into the jury room. +Instruction No. 2. Role of the jury. +Your role is to pass upon and decide the fact issues +that are in the case. You, the members of the jury, are the +sole and exclusive judges of the facts. You pass upon the +weight of the evidence or lack of evidence, you determine the +credibility of the witnesses, you resolve such conflicts as +there may be in the testimony, and you draw whatever reasonable +inferences you decide to draw +solely based on the evidence and +from the facts as you've determined them. You must determine +the facts based solely on the evidence received in this trial. +In determining the facts, you must rely upon your own +recollections of the evidence. +What the lawyers have said, for +instance, in opening statements, in closing arguments, in +objections, or in questions is not evidence. You should bear + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 186 of 257 +3020 +Charge +in mind particularly that questions put to witnesses -- +although they can provide the context -- the questions are not +themselves evidence. It's only the answers that are evidence. +I remind you also that nothing I have said during the +trial or will say during these instructions is evidence. +Similarly, the rulings I've made during the trial are not any +indication of my views of what your decision should be. +The evidence before you consists of the answers given +by the witnesses, and the exhibits and stipulations that were +received into evidence. If I have sustained an objection to a +question or told you to disregard testimony, the answers given +by a witness are no longer part of the evidence and may not be +considered by you. I'll instruct you at the end of these +charges about your ability to request to have testimony read +back and your access to other evidence admitted during the +trial. +Instruction No. 3. Contact with others, social media. +During your deliberations, you must not communicate +with or provide any information to anyone by any means about +this case. You may not use any electronic devices or media +such as a telephone, cell phone, smartphone, iPhone, +BlackBerry, or computer, the internet or any internet service +or any text or instant messaging service or any internet chat +room, blog, or website such as Facebook, Instagram, LinkedIn, +YouTube, Iwitter, or Snapchat to communicate to anyone any + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 187 of 257 +Charge +3021 +information about this case or to conduct any research about +this case until I accept your verdict. In other words, you +cannot talk to anyone on the phone or in person, correspond +with anyone or electronically communicate with anyone about +this case. You can only discuss the case in the jury room with +your fellow jurors during deliberations. +Along the same lines, you may not try to access any +information about the case or do research on any issue that +arose during the trial from any outside source, including +dictionaries, reference books, or anything on the internet. In +our judicial system, it is important that you are not +influenced by anything or anyone outside of this courtroom. +Your sworn duty is to decide the case solely and wholly on the +evidence that was presented to you in the courtroom. +Instruction No. 4. Statements of counsel and Court +not evidence; jury's recollection controls. +You must determine the facts by relying upon your own +recollection of the evidence. The case is not to be decided on +the rhetoric of either the attorneys for the government or the +attorneys for the defendant. The lawyers' arguments are +intended to convince you to draw certain conclusions from the +evidence or lack of evidence, and those arguments are +important. You should weigh and evaluate them carefully; but +you must not confuse them with the evidence. If your +recollection of the evidence differs from the statements of the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 188 of 257 +Charge +3022 +lawyers, follow your recollection. +You should draw no inference or conclusion for or +against any party by reason of lawyers making objections or my +rulings on such objections. Counsel have not only the right, +but the duty to make legal objections that they think are +appropriate. You should not be swayed against the government +or the defendant simply because counsel for either side has +chosen to make an objection. Similarly, statements made by +counsel when arguing the admissibility of evidence are not to +be considered as evidence. +If I comment on the evidence during my instructions, +do not accept my statements in place of your recollection. +Again, it is your recollection that governs. Do not concern +yourself with what was said at sidebar conferences or during my +discussions with counsel. Those discussions related to rulings +of law, which are my duty, and not to matters of fact, which +are your duty to determine. +At times I may have admonished a witness or directed a +witness to be responsive to questions or to keep his or her +voice up or to repeat an answer. My instructions were intended +only to clarify the presentation of evidence. You should draw +no inference or conclusion of any kind, favorable or +unfavorable, with respect to any witness or party in the case +by reason of any comment, question, or instruction of mine. +Nor should you infer that I have any views as to the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 189 of 257 +3023 +Charge +credibility of any witness, as to the weight of the evidence, +or as to how you should decide any issue that is before you. +That is entirely your role. +Instruction No. 5. Improper considerations. +Your verdict must be based solely upon the evidence or +the lack of evidence; and it is important that you discharge +your duties without discrimination. Thus, it would be improper +for you to consider any personal feelings you +. Maxwell's race, color, religious beliefs, national +ancestry, sexual orientation, gender identity, gender, economic +circumstances, or any other such factor. Similarly, it would +be improper for you to consider any personal feelings you may +have about the race, color religious beliefs, national +ancestry, sexual orientation, gender identity, gender, economic +circumstances, or any other similar factor of any other +witnesses or anyone else involved in this case. +Do not allow yourself to be influenced by personal +likes or dislikes, sympathy, prejudice, fear, public opinion, +or biases, including unconscious biases. Unconscious biases +are stereotypes, attitudes, or preferences that people may +consciously reject, but may be expressed without conscious +awareness, control, or intention. Like conscious bias, +unconscious bias can affect how we evaluate information and +make decisions. +Finally, it also would be improper for you to allow + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 190 of 257 +Charge +any feelings you might have about the nature of the crimes +charged to interfere with your decision-making process. +MS - +Maxwell is entitled to a trial free from prejudice; and our +judicial system cannot work unless you reach your verdict +through a fair and impartial consideration of the evidence. +Instruction No. 6. All parties are equal before the +3024 +law. +You are to perform the duty of finding the facts +without bias or prejudice as to any party. You are to perform +your final duty in an attitude of complete fairness and +impartiality. The fact that the prosecution is brought in the +name of the United States of America entitles the government to +no greater consideration than that given to any other party to +this litigation. By the same token, the government is entitled +to no less consideration. All parties stand as equals at the +bar of justice. +Instruction No. 7. Presumption of innocence and +burden of proof. +The law presumes the defendant to be innocent of all +charges against her. Ms. Maxwell has pleaded not guilty to the +charges in the indictment. As a result, the burden is on the +government to prove Ms. Maxwell's guilt beyond a reasonable +doubt as to each charge. This burden never shifts to the +defendant for the simple reason that the law never imposes upon +a defendant in a criminal case the burden or duty of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 191 of 257 +3025 +Charge +testifying, of calling any witness, or locating or producing +any evidence. +In other words, Ms. Maxwell does not have to +prove her innocence. +The presumption of innocence was with Ms. +Maxwell when the trial began, and remains with Ms. Maxwell +unless and until you're convinced that the government has +proven +her guilt beyond a reasonable doubt as to each charge. +Even though Ms. Maxwell has presented evidence in her +defense, the presumption of innocence remains with her, and it +is not her burden to prove that she is innocent. It's always +the government's burden to prove each of the elements of the +crimes charged beyond a reasonable doubt. +Instruction No. 8. Reasonable doubt. +The question that naturally arises is what is a +reasonable doubt? What does that phrase mean? The words +almost define themselves. +A reasonable doubt is a doubt based in reason and +arising out of the evidence in the case or the lack of +evidence. It is a doubt that a reasonable person has after +carefully weighing all of the evidence in the case. Reasonable +doubt is a doubt that appeals to your reason, your judgment, +your experience, and your common sense. Reasonable doubt is +not whim or speculation; it's not an excuse to avoid an +unpleasant duty, nor is it sympathy for the defendant. +The law in a criminal case is that it is sufficient if +the guilt of the defendant is established beyond a reasonable + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 192 of 257 3026 +Charge +doubt, not beyond all possible doubt. Therefore, if, after a +fair and impartial consideration of all of the evidence, you +can candidly and honestly say that you do have an abiding +belief of Ms. Maxwell's guilt as to any crime charged in this +case, such a belief as a prudent person would be willing to act +upon in important matters in the personal affairs of his or her +own life, then you have no reasonable doubt and, under such +circumstances, it is your duty to convict Ms. Maxwell of the +particular crime in question. +On the other hand, if, after a fair and impartial +consideration of all of the evidence, you can candidly and +honestly say that you are not satisfied with Ms. Maxwell's +guilt as to any charge, that you do not have an abiding belief +of her guilt as to that charge, in other words, if you have +such doubt as would reasonably cause a prudent person to +hesitate in acting in matters of importance in his or her own +affairs, then you have a reasonable doubt and, in that +circumstance, it is your duty to acquit Ms. Maxwell of that +charge. +Instruction No. 9. The indictment. +The defendant, Ghislaine Maxwell, has been formally +charged in what is called an indictment. As I instructed you +at the outset of the trial, the indictment is simply a charge +or accusation. It's not evidence; it's not proof of Ms. +Maxwell's guilt. It creates no presumption and it permits no + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 193 of 257 3027 +Charge +inference that Ms. Maxwell is guilty. Ms. Maxwell begins trial +with an absolutely clean slate and without any evidence against +her. You must give no weight to the fact that an indictment +has been returned against Ms. Maxwell. +I will not read the entire indictment to you at this +time; rather, I will first summarize the offenses charged in +the indictment, and then explain in detail the elements of each +of the offenses. +Instruction No. 10. Summary of indictment. +The indictment contains six counts or charges against +the defendant. Each count constitutes a separate offense or +crime. You must consider each count of the indictment +separately and you must return a separate verdict on each +count. I am briefly going to summarize each count and then +I'll give you the law in greater detail. +Count One of the indictment charges Ghislaine Maxwell, +the defendant, with conspiring -- that is, agreeing, with +others -- to entice an individual to travel in interstate +commerce to engage in sexual activity for which a person can be +charged with a criminal offense. Count One relates to multiple +alleged victims and the time period 1994 to 2004. +Count Iwo of the indictment charges the defendant with +enticing an individual to travel in interstate commerce to +engage in sexual activity for which a person can be charged +with a criminal offense. Count Iwo relates solely to Jane and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 194 of 257 +Charge +3028 +the time period 1994 to 1997. +Count Three of the indictment charges the defendant +with conspiring with others to transport an individual under +the age of 17 in interstate commerce with intent that the +individual engaged in sexual activity for which a person can be +charged with a criminal offense. Count Three relates to +multiple alleged victims and the time period 1994 to 2004. +Count Four of the indictment charges the defendant +with transporting an individual under the age of 17 in +interstate commerce, with the intent that the individual engage +in sexual activity for which a person could be charged with a +criminal offense. Count Four relates solely to Jane and the +time period 1994 to 1997. +Count Five of the indictment charges the defendant +with conspiring to engage in sex trafficking of individuals +under the age of 18. Count Five relates to multiple alleged +victims in the time period 2001 to 2004. +Count Six of the indictment charges the defendant with +sex trafficking of an individual under the age of 18. Count +Six relates solely to +and the time period 2001 to 2004. +Instruction No. 11. Multiple counts. +As I just explained, the indictment contains six +counts. Each count charges Ms. Maxwell with a different crime. +You must consider each count separately and return a separate +verdict of guilty or not guilty for each. Whether you find Ms. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 195 of 257 +3029 +Charge +Maxwell guilty or not guilty as to one offense should not +affect your verdict as to any other offense charged unless you +are instructed otherwise. +You +Maxwell guilty of a particular +count if the government has proven each element of the offense +charged with respect to that count beyond a reasonable doubt. +Instruction No. 12. Conspiracy and substantive +counts. +As I've just described, there are certain counts in +the indictment that are conspiracy counts, while others are +what are referred to as substantive counts. Unlike the +conspiracy charges which allege agreements to commit certain +offenses, the substantive counts are based on the actual +commission of offenses or aiding others to actually commit +offenses. +A conspiracy to commit a crime is an entirely separate +and different offense from the substantive crime which may be +the object of the conspiracy. Congress has deemed it +appropriate to make conspiracy standing alone a separate crime, +even if the object of the conspiracy is not achieved. The +essence of the crime of conspiracy is an agreement or +understanding to violate other laws. Thus, if a conspiracy +exists, even if it fails, it's still punishable as a crime. +Consequently, in a conspiracy charge, there's no need to prove +that the crime that was the objective of the conspiracy was + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 196 of 257 +3030 +Charge +actually committed. +By contrast, the substantive counts require proof that +the crime charge was actually committed, but do not require +proof of an agreement. Of course, if a defendant both +participates in a conspiracy to commit a crime and then +actually commits that crime, that defendant may be guilty of +both the conspiracy and the substantive crime, as I'll instruct +you shortly. +We will turn first to the substantive charges in the +indictment, which are more convenient to consider before the +conspiracy charges. Therefore, I'll instruct you first on +Counts Iwo, Four, and Six, and then I'll instruct you on Counts +One, Three, and Five. +Instruction No. 13. Count Iwo, enticement to engage +in an illegal sexual activity, the statute. +The relevant statute for Count Iwo is Title 18, United +States Code, Section 2422, which provides that: "Whoever +knowingly persuades, induces, entices, or coerces any +individual to travel in interstate commerce or in any territory +or possession of the United States to engage in any sexual +activity for which any person can be charged with a criminal +offense" is guilty of a federal crime. +Instruction No. 14. Count Iwo, enticement to engage +in illegal sexual activity, the elements. +To prove the defendant guilty of Count Iwo, the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 197 of 257 +Charge +3031 +government must prove each of the following three elements +beyond a reasonable doubt: +First, that the defendant knowingly persuaded or +induced or enticed or coerced an individual to travel in +interstate commerce as alleged in the indictment. +Second, that the individual traveled in interstate +commerce. +And third, that the defendant acted with the intent +that the individual would engage in sexual activity for which +any person could be charged with a criminal offense under New +York law as alleged in the indictment. +Count Iwo relates solely to Jane during the time +period 1994 to 1997. +Instruction No. 15. Count Iwo, enticement to engage +in illegal sexual activity. First element. +The first element of Count Iwo which the government +must prove beyond a reasonable doubt is that Ms. Maxwell +knowingly persuaded or induced or enticed or coerced an +individual to travel in interstate commerce as alleged in the +indictment. The terms "persuaded, induced, enticed, and +coerced" have their ordinary everyday meanings. The term +"interstate commerce" simply means movement from one state to +another. The term "state" includes a state of the United +States and the District of Columbia. +"Knowingly" defined. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 198 of 257 +3032 +Charge +Ms. Maxwell must have acted knowingly. An act is done +knowingly when it's done voluntarily and intentionally and not +because of accident, mistake, or some other innocent reason. +Now, knowledge is a matter of inference from the proven facts. +Science has not yet devised a manner of looking into a person's +mind and knowing what that person is thinking. Whether Ms. +Maxwell acted knowingly may be proven by Ms. Maxwell's conduct +and by all of the facts and circumstances surrounding the case. +Instruction No. 16. Count Iwo. Enticement to engage +in illegal sexual activity. Second element. +The second element of Count Iwo which the government +must prove beyond a reasonable doubt is that the individual +traveled in interstate commerce as alleged in the indictment. +As I just stated, "interstate commerce" simply means movement +between one state and another. +Instruction No. 17. Count Iwo. Enticement to engage +in illegal sexual activity. Third element. +The third element of Count Iwo which the government +must prove beyond a reasonable doubt is that Ms. Maxwell acted +with the intent that the individual would engage in sexual +activity for which any person can be charged with a criminal +offense under New York law. +"Intentionally" defined. +A person acts intentionally when the act is the +product of her conscious objective; that is, when she acts + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 199 of 257 +Charge +3033 +deliberately and purposely and not because of mistake or +accident. Direct proof of a person's intent is almost never +available; it would be a rare case where it could be shown that +a person wrote or stated that as of a given time, she committed +an act with a particular intent. Such direct proof is not +required. The ultimate fact of intent, though subjective, may +be established by circumstantial evidence based upon the +defendant's outward manifestations, her words, her conduct, her +acts, and all the surrounding circumstances disclosed by the +evidence and the rational or logical inferences that may be +drawn from them. +Significant or motivating purpose. +In order to establish this element, it's not necessary +for the government to prove that the illegal sexual activity +was Ms. Maxwell's sole purpose for encouraging Jane to travel +across state lines. A person may have several different +purposes or motives for such conduct, and each may prompt in +varying degree the person's actions. The government must prove +beyond a reasonable doubt, however, that a significant or +motivating purpose of encouraging Jane to travel across state +lines was that she would engage in illegal sexual activity. In +other words, the illegal sexual activity must not have been +merely incidental to the trip. +Violation of New York criminal law. +Count Iwo alleges that Ms. Maxwell enticed Jane to + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 200 of 257 3034 +Charge +travel across state lines with the intent that she would engage +in sexual activity for which a person could be charged with a +crime under the penal law of New York State, namely, New York +Penal Law Section 130.55. I instruct you as a matter of law +that sexual abuse in the third degree -- the offense set forth +in Count Two of the indictment -- was a violation of New York +State Penal Law from in or about 1994, up to and including in +or about 1997, at the time the acts are alleged to have been +committed. +A person violates New York State Penal Law Section +130.55, sexual abuse in the third degree, when he or she +subjects another person to sexual contact without the latter's +consent. Under New York law, "sexual contact" means any +touching of the sexual or other intimate parts of a person for +the purpose of gratifying the sexual desire of either party. +It includes the touching of the victim by the actor, whether +directly or through clothing; as well as the emission of +ejaculate by the actor upon any part of the victim, clothed or +unclothed. +Also under New York law, lack of consent can result +from incapacity to consent. A person less than 17 years old is +deemed incapable of consenting to sexual contact under New York +law. Thus, the law deems sexual contact with a person less +than 17 years old to be without that person's consent even if, +in fact, that person did consent. However, in order to find + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 201 of 257 3035 +Charge +that the intended acts were nonconsensual solely because of the +victim's age, you must find that Ms. Maxwell knew that Jane was +less than 17 years old. +Instruction No. 18. Count Four. Transportation of an +individual under the age of 17 to engage in illegal sexual +activity. The statute. +The relevant statute for Count Four is Title 18, +United States Code, Section 2423(a), which provides that a +person who "knowingly transports any individual under the age +of 17 years in interstate commerce, with the intent that such +individual engage in any sexual activity for which any person +can be charged with a criminal offense" is guilty of a federal +crime. +Instruction No. 19. Count Four. Transportation of an +individual under the age of 17 to engage in illegal sexual +activity. The elements. +In order to prove the defendant guilty of Count Four, +the government must establish each of the following three +elements of the crime beyond a reasonable doubt: +First, that the defendant knowingly transported an +individual in interstate commerce as alleged in the indictment. +Second, that the defendant transported the individual +with the intent that the individual would engage in sexual +activity for which any person can be charged with a criminal +offense under New York law as alleged in the indictment. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 202 of 257 3036 +Charge +And third, that the defendant knew that the individual +was less than 17 years old at the time of the acts alleged in +Count Four of the indictment. Count Four also relates solely +to Jane during the time period 1994 to 1997. +Instruction No. 20. Count Four. Transportation of an +individual under the age of 17 to engage in illegal sexual +activity. First element. +The first element of Count Four which the government +must prove beyond a reasonable doubt is that Ms. Maxwell +knowingly transported Jane in interstate commerce as alleged in +the indictment. The phrase "to transport an individual in +interstate commerce" means to move or carry or cause someone to +be moved or carried from one state to another. +The government does not have to prove that Ms. Maxwell +personally transported Jane across a state line; it is +sufficient to satisfy the element that Ms. Maxwell was actively +engaged, either personally or through an agent, in the making +of the travel arrangements such as by purchasing tickets +necessary for Jane to travel as planned. Ms. Maxwell must have +knowingly transported or caused the transportation of Jane in +interstate commerce. That means that the government must prove +that Ms. Maxwell knew both that she was causing Jane to be +transported and that Jane was being transported in interstate +commerce. As I've explained, an act is done knowingly when +it's done voluntarily and intentionally and not because of + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 203 of 257 +3037 +Charge +accident, mistake, or some innocent reason. +It is the defendant's intent that matters here. If +the government establishes each of the elements of the crime +beyond a reasonable doubt, then the defendant is guilty of this +charge whether or not the individual agreed or consented to +cross state lines. +Instruction No. 21. Count Four. Transportation of an +individual under the age of 17 to engage in illegal sexual +activity. Second element. +The second element of Count Four which the government +must prove beyond a reasonable doubt is that Ms. Maxwell +knowingly transported Jane in interstate commerce with the +intent that Jane engage in sexual activity for which any person +can be charged with a criminal offense in violation of New York +law. +Like Count Iwo, Count Four alleges sexual activity for +which an individual could be charged with a violation of New +York Penal Law, Section 130.55, sexual abuse in the third +degree. I've already instructed you regarding that crime, and +those instructions apply equally here. +In order to establish this element, it's not necessary +for the government to prove that the illegal sexual activity +was Ms. Maxwell's sole purpose for transporting Jane across +state lines. A person may have several different purposes or +motives for such conduct, and each may prompt in varying degree + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 204 of 257 +Charge +3038 +the person's actions. +The government must prove beyond a reasonable doubt, +however, that a significant or motivating purpose of Jane's +travel across state lines was that she would engage in illegal +sexual activity; in other words, the illegal sexual activity +must not have been merely incidental to the trip. +Instruction No. 22. Count Four. Transportation of an +individual under the age of 17 to engage in illegal sexual +activity. Third element. +The third element of Count Four which the government +must prove beyond a reasonable doubt is that Ms. Maxwell knew +that Jane was less than 17 years old at the time of the acts +alleged in Count Four of the indictment. +Instruction No. 23. Counts Iwo and Four. Failure to +accomplish intended activity is immaterial. +Now, with respect to Counts Iwo and Four, it is not a +defense that the sexual activity which may have been intended +by the defendant was not accomplished. In other words, it's +not necessary for the government to prove that anyone, in fact, +engaged in any sexual activity for which any person can be +charged with a criminal offense with the individual after she +was enticed for Count Iwo or transported for Count Four across +state lines. It is enough if the defendant has the requisite +intent at the time of the enticement or transportation. +Instruction No. 24. Count Six. Sex trafficking of an + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 205 of 257 3039 +Charge +individual under the age of 18. Statute. +The relevant statute for Count Six is Title 18, United +States Code, Section 1591, which provides, in pertinent part, +that: "Whoever knowingly, in or affecting interstate commerce, +recruits, entices, harbors, transports, provides, or obtains by +any means a person, knowing that the person has not attained +the age of 18 years and will be caused to engage in a +commercial sex act" is guilty of a crime. +Instruction No. 25. Count Six. Sex trafficking of an +individual under the age of 18. The elements. +To find the defendant guilty of Count Six, the +government must prove each of the following four elements +beyond a reasonable doubt: +First, the defendant knowingly recruited, enticed, +harbored, transported, provided, or obtained a person. +Second, the defendant knew that the person was under +the age of 18 years. +Third, the defendant knew that the person would be +caused to engage in a commercial sex act. +And fourth, the defendant's acts were in or affecting +interstate commerce. +The count relates solely to +during the time +period 2001 to 2004. +Instruction No. 26. Count Six. Sex trafficking of an +individual under the age of 18. First element. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 206 of 257 +3040 +Charge +The first element of Count Six which the government +must prove beyond a reasonable doubt is that Ms. Maxwell +knowingly recruited, enticed, harbored, transported, provided, +or obtained a person, +The terms "recruited, enticed, +harbored, transported, provided, and obtained" have their +ordinary everyday meanings. +And considering whether Ms. +Maxwell has acted knowingly, please apply the definition of +"knowingly" previously provided to you. +Instruction No. 27. Count Six. Sex trafficking of an +individual under the age of 18. Second element. +The second element of Count Six which the government +must prove beyond a reasonable doubt is that Ms. Maxwell knew +that +was under the age of 18. In considering whether +Ms. Maxwell knew that +had not attained the age of 18, +please apply the definition of "knowingly" previously provided +to you. +Instruction No. 28. Count Six. Sex trafficking of an +individual under the age of 18. Third element. +The third element of Count Six which the government +must prove beyond a reasonable doubt is that Ms. Maxwell knew +that the person +I would be caused to engage in a +commercial sex act. The term "commercial sex act" means any +sex act on account of which anything of value is given to or +received by any person. The thing of value may be money or any +other tangible or intangible thing of value that may be given + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 207 of 257 +Charge +to or received by any person, regardless of whether the person +who receives it is the person performing the commercial sex +act. It's not relevant whether or not +was a willing +participant in performing commercial sex acts when she was +under the age of 18 years old. +Consent by the person is not a defense to the charge +in Count Six of the indictment if +was under the age of +18 at the time the commercial sex acts took place. It's also +not required that the person actually performed a commercial +sex act, so long as the government has proved that Ms. Maxwell +recruited, enticed, harbored, transported, provided, or +obtained the person for the purpose of engaging in commercial +sex acts. +3041 +Instruction No. 29. Count Six. Sex trafficking of an +individual under the age of 18. Fourth element. +The fourth and final element of Count Six which the +government must prove beyond a reasonable doubt is that Ms. +Maxwell's conduct was in interstate commerce or affected +interstate commerce. "Interstate commerce" simply means the +movement of goods, services, money, and individuals between any +two or more states. +I instruct you that acts and transactions that cross +state lines or which affect the flow of money in the stream of +commerce to any degree, however minimal, are acts and +transactions affecting interstate commerce. For instance, it + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 208 of 257 +Charge +3042 +affects interstate commerce to use products that traveled in +interstate +commerce. +It's not necessary for the government to +prove that Ms. Maxwell specifically knew or intended that her +conduct would affect interstate commerce; it's only necessary +that the natural consequences of such conduct would affect +interstate commerce in some way, even if minor. +If you find beyond a reasonable doubt that the +recruitment, enticement, harboring, transportation, providing, +or obtaining of a person for the purpose of engaging in +commercial sex acts was economic in nature and involved the +crossing of state lines or was economic in nature and otherwise +affected the flow of money to any degree, however minimal, you +may find that the interstate commerce requirement of the +offense of sex trafficking of an individual under the age of 18 +has been satisfied. +I further instruct you that to find this element has +been proven beyond a reasonable doubt, it's not necessary for +you to find that any interstate travel occurred. Proof of +actual travel is not required. +Instruction No. 30. Counts Iwo, Four, and Six. +Aiding and abetting. +In connection with the crimes charged in Counts Iwo, +Four, and Six, the defendant is also charged with aiding and +abetting the commission of those crimes. Aiding and abetting +liability is its own theory of criminal liability. In effect, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 209 of 257( +3043 +Charge +it's a theory of liability that permits a defendant to be +convicted of a specified crime if the defendant, while not +herself committing the crime, assisted another person or +persons in committing the crime. As to Counts Iwo, Four, and +Six, therefore, the defendant can be convicted either if she +committed the crime herself or if another person committed the +crime and the defendant aided and abetted that person to commit +that crime. +Under the federal aiding and abetting statute, whoever +"aids, abets, counsels, commands, induces, or procures" the +commission of an offense is punishable as a principle. You +should give those words their ordinary meaning. A person aids +or abets a crime if she knowingly does some act for the purpose +of aiding or encouraging the commission of that crime with the +intention of causing the crime charged to be committed. +"To counsel" means to give advice or recommend. "To +induce" means to lead or move by persuasion or influence as to +some action or state of mind. +"To procure" means to bring +about by unscrupulous or indirect means. "To cause" means to +bring something about to effect something. In other words, +it's not necessary for the government to show that Ms. Maxwell +herself physically committed the crime charged in order for you +to find her guilty. This is because a person who aids, abets, +counsels, commands, induces, or procures the commission of a +crime is just as guilty of that offense as if she committed it + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 210 of 257 3044 +Charge +herself. Accordingly, you +Maxwell guilty of the +offenses +charged in Counts Iwo, Four, and Six if you find +beyond a +reasonable doubt that the government has proven that +another person actually committed the offense with which Ms. +Maxwell is charged, and that Ms. Maxwell aided, abetted, +counseled, commanded, induced, or procured that person to +commit the crime. +As you can see, the first requirement is that another +person has committed the crime charged. Obviously, no one can +be convicted of aided and abetting the criminal acts of another +if no crime was committed by the other person. But if you find +that a crime was committed, then you must consider whether Ms. +Maxwell aided or abetted the commission of the crime. +To aid or abet another to commit a crime, it is +necessary that the government prove that the defendant +willfully and knowingly associated herself in some way with the +crime committed by the other person, and willfully and +knowingly sought by some act to help commit the crime succeed. +However, let me caution you that the mere presence of +the defendant where a crime is being committed, even coupled +with knowledge by the defendant that a crime is being +committed, or the mere acquiescence by a defendant in the +criminal conduct of others, even with guilty knowledge, is not +sufficient to make the defendant guilty under this approach of +aiding and abetting. Such a defendant would be guilty under + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 211 of 257 +3045 +Charge +this approach of aiding and abetting only if, in addition to +knowing of the criminal activity, she actually took actions +intended to help it succeed. An aider and abettor must know +that the crime is being committed and act in a way that is +intended to bring about the success of a criminal venture. +To determine whether Ms. Maxwell aided or abetted the +commission of the crime with which she is charged, ask yourself +these questions: +One. Did the defendant participate in the crime +charged as something she wished to bring about? +Iwo. Did the defendant knowingly and willfully +associate herself with the criminal venture? +Three. Did the defendant seek by her actions to make +the criminal venture succeed? +If she did, then Ms. Maxwell is an aider and abettor +and, therefore, guilty of the offense. If, on the other hand, +your answer to any of these questions is no, then Ms. Maxwell +is not an aider and abettor, and you must find her not guilty +under that theory. +Instruction No. 31. Counts One, Three, and Five. +Conspiracy to violate federal laws. Conspiracy and substantive +counts. +Counts One, Three, and Five of the indictment each +charge Ms. Maxwell with participating in a "conspiracy." The +statute for Counts One, Three, and Five is Title 18, United + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 212 of 257 3046 +Charge +States Code, Section 371, which provides that: "If two or more +people conspire to commit any offense against the United +States, and one or more of such persons do any act to effect +the object of the conspiracy, each person is guilty of a +federal crime." +As I'll explain, a conspiracy is a kind of criminal +partnership, an agreement of two or more people, to join +together to accomplish some unlawful purpose. The crime of +conspiracy to violate federal laws is an independent offense; +it is separate and distinct from the actual violation of any +specific federal laws which the law refers to as "substantive +crimes." +Indeed, you +• Maxwell guilty of conspiring +to violate federal laws, even if you find that the crime which +was the object of the conspiracy was never actually committed. +As I'll explain, the three different conspiracy counts are +separate offenses, and each conspiracy alleges a different +purpose, which I'll describe to you shortly. +Instruction No. 32. Counts One, Three, and Five. +Conspiracy to violate federal law. The elements. +To prove the defendant guilty of the crime of +conspiracy, the government must prove each of the following +four elements beyond a reasonable doubt: +First, that two or more persons entered the unlawful +agreement charged in the particular count of the indictment. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 213 of 257 +Charge +Second, that the defendant knowingly and willfully +became a member of that conspiracy. +Third, that one of the members of the conspiracy +knowingly committed at least one overt act. +And fourth, that the overt act which you find to have +been committed was committed to further some objective of that +conspiracy. +3047 +reasonable doubt. +Each of these elements must be satisfied beyond a +Now, let us separately consider each of these +elements. +Instruction No. 33. Counts One, Three, and Five. +Conspiracy to violate federal law. First element. +Starting with the first element, what is a conspiracy? +A conspiracy is an agreement or an understanding +between two or more persons to accomplish by joint action a +criminal or unlawful purpose. The essence of the crime of +conspiracy is the unlawful agreement between two or more people +to violate the law. +As I mentioned earlier, the ultimate success of the +conspiracy, meaning the actual commission of the crime that is +the object of the conspiracy, is not an element of the crime of +conspiracy. In order to show that a conspiracy existed, the +evidence must show that two or more people in some way or +manner, through any contrivance, explicitly or implicitly -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 214 of 257 +3048 +Charge +that is, spoken or unspoken -- came to a mutual understanding +to violate the law and to accomplish an unlawful plan. +Express language or specific words are not required to +indicate assent or attachment to a conspiracy. If you find +beyond a reasonable doubt that two or more persons came to an +understanding, express or implied, to violate the law and to +accomplish an unlawful plan, then the government will have +sustained its burden of proof as to this element. +To show that a conspiracy existed, the government is +not required to show that two or more people sat around a table +and entered into a solemn pact orally or in writing stating +that they had formed a conspiracy to violate the law, spelling +out all of the details. Common sense tells you that when +people, in fact, agree to enter into a criminal conspiracy, +much is left to the unexpressed understanding. It is rare that +a conspiracy can be proven by direct evidence of an explicit +agreement. Conspirators do not usually reduce their agreements +to writing or acknowledge them before a notary public, nor do +they publicly broadcast their plans. +In determining whether an agreement existed, you may +consider direct as well as circumstantial evidence. The old +adage "actions speak louder than words" applies here. Often +the only evidence that is available with respect to the +existence of a conspiracy is that of disconnected acts and +conduct on the part of the alleged individual co-conspirators. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 215 of 257 +3049 +Charge +When taken all together and considered as whole, however, these +acts +and conduct may +warrant the inference that a conspiracy +existed as conclusively as would direct proof, such as evidence +of an express agreement. +In short, as far as the first element of the +conspiracy is concerned, the government must prove beyond a +reasonable doubt that at least two alleged conspirators came to +a mutual understanding, either spoken or unspoken, to violate +the law in the manner charged in Counts One, Three, and Five of +the indictment. +Instruction No. 34. Counts One, Three, and Five. +Conspiracy to violate federal law. First element. Object of +the conspiracy. +Count One charges Ms. Maxwell with participating in a +conspiracy from at least in or about 1994, up to and including +in or about 2004, to entice individuals under the age of 17 to +travel to engage in sexual activity for which any person can be +charged with a criminal offense. The object of the conspiracy +charged in Count One of the indictment is to entice individuals +under the age of 17 to travel to engage in sexual activity for +which any person could be charged with a criminal offense. +I have already reviewed the elements of that offense +in connection with Count Iwo. If you find beyond a reasonable +doubt that the defendant agreed with at least one other person +that those elements be done, then the enticement of individuals + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 216 of 257 +3050 +Charge +under the age of 17 to travel to engage in sexual activity for +which any person could be charged with a criminal offense +objective would be proved. +Count Three charges the defendant with participating +in a conspiracy from at least in or about 1994, up to and +including in or about 2004, to transport individuals under the +age of 17 with the intent to engage in sexual activity for +which any person can be charged with a criminal offense. +The object of the conspiracy charged in Count Three of +the indictment is to transport individuals under the age of 17 +with the intent to engage in sexual activity for which any +person can be charged with a criminal offense. I've already +reviewed the elements of that offense in connection with Count +Four. If you find beyond a reasonable doubt that the defendant +agreed with at least one other person that those elements be +done, then the transportation of individuals under the age of +17 with the intent to engage in sexual activity for which any +person can be charged with a criminal offense objective would +be proved. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 217 of 257 3051 +Charge +THE COURT: Finally, Count Five charges Ms. Maxwell +with participating in a conspiracy from at least in or about +2001 up to and including in or about 2004 to commit sex +trafficking of individuals under the age of 18. +The object of the conspiracy charged in Count Five of +the indictment is to commit sex trafficking of individuals +under the age of 18. I've already reviewed the elements of +that offense in connection with Count Six. +If you find beyond a reasonable doubt that Ms. Maxwell +agreed with at least one other person that those elements be +done, then the sex trafficking of individuals under the age of +18 objective would be proved. +Instruction No. 35, Counts One, Three, and Five: +Conspiracy to Violate Federal Law - Second Element: Membership +in the Conspiracy. +With respect to each of Counts One, Three, and Five, +if you conclude that the government has proven beyond a +reasonable doubt that the relevant conspiracy existed and that +the conspiracy had the object I just mentioned, then you +must - you must next consider the second element, namely, +whether Ms. Maxwell knowingly and willfully participated in the +conspiracy knowing its unlawful purpose and intending to +further its unlawful objectives. +In order to satisfy the second elements of Counts One, +Three, or Five, the government must prove beyond a reasonable + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 218 of 257 3052 +Charge +doubt that Ms. Maxwell knowingly and willfully entered into the +conspiracy charged in the particular count with a criminal +intent, that is with a purpose to violate the law, and that she +agreed to take part in the conspiracy to further promote and +cooperate in its unlawful objective. +Willfully and Knowingly. +An act it is done knowingly and willfully if it's done +deliberately and purposefully. That is, Ms. Maxwell's actions +must have been her conscious objective rather than a product of +a mistake or accident, mere negligence or some other innocent +reason. +To satisfy its burden of proof that Ms. Maxwell +willfully and knowingly became a member of a conspiracy to +accomplish an unlawful purpose, the government must prove +beyond a reasonable doubt Ms. Maxwell knew that she was a +member of an operation or conspiracy to accomplish that +unlawful purpose and that her action of joining such an +operation or conspiracy was not due to carelessness, +negligence, or mistake. +Now, as I've said, knowledge is a matter of inference +from the proven facts. Science has not yet devised a manner of +looking into a person's mind and knowing what that person is +thinking. However, you do have before you the evidence of +certain acts of conversations alleged to have taken place +involving Ms. Maxwell or in her presence. You may consider + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 219 of 257 +3053 +Charge +this evidence in determining whether the government has proven +beyond a reasonable doubt Ms. Maxwell's knowledge of the +unlawful purposes of the conspiracy. +It is for you to determine whether the government has +established beyond a reasonable doubt that such knowledge and +intent on the part of Ms. Maxwell existed. It is important for +you to know that Ms. Maxwell's participation in the conspiracy +must be established by independent evidence of her own acts or +statements, as well as those of the alleged coconspirators and +the reasonable inferences that may be drawn from that evidence. +It's not necessary for government to show that +Ms. Maxwell was fully informed of all the details of the +conspiracy in order for you to infer knowledge on her part. To +have guilty knowledge, Ms. Maxwell need not have known the full +extent of the conspiracy or all of the activities of all of its +participants. It's not even necessary for a defendant to know +every other member of the conspiracy. +In addition, the duration and extent of Ms. Maxwell's +participation has no bearing on the issue of her guilt. She +need not have joined the conspiracy at the outset. +have joined it for any purpose at any time in its progress +and she will be held responsible for all that was done before +she joined and all that was done during the conspiracy's +existence while she was a member. Each member of a conspiracy +may perform separate and distinct acts and may perform them at + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 220 of 257 3054 +Charge +different times. Indeed, a single act may be enough to bring +one within the membership of the conspiracy, provided that +Ms. Maxwell was aware of the conspiracy, and knowingly +associated herself with its criminal aims. It does not matter +whether Ms. Maxwell's role in the conspiracy may have been more +limited than or different in nature or the length of time from +the roles of her coconspirators, provided she was, herself, a +participant. +I want to caution you, however, that Ms. Maxwell's +mere presence at the scene of the alleged crime does not by +itself make her a member of the conspiracy. Similarly, a +person may know, assemble with, or be friendly with one or more +members of a conspiracy without being a conspirator herself. I +want to caution you that mere knowledge or acquiescence, +without participation in the unlawful plan, is not sufficient. +In other words, knowledge without agreement and participation +is not sufficient. What is necessary is that Ms. Maxwell -- is +that Ms. Maxwell participate in the conspiracy with knowledge +of its unlawful purposes and with an intent to aid in the +accomplishment of its unlawful objectives. +It's also not necessary that Ms. Maxwell receive or +even anticipate any financial benefit from participating in the +conspiracy as long as she participated in it in the way I've +explained. That said, while proof of a financial interest in +the outcome of a scheme is not essential, if you find that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 221 of 257 +3055 +Charge +an interest, that is a factor which you +may properly consider in determining whether or not she was a +member of the conspiracy charged in the indictment. +Once a conspiracy is formed, it is presumed to +continue until either its objective is accomplished or there is +some affirmative act of termination by the members. +So too, +once a person is found to be a member of a conspiracy, she is +presumed to continue as a member in that conspiracy until the +conspiracy is terminated unless it's shown by some affirmative +proof that the person withdrew and disassociated herself +prosecute it. +In sum, the defendant, with an understanding of the +unlawful nature of the conspiracy, may have intentionally +engaged, advised, or assisted in the conspiracy for the purpose +of furthering an illegal undertaking. The defendant thereby +becomes a knowing and willful participant in the unlawful +agreement, that is to say, she becomes a conspirator. +Instruction No. 36: Counts One, Three, and Five: +Conspiracy to Violate Federal Law - Third Element. +The third element that the government must prove +beyond a reasonable doubt to establish the offense of +conspiracy is that at least one overt act was knowingly +committed by at least one of the conspirators. The overt act +element requires the government to show something more than +mere agreement. Some overt step or action must have been taken + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 222 of 257 3056 +Charge +by at least one of the conspirators in furtherance of that +conspiracy. +In other words, the government must show that the +agreement went beyond the mere talking stage. It must show +that at least one the conspirators in furtherance of the +conspiracy. +With respect to the overt acts for Count One, the +indictment alleges as follows: +One, between in or about 1994 and in or about 1997, +when Jane was under the age of 17, Maxwell participated in +multiple group sexual encounters with Epstein and Jane in New +York and Florida. +Two, in or about 1996, when Jane was under the age of +17, Jane was enticed to travel from Florida to New York for +purposes of sexually abusing her at the New York residence in +violation of New York Penal Law, Section 130.55. +Three, in or about 1996, Maxwell provided +an unsolicited massage in New Mexico during which +with +was +topless. +Four, between in or about 2001 and in or about 2002, +when +was under the age of 17, Maxwell and Epstein +invited +to travel from Florida to a place outside of +Florida with Epstein. +With respect to the overt acts to Count Three, the +indictment alleges as follows: +Between in or about 1994 and in or about 1997 when + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 223 of 257 3057 +Charge +Jane was under the age of 17, Maxwell participated in multiple +group sexual encounters with Epstein and Jane in New York and +Florida. +Two, in or about 1996 when Jane was under the age of +17, Jane was enticed to travel from Florida to New York for +purposes of sexually abusing her at the New York residence in +violation of New York Penal Law, Section 130.55. +Three, in or about 1996, Maxwell provided +with +an unsolicited massage in New Mexico during which | +was +topless. +when +invited +Four, between in or about 2001 and in or about 2002 +was under the age of 17, Maxwell and Epstein +to travel from Florida to a place outside of +Florida with Epstein. +With respect to the overt acts for Count Five, the +indictment alleges as follows: +One, between in or about 2001 and in or about 2004, +Epstein and Maxwell recruited +to engage in sex acts +with Epstein at the Palm Beach residence after which Epstein +and, at times, Maxwell provided +with hundreds of +dollars in cash for each encounter. +truthfully told +both Epstein and Maxwell her age. +Iwo, between in or about 2001 and in or about 2004, +Epstein and Maxwell both encouraged and enticed +to +recruit other girls to engage in paid sex acts with Epstein, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 224 of 257 +Charge +3058 +which she did. +Three, between in or about 2001 and in or about 2004, +Epstein's employees sent | +gifts, including lingerie from +an address in the Southern District of New York to +residence in Florida. +For example, on one occasion, in or +about October of 2002, Epstein caused a package to be sent by +Federal Express from an address in Manhattan to +in +Florida. +Four, on multiple occasions between in or about 2001 +and in or about 2004, Epstein, Maxwell, or one of Epstein's +other employees called +to schedule an appointment for +to massage Epstein. For example, in or about April of +2004 or May of 2004, another employee of Epstein's called +to schedule such appointments. +In order for government to satisfy this element, it's +not necessary for the government to prove that Ms. Maxwell +committed the overt act. It is sufficient for the government +to show that any of the members of the conspiracy knowingly +committed some overt act in furtherance of the conspiracy. +Further, the overt act need not be one that is alleged +in the indictment. Rather, it can be any overt act that is +substantially similar to those acts alleged in the indictment, +if you are convinced that the act occurred while the conspiracy +was still in existence and that it was done in furtherance of +the conspiracy as described in the indictment. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 225 of 257 +3059 +Charge +In addition, you need not be unanimous as to which +overt act you find to have been committed. It +is sufficient as +long as all of you find that at least one overt act was +committed by one of the conspirators. +As to Counts One and Three, the government has to +prove that at least one of the overt acts in furtherance of +that conspiracy involved a witness other than +• Put +simply, you +Maxwell on Counts One or Three +solely on the basis of +testimony or an overt act +involving +You are further instructed that the overt act need not +have been committed at precisely at the time alleged in the +indictment. It is sufficient if you are convinced beyond a +reasonable doubt that it occurred at or about the time and +place stated. +Instruction No. 37: Counts One, Three, and Five: +Conspiracy to Violate Federal Law - Fourth Element. +The fourth and final element which the government must +prove beyond a reasonable doubt is that the overt act was +committed for the purpose of carrying out the unlawful +agreement. +In order for the government to satisfy this element, +it must prove beyond a reasonable doubt that at least one overt +act was knowingly and willfully done by at least one +coconspirator in furtherance of some object or purpose of the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 226 of 257 3060 +Charge +conspiracy as charged in the indictment. +In this regard, you should bear in mind that the overt +act, standing alone, may be an innocent, lawful act. +Frequently, however, an apparently innocent act sheds its +harmless character if it is a step in carrying out, promoting, +aiding, or assisting the conspiratorial scheme. You are +therefore instructed that the overt act does not have to be an +act which, in and of itself, is criminal or constitutes an +objective of the conspiracy. +Instruction No. 38: Counts One, Three, and Five: +Liability for Acts and Declarations of Coconspirators. +When people enter into a conspiracy to accomplish an +unlawful end, they become agents or partners of one another in +carrying out the conspiracy. Accordingly, the reasonably +foreseeable acts, declarations, statements, and omissions of +any member of the conspiracy and in furtherance of the common +purse purpose of the conspiracy are deemed under the law to be +acts of all of the members. All of the members are responsible +for such acts, declarations, and statements, and omissions. +If you find beyond a reasonable doubt that the +defendant knowingly and willfully participated in the +conspiracy charged in the indictment, then any acts done or +statements made in furtherance of the conspiracy by persons +also found by you to have been members of that conspiracy may +be considered against the defendant. That is so even if such + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 227 of 257 +Charge +3061 +acts were done and statements were made in the defendant's +absence and without her knowledge. However, before you may +consider the statements or act of a coconspirator in deciding +the issue of the defendant's guilt, you must first determine +that the acts and statements were made during the existence and +if in furtherance of the unlawful scheme. If the acts were +done or the statements made by someone whom you do not find to +have been a member of the conspiracy at the time of the acts or +statements or if they were not done or said in furtherance of +the conspiracy, they may not be considered by you as evidence +against the defendant. +Instruction No. 39: Conscious Avoidance. +This includes my instruction on the crimes charged in +the indictment, but before I move on to my remaining +instructions, I want to instruct you on the instruction of +conscious avoidance. +Each of the counts charged in the indictment requires +the government to prove the defendant acted knowingly. As I've +already defined that term, if a person is actually aware of a +fact, then she knows that fact, but in determining whether the +defendant acted knowingly, you may also consider whether the +defendant deliberately closed her eyes to what otherwise would +have been obvious. +To be clear, the necessary knowledge on the part of +the defendant with respect to any particular charge cannot be + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 228 of 257 +Charge +established by a showing that the defendant was careless, +negligent, or foolish. However, one may not willfully and +intentionally remain ignorant of a material fact and important +to her conduct in order to escape the consequences of criminal +law. The law calls this conscious avoidance or willful +blindness. +An argument by the government of conscious avoidance +is not a substitute for proof, it is simply another factor that +you, the jury, may consider in deciding what the defendant +knew. +Thus, if you find beyond a reasonable doubt that the +defendant was aware that there was a high probability a crime +was being committed but that the defendant deliberately and +consciously avoided confirming this fact such as by +purposefully closing her eyes to it or intentionally failing to +investigate it, then you may treat this deliberate avoidance of +positive knowledge as the equivalent of knowledge, unless you +find that defendant actually believed that she was not engaged +in such unlawful behavior. In other words, a defendant cannot +avoid criminal responsibility for her own conduct by +deliberately closing her eyes or remaining purposefully +ignorant of facts which would confirm to her that she was +engaged in unlawful conduct. +With respect to the conspiracy counts, you must also +keep in mind that there is an important difference between +knowingly and intentionally participating in a conspiracy, on +3062 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 229 of 257 +3063 +Charge +the one hand - and which I just explained to you - and knowing +the specific objective of the conspiracy on the other. You may +consider conscious avoidance in deciding whether the defendant +knew the objective of a conspiracy, that is whether she +reasonably believed that there was a high probability that a +goal of the conspiracy was to commit the crime charged as +objects of the conspiracy and took deliberate and conscious +action to avoid confirming that fact, but participated in the +conspiracy anyway. But conscious avoidance cannot be used as a +substitute for finding that the defendant knowingly and +intentionally joined the conspiracy in the first place. It is +logically impossible for a defendant to intend to agree to join +a conspiracy if she does not actually know it exists. +In sum, if you find the defendant believed there was a +high probability that a fact was so and that the defendant took +deliberate and conscious action to avoid learning the truth of +the fact, you may find that the defendant acted knowingly with +respect to that fact. However, +if you find that the defendant +actually believed the fact was not so, then you may not find +that she has acted knowingly with respect to that fact. +Instruction No. 40: Venue. +With respect to each of the counts of the indictment, +you must also consider the issue of venue, namely whether any +act in furtherance of the unlawful activity charged in that +count occurred within the Southern District of New York. The + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 230 of 257 +3064 +Charge +Southern District of New York encompasses the following +counties +New York County, i.e.. +Manhattan, Bronx, Westchester, +Rockland, Putnam, Dutchess, Orange, and +Counties. +Anything that occurs in any of those places occurs in the +Southern District of New York. +Venue must be examined separately for each count in +the indictment. Venue on one count does not establish venue on +another. If applicable, you may rely on the same evidence to +establish evidence on multiple counts. +The government need not prove venue beyond a +reasonable doubt, but only by a mere preponderance of the +evidence. A preponderance of the evidence means more likely +than not. Thus, the government, which does bear the burden of +proving venue, has satisfied that if you conclude that it is +more likely than not that some furtherance of each charged +offense occurred in the Southern District of New York. If, on +the other hand, you find that the government has failed to +prove the venue requirement as to a particular offense, then +you must acquit Ms. Maxwell of that offense even if all the +other elements of the offense are proven. +Instruction No. 41: Time of Offense. +The indictment alleges that certain conduct occurred +on or about various dates or during various time periods. It's +not necessary, however, for the government to prove that any +conduct alleged occurred exactly on such dates or throughout + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 231 of 257 +Charge +any such time periods. As long as the conduct occurred around +any dates or within any time periods the indictment alleges it +occurred, that is sufficient. +Instruction No. 42: Direct and Circumstantial +3065 +Evidence. +I turn now to some general instructions. +There are two types of evidence that you may use in +reaching your verdict. One type of evidence is direct +evidence. One kind of direct evidence is a witness's testimony +about something that the witness knows by virtue of his or her +own senses, something that the witness has seen, smelled, +touched, or heard. Direct evidence may also be in the form of +an exhibit. +The other type of evidence is circumstantial evidence. +Circumstantial evidence is evidence that tends to prove one +fact by proof of other facts. +There a simple example of circumstantial evidence, +it's often used in the courthouse. Assume that when you came +into the courthouse this morning, the sun was shining and it +was a nice day. Assume that there are blinds on the courtroom +windows that are drawn and you can't look outside. As you're +sitting here, someone walks in with an umbrella that's dripping +wet. Someone else then walks in with a raincoat that's also +dripping wet. Now you can't look outside to courtroom and you +can't see whether or not it's raining, so you have no direct + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 232 of 257 +3066 +Charge +evidence of that fact, but on the combination of the facts that +I've asked you to assume, it would be reasonable and logical +for you to conclude that between the time you arrived at the +courthouse and the time these people walked in it had started +to rain. +That's all there is to circumstantial evidence. You +infer based on reason, experience, and common sense from an +established fact the existence or the nonexistence of some +other fact. Many facts, such as a person's state of mind, can +only rarely be proved by direct evidence. +Circumstantial evidence is of no less value than of +direct evidence. It is a general rule that the law makes no +distinction between direct and circumstantial evidence, but +simply requires that, before convicting Ms. Maxwell, you, the +jury, must be satisfied of her guilt beyond a reasonable doubt +from all of the evidence in the case. +Instruction No. 43: Inferences. +During the trial, and as I give you these +instructions, you've heard and will hear the term inference. +For instance, if, in their closing arguments, attorneys have +asked you to infer based on your reason, experience, and common +sense from one or more established facts the existence of some +other fact. I've instructed you on circumstantial evidence in +that it involves inferring a fact based on other facts, your +reason, and common sense. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 233 of 257 +3067 +Charge +What is an inference? What does it mean to infer +something? An inference is not a suspicion or a guess. It is +a reasoned, logical decision to conclude that a disputed fact +exists based on another fact that you are satisfied exists. +There are times when different inferences may be drawn +from different facts, whether proved by direct or +circumstantial evidence. The government asks you to draw one +set of inferences while the defense asks you to draw another. +It is for you and you alone to decide what inferences you will +draw. The process of drawing inferences from facts in evidence +is not a matter of guesswork or speculation. An inference is a +deduction or a conclusion that you, the jury, are permitted but +not required to draw from the facts that have been established +by either direct or circumstantial evidence. +In drawing inferences, you should exercise your common +sense. Therefore, while you're considering the evidence +presented to you, you may draw from the facts that you find to +be proven such reasonable inferences as would be justified in +light of your experience. Some inferences, however, are +impermissible. You may not infer that Ms. Maxwell is guilty of +participating in criminal conduct if you find merely that she +was present at the time the crime was being committed and had +knowledge that it was being +committed. Nor may you use +evidence that I instructed you was admitted for a limited +purpose for any inference beyond that limited purpose. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 234 of 257 +Charge +3068 +In addition, you may not infer that Ms. Maxwell is +guilty of participating in criminal conduct merely from the +fact that she associated with other people who were guilty of +wrongdoing or merely because she had has or had knowledge of +the wrongdoing of others. +Here again, let me remind you that, whether based upon +direct or circumstantial evidence or upon logical reasonable +inferences drawn from such evidence, you must be satisfied of +the guilt of Ms. Maxwell as to each count charged before you +may convict her as to that count. +Instruction No. 44: Credibility of Witnesses. +You've had the opportunity to observe the witnesses. +It is your job to decide how believable each witness was in his +or her testimony. You are the sole judges of the credibility +of the witnesses. +How do you evaluate the credibility or believability +of the witness? The answer is that you use your common sense, +judgment, and experience. +Common sense is your greatest asset +as a juror. You should ask yourself, did the witness impress +to you as honest, open, and candid? Or did the witness appear +evasive as though the witness was trying to hide something? +How responsive was the witness to the questions asked on direct +examination and on cross examination? Consider the witness's +demeanor, manner of testifying, and accuracy of the witness's +recollection. In addition, consider how well the witness + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 235 of 257 +3069 +Charge +recounted what was heard or observed as the witness may be +honest but mistaken. +If you find that a witness is intentionally telling a +falsehood, that is always a matter of importance that you +should weigh carefully. If you find that any witness has lied +under oath at this trial, you should view the testimony of such +a witness cautiously and weigh it with great care. You may +reject the entirety of the witness's testimony, part of it, or +none of it. It's for you to decide how much of any witness's +testimony, if any, you wish to credit. A witness may be +inaccurate, contradictory, or even untruthful in some respects, +and yet entirely believable and truthful in other respects. +It's for you to determine whether such untruths or +inconsistencies are significant or inconsequential and whether +to accept or reject all or to accept some and reject the +balance of the testimony of any witness. +In evaluating the credibility of the witnesses, you +should take into account any evidence that the witness who +testified may benefit in some way from the outcome of this +case. If you find that any witness whose testimony you're +considering may have an interest in the outcome of the trial, +then you should bear that factor in mind when evaluating the +credibility of his or her testimony and accept it with great +care. This is not to suggest that any witness who has an +interest in the outcome of the case would testify falsely. It + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 236 of 257 +3070 +Charge +is for you to decide to what extent, if at all, the witness's +interest has affected or colored his or her testimony. +You have heard the testimony of a witness who was +previously convicted of a crime punishable by more than one +year in jail. This prior conviction was put into evidence for +you to consider in evaluating the witness's credibility. You +may consider the fact that the witness who testified is a +convicted felon in deciding how much of his or her testimony to +accept and what weight, if any, it should be given. You're not +required to accept testimony even though the testimony is not +contradicted and the witness's testimony is not challenged. +You may decide because of the witness's bearing or demeanor or +because of the inherent improbability of the testimony or for +other reasons sufficient to yourselves that the testimony is +not worthy of belief. On the other hand, you may find because +of a witness's bearing and demeanor and based upon your +consideration of all of the other evidence in the case that the +witness is truthful. +Thus, there is no magic formula by which you can +evaluate testimony. You bring to this courtroom all your +experience and common sense. You determine for yourselves in +many circumstances the reliability of statements that are made +by others to you and upon which you are asked to rely and act. +You may use the same tests here that you use in your everyday +lives. You may consider the interest of any witness in the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 237 of 257 +Charge +3071 +outcome of this case and any bias or prejudice of any such +witness, and this is true regardless of who called or +questioned the witness. +Finally, as you know, I have permitted certain +witnesses to be referred to in open court either by their first +name or a pseudonym. As I explained to you in my preliminary +instructions before opening statements, this process is to +protect the privacy of witnesses as this case has received +significant attention in the media. I instruct you again that +this process should not bear in any way on your evaluation of +the evidence or credibility of any witness in this case. +Instruction No. 45: Credibility of Witnesses - +Impeachment by Prior Inconsistent Statement. +You have heard evidence that a witness made a +statement on an earlier occasion which counsel argues is +inconsistent with the witness's trial testimony. Evidence of a +prior inconsistent statement is not to be considered by you as +affirmative evidence bearing on Ms. Maxwell's guilt. Evidence +of the prior inconsistent statement was placed before you for +the more limited purpose of helping you decide whether to +believe the trial testimony of the witness who contradicted him +or herself. If you find that the witness made an earlier +statement that conflicts with his or her trial testimony, you +may consider that fact in deciding how much of the trial +testimony, if any, to believe. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 238 of 257 +3072 +Charge +In making this determination, you may consider whether +the witness purposefully made a false statement or whether it +was an innocent mistake, whether the inconsistency concerns an +important fact or whether it had to do with a small detail, +whether the witness had an explanation for the inconsistency +and whether the explanation appealed to your common sense. +It is exclusively your duty based on all the evidence +and your own good judgment to determine whether the prior +statement was inconsistent and, if so, how much, if any, weight +to be given to the inconsistent statement in determining +whether to believe all or part of the witness's testimony. +Instruction No. 46: Law Enforcement and Government +Employee Witnesses. +You have heard testimony from law enforcement +officials and employees of the government. The fact that a +witness may be employed by the federal government as a law +enforcement official or employee does not mean that his or her +testimony is necessarily deserving of more or less +consideration or greater or less weight than that of an +ordinary witness. In this context, defense counsel is allowed +to try to attack the credibility of such a witness on the +ground that his or her testimony may be colored by a personal +or professional interest in the outcome of the case. It is +your decision after reviewing all the evidence whether to +accept the testimony of the law enforcement or government + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 239 of 257 3073 +Charge +employee witness and to give to that testimony the weight you +find it deserves. +Instruction No. 47: Expert Testimony. +You have heard what is called expert testimony. An +expert is allowed to express his or her opinion -- his or her +opinion on those matters about which he or she has special +knowledge and training. Expert testimony is presented to you +on the theory that someone who is experienced in the field can +assist you in understanding the evidence or in reaching an +independent decision on the facts. +In weighing an expert's testimony, you may consider +the expert's qualifications, opinions, reasons for testifying, +as well as all of the other considerations that ordinarily +apply when you are deciding whether or not to believe a +witness's testimony. You may give the expert testimony +whatever weight, if any, you find it deserves in light of all +of the evidence in this case. +You should not, however, accept a witness's testimony +merely because he or she is an expert. Nor should you +substitute it for your own reason, judgment, and common sense. +The determination of the facts in this case rests solely with +you. +Instruction No. 48: Limiting Instructions - Similar +Act Evidence. +The government has offered evidence which it argues + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 240 of 257 +Charge +3074 +shows on different occasions Ms. Maxwell engaged in conduct +similar to the charges in the indictment. It is for you to +decide whether Ms. Maxwell engaged in the other conduct. +Let me remind you that Ms. Maxwell is on trial only +for committing acts alleged in the indictment. Accordingly, +you may consider this evidence of similar acts as a +substitute -- you may not consider this evidence -- let me +start that sentence again. Accordingly, you may not consider +this evidence of similar acts as a substitute for proof that +Ms. Maxwell committed the crimes charged nor may you consider +this evidence as proof that Ms. Maxwell has a criminal +personality or bad character. The evidence of the other +similar acts was admitted for a much more limited purpose and +you may consider it only for that limited purpose. +If you determine that Ms. Maxwell committed the acts +charged in the indictment and the similar acts, as well, then +you may, but you need not draw an inference that in doing the +acts charged in the indictment, that Ms. Maxwell acted +knowingly and intentionally and not because of some mistake, +accident, or other innocent reasons. You may also consider +this evidence in determining whether Ms. Maxwell utilized a +scheme or common plan in committing both the crimes charged in +the indictment and the similar acts introduced by the +government. +Evidence of similar acts may not be considered by you + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 241 of 257 3075 +Charge +for any other purpose. Specifically, you may not consider it +as evidence that Ms. Maxwell is of bad character or has the +propensity to commit crimes. +Instruction No. 49: Defendant's Right Not to Testify. +The defendant did not testify in this case. Under our +constitution, a defendant has no obligation to testify or to +present any evidence, because it is the government's burden to +prove a defendant guilty beyond a reasonable doubt. That +burden remains with the government throughout the entire trial, +never shifts to a defendant. A defendant is never required to +prove that she is innocent. +You may not attach any significance to the fact that +Ms. Maxwell did not testify. +No adverse inference against +be drawn +by you because she did not take the witness stand. You may not +consider this against Ms. Maxwell in any way in your +deliberations in the jury room. +Instruction No. 50: Uncalled Witnesses - Equally +Available to Both Sides. +There are people whose names you heard during the +course of the trial that did not appear to testify. One or +more of the attorneys has referred to their absence from the +trial. I instruct you that each party had an equal opportunity +or lack of opportunity to call any of these witnesses. +Therefore, you should not draw any inference or reach any + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 242 of 257 +3076 +Charge +conclusion as to what they would have testified to had they +been called. Their absence should not affect your judgment in +any way- +You should remember my instruction, however, that the +law does not impose on the defendant in a criminal case the +burden or duty of calling any witness or producing any +evidence. +Instruction No. 51: Particular Investigative +Techniques Not Required. +You have heard reference, in the arguments of defense +counsel in this case, to the fact that certain investigative +techniques were used or not used by the government. There is +no legal requirement, however, that the government prove its +case through any particular means. Your concern is to +determine whether or not on the evidence or lack of evidence +the defendant's guilt has been proved beyond a reasonable +doubt. +Instruction No. 52: Use of Evidence From Searches. +You have heard testimony about evidence seized in +connection with certain searches conducted by law enforcement +officers. Evidence obtained from these searches was properly +admitted in this case and may be properly considered by you. +Such searches were appropriate law enforcement actions. +Whether you approve or disapprove of how the evidence was +obtained should not enter into your deliberations because I + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 243 of 257 +Charge +3077 +instruct you that the government's use of the evidence is +entirely lawful. You must therefore, regardless of your +personal opinions, give this evidence full consideration along +with all the other evidence in the case in determining whether +the government has proven the defendant's guilt beyond a +reasonable doubt. As with all evidence, it's for you to +determine that -- to determine what weight, if any, to give +such evidence. +Instruction No. 53: Use of Electronic Communications. +Some of the evidence in this case has consisted of +electronic communications +seized from computers or electronic +accounts. There is nothing illegal about the government's use +in such electronic communications in this case and you may +consider them along with all the other evidence in the case. +Whether you approve or disapprove of the seizure of these +communications may not enter your deliberations. +You may, therefore, regardless of any personal +opinions, consider this evidence along with all the other +evidence in the case in determining whether the government has +proven the defendant's guilt beyond a reasonable doubt. +However, as with the other evidence, it is for you to determine +what weight, if any, to give such evidence. +Instruction No. 54: Persons Not on Trial. +You may not draw any inference, favorable or +unfavorable, towards the government or the defendant on trial + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 244 of 257 +3078 +Charge +from the fact that any person, in addition to the defendant, is +not on trial here. You also may not speculate as to the +reasons why other persons are not on trial. Those matters are +wholly outside your concern and have no bearing on your +function as jurors in deciding the case before you. +Instruction No. 55: Preparation of Witnesses. +You've heard evidence during the trial that witnesses +have discussed the facts of the case and the testimony with the +government lawyers, the defense lawyers, their own lawyers +before the witnesses appeared in court. Although you may +consider that fact while you're evaluating witness's +credibility, I should tell you there is nothing either unusual +or improper about a witness meeting with lawyers before +testifying so that the witness can be aware of the subjects he +or she will be questioned about, focus on those subjects, and +have the opportunity to review relevant exhibits before being +questioned about them. Such consultation helps conserve your +time and the Court's time. It would be unusual for a lawyer to +call a witness without such consultation. The weight you give +to the witness's preparation for his or her testimony and what +inferences you draw from such preparation are matters +completely within your discretion. +Instruction No. 56: Redaction of Evidentiary Items. +We have, among the exhibits received in evidence, some +documents that are redacted. Redacted means that part of a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 245 of 257 +3079 +Charge +document has been taken out. Material may be redacted for any +number of reasons, +including that it's not relevant to the +issues you must decide in this case among other reasons. You +are to concern yourself only with a part of the item that's +been admitted into evidence and you should not consider any +possible reason for the redactions. +Instruction No. 57: Stipulations. +In this case, you've heard evidence in the form of +stipulations. A stipulation of testimony is an agreement among +the parties that, if called, a witness would have given certain +testimony. You must accept as true the fact that the witness +would have given the testimony. However, it is for you to +determine the effect or weight to be given -- to give to that +testimony. +You've also heard evidence in the form of stipulations +that contain facts that were agreed to be true. In such cases, +you must accept those facts as true. +Instruction No. 58: Punishment Not to be Considered +by the Jury. +Under your oath as jurors, you cannot allow a +consideration of possible punishment that may be imposed upon a +defendant if convicted to influence you in any way or in any +sense to enter into your deliberations. The duty of imposing +sentence is mine and mine alone. +Your function is to weigh the evidence in the case and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 246 of 257 3080 +Charge +to determine whether or not the government has proved that +Ms. Maxwell is guilty beyond a reasonable doubt, solely upon +the basis of such evidence. +Therefore, I instruct you not to consider punishment +or possible punishment in any way in your deliberations in this +case. +Instruction No. 59: Right to Hear Testimony; Election +of Foreperson; Communications with the Court; Juror +Note-Taking. +You're about to go into the jury room and begin your +deliberations. The documentary evidence will be sent back with +you. If you want any of the testimony read to you, that can be +arranged, but please remember that it's not always easy to +locate or you might want to be as specific as you possibly can +in requesting portions of the testimony that you might want. +Your first task as a jury will be to choose your +foreperson. The foreperson has no greater voice or authority +than any other juror, but is the person who will communicate +with the Court through written note when questions arise and to +indicate when you've reached your verdict. +Your request for testimony - in fact, any +communications with the Court - should be made to me in +writing, signed by your foreperson, by number, and given to one +of the marshals outside the jury room. I'll respond to any +questions or requests you have as promptly as possible, either + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 247 of 257 +3081 +Charge +in writing or by having you return to the courtroom so I can +speak with you in person. In any communication, please do not +tell me or anyone else how the jury stands on the issue of the +jury's verdict until after a unanimous verdict is reached. +For those of you who took notes during the course of +the trial, you should not show your notes to or discuss your +notes with any other juror during your deliberations. Any +notes you have taken are to assist you and you alone. The fact +that a particular juror has taken notes entitles that juror's +views to no greater weight than those of any other juror. +Finally, your notes are not to substitute for your +recollection of the evidence in this case. If you have any +doubt as to any testimony, you may request that the official +transcript that has been made of these proceedings be read or +otherwise provided to you. +Concluding Remarks. +Members of the jury, that about concludes my +instructions to you. The most important part of this case, +members of the jury, is the part that you, as jurors, are now +about to play as you deliberate on the issues of fact. It's +for you and you alone to weigh the evidence in this case and +determine whether the government has proved beyond a reasonable +doubt each of the essential elements of the crime with which +Ms. Maxwell is charged. If the government has succeeded, your +verdict should be guilty as to that charge. If it has failed, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 248 of 257( +3082 +Charge +your verdict should be not guilty as to that charge. +You must base your verdict solely on the evidence or +lack of evidence and these instructions as to the law, and +you're obliged under your oath as jurors to follow the law as +I've instructed you, whether you agree or disagree with the +particular law in question. +Under your oath as jurors, you're not to be swayed by +sympathy. You should be guided solely by the evidence +presented during the trial and the law as I gave it to you +without regard to the consequences of your decision. You have +been chosen to try the issues of fact and reach a verdict on +the basis of the evidence or lack of evidence. If you let +sympathy interfere with your clear thinking, there is a risk +that you'll not arrive at a just verdict. +As you deliberate, please listen to the opinions of +your fellow jurors and ask for an opportunity to express your +own views. Every juror should be heard, no one juror should +hold center stage in the jury room, and no one juror should +control or monopolize the deliberations. If, after listening +to your fellow jurors, and if, after stating your own view, you +become convinced that your view is wrong, do not hesitate +because of stubbornness or pride to change your view. On the +other hand, do not surrender your honest convictions and +beliefs solely because of the opinions of your fellow jurors or +because you are outnumbered. Your final vote must reflect your + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 249 of 257 3083 +Charge +conscientious belief as to how the issues should be decided. +Thus, the verdict must represent the considered +judgment of each juror. In order to return a verdict, it is +necessary that each juror agree to it. Your verdict must be +unanimous. +If at any time you are divided, do not report how the +vote stands, and if you have reached a verdict, do not report +what it is until you are asked in open court. +A verdict form has been prepared for your convenience. +After you've reached your decision, your foreperson will fill +in the form. At that point, the foreperson should advise the +marshal outside your door that you are ready to return to the +courtroom. +Finally, I say this not because I think it necessary, +but because it is the custom in this courthouse to say this: +You should treat each other with courtesy and respect during +your deliberations. +In conclusion, ladies and gentlemen, I am sure that if +you listen to the views of your fellow jurors and if you apply +your own common sense, you will deliberate fairly. +Members of the jury, I ask your patience for a few +minutes longer. It's necessary for me to spend a few moments +with counsel and the reporter at sidebar. I'll ask you to +remain patiently in the jury box without speaking to each other +and we will return in just a moment to submit the case to you. + + +Document 767 Filed 08/10/22 Page 250 of 257 +Charge +3084 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Thank you. And I ask +all members -- all people in the +courtroom to make -- remain quiet while we have this final +sidebar thank you. + + +Document 767 Filed 08/10/22 Page 251 of 257| +3085 +Charge +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(At the sidebar) +THE COURT: Counsel, anything to raise in my reading +of the charge? +: No, your Honor. +MS. MENNINGER: No, your Honor. +THE COURT: Iwo things. One, I will indicate the +alternate jurors, I will tell them they will not take part in +the deliberations, but they are not excused and they are under +my rules until they hear from +I'm going to put +extra emphasis on that because we're in a pandemic and we might +need a juror to return. I'll could say what I normally say, +but just say this could happen. +MS. STERNHEIM: Judge, are you requiring that they be +here or just on call? +THE COURT: I mean, I've always just done on call, but +I'm happy to take a suggestion otherwise. +MR. PAGLIUCA: There is no need for them to stay here. +MS. STERNHEIM: That's fine. +THE COURT: We'l1 bring them in if we need to. +Just so everybody agrees, the alternates are 125, 149, +151, 152, and 170. +MS. STERNHEIM: We're all too tired. That's right. +THE COURT: I'm going to tell the jurors, I just want +to make sure everybody agrees with the wording, you may +deliberate as long this evening as you all agree to. Just let + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 767 Filed 08/10/22 Page 252 of 257 3086 +Charge +me know by a note when you wish to be - when you wish to break +for the evening. I'll bring you into the courtroom for +directions. +MS. STERNHEIM: Are you allowing them to set the start +time or is the Court -- +THE COURT: I will set it. So, assuming we don't get +a verdict tonight, when they say they're ready to break, I'11 +bring them in and I'll direct them to resume deliberations at +9:00 a.m., that they should go straight to the jury room and +begin deliberations once all 12 of them are there. +Anything else? +MR. PAGLIUCA: During the morning when they get here, +we will be here in the courthouse, but we're not in the +courtroom necessarily, and then when they break in the evening, +you just let them go and we're not in the courtroom? +THE COURT: Right. And to be clear, they can take the +instructions back with them and then my deputy will hand one +copy of the verdict form to someone as they're going in. +MR. EVERDELL: Do they need to request the exhibits or +does that go back automatically? +THE COURT: That's automatic. So you give back to +to send back what you need and hopefully we've got +the person -- she can show them how to technologically use it. +Last point is, we'll have the marshal come forward to +be sworn before they go back. + + +Document 767 Filed 08/10/22 Page 253 of 257 +3087 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(In open court) +THE COURT: Thank you so much for your patience, +members of the jury. I am going to send you back in a moment +to begin your deliberations. +There are five of you who are alternate jurors, and +I'm going to tell you, you're the higher number five. They are +juror number 125, juror number 149, 151, 152, and 170. +The alternate jurors were not to participate in the +deliberations, however, it is possible, and it does happen, +that we need to bring an alternate juror back in order to +participate in the deliberations. So, I am going to release +the alternate jurors. +You can't participate in the deliberations unless and +until you hear from +that you're being brought back +into the deliberations. However, because you could be brought +back into the deliberations, and because it does happen, all of +my rules continue to apply. +So, for my alternate jurors, no communications with +anyone through any means about the case, no discussions, no +consuming of any information through any means about the case +until you hear from +either asking you to come back +because we need you for the deliberations or telling you that +the process is over, and that is very important. +So, again, the alternates are 125, 149, 151, 152, and +170. + + +Document 767 Filed 08/10/22 Page 254 of 257 3088 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +So when I send you back in a moment, the alternates +will gather their belongings, no communications with each other +about the case, gather their belongings, quick wave goodbye and +then you may head home until you hear from +about +next steps. +With respect to the 12 jurors who will be +deliberating, it's 4:48. You may deliberate as long as this +evening as you all agree to. So just let me know by a note +when you wish to break for the evening. At that point, I'1l +bring you into the courtroom for instructions. +I'll ask the U.S. Marshal, the court security officer, +who will safeguard the jury's deliberations, to please come +forward and be sworn by +(Marshal sworn) +With that, you'll take your instructions back to the +jury room with you. +For the alternates, +will collect the +instructions from you. +We will send you back with a copy of the verdict form, +and +will show you how to access the admitted +exhibits should you wish to access them. +Members of the jury, you may begin your deliberations. +(At 4:49 p.m., the jury retired to deliberate) + + +Document 767 Filed 08/10/22 Page 255 of 257 3089 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Jury not present) +THE COURT: Matters to take up? +Not from the government, your Honor. Thank +you. +MS. MENNINGER: Your Honor, I believe at the outset +you said you would provide counsel a copy of a juror seating +chart. I don't think we ever got one, but is it possible to +get one to refresh our recollection? +THE COURT: Yes. +We have that prepared. I had +thought you gotten it, but we will get you each a copy. +MS. MENNINGER: Thank you, your Honor. +THE COURT: Anything else? +No, your Honor. Thank you. +THE COURT: All right. With that, we will wait until +we hear from the jury. +Let me just thank counsel for your zealous advocacy. +The eight of you performed your duties with professionalism and +excellence and I learned a lot from watching the eight of you. +Thank you. +(Recess) +THE COURT: We received a note that says. "We're +leaving at 5:30. Thanks." +Which we'll mark as a court +exhibit. We'll bring in the jury, I'll give them instructions +for resuming deliberations in the morning. + + +Document 767 Filed 08/10/22 Page 256 of 257 3090 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Jury present) +THE COURT: I did get your note saying you're ready to +leave at 5:30. Sorry you're a little delayed getting you out +of here, I know it's a long day. Thank you for your diligence +and your attention. +I want to of course remind you, bear all of my +instructions in mind, even though we're at the deliberations, +especially because and in addition we're at the deliberation +stage of the case. +So just to reiterate, +no communications with each +other or -- no communications outside of the jury room with +each other or anyone else regarding the case, no consuming any +information regarding the case in any way. +I'm going to ask that you resume your deliberations +tomorrow morning at 9:00 a.m. You come straight into the jury +room. Once all 12 of you are there, you begin your +deliberations, not before, but once all 12 of you are there. +Just start right away again with your deliberations, you don't +have to wait for further instruction for me. If you have +questions, you put them in a note and I'll get you a response. +will get your lunch order. Even though we're at +this phase in the case, please continue to keep an open mind +until you're together deliberating in the jury room. +Have a goodnight. Thank you. + + +Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 257 of 257 +3091 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +(Jury not present) +THE COURT: Any matters to take up, counsel? +Not from the government, your Honor. Thank +you. +MS. STERNHEIM: No. Thank you. +THE COURT: Please be ready to pick up any notes +beginning at 9:00. Have a goodnight, everyone. +(Adjourned to December 21, 2021 at 9:00 a.m.) +* * * \ No newline at end of file diff --git a/vision-fixhub/court-05/6bac5ce6f417574caa12b6852fe58ecef43bcadd0d68eb529f73c33febced037.receipt.json b/vision-fixhub/court-05/6bac5ce6f417574caa12b6852fe58ecef43bcadd0d68eb529f73c33febced037.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..31c779dc6dded1ab3484249f6c0e909ba1e92d0d --- /dev/null +++ b/vision-fixhub/court-05/6bac5ce6f417574caa12b6852fe58ecef43bcadd0d68eb529f73c33febced037.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -32335, + "dataset": "marble-joined", + "doc_id": "6bac5ce6f417574caa12b6852fe58ecef43bcadd0d68eb529f73c33febced037", + "engine": "marble-apple-vision", + "event_count": 339, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "3ab9ab5a2720a87374bb14b569fd4b294e5cd27f7673a947a459d181e93720ef", + "output_sha256": "b0fa99c85b6904e0f436837bb88b8d924306bef487ec9045bbb9ba74bbd83360", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6bb59f376a3e4a9474ab5ddadf772fbad0fd4de809daaf9e16d0d772b8f43438.md b/vision-fixhub/court-05/6bb59f376a3e4a9474ab5ddadf772fbad0fd4de809daaf9e16d0d772b8f43438.md new file mode 100644 index 0000000000000000000000000000000000000000..1bdd983f62cc603c7a5261003814310269da4197 --- /dev/null +++ b/vision-fixhub/court-05/6bb59f376a3e4a9474ab5ddadf772fbad0fd4de809daaf9e16d0d772b8f43438.md @@ -0,0 +1,21 @@ +Case 1:22-cV-10904-JSR Document 284-58 Filed 08/14/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 284-58 Filed 08/14/23 Page 2 of 2 +Date: 1/24/2019 4:53:55 PM +From: "Carlos Rodriguez" +To : "Cecile de Jongh" +Subject: Carlos work obligations +Greetings Cecile, here is a list of things Im doing for LS/GSJ and STC. +Take care of STC vehicles and vehicles at hangar, keep them fueled and clean. Every time JE visits all his vehicles are washed and detailed, also +hangar vehicles are washed and detailed. Go on JE Denali to airport on his arrival to ensure there is a spare vehicle in case heli has issues, help with +luggage and bring to red hook for pik up. Keep hangar bedroom sheets always fresh laundered, 1 bring them to Isj for washing and ironing. Provide +access to hangar to contractors such as A/C, pest control etc, and take care of any request Larry might have also I keep generator always full of diesel. +Ive been doing most of the ordering of parts for boats, also been doing most shopping for LS/GSJ for most departments. +Some of my other obligations include, picking up guests and contractors from airport and bring them to and from to hotels and LSJ, some early moming +some late at night. Ive been dealing with boat repair contractors in Tortola to help Randy and +- I do all boat registrations, some pikups at tropical +and anything requested from me + +ESTATE_JPM055884 diff --git a/vision-fixhub/court-05/6bb59f376a3e4a9474ab5ddadf772fbad0fd4de809daaf9e16d0d772b8f43438.receipt.json b/vision-fixhub/court-05/6bb59f376a3e4a9474ab5ddadf772fbad0fd4de809daaf9e16d0d772b8f43438.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1b9f43b08d036199fc323c6709cc5ef065f61b57 --- /dev/null +++ b/vision-fixhub/court-05/6bb59f376a3e4a9474ab5ddadf772fbad0fd4de809daaf9e16d0d772b8f43438.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "6bb59f376a3e4a9474ab5ddadf772fbad0fd4de809daaf9e16d0d772b8f43438", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "d8a3b2252c4685e233afb879d3e589bcf70bc565dc8d0efc96d9b932883c7a5a", + "output_sha256": "a6ed6ae9b330d8ae591864d9f9de489a8c6f5c2a19e5737ef83e23229abd2499", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6be772bb5323ba9e1bfdca01da913adba2272dcc998bd83c015e1a307f631be2.md b/vision-fixhub/court-05/6be772bb5323ba9e1bfdca01da913adba2272dcc998bd83c015e1a307f631be2.md new file mode 100644 index 0000000000000000000000000000000000000000..584d79c7b79716dc33f4461239b5db636734566a --- /dev/null +++ b/vision-fixhub/court-05/6be772bb5323ba9e1bfdca01da913adba2272dcc998bd83c015e1a307f631be2.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 242-41 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/6be772bb5323ba9e1bfdca01da913adba2272dcc998bd83c015e1a307f631be2.receipt.json b/vision-fixhub/court-05/6be772bb5323ba9e1bfdca01da913adba2272dcc998bd83c015e1a307f631be2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..43e6a8f0c719e603d40d91a8c9190b5723388871 --- /dev/null +++ b/vision-fixhub/court-05/6be772bb5323ba9e1bfdca01da913adba2272dcc998bd83c015e1a307f631be2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "6be772bb5323ba9e1bfdca01da913adba2272dcc998bd83c015e1a307f631be2", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "0fc854a67d0b0bb0a09090276917cf63cee332a9a4b4cbd4ccb0bb629f5a2bda", + "output_sha256": "375a9ab066d2ce6a94836f71b55deb9cee1991753a268c244f45a19ee1ebeabb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6bf7688b0c2c5eac35660131b67d6883a2a5b209769a4444644b0f4954f41bf4.md b/vision-fixhub/court-05/6bf7688b0c2c5eac35660131b67d6883a2a5b209769a4444644b0f4954f41bf4.md new file mode 100644 index 0000000000000000000000000000000000000000..bd0df6858da88c60fb20f6e4c7e8a839bf966ddc --- /dev/null +++ b/vision-fixhub/court-05/6bf7688b0c2c5eac35660131b67d6883a2a5b209769a4444644b0f4954f41bf4.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 268-13 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6bf7688b0c2c5eac35660131b67d6883a2a5b209769a4444644b0f4954f41bf4.receipt.json b/vision-fixhub/court-05/6bf7688b0c2c5eac35660131b67d6883a2a5b209769a4444644b0f4954f41bf4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9ef4c04e4ba2e9bed677634c06c47dc276f297a8 --- /dev/null +++ b/vision-fixhub/court-05/6bf7688b0c2c5eac35660131b67d6883a2a5b209769a4444644b0f4954f41bf4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "6bf7688b0c2c5eac35660131b67d6883a2a5b209769a4444644b0f4954f41bf4", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "0a7ef46ba9e76fea79d4ea0dc6e8df9ebb3d855864764b69c9a08ef05c872fdc", + "output_sha256": "8427aa3f951199692b678b155e32d0cc2ed8f6294c28669134036089cd4a3134", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6bffd53d466dd8ce21ebec00710ed15cd14765ab453517610b5a8ab3033d9c05.md b/vision-fixhub/court-05/6bffd53d466dd8ce21ebec00710ed15cd14765ab453517610b5a8ab3033d9c05.md new file mode 100644 index 0000000000000000000000000000000000000000..fcf2d7e57b00063c04a19f445053d4f4a0e7ee2f --- /dev/null +++ b/vision-fixhub/court-05/6bffd53d466dd8ce21ebec00710ed15cd14765ab453517610b5a8ab3033d9c05.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 239-10 Filed 07/25/23 +_Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/6bffd53d466dd8ce21ebec00710ed15cd14765ab453517610b5a8ab3033d9c05.receipt.json b/vision-fixhub/court-05/6bffd53d466dd8ce21ebec00710ed15cd14765ab453517610b5a8ab3033d9c05.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..318fb61f8c3430bfb55ccd8eba84081478ad1f90 --- /dev/null +++ b/vision-fixhub/court-05/6bffd53d466dd8ce21ebec00710ed15cd14765ab453517610b5a8ab3033d9c05.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "6bffd53d466dd8ce21ebec00710ed15cd14765ab453517610b5a8ab3033d9c05", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "f50664c42c5ec84d989c6438b1179308442dd915b9650f57eab0157b028e9250", + "output_sha256": "2667b25b25c3151bdca1810d006d6454faa0baea8b4c69c3dea2aeb922c20697", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6c226afbe71c55b84e5bca0d90eeee4452a9c376995351087efe98d26d2045e9.md b/vision-fixhub/court-05/6c226afbe71c55b84e5bca0d90eeee4452a9c376995351087efe98d26d2045e9.md new file mode 100644 index 0000000000000000000000000000000000000000..5b8a52c7a39662fbe32fcf114913b18042598948 --- /dev/null +++ b/vision-fixhub/court-05/6c226afbe71c55b84e5bca0d90eeee4452a9c376995351087efe98d26d2045e9.md @@ -0,0 +1,490 @@ +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 1 of 20 +IN THE UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A., +Defendant/Third-Party +Plaintiff, +V. +JAMES EDWARD STALEY, +Third-Party +Defendant. +JANE DOE, individually and on behalf of all +others similarly situated, +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A., +Defendant/Third-Party +Plaintiff, +Case No. 22-cv-10904 (JSR) +Case No. 22-cv-10019 (JSR) +v. +JAMES EDWARD STALEY, +Third-Party +Defendant. +DECLARATION OF FELICIA H. ELLSWORTH IN SUPPORT OF JPMORGAN +CHASE BANK, N.A.'S OPPOSITION TO THIRD PARTY DEFENDANT'S MOTION +FOR SUMMARY JUDGMENT + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 2 of 20 +Pursuant to 28 U.S.C. § 1746, I, Felicia H. Ellsworth, declare under penalty of perjury as +follows: +1. I am a member in good standing of the bar of the Commonwealth of Massachusetts. I +am one of the attorneys representing Defendant JPMorgan Chase Bank, N.A. ("JPMC") +in the above-captioned action and have been admitted to this Court pro hac vice. I am a +Partner with the law firm of Wilmer Cutler Pickering Hale and Dom LLP, 60 State +Street, Boston, Massachusetts 02109. I am familiar with the facts set forth herein, and if +called as a witness, I could and would competently testify thereto. +2. Attached as Exhibit 1 is a true and correct copy of excerpts of the transcript from the +June 10, 2023, deposition of James Staley, designated confidential pursuant to the +3. Attached as Exhibit 2 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00178144_R, designated confidential pursuant to the +4. Attached as Exhibit 3 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00178391, designated confidential pursuant to the +5. Attached as Exhibit 4 is a true and correct of copy of excerpts of the transcript from the +May 30, 2023, deposition of Francis Pearn. +6. Attached as Exhibit 5 is a true and correct copy of excerpts of the transcript from the +April 21, 2023, deposition of Justin Nelson. + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 3 of 20 +7. Attached as Exhibit 6 is a true and correct copy of excerpts of the transcript from the +May 26, 2023, deposition of James Dimon, designated confidential pursuant to the +8. Attached as Exhibit 7 is a true and correct copy of excerpts of the transcript from the +July 18, 2023, deposition of Catherine Keating, designated confidential pursuant to the +9. Attached as Exhibit 8 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, | +stamped ESTATE_JPM002037, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +10. Attached as Exhibit 9 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_JPM001394, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +11. Attached as Exhibit 10 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, [ +stamped ESTATE_JPM001626, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +12. Attached as Exhibit 11 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_JPM001462, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +13. Attached as Exhibit 12 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, | +stamped ESTATE_JPM001463, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +14. Attached as Exhibit 13 is a true and correct copy of excerpts of the transcript from the +April 28, 2023, deposition of Kevin McCleerey. + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 4 of 20 +15. Attached as Exhibit 14 is a true and correct copy of excerpts of the transcript from the +July 12, 2023, deposition of William Marcus Sheridan, designated confidential pursuant +to the Protective Order in this matter and filed under seal. +16. Attached as Exhibit 15 is a true and correct copy of excerpts of the transcript from the +July 13, 2023, deposition of John Duffy, designated confidential pursuant to the +17. Attached as Exhibit 16 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00012641, designated confidential pursuant to the +18. Attached as Exhibit 17 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00149050. +19. Attached as Exhibit 18 is a true and correct copy of excerpts of the transcript from the +July 12, 2023, deposition of Mary Erdoes. +20. Attached as Exhibit 19 is a true and correct copy of excerpts of the transcript from the +July 10, 2023, deposition of Stephen Cutler. +21. Attached as Exhibit 20 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00755251. +22. Attached as Exhibit 21 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00100770. +23. Attached as Exhibit 22 is a true and correct copy of excerpts of the transcript from the +July 13, 2023, deposition of Francis Pearn, designated confidential pursuant to the +4 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 5 of 20 +24. Attached as Exhibit 23 is a true and correct copy of an article titled, "Epstein Scandal, +Barclays Boss Investigated Over 'Professional Relationship' with Paedo Jeffrey +Epstein," dated February 13, 2020, available at +https://www.thesun.co.uk/news/10954385/barclays-boss-jes-staley-investigated-jeffreyepstein-professional-relationship/. +25. Attached as Exhibit 24 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00149726, designated confidential pursuant to the +26. Attached as Exhibit 25 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00731259, designated confidential pursuant to the +27. Attached as Exhibit 26 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00100605. +28. Attached as Exhibit 27 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, [ +stamped ESTATE_006622, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +29. Attached as Exhibit 28 is a true and correct copy of the September 11, 2014 FinCEN +Advisory Fin-2014-A008. +30. Attached as Exhibit 29 is a true and correct copy of excerpts of the transcript from the +August 14, 2023, deposition of Francis Pearn, designated confidential pursuant to the +5 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 6 of 20 +31. Attached as Exhibit 30 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00920680, designated confidential pursuant to the +32. Attached as Exhibit 31 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00920690, designated confidential pursuant to the +33. Attached as Exhibit 32 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00920705, designated confidential pursuant to the +34. Attached as Exhibit 33 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00920695, designated confidential pursuant to the +35. Attached as Exhibit 34 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00920672, designated confidential pursuant to the +36. Attached as Exhibit 35 is a true and correct copy of excerpts of the transcript from the +July 14, 2023, deposition of Jonathan +37. Attached as Exhibit 36 is a true and correct copy of excerpts of the transcript from the +June 11, 2023, deposition of James Staley, designated confidential pursuant to the +38. Attached as Exhibit 37 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006592. +6 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 7 of 20 +39. Attached as Exhibit 38 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013463, designated confidential pursuant to the +40. Attached as Exhibit 39 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00013402. +41. Attached as Exhibit 40 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00194065. +42. Attached as Exhibit 41 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00099897. +43. Attached as Exhibit 42 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-01035045. +44. Attached as Exhibit 43 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00178378. +45. Attached as Exhibit 44 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00178379. +46. Attached as Exhibit 45 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00178380. +47. Attached as Exhibit 46 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00178381. +48. Attached as Exhibit 47 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00178382. +49. Attached as Exhibit 48 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00178383. +7 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 8 of 20 +50. Attached as Exhibit 49 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00274948. +51. Attached as Exhibit 50 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00274984. +52. Attached as Exhibit 51 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00275020. +53. Attached as Exhibit 52 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00149115. +54. Attached as Exhibit 53 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00275091. +55. Attached as Exhibit 54 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00149210. +56. Attached as Exhibit 55 is a true and correct copy of JPMC's Fourth Supplemental Initial +Disclosures served on July 18, 2023. +57. Attached as Exhibit 56 is a true and correct copy of JPMC's Fifth Supplemental Initial +Disclosures served on July 18, 2023. +58. Attached as Exhibit 57 is a true and correct copy of excerpts of the transcript from the +March 3, 2023, deposition of Jane Doe 1, designated confidential pursuant to the +Protective Order in this matter and filed under seal.' +'Certain proper names are redacted from the sealed version in order to ensure the +confidentiality and privacy of victims. + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 9 of 20 +59. Attached as Exhibit 58 is a true and correct copy of a document produced by Jane Doe 1, +stamped JDoe_JPMC_007837, designated confidential pursuant to the Protective +Order in this matter and filed under seal. 2 +60. Attached as Exhibit 59 is a true and correct copy of a document produced by Jane Doe 1, +stamped JDoe_JPMC_000956, designated confidential pursuant to the Protective +Order in this matter and filed under seal. 3 +61. Attached as Exhibit 60 is a true and correct copy of a document produced by Jane Doe 1, +stamped JDoe_DBAG_009963, designated confidential pursuant to the Protective +Order in this matter and filed under seal. 4 +62. Attached as Exhibit 61 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006171. +63. Attached as Exhibit 62 is a true and correct copy of a document produced by third party +stamped ESTATE_JPM002773, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +64. Attached as Exhibit 63 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006718. +65. Attached as Exhibit 64 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006716, designated confidential pursuant to the +2 Certain proper names are redacted from the sealed version in order to ensure the +confidentiality and privacy of victims. +3 Certain proper names are redacted from the sealed version in order to ensure the +confidentiality and privacy of victims. +* Certain proper names are redacted from the sealed version in order to ensure the +confidentiality and privacy of victims. +9 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 10 of 20 +66. Attached as Exhibit 65 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00006791. +67. Attached as Exhibit 66 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006792, designated confidential pursuant to the +68. Attached as Exhibit 67 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00008342. +69. Attached as Exhibit 68 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00008669. +70. Attached as Exhibit 69 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00003569. +71. Attached as Exhibit 70 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, [ +stamped ESTATE_JPM002701, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +72. Attached as Exhibit 71 is a true and correct copy of a document produced by third party +stamped ESTATE_JPM001589, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +73. Attached as Exhibit 72 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_005147, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +74. Attached as Exhibit 73 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013210, designated confidential pursuant to the +10 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 11 of 20 +75. Attached as Exhibit 74 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013475. +76. Attached as Exhibit 75 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013669. +77. Attached as Exhibit 76 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00013762. +78. Attached as Exhibit 77 is a true and correct copy of a document produced by third party +stamped ESTATE_JPM003612, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +79. Attached as Exhibit 78 is a true and correct copy of a document produced by third party +stamped ESTATE_JPM003630, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +80. Attached as Exhibit 79 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, I +stamped ESTATE_JPM003801, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +81. Attached as Exhibit 80 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00023238, designated confidential pursuant to the +82. Attached as Exhibit 81 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_JPM017538, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +11 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 12 of 20 +83. Attached as Exhibit 82 is a true and correct copy of a document produced by third party +stamped ESTATE_JPM017540, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +84. Attached as Exhibit 83 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00005845, designated confidential pursuant to the +85. Attached as Exhibit 84 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006553, designated confidential pursuant to the +86. Attached as Exhibit 85 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006886, designated confidential pursuant to the +87. Attached as Exhibit 86 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00010121, designated confidential pursuant to the +88. Attached as Exhibit 87 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00010989, designated confidential pursuant to the +89. Attached as Exhibit 88 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00012289, designated confidential pursuant to the +12 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 13 of 20 +90. Attached as Exhibit 89 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00012466, designated confidential pursuant to the +91. Attached as Exhibit 90 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00099334 +92. Attached as Exhibit 91 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004661. +93. Attached as Exhibit 92 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_JPM001758, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +94. Attached as Exhibit 93 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006586. +95. Attached as Exhibit 94 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006874. +96. Attached as Exhibit 95 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00012494. +97. Attached as Exhibit 96 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00003060. +98. Attached as Exhibit 97 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004394, designated confidential pursuant to the +13 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 14 of 20 +99. Attached as Exhibit 98 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004388, designated confidential pursuant to the +100. Attached as Exhibit 99 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_JPM002742, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +101. Attached as Exhibit 100 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00006704, designated confidential pursuant to the +102. Attached as Exhibit 101 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00010330, designated confidential pursuant to the +103. Attached as Exhibit 102 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00010603, designated confidential pursuant to the +104. Attached as Exhibit 103 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00004186, designated confidential pursuant to the +105. Attached as Exhibit 104 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00010284. +106. Attached as Exhibit 105 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_JPM003001, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +14 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 15 of 20 +107. Attached as Exhibit 106 is a true and correct copy of a document produced by third party +stamped ESTATE_JPM002019. +108. Attached as Exhibit 107 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00013770. +109. Attached as Exhibit 108 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_004285, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +110. Attached as Exhibit 109 is a true and correct copy of a document produced by third party +stamped ESTATE_004300, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +111. Attached as Exhibit 110 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_004303, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +112. Attached as Exhibit 111 is a true and correct copy of a document produced by third party +The Estate of Jeffrey E. Epstein, +stamped ESTATE_003218, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +113. Attached as Exhibit 112 is a true and correct copy of the February 13, 2020, Barclays +Director Effectiveness Assessment: Disclosure of Regulatory Investigation. +114. Attached as Exhibit 113 is a true and correct copy of excerpts of the transcript from the +May 3, 2023, deposition of William Langford, designated confidential pursuant to the +115. Attached as Exhibit 114 is a true and correct copy of excerpts of the transcript from the +April 7, 2023, deposition of Mary L +15 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 16 of 20 +116. Attached as Exhibit 115 is a true and correct copy of excerpts of the transcript from the +March 15, 2023, deposition of Mary Erdoes. +117. Attached as Exhibit 116 is a true and correct copy of excerpts of the transcript from the +August 24, 2023, deposition of Lisa Waters. +118. Attached as Exhibit 117 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00447294. +119. Attached as Exhibit 118 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00099899. +120. Attached as Exhibit 119 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00007344. +121. Attached as Exhibit 120 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00123680. +122. Attached as Exhibit 121 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00007895. +123. Attached as Exhibit 122 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00009550. +124. Attached as Exhibit 123 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00011795. +125. Attached as Exhibit 124 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00013688. +126. Attached as Exhibit 125 is a true and correct copy of excerpts of the transcript from the +July 6, 2023, deposition of Mary L +16 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 17 of 20 +127. Attached as Exhibit 126 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00127953. +128. Attached as Exhibit 127 is a true and correct copy of a document produced by JPMC, +| stamped JPM-SDNYLIT-00001893. +129. Attached as Exhibit 128 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00449994. +130. Attached as Exhibit 129 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00274766. +131. Attached as Exhibit 130 is a true and correct copy of a document produced by Jane Doe +stamped JDoe_JPMC +_ 001314, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +132. Attached as Exhibit 131 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00751728. +133. Attached as Exhibit 132 is a true and correct copy of a document produced by JPMC, +I stamped JPM-SDNYLIT-00450343. +134. Attached as Exhibit 133 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00127944. +135. Attached as Exhibit 134 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00026008, designated confidential pursuant to the +136. Attached as Exhibit 135 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-W-00031038, designated confidential pursuant to the + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 18 of 20 +137. Attached as Exhibit 136 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00274774, designated confidential pursuant to the +138. Attached as Exhibit 137 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00127930, designated confidential pursuant to the +139. Attached as Exhibit 138 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00157127. +140. Attached as Exhibit 139 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00274429, designated confidential pursuant to the +141. Attached as Exhibit 140 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00205452. +142. Attached as Exhibit 141 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00754926, designated confidential pursuant to the +143. Attached as Exhibit 142 is a true and correct copy of excerpts of the transcript from the +May 24, 2023, deposition of Stephen Cutler. +144. Attached as Exhibit 143 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00127928. +145. Attached as Exhibit 144 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00454037. + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 19 of 20 +146. Attached as Exhibit 145 is a true and correct copy of a document produced by JPMC, +I stamped JPM-SDNYLIT-00755043. +147. Attached as Exhibit 146 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00136519, designated confidential pursuant to the +148. Attached as Exhibit 147 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00231636, designated confidential pursuant to the +149. Attached as Exhibit 148 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00230825, designated confidential pursuant to the +150. Attached as Exhibit 149 is a true and correct copy of excerpts of the transcript from the +May 10, 2023, deposition of Bonnie +151. Attached as Exhibit 150 is a true and correct copy of excerpts of the transcript from the +April 19, 2023, deposition of Philip DeLuca, designated confidential pursuant to the +152. Attached as Exhibit 151 is a true and correct copy of excerpts of the transcript from the +May 24, 2023, deposition of Maryanne Ryan, designated confidential pursuant to the +153. Attached as Exhibit 152 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00152809. +154. Attached as Exhibit 153 is a true and correct copy of excerpts of the transcript from the +April 18, 2023, deposition of Paul Morris. +19 + + +Case 1:22-cv-10904-JSR Document 326 Filed 09/08/23 Page 20 of 20 +155. Attached as Exhibit 154 is a true and correct copy of a document produced by third party +stamped ESTATE_005175, designated +confidential pursuant to the Protective Order in this matter and filed under seal. +156. Attached as Exhibit 155 is a true and correct copy of a document produced by JPMC, +_stamped JPM-SDNYLIT-00274527. +157. Attached as Exhibit 156 is a true and correct copy of a document produced by JPMC, +_ stamped JPM-SDNYLIT-00731595. +158. Attached as Exhibit 157 is a true and correct copy of JPMC's First Supplemental +Responses and Objections to Interrogatories in Lieu of Rule 30(b)(6) Deposition +Testimony served on April 14, 2023, designated confidential pursuant to the Protective +Order in this matter and filed under seal. +159. Attached as Exhibit 158 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00002141. +160. Attached as Exhibit 159 is a true and correct copy of a document produced by JPMC, +stamped JPM-SDNYLIT-00194181, designated confidential pursuant to the +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and +correct. +Dated: September 8, 2023 +/s/ Felicia Ellsworth +Felicia H. Ellsworth +20 \ No newline at end of file diff --git a/vision-fixhub/court-05/6c226afbe71c55b84e5bca0d90eeee4452a9c376995351087efe98d26d2045e9.receipt.json b/vision-fixhub/court-05/6c226afbe71c55b84e5bca0d90eeee4452a9c376995351087efe98d26d2045e9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..207bd1365cac009c37de5a50433074ea8f6d9af5 --- /dev/null +++ b/vision-fixhub/court-05/6c226afbe71c55b84e5bca0d90eeee4452a9c376995351087efe98d26d2045e9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -3123, + "dataset": "marble-joined", + "doc_id": "6c226afbe71c55b84e5bca0d90eeee4452a9c376995351087efe98d26d2045e9", + "engine": "marble-apple-vision", + "event_count": 22, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "48b79089ff0420b6e2f40117dcc4819d6059677adb6ccd173f3846b2c6fc39f7", + "output_sha256": "0c97aaf1d0d9e1a0274e2c1992e91e2f84f1e744365b14e43daee7283fe9ebf3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6c290537aa23bbae2ed6532429f19c3b262c0318f3d91b0a0f70c689f17d4acf.md b/vision-fixhub/court-05/6c290537aa23bbae2ed6532429f19c3b262c0318f3d91b0a0f70c689f17d4acf.md new file mode 100644 index 0000000000000000000000000000000000000000..1c1a50dc664cfbd910c7b56d104626d6209e4d05 --- /dev/null +++ b/vision-fixhub/court-05/6c290537aa23bbae2ed6532429f19c3b262c0318f3d91b0a0f70c689f17d4acf.md @@ -0,0 +1,32 @@ +Case 1:20-cr-00330-PAE | +Document 798 +Filed 08/01/25 + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +- against - +GHISLAINE MAXWELL, +20 Cr. 330 (PAE) +NOTICE OF MOTION TO WITHDRAW +Defendant. +X +PLEASE TAKE NOTICE that, upon the accompanying Declaration of Christian R. +Everdell, I respectfully move this Court for an Order pursuant to Local Rule 1.4 permitting +myself, Mark S. +Ghislaine Maxwell. +& Gresser LLP to withdraw as co-counsel for defendant +Dated: August 1, 2025 +New York, New York +Respectfully submitted, +& GRESSER LLP +Coke +Christian R. Everdell +Mark S. +800 Third Avenue, 21 Floor +New York, NY 10022 +Phone: (212) 957-7600 +Fax: (212) 957-4514 +ceverdell@cohengresser.com +mcohen@cohengresser.com +Attorneys for Ghislaine Maxwell diff --git a/vision-fixhub/court-05/6c290537aa23bbae2ed6532429f19c3b262c0318f3d91b0a0f70c689f17d4acf.receipt.json b/vision-fixhub/court-05/6c290537aa23bbae2ed6532429f19c3b262c0318f3d91b0a0f70c689f17d4acf.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3362d206f341912000fc22024a5f1bc89886054b --- /dev/null +++ b/vision-fixhub/court-05/6c290537aa23bbae2ed6532429f19c3b262c0318f3d91b0a0f70c689f17d4acf.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "6c290537aa23bbae2ed6532429f19c3b262c0318f3d91b0a0f70c689f17d4acf", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "3569faf3a00c401be010ead62ad55b7a706d49b85a98520e143f422cc0fd4c92", + "output_sha256": "d0217ed76d3bf6d7a1a2be8096525e6fc25978e9444104c3482a6d4ba0f434d7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6c2fa5b4d76607b36904bc16c29f0b8f544ac1f45cd50a2714d9b0be4390328a.md b/vision-fixhub/court-05/6c2fa5b4d76607b36904bc16c29f0b8f544ac1f45cd50a2714d9b0be4390328a.md new file mode 100644 index 0000000000000000000000000000000000000000..308722e6563cb895090f3fe122d275965e16d114 --- /dev/null +++ b/vision-fixhub/court-05/6c2fa5b4d76607b36904bc16c29f0b8f544ac1f45cd50a2714d9b0be4390328a.md @@ -0,0 +1,2622 @@ +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 1 of 49 +1974 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-x +UNITED STATES OF AMERICA, +V. +20 CR 330 (AJN) +GHISLAINE MAXWELL, +Defendant. +-x +Before: +HON. ALISON J. NATHAN, +Jury Trial +New York, N.Y. +December 9, 2021 +9:00 a.m. +District Judge +APPEARANCES +DAMIAN +United States Attorney for the +Southern District of New York +BY: MAURENE COMEY +ALISON MOE +LARA POMERANTZ +ANDREW ROHRBACH +Assistant United States Attorneys +HADDON | +AND +Attorneys for Defendant +BY: JEFFREY S. PAGLIUCA +LAURA A. MENNINGER +-and- +BOBBI C. STERNHEIM +-and- +& GRESSER +BY: +CHRISTIAN R. EVERDELL +Also Present: Amanda Young, FBI +Paul Byrne, NYPD + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 2 of 49 +1975 +(Trial resumed; jury not present) +THE COURT: All right. Matters to take up. +MS. COMEY: There were just a couple issues that we +wanted to put on the record, your Honor. +First, I've conferred with defense counsel, and they +have indicated that they are releasing Carolyn from recall. So +I understand that any sequestration order no longer applies to +her. +MR. PAGLIUCA: That's correct, your Honor. +THE COURT: All right. Thank you. +MS. COMEY: And then I also conferred with defense +counsel about Kimberly Meder and whether she would be permitted +to be in the courtroom for the remainder of trial. I'm told by +defense counsel that they have no objection; though, of course, +they may end up seeking to recall her in the defense case, but +that they have no objection to her being in the courtroom. +MR. EVERDELL: That's correct, your Honor. +THE COURT: Okay. +MS. COMEY: And then with respect to redacted 296, +which was the video of the Palm Beach residence, defense +counsel has been reviewing the redacted version that we sent +them on Tuesday. Once they have their position on its +admissibility, we will formally offer it. +MR. PAGLIUCA: Also correct, your Honor. +THE COURT: Great. Okay. Thank you. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 3 of 49 +1976 +MR. EVERDELL: Just a few procedural things from the +defense. +I believe the next witness from the government is +going to be Tracy Chapell from Federal Express. And I have +some documents I can hand up to the Court. I have one exhibit +that I intend to introduce through Ms. Chapel which I've given +to the government; I can give the Court a copy. It's going to +be done in paper. +These are Federal Express invoices. +I'm going to offer them -- assuming they are allowed +to be admitted, I will offer them under temporary seal because +we haven't had the chance to go through and do all the +redactions. But we will do that as soon as we can and get the +Court a redacted copy so that that could be published publicly. +But for the moment, we'll have to do this under seal. +THE COURT: Is there going to be a lot of walking the +witness through the document? +MR. EVERDELL: No. Actually I'm just going to admit +them; no walking through, it's going to be for the jury's eyes +if they want to see it. +THE COURT: Okay. And so a redacted version for the +public by when? +MR. EVERDELL: If we could do it over the weekend, +because there's a decent number of records, and have them ready +by Monday, we could do that. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | +Document 757 Filed 08/10/22 Page 4 of 49 +1977 +THE COURT: Okay. Thank you. +MR. EVERDELL: I have a copy which I can hand up to +the Court now. +THE COURT: Sure. Thank you. +MR. EVERDELL: Your Honor, on that same score, we'd +like to be able to put folders under the jurors' chairs with +that exhibit in them that they would only be asked to open if +it's admitted. +MS. COMEY: No objection, your Honor. +THE COURT: Okay. Thank you. +MR. EVERDELL: I will take care of that. +Thank you, your Honor. +MS. MENNINGER: Good morning, your Honor. +THE COURT: Good morning, Ms. Menninger. +MS. MENNINGER: A couple of issues. +I've conferred with the government, and I believe we +have agreement. I would like to just put them on the record +prior to the testimony of +She is not testifying +anonymously, your Honor. Therefore, my plan is to use the +counsel screen as one normally would in these situations, +rather than so much of the paper. But we have binders in the +event someone wants to look at the whole set, for the Court, +the government for any impeachment materials, and for the +witness. +THE COURT: Correct to assume that none of the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | +Document 757 Filed 08/10/22 Page 5 of 49 +documents you'll show her have the full or real names of the +other witnesses testifying under pseudonym? +MS. MENNINGER: Right, your Honor. I don't think they +had any interaction with one another. I don't believe there's +anything in here that references anyone else. +THE COURT: Okay. +MS. MENNINGER: Your Honor, there is a substantial +amount of hearsay, both within the record and also in the +public domain as between | +and her sister +• I've conferred with the government that there won't be +hearsay being offered from +, with the exception of +at least one place I know where it's in effect on the listener +that Annie traveled to New York because her sister told her to +come there. But outside of that, we have agreed that we're not +having -- there's no other hearsay exception that applies to +statements. +Within that subset, your Honor, there has been a +contention by +that nude photographs or provocative +photographs were stolen from her. None were found when +Mr. Epstein's home was searched. That, again, would be hearsay +from Maria and is not planning to be a part of the government's +case or the defense's cross. +And lastly, your Honor, because +is herself +a practicing therapist, psychologist, she has made a number of +statements publicly about her opinions on the topic of +1978 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 6 of 49 +grooming. As she was not endorsed, obviously, under 702, I +expect that she will not use that word or give anything that +sounds like an opinion along those lines. +She's here as a fact +witness, your Honor. And the government has agreed they don't +intend to offer any opinion testimony from her. +THE COURT: Great. Thank you. +MS. POMERANTZ: That all sounds accurate, your Honor. +THE COURT: Thank you, Ms. Pomerantz. +What else to take up? +MR. PAGLIUCA: Your Honor, if I might, I don't know if +the Court wants to take this up now, but I'll just give this as +a preview for later. +The government has endorsed Mr. Buscemi as a, as I +understand it, summary witness. This is a 1006 issue. As I +understand it, I don't believe that this is an appropriate +summary witness under 1006. As I understand it, the purpose is +to talk about testimony or pieces of evidence that have been +admitted, specifically not to analyze any complex records or +other business transactions or phone records or things like +that. So I just wanted to give the Court a heads-up on that. +I'm not exactly sure precisely what he's being offered to +testify about, but I expect that there will be an objection to +that testimony before it happens. +THE COURT: Who will I hear from? +MS. MOE: Yes, your Honor. +1979 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 7 of 49 +1980 +As we explained to the defense this morning, we +anticipate calling Special Agent Michael Buscemi as a summary +witness, as is common in this district. His testimony will be +limited to his analysis of exhibits; he won't be analyzing +testimony of other witnesses. +There are a number of exhibits in this case which have +not yet been published or reviewed during the course of this +case; and so we anticipate fairly brief testimony from Special +Agent Buscemi about his review of several exhibits. +In short, the testimony will concern, among other +things, the message pads, the majority of which have not been +published or viewed by the jury at this point. And the purpose +of the testimony is to connect up several exhibits and review +them in a way to make those exhibits clear to the jury and +publish them to show, for example, the continuity of certain +phone numbers and names, where they change over time, where +they are in the message books in order to make that clear for +the jury. +I anticipate that the testimony from Special Agent +Buscemi would be likely something like 15 to 20 minutes, maybe +slightly more, again, just talking about exhibits and the +similarity of phone numbers and names between a variety of +different exhibits. That's the scope of his testimony. +Our view is that's consistent with the way summary +witnesses are called in many trials in this district and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 8 of 49 +1981 +doesn't exceed the scope of the ordinary practice. +THE COURT: Let's take the specific example that +you've given on message pads. +So just give me an example of +the kind of testimony he would provide there. +MS. MOE: Yes, your Honor. +So, for example, within the message pads, we published +yesterday, I think, just either two or three specific messages +that had a first and last name of someone and a phone number. +But elsewhere throughout the message pads, there appear entries +that only have a first name, and sometimes that entry is, for +example, Carolyn and sometimes it's Caroline. But when you +compare the phone numbers -- and there are a variety of +different phone numbers throughout the book -- it becomes clear +that Caroline is the same Carolyn, first and last name, as some +of the other messages, because there's continuity between the +phone numbers. +And there are a variety of different phone numbers +throughout the exhibits with different names like Carolyn, +Caroline, and Carolyn with a last name. And reviewing them and +analyzing them makes it clear throughout the books and across a +variety of different dates that we're talking about the same +person. And so that facilitates both publishing the exhibits +so that the jury can see them for the first time, and doing +that in a way that sort of connects up those different +exhibits. And so that's the purpose of that testimony. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 9 of 49 +1982 +THE COURT: Let's take that example, Mr. Pagliuca. +MR. PAGLIUCA: Your Honor, the problem, I think, is +that it is simply highlighting a specific piece of evidence; +that this is summation, essentially, and not witness testimony. +The witness has no personal knowledge of the phone calls. The +witness is simply comparing this to that, which is what should +be done in summation or should have been done with the witness +who actually was the testifying witness with the exhibit. +So this could have been done, you know, with +, for example. You have that message pad? Yes. +Compare that message pad with this particular record. Are +those the same phone numbers? I suppose that could happen. +Or with Carolyn, could have been asked, Is that your +phone number? Does that match the record? +This is simply an FBI agent who's going to take those +pieces of evidence selectively and then talk about them; this +matches this, this matches that. I don't believe that's +appropriate under 1006, which is, you know, the rule that +allows for summary exhibits, for example, but does not allow +for summary testimony of things that have already been admitted +into evidence. +Certainly in the government's closing argument they +can do this and they can make whatever arguments they want. +But this is simply a closing argument through a summary witness +in the middle of a trial before a very long break, and I just + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +1983 +don't think it's appropriate under these circumstances. +THE COURT: This agent, what was his role in the +investigation? +MS. MOE: Your Honor, this agent's role was limited to +analyzing these records in preparation for trial. +Your Honor, in particular because these exhibits +contain identifying phone numbers and names, we feel more +comfortable publishing these exhibits with an agent, as opposed +to asking lay witnesses to review government exhibits for us in +order to facilitate that testimony. Our preference is to +publish this with an agent to do this carefully and +thoughtfully so that we're able to publish the exhibits before +the jury without exposing any identifying information. +It's very streamlined testimony, your Honor. We're +talking about exhibits the jury hasn't yet seen that haven't +been published. It's not duplicative of anything that's +already happened at the trial. And in particular, because +closings will be maybe as long as two weeks from now, we think +the jury should see these exhibits now; they have not yet been +published. +THE COURT: That's a little bit of the problem. +Typically, in my experience, the summary agent witness +is the agent who talks about what he did in the investigation, +and that helps draw out complicated document comparators and +the like, not somebody who's just effectively doing a mini + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +closing. + +1984 +MS. MOE: Your Honor, we often call summary witnesses +who are not involved in the investigation who are just talking +about their analysis of records. The purpose here isn't to +have the summary witness talk through the investigation or +investigative steps, but to talk about a review of exhibits. +And I have called agents to do just that. +THE COURT: But for the purposes of doing what 1006 +permits, that's not what this is. I've seen it in two +contexts: One, 1006 you've got a complicated, extensive set of +records that are being summarized via a witness. And then +you've got investigative summary witnesses who talk through +factually what they did in a sense. And you're not doing +either of those; you're providing essentially a closing +argument or mini closing argument via a witness who has no +personal involvement in the investigation and doing so, sounds +like, with materials that don't require the type of 1006 +summary. +So you've created, I think, a little bit of a hybrid +of certainly what I've seen those two exemplars, for them to be +used. And so it just does sound like argument, summation, and +the kind of thing that - I mean, it's certainly true you could +have done it with the witnesses. At some point I might have +said, Save it for summation, counsel. But I can't say I've +ever seen a version like this. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +1985 +MS. MOE: Yes, your Honor. +I have in trials in this district called summary +witnesses who helped publish and connect up facts across +exhibits without creating summary charts under Rule 1006. I +think this testimony -- +THE COURT: You're not offering him under 1006? +MS. MOE: That's correct, your Honor. +THE COURT: And he isn't involved in the +investigation. +MS. MOE: That's correct, your Honor. +We'd just like an opportunity to publish these +exhibits in a way that facilitates the jury seeing them without +doing this through lay witnesses where there are complications +about reading things out loud, so that it's streamlined and +efficient so the jury can see the evidence that's been +admitted. We think that's appropriate. +THE COURT: Why not just do it in closing? +MS. MOE: Your Honor, I think to rest our case and +have the jury not see some of the evidence in this case, our +preference would be -- +THE COURT: The one thing I've seen that it sounds +like you're saying is actually not with a witness, but a bunch +of documents come in, and then the government spends a little +bit of time just publishing, publish this and publish that. +Again, I've never seen -- never seen -- an agent, a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +1986 +law enforcement agent, who had no involvement in the +investigation of the case and who isn't providing testimony +essentially pursuant to 1006. +MS. MOE: Your Honor, if the Court's preference is for +us to, without a person on the stand, just ask the jury to turn +from one exhibit to another to another, we can do that. I +think that is slightly more awkward than facilitating that +through a witness and pointing out the connections between two +things. +THE COURT: Right. But the witness is providing +testimony over which they have no personal knowledge. You're +simply asking them to do the work of the government in the +closing. +So, Mr. Pagliuca, do you have any objection to the +government publishing a few documents, going to a few points, +and then we move on, without a witness? +MR. PAGLIUCA: I don't understand that process, I +guess, your Honor. We're simply going to -- is this with a +witness or without a witness? +THE COURT: Without a witness. +MR. PAGLIUCA: We're simply going to say, The +government would like the jury to look at this and then look at +that? +THE COURT: Yes. +MR. PAGLIUCA: I do object to that process, your + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +1987 +Honor. This is classically what someone would do in a closing +argument. You can put this in a Power Point and put up a +screen that shows this, and then put up a screen that shows +that, and then make an argument about it. +And if they wanted to elicit this testimony, it should +have been done, I believe, with a witness that then could be +cross-examined substantively about what was being discussed. +This witness, Mr. -- if I'm saying it correctly, +Mr. Buscemi, can't be cross-examined substantively about +anything; all he's going to be able to say would be, I looked +at this, and I looked at that, and I looked at this, I looked +at that, and those are the exhibits. +So I guess I'm a little confused about the process, +where one would just look at a jury and say, Look at this and +then look at that. And I don't understand why that isn't, sort +of, impermissibly highlighting certain pieces of evidence. And +then, you know, am I allowed to get up and say, Why don't you +look at this and why don't you look at that? It just seems +rather awkward to me to be doing it in that fashion. +MS. MOE: Your Honor, that's why we propose doing this +with a witness, to avoid any, sort of, awkwardness. But I +don't understand the objection to publishing items that are in +evidence that the jury has not yet seen. Again, our hope was +for this to be very streamlined; but I understand the Court's +concerns. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 15 of 49 +1988 +THE COURT: Right. It's a streamlined version of the +closing argument. And again, I'm not aware -- I'm not aware -- +certainly seen summary with investigative officers. That's not +this. And I've seen officers who are analyzing complicated +data under 1006 provide that to the jury. That's not this. +And I've seen, when the evidence comes in, the government spend +a fair amount of time -- as you've done with some exhibits -- +going through piece by piece in order to highlight and draw +certain connections. +I'm not going to let you do it through a witness who +has no personal experience. I think you do it in closing. +That's what this is, it's closing argument. +MS. MOE: Understood, your Honor. +THE COURT: Okay. What else? +MR. PAGLIUCA: I think the only open issue that I'm +aware of, your Honor, is the Exhibit 52 issue. +THE COURT: Yes. I got the briefing at 9:45, so 15 +minutes early finished, I appreciate it. And I am still +dotting my i's and crossing my t's. I think we don't need it +till the government is prepared to rest; is that right? +MS. COMEY: That's correct, your Honor. +THE COURT: You agree with that? +MR. PAGLIUCA: Yes, your Honor. +THE COURT: Anything else to take up now? +MR. PAGLIUCA: Not from the defense, your Honor. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +1989 +THE COURT: On scheduling, needless to say, I didn't +send you a draft of the charge last night. I think my thinking +is if the government rests today or tomorrow, which sounds like +what we anticipate, I'll use the remainder of tomorrow, one, to +hear the defense motions; and two, for me to work on the charge +on my own, having already received your drafts. +And then I'll send it to you at some point in advance +of a charging conference, which we'll do next week. And again, +I'm open to you telling me whether you want to do it in the +evenings after testimony or on Saturday. I think really the +analysis there depends on what the defense now anticipates as +the length of its case. +So are you in a position to give any additional +estimate as to that? +MR. PAGLIUCA: We don't, your Honor. +I think we're hoping to take this evening and tomorrow +to put those pieces together, and then provide the Court and +the government with that analysis. +THE COURT: Okay. Ms. Sternheim. +I just say, I think it is our +thinking at the moment that if we are going to be using the +trial days, that our preference would be to Saturday for a +charge conference. It seems that it would just be a more +focused time. +THE COURT: I think really the only reason not to do + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +1990 +that -- and, as I said, I wanted to have agreement from both +sides on it. But the reason not to do that would be if we +might get to closings before the following Monday. And that's +why it's really -- because if we will get to closings before +the following Monday, the charge needs to be done before then. +MS. STERNHEIM: Of course. And we will update the +government and the Court with regard to scheduling. +THE COURT: okay. +So I think if there's a chance that the defense either +won't put on a case or would rest before Friday, then we should +do the charge conference Thursday night. So that's the +question. +MR. PAGLIUCA: Understood, your Honor. +THE COURT: Okay. +Does the government have any preference or views on +that? +MR. ROHRBACH: The government has no preference. That +makes sense to us. Thank you, your Honor. +THE COURT: Okay. Great. Yes. +MS. COMEY: Your Honor, in connection with the defense +case, I do think there's still the outstanding issue of the +subpoena to Mr. Glassman. +THE COURT: Yes. I was looking at that last night as +well. And I have a question and a little bit of a proposal, +see if we can get back to a magical moment. It's a difficult + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | + +1991 +issue and it's close, I'll admit, based on where I am now. I +think it's close. +But what I'm wondering is if what the defense +essentially needs to make the arguments it wants to make is +testimony from Mr. Glassman that he told the government that he +told Jane that some form of cooperation or testimony would help +her case. +That question might have some evidentiary issues, +but it's not an attorney-client privilege issue. +I think the answer to that question basically gets the +defense what it's looking for without infringing on +attorney-client privilege. +And so I'd like you to consider a +proposal in which the testimony that you're seeking is limited +to that and, depending on the parties' views and Mr. Glassman's +views, if that is the limit of the testimony, whether it could +be through stipulation. +So you'll consider that. +MS. COMEY: Yes, your Honor. +MR. PAGLIUCA: We will, your Honor. +THE COURT: Okay. All right. +Anything else I can take up? +We're checking on our jurors. +MR. EVERDELL: Nothing from the defense, your Honor. +THE COURT: I'm sorry. +So you put in the letters to me last night on 52. +You'll docket those today? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +1992 +MR. ROHRBACH: Yes, your Honor. The government has a +few proposed redactions to its letter; so we will propose those +redactions and docket a version that implements those +redactions subject to the Court's ruling on them. +THE COURT: Okay. Remember, my basic view is get it +on the docket and then propose your redactions so that I'm +not - put it on the docket with your proposed redactions and +I'll let you know if it should be redacted less. +MR. ROHRBACH: Yes, your Honor. And we will do that +today. +THE COURT: Okay. And same for -- I think you were +just waiting to see if the government had proposed redactions, +is that -- +MR. PAGLIUCA: That's correct, your Honor. +I think we can mirror the government's redactions. I +have to just think about whether the Exhibit A, I think it was, +that was attached and then responded to, I think we need to +think about how that gets redacted. And I think likely my view +would be the entirety of it gets redacted. +THE COURT: Okay. I will consider that. +Anything else? +MR. ROHRBACH: Nothing from the government. +MR. EVERDELL: No, your Honor. +THE COURT: All right. +We're missing a couple jurors, +but I suspect they'll be here soon. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +1993 +We'll take a break and start as soon as they're here. +Thank you. +(Recess) +THE COURT: Anything to take up before we bring in the +jury? +MR. ROHRBACH: +Nothing from the government, your +Honor. +MR. EVERDELL: Nothing from the defense, your Honor. +THE COURT: Okay. We'll bring in the jury please. +(Jury present) +THE COURT: Good morning, members of the jury. +Hope you had a good of evening. Thank you again for +your continued diligence, punctuality, and patience. +Mr. Rohrbach, the government may call its next +witness. +MR. ROHRBACH: The government calls Tracy Chapell. +THE COURT: Tracy Chapell may come forward. +TRACY CHAPELL, +called as a witness by the Government, +having been duly sworn, testified as follows: +THE COURT: Thank you, Ms. Chapell. +Mr. Rohrbach, you may inquire. +DIRECT EXAMINATION +BY MR. ROHRBACH: +Q. Good morning, Ms. Chapell. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +1994 +A. Good morning. +Q. Ms. Chapell, where do you work? +A. +Federal Express Corporation. +Q. How long have you worked there? +A. One year. +Q. What's +your position at Federal Express? +A. +Senior paralegal. +THE COURT: Mr. Rohrbach, could you pull the mic up a +little please. Thank you. +MR. ROHRBACH: Of course. I apologize, your Honor. +THE COURT: Thank you. +l. And what are your duties and responsibilities as a senior +paralegal at Fedex? +A. Io respond to subpoenas and produce the records of Federal +Express. +l. And as part of your job, are you familiar with Federal +Express's recordkeeping practices? +l. In particular, are you familiar with the business practices +regarding billing invoices? +l. How are billing invoices generated? +A. They are generated through the scanning events and then +populated through the revenue service department. +Q. Can you explain what you mean by scanning events? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +A. Well, each movement of the package is scanned so it can be +tracked through the system as to where the package is. Once it +meets the final delivery spot, then that final scan will +generate an invoice. +Q. What sort of information is contained in an invoice? +A. The account number, +the invoice number, the invoice date, +the account holder information, and the amount of the shipment. +Q. +Does FedEx keep billing invoices in the ordinary course of +business? +l. And is making invoices a regular practice of FedEx? +l. Ms. Chapell, in the binder next to you, would you please +look at what's been marked for identification as Government + +Do you recognize this? +1995 +l. What is it? +A. It's a invoice on Jeffrey E. Epstein's account. +l. Have you reviewed this before today? +l. Is it a fair and accurate copy of an invoice held by FedEx? +MR. ROHRBACH: Your Honor, the government offers +Government Exhibit 801 under seal to protect third-party and + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +1996 +pseudonym-protected witnesses, and Government Exhibit 801-R not +under seal. +MR. EVERDELL: No objection. +THE COURT: All right. GX-801 is admitted under seal +for the reason indicated. And 801-R is admitted as a public +exhibit. +(Government's Exhibits 801, 801-R received in +evidence) +BY MR. ROHRBACH: +l. Ms. Chapell, would you turn to Government Exhibit 802, +what's been marked for identification as Government Exhibit 802 +in your binder. +A. Okay. +l. And do you recognize this? +l. What is it? +A. Invoice on Jeffrey E. Epstein's account. +l. Have you reviewed this before today? +FedEx? +l. And is it a fair and accurate copy of the version held by +MR. ROHRBACH: Your Honor, the government offers +Government Exhibit 802 under seal for the same reasons, and +Government Exhibit 802-R without any sealing. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 24 of 49 +1997 +MR. EVERDELL: No objection. +THE COURT: All right. 802 is admitted under seal for +the reason indicated. 802-R is admitted as a public exhibit. +(Government's Exhibits 802, 802-R received in +evidence) +BY MR. ROHRBACH: +e. And finally, Ms. Chapell, would you turn to what's been +marked for identification as Government Exhibit 803. +A. Okay. +l. Do you recognize this? +l. And what is it? +A. Invoice on Jeffrey E. Epstein's account. +Q. Have you reviewed it before today? +l. And is this a fair and accurate copy of the version held by +Federal Express? +MR. ROHRBACH: Your Honor, the government offers +Government Exhibit 803 under seal for the same reasons, and +Government Exhibit 803-R to the public. +MR. EVERDELL: No objection. +THE COURT: GX-803 is admitted under seal; 803-R is +admitted as a public exhibit. +(Government's Exhibits 803, 803-R received in + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +evidence) +Document 757 Filed 08/10/22 Page 25 of 49 +1998 +MR. ROHRBACH: +With your Honor's permission, may I +publish the documents? +THE COURT: Yes, you may publish the R versions. +MR. ROHRBACH: Yes. +Ms. Drescher, will you please pull up Government +Exhibit 801-R for everyone. +BY MR. ROHRBACH: +l. Ms. Chapell, would you please turn to Government Exhibit +801 in your binder. +MR. ROHRBACH: And with the Court's permission, I +would ask that the jury be instructed to turn to Exhibit 801 in +their binders. +THE COURT: Okay. Is it the large binder? +MR. ROHRBACH: My understanding, there's one binder. +THE COURT: Okay. The only binder, 801 - GX-801, +please. +Q. Now that we're looking at it, Ms. Chapell, who is the +account holder on this invoice? +A. Jeffrey E. Epstein. +Q. And turning now to page 5 of the invoice and looking at the +top row of the invoice. +A. Okay. +l. Who is the sender of this package? +A. S. +I, and underneath it's Jeffrey E. Epstein. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Document 757 Filed 08/10/22 Page 26 of 49 +1999 +Q. And what is the sender address? +A. It is 457 Madison Avenue, New York, New York, 10022. +Q. And without saying any names, without saying the last name +of the recipient, what is the first name of the recipient? +A. Carolyn. +Q. And where is the city and state of the delivery? +A. West Palm Beach, Florida. +Q. Thank you. +MR. ROHRBACH: And with the Court's permission, I +would ask the jurors to hold their place here and turn to +Government Exhibit 11 for a moment, which is in evidence. +MR. EVERDELL: No objection. +THE COURT: All right. +Please 1ook at GX-11, and then turn back to this page. +MR. ROHRBACH: And on GX-11 we would direct the jury's +attention to the date of birth. +THE COURT: Okay. Okay. +So you've looked at GX-11. +And then you'll go back to GX-803. +MR. ROHRBACH: 801, your Honor. +THE COURT: I'm sorry. 801. Apologies. +BY MR. ROHRBACH: +Q. Ms. Chapell, what is the date that this package was sent? +A. It was picked up to be shipped on December 3rd, 2002. +Q. Keeping in mind the recipient's address, Ms. Chapell, I'd + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 27 of 49 2000 +like to turn to Government Exhibit 802 and to the eighth page. +And looking at the middle row, does the recipient have the same +address as the recipient we were just looking at? +MR. ROHRBACH: Your Honor, if they haven't already +done so, we'd ask the jury to turn to Government Exhibit 802. +THE COURT: Okay. +Please turn to GX-802. +Q. Ms. Chapell, directing your attention to the middle row on +this page, who is the sender of this package? +A. J. Epstein. +Q. And what is the address? +A. 457 Madison Avenue, New York, New York. +Q. And would you spell the first name of the recipient here? +A. C-A-R-D-I-N-E. +Q. And what is the city and state? +A. West Palm Beach, Florida. +Q. On what date was this package sent? +A. December 12th, 2002. +MR. ROHRBACH: And finally, your Honor, I would like +to turn the jurors' attention to Government Exhibit 803. +THE COURT: Okay. You may turn to 803, please. +l. And Ms. Chapell, if you would please do the same. And +turning to page 6 of this document and directing your attention +to the bottom row, Ms. Chapell, who is the sender of this +package? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2001 +A. +Q. Are there any other names listed? +A. Yes, Jeffrey E. Epstein. +Q. What is the shipping address? +A. 457 Madison Avenue, New York, New York. +Q. Without saying +the last name, what is the first name of the +recipient? +A. Caroline. +l. What is the city and state of the recipient? +A. West Palm Beach, Florida. +Q. What is the date of this package? +A. October 7th, 2002. +e. Thank you. +MR. ROHRBACH: No further questions, your Honor. +THE COURT: Okay. Mr. Everdell. +MR. EVERDELL: Thank you, your Honor. +THE COURT: You may put your binders down. Thank you. +MR. EVERDELL: May I inquire, your Honor? +THE COURT: You may. +CROSS-EXAMINATION +BY MR. EVERDELL: +l. Good morning, Ms. Chapell. +A. Good morning. +l. You just testified about a few invoices from Federal +Express that were provided to you by the government; is that + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 29 of 49 +2002 +right? +A. Correct. +Q. And you testified that they were associated with a FedEx +account of Jeffrey Epstein, right? +Q. And all of those -- three of those invoices that we just +looked at, Government's Exhibit 801, 802, and 803, were from +the last few months of 2002; is that right? +Q. And those invoices each showed shipments for roughly a few +week to a month period of time, right? +A. Correct. +l. I just want to look at a few of those invoices that we +looked at. I'm going to start with Government's Exhibit 803, +and I'm going to direct your attention to page 6 of 9. +MR. EVERDELL: With the Court's permission, I'll have +the jurors look in the same binder at Government's 803. +THE COURT: Yes. +Members of the jury, please 1o0k at GX-803. +MR. EVERDELL: And just directing the jurors' +attention to page 6 of 9. +THE COURT: Page 6. Okay. 803, page 6. +MR. EVERDELL: Actually, I apologize. If we can just +first start with page 1 just so we can orient ourselves. +THE COURT: Okay. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2003 +BY MR. EVERDELL: +Q. So, Ms. Chapell, if you look at page 1. So we're looking +here on Government's Exhibit 803-R at the invoice dated October +14th, 2002, right? +A. Correct. +Q. And as you said before, this is an invoice that's +associated with an account, the FedEx account of Jeffrey +Epstein, right? +l. And if you look up at that top left-hand corner, you see +the billing account shipping address, right? +2. And it says Jeffrey E. Epstein, 457 Madison Avenue, New +York, New York, 10022, right? +l. That's the address associated with this account for billing +purposes, right? +A. Correct. +2. Now, I want you to skip to the page I mentioned before, +page 6 of 9. All right. Now, I think if you look down at the +last transaction on that page, that's a shipment that was sent +out or was picked up for shipment on October 7th of 2002, +right? +l. And do you see the information that's over on the left-hand + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2004 +side under the heading "Sender"? +2. That information says +is that right? +l. And it has then Jeffrey E. Epstein and the address 457 +Madison Avenue, right? +Q. And that is the information that is present on the FedEx +slip that goes with the package, right? +A. Correct. +l. So whatever information is filled out on the slip that gets +attached to the FedEx package is what appears under "Sender, " +right? +A. Correct. +l. Okay. And you see that this, the recipient here -- and I'm +not asking you to say her full name, but the first name of the +recipient here is Caroline; is that right? +A. Correct. +2. And I think you mentioned the city and state, is that +right, of where this was going? +MR. EVERDELL: May I confer? +THE COURT: Yes. +(Counsel conferred) +l. You said that this was going to West Palm Beach, Florida, +right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 32 of 49 +2005 +A. Correct. +l. Okay. And I just want to refer back to the sender though, +okay. +That sender says that the package was sent by +¡ correct? +A. Correct. +Q. It goes without saying that +is not Ghislaine +Maxwell; correct? +A. Correct. +l. Okay. And that is the only transaction on this invoice +that the government showed you to discuss in your direct +testimony, right? +A. Correct. +l. I want to show you another transaction on this invoice. If +you can go to page 7 of 9. +A. Okay. +l. And I want to show you the transaction in the middle of the +page, the middle of the three. Do you see that one? +l. That is also a shipment that was picked up for shipment the +same day, October 7th of 2002, right? +A. Correct. +Q. And that is the same day as the package we just looked at +that was sent by +on the page before, isn't it? +l. All right. Well, looking at this one, you see the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | +Document 757 Filed 08/10/22 Page 33 of 49 +2006 +recipient there is one named +• Wasserman, right? +A. Correct. +Q. And you see the +sender information on this shipment; +correct? +A. Correct. +Q. And the sender there is listed as Ghislaine Maxwell; is +that right? +A. Correct. +l. And then, of course, there's the information below, Jeffrey +Epstein, 457 Madison Avenue. +l. Okay. It goes without saying that -- well, I shouldn't say +"goes without saying." +There is no other transaction or there is no +transaction on this invoice we're looking at where someone +named Ghislaine Maxwell is sending a package to anyone named +Carolyn; correct? +A. Correct. +2. Okay. Let's look at the next one. This is government's +801. And I'm doing this because I believe this goes +chronologically in order, right. The one we just looked at was +October, right? +l. So let's 1o0k at 801. +MR. EVERDELL: And the jurors can do the same, with + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2007 +the Court's permission. +THE COURT: Yes. +Q. And we'll go to the first page of 801-R. +So, Ms. Chapell, do you have that? +Q. So this is an invoice from December 16th of 2002, right? +Q. So that's just roughly two months after the invoice we just +saw? +2. And it's the same billing information, it's the same +account we're looking at? +Q. That's the account of Jeffrey Epstein at 457 Madison +Avenue, right? +A. Correct. +l. All right. Let's take a look at page 5. +Do you have that page, Ms. Chapell? +l. All right. This is the transaction that you were shown by +the government to discuss, right? +l. And this shows a shipment that was picked up for shipment, +FedEx package that was picked up for shipment on December 3rd +of 2002, right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | + +2008 +Q. And here the recipient -- again, I'm just going to use +first names here. +The recipient is Carolyn, right? +A. Correct. +Q. That was going to West Palm Beach, Florida, as well? +Q. All right. But you see over at the sender information; +correct? +l. The sender is listed as S. +right? +A. Correct. +e. Do you know who S. +is? +A. No. +l. Okay. Safe to say that S. +right? +is not Ghislaine Maxwell, +A. NO. +l. Okay. Now, you were shown this transaction by the +government, right? +A. Correct. +l. I want to point you to a different transaction in the same +invoice. +MR. EVERDELL: If we can go to page 6, the next page. +2. And I want you to 1ook at the bottom of that page, the last +transaction. +A. Okay. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Document 757 Filed 08/10/22 Page 36 of 49 +2009 +l. That is a shipment, a FedEx package that was picked up for +shipment on December 9th, 2002, right? +A. Correct. +Q. And you see that the recipient of that package is someone +named Lisa Anasrons is how it's spelled? +l. And the sender of that is G. Maxwell; correct? +A. Correct. +l. And safe to say that this is not a package going to anybody +named Carolyn, right? +A. It is not. +l. It's going to Lisa Anasrons, whoever that may be, right? +A. Correct. +l. Okay. Let's look at another one from this invoice, page 8. +I'll ask you to look at both of these transactions, if we +could. These are both FedEx packages that were picked up for +shipment on December 10th of 2002; correct? +A. Correct. +2. And if we look at the first one, the recipient there is +listed there as Isabel Maxwell? +l. And the sender is G. Maxwell? +Q. And if you look down at the next one, the recipient there +is Ron Burckle, right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| + +2010 +l. And again, +sender of that package same day is G. Maxwell, +right? +A. Correct. +l. And in both the sender -- again, we have that information, +Jeffrey Epstein, 457 Madison Avenue, right? +l. So the first package looks like it's going to Isabel +Maxwell, and the second going to Ron Burckle, right? +l. Neither one of those is named Carolyn; correct? +A. Correct. +l. And, in fact, there is no shipment or transaction reflected +in this invoice where someone named Ghislaine Maxwell is +sending a package to someone named Carolyn, right? +A. Correct. +l. All right. And let's just look at the last invoice you +were shown by the government, that's Government's 802. +MR. EVERDELL: If you can pull that up. +A. Okay. +THE COURT: Jurors may turn to 802. +MR. EVERDELL: Thank you, your Honor. +l. All right. Ms. Chapell, do you have that in front of you? +Q. All right. So looking at the first page, this is the + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | + +2011 +invoice dated December 23rd, 2002; correct? +Q. All right. Again, +same account we're looking at of Jeffrey +Epstein? +A. Correct. +Q. All right. Let's flip to page 8. I want you to take a +look at the middle of the three transactions there. +We'll pull +that up. This was the transaction that you were shown by the +government on your direct, right? +A. Correct. +Q. And that is a FedEx package picked up for shipment on +December 12th, 2002; correct? +A. Correct. +l. All right. And the recipient there, I'm, again, not going +to use full names, but the first name there is listed as +Cardine; correct? +A. Correct. +l. And the address is West Palm Beach, Florida, right? +right? +A. Right. +l. The sender there is J. Epstein, right? +l. Safe to say that J. Epstein is not Ghislaine Maxwell, +2. Okay. Now, I want to show you some other transactions on + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2012 +that same invoice that you weren't shown by the government. +And I want to stay on the same page and I want to look at the +first transaction on the page. +Okay. Now, I want to be careful about this. I don't +want to use any names when we discuss this transaction, okay? +A. Okay. +Q. All right. That is a package that was picked up for +shipment on the same day as the one we just looked at, December +12th, 2002; correct? +Q. And I'm not going to name who the recipient is, but I'm +going to refer to that person as "Jane, " okay? +A. Okay. +l. So the recipient there is Jane. +l. The sender is someone named J. Epstein; correct? +A. Correct. +l. Okay. Again, that is not Ghislaine Maxwell or G. Maxwell, +right? +A. No. +l. Okay. Let's 100k at just a few others. +Page 4 of the same invoice, and we'll look at the +middle transaction here. +All right. Now, that is a FedEx package that was +picked up for shipment on December 9th of 2002, right? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2013 +Q. That was just a few days before the shipments we just +looked at on December 12th, right? +A. Correct. +l. And you see the recipient here is listed as someone named +Laura +Wasserman, right? +Q. And the sender is G. Maxwell? +l. This obviously is -- the recipient is not anyone named +Carolyn or Cardine, right? +A. Correct. +2. And again, let's look at page 5, the next page. And 1o0k +at the first transaction on this invoice. That is a FedEx +package picked up for shipment on December 10th of 2002, right? +l. And the recipient there is someone named Danny Hillis? +Q. And the sender is G. Maxwell? +A. Correct. +l. Danny Hillis is not named Carolyn or Cardine or anything +like that, right? +A. Correct. +l. Okay. And again, on this invoice there is no transaction +reflected on this invoice where someone named Ghislaine Maxwell + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Page 41 of 49( +2014 +or G. Maxwell is sending any packages to anybody named Carolyn +or Cardine or anything like that? +A. Correct. +Q. You can put those down. +MR. EVERDELL: And the jurors, with the Court's +permission, can do the same. +THE COURT: Yes. +Thank you. +Q. Ms. Chapell, I'll just wait a moment. +Before you came to testify today, you had some phone +calls with the government; is that right? +l. And that was to prepare your testimony today; correct? +l. And before you spoke to them, they sent you those three +invoices that we were just talking about, is that right? +l. And you looked at them to verify that they were true and +accurate records that FedEx had in their system, right? +l. And those were the only invoices they sent you to verify; +is that right? +l. Those three that we were looking at? +l. Okay. And I think they were so old at that point that you + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE| +Document 757 Filed 08/10/22 Page 42 of 49 +actually had to go back and look at archived copies to verify +that they were true records, right? +A. Correct. +Q. They weren't still in your system; you had to go back to +the boxes in the warehouse, right? +A. Correct. +Q. But you were able to do that? +Q. Okay. Now, do you recall at any point where the defense +sent you some invoices to verify? +defense? +l. And do you remember how many roughly you were sent by the +A. There were several hundred. +l. And were they from the same account or different accounts? +A. Iwo different accounts. +l. Were those accounts associated with Jeffrey Epstein? +A. Yes, they were both his. +Q. And what were you asked to do with those records? +A. Just verify the records. +l. Were you able to take those records and verify them with +the records in the boxes, that they were accurate business +records? +Q. Okay. And these were all records for accounts that +2015 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +belonged to Jeffrey Epstein, right? +l. And can you explain just how you were able to verify them? +A. I went back to the paper copies and verified the invoices +one by one. +Q. Okay. +2016 +MR. EVERDELL: Your Honor, I'm going to do this in +paper, if I could. May I approach? +THE COURT: You may. +MR. EVERDELL: Okay. +THE COURT: Showing the witness what's been marked as +Defendant's IC-1; is that correct? +MR. EVERDELL: Correct, your Honor. +THE COURT: Okay. +BY MR. EVERDELL: +l. All right. Ms. Chapell, do you have in front of you what's +been marked for identification as Defendant's Exhibit IC-1? +2. Now, do you recognize what those are? +I. What are they? +A. Jeffrey Epstein invoices. +l. Are those some of the records that were provided to you by +the defense? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:20-cr-00330-PAE | + +2017 +Q. Are they all of the several hundred records or just a +subset of those records? +A. +Just a few. +Q. And how many roughly are there? +A. In this stack? +Q. Yes. +A. About 50. +Q. And what year or years do those invoices come from? +A. 2002. +l. And how is it that you recognize that that's what those +are? +A. Because I verified it with the originals that we produced. +2. But how do you know that it's the same invoices that you +were asked to look at? +A. I initialed at the bottom. +2. Now, were those records that you're looking at in Defense +Exhibit TC-1 made at or near the time of the shipping records +that are reflected in the invoice? +l. And are they based on information that was available at the +time that those shipments were made? +l. And is it the regular practice of Federal Express to make +invoices like this? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 Filed 08/10/22 Page 45 of 49 +2018 +Q. And were these invoices kept in the regular course of +FedEx's business? +MR. EVERDELL: Your Honor, at this time the defense +offers Defense Exhibit IC-1 under temporary seal. We have not +yet had the chance to make the appropriate redactions, but we +will do so as soon as we can. +MR. ROHRBACH: No objection. +THE COURT: Thank you. Defendant's IC-1 is admitted +under temporary seal until narrow redactions can be offered. +(Defendant's Exhibit IC-1 received in evidence) +MR. EVERDELL: Absolutely, your Honor. +And if the jurors would like to take a look, with the +Court's permission, there is a folder underneath their chairs +with this exhibit. +THE COURT: Yes, please. You can open the folder to +Defendant's Exhibit IC-1. +BY MR. EVERDELL: +Q. Ms. Chapell, I'm not going to go through these records with +you -- and the jurors are free to review it if they like -- but +I have no further questions for this witness. +THE COURT: Okay. +MR. ROHRBACH: Nothing further, your Honor. +THE COURT: Okay. Ms. Chapell, thank you. +You are excused. You may step down. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2019 +(Witness excused) +MS. MOE: Your Honor, could I have just a moment to +confer with the defense? +THE COURT: You may. +(Counsel conferred) +THE COURT: Members of the jury, you may put the +folder back under your seats. +MS. COMEY: Your Honor with the defense's consent, +we'd ask to be heard in the robing room please. +THE COURT: Okay. You anticipate an extended sidebar? +MS. COMEY: We just need to be in the robing room, +your Honor. +THE COURT: Okay. Why don't I send the jury back to +the jury room for a break and then -- +MS. MOE: Thank you, your Honor. +THE COURT: Yes, to the regular room. +(Jury not present) +THE COURI: All right. I'll hear you in the robing +room. This is an extended discussion? +MS. MOE: I'm not sure, your Honor, but our joint +preference would be to be heard in the robing room. +THE COURT: Okay. All right. +(Pages 2020 to 2024 SEALED) +(Continued on next page) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 + +2025 +(In open court) +THE COURT: Bring in the jury. +MR. EVERDELL: Your Honor? +MS. MENNINGER: Our client is not here. +THE COURT: I'm going to step off. +(Recess) +THE COURT: We'll bring in the jury. +(Jury present) +THE COURT: Thank you, members of the jury. +I've been informed there's an attorney in the case +who's ill, and that attorney needs to get care. We have no +reason to believe it's COVID-related, but we do need that +attorney for what was anticipated to happen today. So we need +to break. +My assumption is we'll resume tomorrow morning at our +normal time. And I'll give you any additional information, if +I have that information. But we want to make sure the attorney +is taken care of. And rather than pause and delay, we're going +to break for the day. +So all of my instructions apply. +Thank you for your time and attention. +We'll see you tomorrow morning. Thank you. +(Jury not present) +THE COURT: Counsel, is there anything we can take up +now or wait until we get further word? + + +Page 48 of 49 2026 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +MS. COMEY: I don't believe there's anything we can +take up now, your Honor. +We will keep the Court and the +defense informed. +THE COURT: Okay • +MR. EVERDELL: Nothing from the defense, your Honor. +THE COURT: All right. Thank you, everyone. +We're adjourned till tomorrow. +MS. MOE: Thank you, your Honor. +(Adjourned to December 10, 2021 at 8:45 a.m.) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Document 757 +Filed 08/10/22 + +2027 +INDEX OF EXAMINATION +Examination of: +TRACY CHAPELL +Direct By Mr. Rohrbach . . +Cross By Mr. Everdell +Page +* +• . .....1993 +..........2001 +GOVERNMENT EXHIBITS + +801, 801-R +802, 802-R +803, 803-R +.. = +Received +... .1996 +... 1997 +• 1997 +DEFENDANT EXHIBITS + +IC-1 +Received +.. .. +• 2018 \ No newline at end of file diff --git a/vision-fixhub/court-05/6c2fa5b4d76607b36904bc16c29f0b8f544ac1f45cd50a2714d9b0be4390328a.receipt.json b/vision-fixhub/court-05/6c2fa5b4d76607b36904bc16c29f0b8f544ac1f45cd50a2714d9b0be4390328a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7f597d20242769da99003c7bc174433721a8508d --- /dev/null +++ b/vision-fixhub/court-05/6c2fa5b4d76607b36904bc16c29f0b8f544ac1f45cd50a2714d9b0be4390328a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -6357, + "dataset": "marble-joined", + "doc_id": "6c2fa5b4d76607b36904bc16c29f0b8f544ac1f45cd50a2714d9b0be4390328a", + "engine": "marble-apple-vision", + "event_count": 80, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "496ed2c41f2d752593542dde1318c965d9efcf9ff0878c222c115be21cff7f67", + "output_sha256": "2292ca6070bc0c0a32a61c2734b3db08c7fc07ec944257f3e22693406bd526a4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6c4765e9d33dc72115f9b780ffe8b645ec10d901624896e446c4890fc8d1b46b.md b/vision-fixhub/court-05/6c4765e9d33dc72115f9b780ffe8b645ec10d901624896e446c4890fc8d1b46b.md new file mode 100644 index 0000000000000000000000000000000000000000..fd8df1bf0efd4ceb3048f0e77f6cf61911ae953e --- /dev/null +++ b/vision-fixhub/court-05/6c4765e9d33dc72115f9b780ffe8b645ec10d901624896e446c4890fc8d1b46b.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 237-4 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/6c4765e9d33dc72115f9b780ffe8b645ec10d901624896e446c4890fc8d1b46b.receipt.json b/vision-fixhub/court-05/6c4765e9d33dc72115f9b780ffe8b645ec10d901624896e446c4890fc8d1b46b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b5b65b3f1728f2892e688e5e9ffeb32323cd8582 --- /dev/null +++ b/vision-fixhub/court-05/6c4765e9d33dc72115f9b780ffe8b645ec10d901624896e446c4890fc8d1b46b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "6c4765e9d33dc72115f9b780ffe8b645ec10d901624896e446c4890fc8d1b46b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "0e9e61c356f6bf63ac4046168745603b8bc5818f5843207ab0abf7aacc56e8b0", + "output_sha256": "d4b39b3ef5b6950123242be34c2497c2226323307cb543c607b34e79009e6c18", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6c560cec45b7c94bbc972073e17cfcb3a93dc876f57829f89808150953dfabc1.md b/vision-fixhub/court-05/6c560cec45b7c94bbc972073e17cfcb3a93dc876f57829f89808150953dfabc1.md new file mode 100644 index 0000000000000000000000000000000000000000..83c15414a46d5507bdfc2cbc4a9cef8b1c5ed6e3 --- /dev/null +++ b/vision-fixhub/court-05/6c560cec45b7c94bbc972073e17cfcb3a93dc876f57829f89808150953dfabc1.md @@ -0,0 +1,115 @@ +Case 1:22-cv-10904-JSR Document 90 +Filed 03/20/23 Page 1 of 4 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +JANE DOE 1, Individually and on +Behalf of All Others Similarly +Situated, +22-cv-10018 +(JSR) +Plaintiff, +-V- +DEUTSCHE BANK AKTIENGESELLSCHAFT, +DEUTSCHE BANK AG NEW YORK BRANCH, +DEUTSCHE BANK TRUST COMPANY +AMERICAS, +Defendants. +JANE DOE 1, Individually and on +Behalf of All Others Similarly +situated, +22-cv-10019 (JSR) +Plaintiff, +-y- +JP +CHASE BANK, N.A., +Defendant. +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +22-cv-10904 (JSR) +ORDER +-v- +JP +CHASE BANK, N.A., +Defendant. +1 + + +Case 1:22-cv-10904-JSR Document 90 Filed 03/20/23 Page 2 of 4 +JED S. RAKOFF, U.S.D.J.: +On February 1, 2023, and February 7, 2023, defendants filed +motions to dismiss the operative complaints in the above-captioned +cases. Upon consideration of all parties' written submissions and oral +argument, the Court hereby grants those motions +in part and denies +those motions in part, as specified below. +With respect to Jane Doe v. Deutsche Bank Aktiengesellschaft et +al., 22-cv-10018, the Court hereby grants defendants' motion to dismiss +with respect to Counts II, III, IV, V, VII, VIII, IX, and X of the +First Amended Complaint. The Court hereby denies defendants' motion +with respect to Counts I, VI, XI, and XII of the First Amended +Complaint. Thus, for clarity, +the following claims asserted by +plaintiff Jane +Doe +against defendants Deutsche +Bank +Aktiengesellschaft, Deutsche Bank AG New +York Branch, and Deutsche +Bank Trust Company Americas +remain as +part of the case: (1) the claim +that defendants knowingly benefited from participating in a sextrafficking venture, in violation of 18 U.S.C. § 1591(a) (2); (2) the +claim that defendants obstructed enforcement of the Trafficking +Victims Protection Act, in violation of 18 U.S.C. S 1591(d); (3) the +claim that defendants negligently failed to exercise reasonable care +to prevent physical harm; and (4) the claim that defendants negligently +failed to exercise reasonable care as a banking institution providing +non-routine banking. All other claims are dismissed. +With respect to Jane Doe V. JP +Chase Bank, N.A., 22-cv- +10019, the Court hereby grants defendant's motion to dismiss with +2 + + +Case 1:22-cv-10904-JSR Document 90 Filed 03/20/23 Page 3 of 4 +respect to Counts I, II, VI, VII, VIII, and IX of the First Amended +Complaint. The Court hereby denies defendant's motion with respect to +Counts III, IV, V, and X of the First Amended Complaint. Thus, for +clarity, the following claims asserted by plaintiff Jane Doe against +defendant J.P. +Chase Bank, N.A. remain as part of the case: (1) +the claim that defendant negligently failed to exercise reasonable +care to prevent physical harm; (2) the claim that defendant negligently +failed to exercise reasonable care as a banking institution providing +non-routine banking; (3) the claim that defendant knowingly benefited +from participating in a sex-trafficking venture, in violation of 18 +U.S.C. § 1591(a) (2); and (4) the claim that defendant obstructed +enforcement of the Trafficking Victims Protection Act, in violation +of 18 U.S.C. § 1591(d). All other claims are dismissed. +With respect to Government of the United States Virgin Islands +V. JP +Chase Bank, N.A., 22-cv-10904, the Court hereby grants +defendant's motion to dismiss with respect to Counts II, III, and IV +of the First Amended Complaint. The Court hereby denies defendant's +motion with respect to Count I of the First Amended Complaint. Thus, +for clarity, the claim of plaintiff the Government of the United States +Virgin Islands that defendant JP +Chase Bank, N.A. knowingly +benefited from +participating in a sex-trafficking venture, in +violation of 18 U.S.C. S 1591(a) (2), remains as part of the case. All +other claims are dismissed. +An opinion explaining the reasons for these rulings will follow +in due course. + + +Case 1:22-cv-10904-JSR Document 90 Filed 03/20/23 Page 4 of 4 +The Clerk is respectfully directed to close entry numbers 37 and +43 on the docket of 22-cv-10018; numbers 31 and 44 on the docket of +22-cv-10019; and number 38 on the docket of 22-cv-10904. +SO ORDERED. +New York, NI +March 20. 2022 +"RR... +4 diff --git a/vision-fixhub/court-05/6c560cec45b7c94bbc972073e17cfcb3a93dc876f57829f89808150953dfabc1.receipt.json b/vision-fixhub/court-05/6c560cec45b7c94bbc972073e17cfcb3a93dc876f57829f89808150953dfabc1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d641b64367fb4c035954dce7456f21e7a120a626 --- /dev/null +++ b/vision-fixhub/court-05/6c560cec45b7c94bbc972073e17cfcb3a93dc876f57829f89808150953dfabc1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -50, + "dataset": "marble-joined", + "doc_id": "6c560cec45b7c94bbc972073e17cfcb3a93dc876f57829f89808150953dfabc1", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "72f9ce8cea0167c60f210784880252d041b5b018429026beb2b82521c390da0f", + "output_sha256": "f80c2f2a9ce7c419e2047692f079101243c8065d89d1c082811c115d75986dc0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6c69945b6381e2c2053f264aae2c1f59f0f736280e16fa5a37515b0150f0ccf9.md b/vision-fixhub/court-05/6c69945b6381e2c2053f264aae2c1f59f0f736280e16fa5a37515b0150f0ccf9.md new file mode 100644 index 0000000000000000000000000000000000000000..eb23a11478d988635e8cfded0151f1522c7cf68c --- /dev/null +++ b/vision-fixhub/court-05/6c69945b6381e2c2053f264aae2c1f59f0f736280e16fa5a37515b0150f0ccf9.md @@ -0,0 +1,30 @@ +Case 1:20-cr-00330-PAE| +Document 783 +Filed 01/15/25 Page 1 of 1 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA +USA / Plaintiffs) +Case No.: 20-cr-330 +GHISLAINE MAXWELL, +Defendant(s) +) +NOTICE OF FILING OF OFFICIAL TRANSCRIPT +Hearing +Notice is hereby given that an official transcript of a +has been filed by the court reporter/transcriber in the above-captioned matter. +held on +November 10, 2021 +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting +the transcript is a judge or a member of the public or media. +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court +any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also +be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically +available to the public without redaction after ninety (90) calendar days. +This process may only be used to redact the following personal data identifiers: Social Security +numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure +5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information +may proceed by motion. +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. +Court Reporter/Transcriber +Date diff --git a/vision-fixhub/court-05/6c69945b6381e2c2053f264aae2c1f59f0f736280e16fa5a37515b0150f0ccf9.receipt.json b/vision-fixhub/court-05/6c69945b6381e2c2053f264aae2c1f59f0f736280e16fa5a37515b0150f0ccf9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8136976152211c454f7a8002c63d16cba83d6a13 --- /dev/null +++ b/vision-fixhub/court-05/6c69945b6381e2c2053f264aae2c1f59f0f736280e16fa5a37515b0150f0ccf9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -14, + "dataset": "marble-joined", + "doc_id": "6c69945b6381e2c2053f264aae2c1f59f0f736280e16fa5a37515b0150f0ccf9", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "a181c6d5728c08ef7e2da420dfc128c88120b7fb0fdd4d4c456b010a57603c47", + "output_sha256": "f81696bcbd5aa679dcbd8b3df1aa125a6a692389bedc9347949964eac8c0dd8e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6c6bc40a6bb7874f9c48f2727ddf776aa4dec10db6e325fbf95c2a16a50f1c24.md b/vision-fixhub/court-05/6c6bc40a6bb7874f9c48f2727ddf776aa4dec10db6e325fbf95c2a16a50f1c24.md new file mode 100644 index 0000000000000000000000000000000000000000..72581f81792f29610e9b4aecbf7f2bef12db0ff9 --- /dev/null +++ b/vision-fixhub/court-05/6c6bc40a6bb7874f9c48f2727ddf776aa4dec10db6e325fbf95c2a16a50f1c24.md @@ -0,0 +1,136 @@ +Case 1:22-cv-10904-JSR Document 50 Filed 02/17/23 Page 1 of 5 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +Case No. 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A., +Defendant. +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +MOTION FOR ORDER AUTHORIZING ALTERNATIVE SERVICE +OF SUBPOENA BY CERTIFIED MAIL UPON LESLIE WEXNER +NOW COMES the Government of the United States Virgin Islands, the Plaintiff in the +above-captioned action, and moves pursuant to Fed. R. Civ. P. 45 for an Order authorizing the +Government to provide alternative service by certified mail of a Subpoena to Produce Documents +upon non-party Leslie Wexner. +. As grounds for this Motion, the Government states the following: +The Government brought this civil action against Defendant JPMorgan Chase Bank, N.A. +("JPMorgan") as part of its ongoing effort to protect public safety and to hold accountable those +who facilitated or participated in, directly or indirectly, the trafficking enterprise of Jeffrey Epstein +("Epstein"). The Government's investigation has revealed that JPMorgan knowingly, recklessly, +and unlawfully provided and pulled the levers through which Epstein's recruiters and victims were +paid and was indispensable to the operation and concealment of the Epstein trafficking enterprise. +Financial institutions can connector choke—human trafficking networks, and enforcement +actions filed and injunctive relief obtained by attorneys general are essential to ensure that +enterprises like Epstein's cannot flourish in the future. + + +Case 1:22-cv-10904-JSR Document 50 Filed 02/17/23 Page 2 of 5 +Among the many payments JPMorgan processed that the Government has identified as +evidencing Epstein's wrongdoing was one by an ostensibly charitable organization of Epstein, +Enhanced Education, in the amount of $124,232 to billionaire businessman Leslie Wexner +("Wexner"). First Amended Complaint ("FAC") (ECF 47-1), 968. Epstein and Wexner had a +longstanding business and personal relationship until Wexner terminated Epstein in 2008, facts of +which JPMorgan was well aware. See JPM-SDNYLIT-00036291-36299 (Ex. A) at 36296 +(JPMorgan description of Epstein-Wexner relationship and termination). +Given Wexner's relationship with Epstein and interactions with JPMorgan, the +Government is attempting to serve a Subpoena to Produce Documents (Ex. B) upon Wexner. The +Government seeks documents concerning the transactions and relationship between Wexner and +Epstein and communications with JPMorgan regarding Epstein. Subpoena at 6 (Requests 1-4). +The Government attempted to serve the Subpoena upon Wexner at his home on February +8, 2023 at 8:10am, but was prevented from doing so by a security guard, who would not allow the +process server to access or communicate with Wexner. Affidavit of Due Diligence of Ericka +Cremeans (Cremeans Aff."). The Government then attempted to serve the Subpoena upon +Wexner also on February 8, 2023 at 8:40am at the office of the Wexner Foundation, but was +blocked from physical entry and was told via intercom that Wexner was not present and only +comes in to the Foundation office two or three times per year. Id. The Government attempted +again to serve the Subpoena upon Wexner at his home on February 11, 2023 at 2:00pm, but again +was prevented from doing so by a security guard. Id. +On February 2, 2023, counsel for the Government, Linda +I, emailed attorney John W. +Zeiger of Zeiger, Tigges & Little LLP in Columbus, Ohio, who has represented Wexner on other +matters. Declaration of Linda +Decl."), 1|2. Attorney| +asked Attorney Zeiger +2 + + +Case 1:22-cv-10904-JSR Document 50 Filed 02/17/23 Page 3 of 5 +if he would be authorized to accept service of the Government's Subpoena on Wexner's behalf. +Id. Attorney Zeiger responded that he was unable to speak that day, to which Attorney | +answered that the Government was sending the Subpoena to a process server but remained open +to his accepting service. Id., 13. She later placed two telephone calls to Attorney Zeiger, which +were not returned. Id., 14. On February 15, 2023, Attorney +spoke with attorney Marion +Little of Attorney Zeiger's firm. Id. Attorney Little stated that he has represented Wexner as +counsel. Id., IS. Attorney +asked if he would accept service of the Government's Subpoena +on Wexner's behalf, but he refused to do so without being given a detailed description of the +Subpoena's contents. Id., II6. Attorney | +provided a general description and offered to email +the Subpoena without requiring that this be deemed acceptance of service, id., 97, but Attorney +Little instructed her not to do so. ld., 18. +This Court long has recognized that Fed. R. Civ. P. 45 permits alternative service of a +subpoena by certified mail where a party is unable to provide personal service, "li]n accordance +with the interpretive principle that the rules 'be construed and administered to secure the just, +speedy, and inexpensive determination of every action."" Cordius Trust v. Kummerfeld, 45 Fed. +R. Serv. 3d 1151, 2000 WL 10268, at *2 (S.D.N.Y. Jan. 3, 2000) (quoting Fed. R. Civ. P. 1). The +Court has permitted alternative service where a party's repeated attempts at personal service have +failed, SEC v. David, 2020 WL 703464, at *1-2 (S.D.N.Y. Feb. 12, 2020) (Rakoff, J.), or where +there is an "approaching close of discovery." In re Petrobras Securities Litig., 2016 WL 908644, +at *1-2 (S.D.N.Y. March 4, 2016) (Rakoff, J.) (authorizing alternative service 56 days before April +29, 2016 discovery end date). +Both circumstances are present here. The Government has attempted to effectuate service +seven times at two different locations and through Wexner's attorneys, but each time was +3 + + +Case 1:22-cv-10904-JSR Document 50 Filed 02/17/23 Page 4 of 5 +unsuccessful. Moreover, the fact-discovery end date is in 46 days, on April 4, 2023. In these +circumstances, the Court should in the interest of securing just and expeditious resolution authorize +the Government to provide alternative service by certified mail of its subpoena upon Mr. Wexner. +Dated: February 17, 2023 +CAROL +, ESQ. +ACTING ATTORNEY GENERAL +/s/ Linda +Linda +(pro hac vice) +Mimi Liu (pro hac vice pending) +David I. Ackerman +Paige Boggs (pro hac vice) +MOTLEY RICE LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Fax: (202) 232-5513 +Isinger@motleyrice.com +mliu @motleyrice.com +dackerman@motleyrice.com +pboggs@motleyrice.com +Carol +(pro hac vice) +Acting Attorney General of the +/nited States Virgin Island +irgin Islands Department of Justic +34-38 Kronprindsens Gade +St. +1 U.S. Virgin Islands 00802 +Tel: (340) 774-5666 ext. 10101 +Attorneys for Plaintiff Government of the +United States Virgin Islands +4 + + +Case 1:22-cv-10904-JSR Document 50 Filed 02/17/23 Page 5 of 5 +CERTIFICATE OF SERVICE +I hereby certify that on February 17, 2023, I electronically filed the foregoing Motion +for Order Authorizing Alternative Service of Subpoena by Certified Mail Upon Leslie Wexner +with the Clerk of the Court and served on counsel of record using the Court's CM/ECF system. +Notice of this filing will be sent to all parties of record by operation of, and parties may access +this filing through, the Court's CM/ECF system. +By: Is/ Linda +Linda +5 diff --git a/vision-fixhub/court-05/6c6bc40a6bb7874f9c48f2727ddf776aa4dec10db6e325fbf95c2a16a50f1c24.receipt.json b/vision-fixhub/court-05/6c6bc40a6bb7874f9c48f2727ddf776aa4dec10db6e325fbf95c2a16a50f1c24.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..eaa16f6aa200072e7b12cd8e74f84a036249901b --- /dev/null +++ b/vision-fixhub/court-05/6c6bc40a6bb7874f9c48f2727ddf776aa4dec10db6e325fbf95c2a16a50f1c24.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -60, + "dataset": "marble-joined", + "doc_id": "6c6bc40a6bb7874f9c48f2727ddf776aa4dec10db6e325fbf95c2a16a50f1c24", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "41f815c0f6dd79969bfd0efcb4fee9f28ea011adade10ddd0bbea2200466b227", + "output_sha256": "942ef53e2ed68daa3449aa8f8baf4a3ab7661465352495d891a95f3c51cfb260", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6c9da18f6d4ae75d29d96960d2f5bec48d332820550205e3af782e0e893ac6d7.md b/vision-fixhub/court-05/6c9da18f6d4ae75d29d96960d2f5bec48d332820550205e3af782e0e893ac6d7.md new file mode 100644 index 0000000000000000000000000000000000000000..1fefdc0df8ef5685b8622851f431e930a2bb9a07 --- /dev/null +++ b/vision-fixhub/court-05/6c9da18f6d4ae75d29d96960d2f5bec48d332820550205e3af782e0e893ac6d7.md @@ -0,0 +1,19 @@ +Case 1:22-cV-10904-JSR Document 268-51 Filed 08/07/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 268-51 Filed 08/07/23 Page 2 of 2 +Date: +Thursday, December 202018 05:33 PM +Subject: Inaugural Committee +From: Cecile de Jongh < +@yahoo.com> +To: +Jeffrey Epstein ; +Hi Jeffrey, +I got a call from the Bryan/Roach Inaugural Committee and they asked for a $25,000 donation to the +inaugural events. They are trying to raise all the money privately. Please let me know your thoughts. +With warm regards, +Cecile de Jongh + +ESTATE_JPM016245 diff --git a/vision-fixhub/court-05/6c9da18f6d4ae75d29d96960d2f5bec48d332820550205e3af782e0e893ac6d7.receipt.json b/vision-fixhub/court-05/6c9da18f6d4ae75d29d96960d2f5bec48d332820550205e3af782e0e893ac6d7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d75f0c04f066f89568ccdebae7367187f7f6f689 --- /dev/null +++ b/vision-fixhub/court-05/6c9da18f6d4ae75d29d96960d2f5bec48d332820550205e3af782e0e893ac6d7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "6c9da18f6d4ae75d29d96960d2f5bec48d332820550205e3af782e0e893ac6d7", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "353320f343334957754b442c16fe447f7dc43dd93eeedb87f0b3113e0ab83883", + "output_sha256": "7c79bef20656f6617266b84761df4e54b36921d0c83bbdede918425f1cc7d19a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6cb7d0c81e6766d72df6d04ebcd1c793e4e81a9f5efbadbaa8c8ed0b30f291ba.md b/vision-fixhub/court-05/6cb7d0c81e6766d72df6d04ebcd1c793e4e81a9f5efbadbaa8c8ed0b30f291ba.md new file mode 100644 index 0000000000000000000000000000000000000000..0ceddf191346e6f903f4f79cd5235eb0786f072c --- /dev/null +++ b/vision-fixhub/court-05/6cb7d0c81e6766d72df6d04ebcd1c793e4e81a9f5efbadbaa8c8ed0b30f291ba.md @@ -0,0 +1,57 @@ +Case 1:22-cv-10904-JSR Document 203 Filed 07/06/23 Page 1 of 3 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +V. +Case No. 22-ev-10904-JSR +MOTION FOR ADMISSION +PRO HAC VICE +FOR I +BAYERL +JPMORGAN CHASE BANK, N.A., +Defendant / +Third-Party Plaintiff +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +V. +JAMES EDWARD STALEY, +Third-Party Defendant. +Pursuant to Rule 1.3(c) of the Local Rules for the United States District Courts for the +Southern and Eastern Districts of New York, I, +Bayerl, hereby move this Court for an Order +for admission to practice pro hac vice to appear as counsel in the above-captioned case on behalf +of Third-Party Defendant James Edward Staley. +I am a member in good standing of the bar of California and the bar of the District of +Columbia, and there are no pending disciplinary proceedings against me in any state or federal +court. I have never been convicted of a felony. + + +Case 1:22-cv-10904-JSR Document 203 Filed 07/06/23 Page 2 of 3 +I have never been censured, suspended, disbarred or denied admission or readmission by +any court. I have attached the affidavit pursuant to Local Rule 1.3. +Dated: July 6, 2023 +Respectfully submitted, +/s/ +Bayerl_ +Applicant Signature +Applicant's Name: +Firm name: +Bayerl +& Connolly LLP +Address: 680 Maine Avenue, S.W. +City / State / Zip: Washington, D.C. 20024 +Telephone: (202) 434-5483 +Fax: (202) 434-5029 +Email: jbayerl@wc.com +Attorney for James Edward Staley + + +Case 1:22-cv-10904-JSR Document 203 Filed 07/06/23 Page 3 of 3 +CERTIFICATE OF SERVICE +I hereby certify that on July 6, 2023, I electronically filed the foregoing document with the +Clerk of Court using the CM/ECF system which will send notification of such filing to all counsel +of record in this matter who are on the CM/ECF system. +Bayerl +Bayerl diff --git a/vision-fixhub/court-05/6cb7d0c81e6766d72df6d04ebcd1c793e4e81a9f5efbadbaa8c8ed0b30f291ba.receipt.json b/vision-fixhub/court-05/6cb7d0c81e6766d72df6d04ebcd1c793e4e81a9f5efbadbaa8c8ed0b30f291ba.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c064c36cd75d74a203156fae95c6c291ceb4c802 --- /dev/null +++ b/vision-fixhub/court-05/6cb7d0c81e6766d72df6d04ebcd1c793e4e81a9f5efbadbaa8c8ed0b30f291ba.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "6cb7d0c81e6766d72df6d04ebcd1c793e4e81a9f5efbadbaa8c8ed0b30f291ba", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "9582dcfb0f7960ffcb3ef39cbadec85f0c647f5f4c4ffe7fcf1cfddd71eb5a99", + "output_sha256": "56b7df5cad56c465e1dc0744b7e521fe7dfd94c76bda2fe8127720eda15dfbaf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6cbdb533c4006a901e8306a801f8651a2c206a473a6277bbdb5b81243600c23b.md b/vision-fixhub/court-05/6cbdb533c4006a901e8306a801f8651a2c206a473a6277bbdb5b81243600c23b.md new file mode 100644 index 0000000000000000000000000000000000000000..4bebce7df0d9e923fd1bd621b5f87dc66041d975 --- /dev/null +++ b/vision-fixhub/court-05/6cbdb533c4006a901e8306a801f8651a2c206a473a6277bbdb5b81243600c23b.md @@ -0,0 +1,220 @@ +Case 1:22-cV-10904-JSR Document 268-50 Filed 08/07/23 Page 1 of 6 + + + +Case 1:22-cV-10904-JSR Document 268-50 Filed 08/07/23 Page 2 of 6 +FINANCIAL TRUST COMPANY, INC. +1. APPLICATIONS: +(A) Original Application: +a. Date: +i. Received: 12/18/98 +ii. Accepted: 02/22/09 +b. Activity: Financial and Economic Consulting, Money Management, Investment +Advisory and Financial Services +c. Commitment: +i. Investment: $300K +ii. Employment: 11 people +d. Public Hearing : 04/23/99 +e. Decision Meeting: 09/07/99 +Governor Approval: 11/26/99 +g. Certificate: 10 years (Staggered Benefits) +i. Commence: 04/01/99 +ii. Terminate: 12/31/09 +h. Incentives: +i. Income Tax: 100% +ii. Gross Receipts Tax: 100% +ili. Real Property Tax (Business): 100% +iv. Excise Tax (Machinery & Equipment): 100% +v. Excise Tax (Raw Materials): 100% +vi. Custom Duties: 1% +(B) Modification/Extension Application: +a. Date: +i. Received: 12/18/98 +ii. Accepted: 02/22/09 +b. Activity: Designated Service Business - Financial and Economic Consulting +c. Commitment: +i. Investment: $100K +ii. Employment: 10 people +d. Public Hearing : 02/12/09 +e. Decision Meeting: +i. 11/27/09 (Tabled) +ii. 05/07/09 (Continued) +ili. 05/28/09 (Tabled) +iv. 10/15/09 (Approved) +f. +Governor Approval: 02/13/10 +g. +Certificate: 5 years (Staggered Benefits) +h. Incentives: +i. Commence: 04/01/09 +1 Page +VI-JPM-000019063 + + +Case 1:22-CV-10904-JSR Document 268-50 Filed 08/07/23 Page 3 of 6 +ii. Terminate: 12/31/14 +ill. Income Tax: 81% +iv. Gross Receipts Tax: 90% +v. Real Property Tax (Business): N/A +vi. Excise Tax (Machinery & Equipment): 90% +vii. Excise Tax (Raw Materials): N/A +vili. Custom Duties: N/A +2. PETITIONS: +(A) Suspension Request: +a. Date: 04/04/12 +b. Period: 03/23/12 - 03/22/13 (1 Year) +c. Decision Meeting: +i. 05/02/12 (Continued) +ii. 05/17/12 (Tabled) +ili. 06/21/12 (Approved) +(B) Termination Request: +a. Date: 03/28/13 +b. Decision Meeting: +c. Effective: 03/28/13 +3. COMPLIANCE: +(A) 1" Compliance Report: +a. Date: 04/17/08 +b. Period: 04/01/99 - 12/31/06 +c. Findings: In Compliance with All Certificate's Standard and Special Conditions +(B) 2º Compliance Report: +a. Date: 01/31/14 +b. Period: 01/01/07 - 12/31/08 +c. Findings: In Compliance with All Certificate's Standard and Special Conditions +(C) 3'd Compliance Report: +a. Date: 01/31/14 +b. Period: 01/01/09 - 03/23/12 +c. Findings: In Compliance with All Certificate's Standard and Special Conditions +2| Page +VI-JPM-000019064 + + +Case 1:22-cV-10904-JSR Document 268-50 Filed 08/07/23 Page 4 of 6 +SOUTHERN TRUST COMPANY, INC. +1. APPLICATIONS: +(A) Original Application: +a. Date: +i. Received: 09/21/12 +li. Accepted: +b. Activity: Designated Financial Services Business - Development of Financial and +Biomedical Informatics +c. Commitment: +i. Investment: $400K +ii. Employment: 10 people (5 people immediately plus an additional 5 +people by the end of the 6* year of operation) +d. Public Hearing : 11/15/12 +e. Decision Meeting: 01/23/13 +f. +Governor Approval: 05/31/13 +g. Certificate: 10 years +i. Commence: 02/01/13 +ii. Terminate: 01/31/23 +h. Incentives: +i. Income Tax: 90% +ii. Gross Receipts Tax: 100% +iii. Real Property Tax (Business): N/A +iv. Excise Tax (Machinery & Equipment): 100% +v. Excise Tax (Raw Materials): N/A +vi. Custom Duties: N/A +2. PETITIONS: N/A +3. COMPLIANCE: +• Compliance Report: +a. Date: 11/15/18 +b. Period: 02/01/13 - 12/31/17 +c. Findings: In Compliance with All Certificate's Standard and Special Conditions +3 | Page +VI-JPM-000019065 + + +Case 1:22-cV-10904-JSR Document 268-50 Filed 08/07/23 Page 5 of 6 +HOLDING, LLC +IGY-AYH ST. +1. APPLICATIONS: +(A) Transfer Application: +a. Date: +i. Received: 04/25/07 +ії. +Accepted: +b. Public Hearing : 05/24/07 +Decision Meeting: 05/04/10 +d. Approved By The Governor: N/A +e. Certificate: Remainder of Certificate Benefit Period +i. Commence: 01/19/07 +ii. Terminate: 10/31/12 +f. Incentives: +i. Income Tax: 100% +il. Gross Receipts Tax: 100% +ili. Real Property Tax (Business): 100% +iv. Excise Tax (Machinery & Equipment): 100% +v. Excise Tax (Raw Materials): N/A +vi. Custom Duties: 1% +g. Note: Jeffery Epstein acquired 50% interest as a passive investor on 05/29/07 +(B) Extension Application: +a. Date: +i. Received: 10/22/10 +ii. Accepted: 11/12/10| +b. Activity: Marina & Upland Services +c. Commitment: +i. Investment: $210K +ii. Employment: 24 people +d. Public Hearing: 11/23/10 +e. Decision Meeting: 02/24/11 +f. +Governor Approval: 06/21/11 +g. +Certificate: 5 years (Staggered Benefits) +h. Commence: 03/08/10 +i. +Terminate: 10/31/17 +j. Incentives: +i. Income Tax: 81% +ii. Gross Receipts Tax: 90% +ili. Real Property Tax (Business): 90% +iv. Excise Tax (Machinery & Equipment): 90% +v. Excise Tax (Raw Materials): N/A +vi. Custom Duties: 1% +4| Page +VI-JPM-000019066 + + +Case 1:22-CV-10904-JSR Document 268-50 Filed 08/07/23 Page 6 of 6 +(C) Modification/Extension Application (Act 7651 & 5 years investment) +a. Received: 03/05/18 +b. Accepted: 05/31/08 +c. Activity: Marina & Upland Services +d. Commitment: +i. Investment: $2MM +ii. Employment: 17 people +e. Public Hearing : 06/05/18 +f. Decision Meeting: 07/05/18 +g. Governor Approval: N/A +h. Certificate: 10 years (Staggered Benefits) +i. Commence: 03/08/15 +ii. Terminate: 10/31/27 +i. Incentives: +i. Income Tax: 81% +ii. Gross Receipts Tax: 90% +ili. Real Property Tax (Business): 90% +iv. Excise Tax (Machinery & Equipment): 90% +v. Excise Tax (Raw Materials): N/A +vi. Custom Duties: N/A +2. PETITIONS: N/A +3. COMPLIANCE: +(A) 1" Compliance Report: +a. Date: 04/24/17 +b. Period: 01/19/07 - 12/31/12 +c. Findings: Out of Compliance +i. Retirement Benefits - Accepted $500.97 Contribution Made to Workforce +Development Fund +ii. Contractors & Subcontractors Have Valid Business License - Paid $5,000 to +the Industrial Promotion Fund +ili. Compliance Clearance Granted +(B) 2^° Compliance Report: +a. Date: 04/24/17 +b. Periods: 01/01/13 - 12/31/17 +c. Findings: Out of Compliance +i. Procurement Procedures - Paid $6,000 Fine to the Industrial Promotion +ii. Long-term Disability Insurance during 2015 - Paid $5,000 Fine to the +Industrial Promotion Fund +ili. Compliance Clearance Granted +5 | Page +VI-JPM-000019067 \ No newline at end of file diff --git a/vision-fixhub/court-05/6cbdb533c4006a901e8306a801f8651a2c206a473a6277bbdb5b81243600c23b.receipt.json b/vision-fixhub/court-05/6cbdb533c4006a901e8306a801f8651a2c206a473a6277bbdb5b81243600c23b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..53a812ca1a86f02169933730d44de3943beb4c8d --- /dev/null +++ b/vision-fixhub/court-05/6cbdb533c4006a901e8306a801f8651a2c206a473a6277bbdb5b81243600c23b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -439, + "dataset": "marble-joined", + "doc_id": "6cbdb533c4006a901e8306a801f8651a2c206a473a6277bbdb5b81243600c23b", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "b439e7b74cbbcc17aa3ea0798f740e8dc9f35f53f978b1e9570a7d09a0f20c4e", + "output_sha256": "cf9908c0f49b7c42691e79b7daade5f4289b4c53057eb20cba790a964a0a27d6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6cc2f6018148c9e89a160064420623d6fdf186afbddd365c1d0040ce1f16b04a.md b/vision-fixhub/court-05/6cc2f6018148c9e89a160064420623d6fdf186afbddd365c1d0040ce1f16b04a.md new file mode 100644 index 0000000000000000000000000000000000000000..a1f639823e0246f213f0077c07e865e06a1ffb04 --- /dev/null +++ b/vision-fixhub/court-05/6cc2f6018148c9e89a160064420623d6fdf186afbddd365c1d0040ce1f16b04a.md @@ -0,0 +1,139 @@ +Case 1:22-cV-10904-JSR Document 265-68 Filed 08/07/23 Page 1 of 4 + +FILED UNDER SEAL + + +Case 1:22-cv-10904-JSR Document 265-68 Filed 08/07/23 Page 2 of 4 +From: +Sent: +To: +Subject: +Duffy, John R [john.r.duffy@jpmorgan.com] +8/14/2013 10:16:00 AM +Nelson, Justin D justin.d.nelson@jpmorgan.com] +Re: JE +I said +and I spoke as well about his advisory business and whether our not we would work with him. +, as long as we were not transacting in JE accounts. +John R. Duffy +J.P. +CEO, U.S. Private Bank +270 Park Avenue +New York, +NY 10017 +Tel: 212-464-1468 +Email: john.r.duffy@jpmorgan.com +J.P. +Securities LLC +- original Message +From: Nelson, Justin D +Sent: Tuesday, August 13, 2013 05:00 PM Eastern Standard Time +To: Duffy, John R +Subject: Re: JE +Spoke to him. Relayed the message as discussed. Regards, Justin +Justin D. Nelson - Managing Director +The Private Bank at J.P. +728, 625.3122 . 232.15.3601 10: 205.561.6702 TermarT: gustin: d.elongmorgan.com 1N4s To: +Original Message +From: Duffy, John R +Sent: Tuesday, August 13, 2013 11:16 AM Eastern Standard Time +To: Nelson, Justin D +Subject: Re: JE +K. Thx, he reached to ME. +John R. Duffy +J.P. +CEO, U.S. +Private Bank +270 Park Avenue +New York, NY 10017 +Tel: 212-464-1468 +Email: john.r.duffy@jpmorgan.com +J.P. +Securities LLC +- original Message +From: Nelson, Justin D +Sent: Tuesday, August 13, 2013 10:29 AM Eastern Standard Time +5, Justiyesterday afternoon to follow-up. Haven't heard back. Will try again this +-- original Message + +JPM-SDNYLIT-00100998 + + +Case 1:22-cV-10904-JSR Document 265-68 Filed 08/07/23 Page 3 of 4 +From: Duffy, John R +Sent: Monday, August 12, 2013 03:10 PM Eastern Standard Time +To: Nelson, Justin D +Subject: Re: JE +Yes. will call u in 2 mins +John R. Duffy +J.P. +CEO, U.S. Private Bank +270 Park Avenue +New York, NY 10017 +Tel: 212-464-1468 +Email: john.r.duffy@jpmorgan.com +J.P. +Securities LLC +Original Message +From: Nelson, Justin D +Sent: Monday, August 12, 2013 03:07 PM Eastern Standard Time +To: Duffy, John R +Subject: Re: JE +I spoke to him. Do you have a minute to discuss by phone? I'm at +update. +Can give you the full +Justin D. Nelson - Managing Director +The Private Bank at J.P. +B:2203.625.3124 (P: 1P: 212.904-1601 205.P02-6702Y eat: gustin: guseih: d.netsonejpmorgan.com +INMLS ID: +- Original Message +From: Duffy, John R +Sent: Monday, August 12, 2013 03:04 PM Eastern Standard Time +Subjeet stir o +Thanks Justin. +3.Pn R. DuEfy +J.P. +270 Park Avenuet +U.S. Private Bank +New York, NY 10017 +Tel: 212-464-146 +mail: john.r.duffy@jpmorgan.com +J.P. +Securities LLC +----- Original Message ----- +From: Nelson, Justin D +Sent: Monday, August 12, 2013 02:36 PM Eastern Standard Time +To: Dutty, John R +Subiect: Re: JE +Been playing phone tag with Jeffrey. Hoping to connect this afternoon. In the meantime I am working on i +summary of all accounts for them. +Ill find out if they have a similar structure elsewhere. +Justin D. Nelson - Managing Director +The Private Bank at J.P. +7135 6250 22 5: 212.102102 709: 205.802.6702 Tendr:ch:d.ne/son23pmorgan.com/MAS ID: +----- Original Message +From: Duffy, John R +Sent: Monday, August 12, 2013 01:20 PM Eastern Standard Time +To: Nelson, Justin D + +JPM-SDNYLIT-00100999 + + +Case 1:22-cv-10904-JSR Document 265-68 Filed 08/07/23 Page 4 of 4 +Subject: JE +Sooner is beuter let ter tin to days 15 targetimeframes for JE's exit. +Cash activity is top priority - +an you talk with Harry to see if they have a parallel account structure (same as ours) at another bank +his would make transition easy. Thy +John R. Duffy +J.P. +CEO, U.S. +Private Bank +270 Park Avenue +New York, NY 10017 +Tel: 212-464-1468 +Email: john.r.duffy@jpmorgan.com +J.P. +Securities LLC + +JPM-SDNYLIT-00101000 \ No newline at end of file diff --git a/vision-fixhub/court-05/6cc2f6018148c9e89a160064420623d6fdf186afbddd365c1d0040ce1f16b04a.receipt.json b/vision-fixhub/court-05/6cc2f6018148c9e89a160064420623d6fdf186afbddd365c1d0040ce1f16b04a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1fb9628deaa97bd0e31a15ac100f203f6f3b532c --- /dev/null +++ b/vision-fixhub/court-05/6cc2f6018148c9e89a160064420623d6fdf186afbddd365c1d0040ce1f16b04a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -83, + "dataset": "marble-joined", + "doc_id": "6cc2f6018148c9e89a160064420623d6fdf186afbddd365c1d0040ce1f16b04a", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "e3254d8962ee2c3203c9a09608dccba8b70acaafb9c066ae46b4bfe7081cdd1a", + "output_sha256": "fcb1159833e16a9c3155797c8fdf61254492cfe852db7d684d387248f80ba32f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6ce52ad1e1dc8e433fc861f1e4abff97ae5d051f7032e80e03d247a7305d6740.md b/vision-fixhub/court-05/6ce52ad1e1dc8e433fc861f1e4abff97ae5d051f7032e80e03d247a7305d6740.md new file mode 100644 index 0000000000000000000000000000000000000000..9264a3b362ccbd53c49099aa17cea9f2eab670ac --- /dev/null +++ b/vision-fixhub/court-05/6ce52ad1e1dc8e433fc861f1e4abff97ae5d051f7032e80e03d247a7305d6740.md @@ -0,0 +1,384 @@ +Case 1:22-cV-10904-JSR Document 267-62 Filed 08/07/23 Page 1 of 6 + +Part 3 + + +Case 1:22-cV-10904-JSR Document 267-62 Filed 08/07/23 Page 2 of 6 +Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 23 of 27 +leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical +and psychological expenses, and Plaintiff will in the future suffer additional medical and +psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn +income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in +nature, and Plaintiff will continue to suffer these losses in the future. +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, +Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, +actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as +this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right +by a jury. +COUNT NINE +(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. § +2255 in Violation of 18 U.S.C. § 2252A(g)) +66. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by +reference the allegations contained in paragraphs 1 through 32 above and Counts One through +Eight above. +67. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, +as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 U.S.C. § 2252A(g)(1). As more fully +set forth above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § +1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 +U.S.C. §§ 2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal +sexual activity in violation of 18 U.S.C. §§ 2421, 2422, and 2423). As more fully set forth above +in paragraphs 9 through 32, Defendant's actions involved countless victims and countless +separate incidents of sexual abuse, which he committed against minors, including Plaintiff, in +concert with at least three other persons. +23 +25 West Flagler Street, Suite 500, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 + + +• +Case 1:22-cV-10904-JSR Document 267-62 Filed 08/07/23 Page 3 of 6 +Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 24 of 27 +68. +Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in +18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, +pursuant to this Section of the United States Code. +69. +As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 +being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, +and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, +psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, +loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, +separation from her family, and other damages associated with Defendant's manipulating and +Icading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical +and psychological expenses, and Plaintiff will in the future suffer additional medical and +psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to carn +income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in +nature, and Plaintiff will continue to suffer these losses in the future. +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, +Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, +actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as +this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right +by a jury. +Date: +May 1, 2009 +KWE +25 West Flagler Street, Suite 800 +Miami, Florida 33130 +(305) 358-2800 +(305) 358-2382 (fax) +rjosefsberg@podhurst.coml +24 +25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 + + +Case 1:22-cv-10904-JSR Document 267-62 Filed 08/07/23 Page 4 of 6 +Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 25 of 27 +kezell@podhurst.com +Attorneys for Plaintiff +DEMAND FOR JURY TRIAL +Plaintiff demands to have her case tried before a jury. +Robert C. profate be thes +Robert C. Josefsberg, Bar No. 040856 +Katherine W. Ezell, Bar No. 114771 +25 West Flagler Street, Suite 800 +Miami, Florida 33130 +(305) 358-2800 +(305) 358-2382 (fax) +rjosefsberg@podhurst.com +kezell@podhurst.com +Attorneys for Plaintiff +25 +25 West Flagler Stret, Suite 800, Miami, FL. 3330, Miami 305.358.2800 Fax 305.35.2382 • Fort Lauderdale 954463.4346 T + + +Case 1:22-cV-10904-JSR Document 267-62 Filed 08/07/23 Page 5 of 6 +Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 + +eJ5 44 (Rev. 11/05) +CIVIL COVER SHEET +he JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provide +y local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiatin +the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) +NOTICE: Attorneys MUST Indicate All Re-filed Cases Below. +I. (a) PLAINTIFFS +DEFENDANTS +Jane Doe No. 102 +Jeffrey Epstein +(b) County of Residence of First Listed Plaintiff +West Palm Beach +(EXCEPT IN US. PLAINTIFF CASES) +(c) Attorney's (Firm Name, Address, and Telephone Number) +Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq. +25 W. Flagler St., Suite 800 +Miami FI +09-Cv- 80656-Ruskam +(d) Check County Where Action Arose: • MIAMI- DADE • MONROE D BROI +County of Residence of First Listed Defendant +West Palm Beach +(IN U.S. PLAINTIFE CASES ONLIA- +NOTE: INLAND CONDEMNATION CASE ED THE ONE THE TRACT +LAND INVOLVED. +Attorncys (Jf Known) +MAY +- 1,2009 +Jack A. Goldberger, Esq., Atterbury Goldberger, et al., 250 S. +Australian Ave., #1400, West Palm Beashi PEN 1840E@Robeft D.o +CLERK US. DIST +• ST. LUCIE D INDISNRIVEFLA CBANCHOBEF +II. BASIS OF JURISDICTION (Place an "X" in One Box Only) +• I U.S. Goverument +PlaintifT +/ 3 Foderal Question +(U.S. Govemment Not a Party) +• 2 +U.S. Govemment +Defendan +04 +Diversity +(Indicate Cirizenship of Parties in Item III) +III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box for Plaimitr +(For Diversity Cases Only) +and One Box for Defendant) +PTF +Citizen of This State +DEF +51 +PTF +DEF +Incorporated or Principal Place +4 04 +of Business In This State +Citizen of Another State 0 +2 +• 2 Incorporated and Principal Place +5 +0 5 +of Business In Another State +Citizen or Subjectof a 0 +3 • 3 Foreign Nation +606 +Forein Country +IV. NATURE OF SUIT +(Place an "23" in One Box Onli +CONTRACI +TORTE +• 1J0 Insurance +• 120 Marine +130 +Act +140 N +egotiable instrument +• 150 Recovery of Overpayment +& Enforcement of Judgment +• 151 Medicare Act +• 152 Recovery of Defaulted +Student Loans +(Excl. Veterans) +• 153 Recovery of Overpayment +of Veteran's Benefits +• 160 Stockholders" Suits +| 190 Other Contract +• 195 Contract Product Liability +• 196 Franchise +REAL PROPERTY +• 210 Land Condemnation +• 220 Foreclosure +• 230 Rent Lease & Ejectment +• 240 Torts to Land +• 245 Tort Product Liability +• 290 All Other Real Property +PERSONAL INJURY +• 310 Airplane +• 315 Airplane Product +Liability +• 320 Assault, Libel & +Slander +O 330 Foderal Employers* +Liability +• 340 Marine +• 345 Marine Product +Liability +O 350 Motor Vehicle +J 355 Motor Vehicle +Product Liability +I9 360 Other Personal +Injury +CIVIL RIGHTS +• 441 Voting +• 442 Employment +O 443 Housing/ +Accommodations +• 444 Welfare +• 445 Auner. w/Disabilities - +Employment +• 446 Amer. w/Disabilities - +Other +• 440 Other Civil Rights +PERSONAL INJURY +362 Personal Injury - +Med. Malpractice +365 Personal Injury - +Product Liability +368 Asbestos Personal +Injury Product +Liability +PERSONAL PROPERTY +370 Other Fraud +371 Truth in Lending +380 Other Personal +Property Damage +385 Property Damage +Product Liability +FORFEITURE PENALTY +• 6I0 Agriculture +620 Other Food & Drag +625 Drug Related Seizure +of Property 21 USC 891 +630 Liquor Laws +640 R.R. & Truck +650 Airline Regs. +660 Occupational +Safety/Health +690 Other +LABOR +710 Fair Labor Standards +Act +720 Labor/Mgmt. Relations +730 Labon Mgmt Reporting +& Disclosure Act +740 Railway Labor Act +790 Other Labor Litigation +791 Empi. Ret. Inc. +Security Act +BANKRUPTCY +• 422 Appeal 28 USC 158 +• 423 Withdrawal +28 USC 157 +• 820 Copyrights +• 830 Patent +• 840 Trademark +PRISONER PETITIONS +5I0 Metions to Vacale +Sentence +Habeas Corpus: +530 General +535 Death Penalty +540 Mandamus & Other +550 Civil Rights +555 Prison Condition +SOCIAL SECURITY +• 861 HIA (1395ff) +• 862 Black Lung (923) +• 863 DIWC/DIWW (405(g)) +• 864 SSID Title XVI +• 865 RSI (405(:)) +FEDERAL TAX SUNE +7 870 Taxes (U.S. Plaintiff +or Defendant) +0 871 IRS —Third Party +26 USC 7609 +OTHER STATUTES +400 State Reapportionment +410 Antitrust +0 +430 Banks and Banking +450 Commerce +460 Deportation +470 Racketeer Influenced and +Corrupt Organizations +480 Consumer Credit +00 +490 Cable/Sat TV +SIO Selective Service +850 Securities/Commodities/ +Exchange +• 875 Customer Challenge +12 USC 3410 +890 Other Statutory Actions +891 Agnicultural Acts +892 Economic Stabilization Act +893 Environmental Matters +894 Energy Allocation Act +895 Freedom of Information +Act +900Appeal of Fice Determination +Under Equal Access +so Justice +950 Constitutionality of +State Statutes +V. ORIGIN +7 I Origina +Proceeding +(Place an "X" in One Box Only) +• 2 +Removed from +• 3 +State Court +Re belon +Transferred from +• 4 Reinstatedor O 5 +• 6 Multidistrict +Reopened +another district +(specify) +Litigation +Appeal to District +• 7 +Judge from +Magistrate +Judsment +a) Re-filed Case O YES EINO +b) Related Cases 7YES O NO +VI. RELATED/RE-FILED +CASE(S) +(See instructions +second pagel: +JUDGE Kenneth A. Marra +DOCKET See Attached +NUMBER +Cine the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless +diversity): +VII. CAUSE OF +ACTION +18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b), 2423(b), 2423(e), 2251, 2252, 2252A(a)(I), 2252A(gX1) +LENGTH OF TRIAL via 4 +days estimated (for both sides to try entire case) +VIII. REQUESTED IN +IO CHECK IF THIS IS A CLASS ACTION +DEMANDS +COMPLAINT: +UNDER F.R.C.P. 23 +ABOVE INFORMATION IS TRUE & CORRECT TO +THE BEST OF MY KNOWLEDGE +Katherene +CHECK YES only if demanded in complaint: +JURY DEMAND: +[al Yes No +DATE +5|1/09 +FOR OFFICE USEONESO +AMOUNT A 350. +RECEIPT TIO0ABT +05/01/09 + + +Case 1:22-cV-10904-JSR Document 267-62 Filed 08/07/23 Page 6 of 6 +Case 9:09-cV-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 27 of 27 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF FLORIDA +WEST PALM BEACH DIVISION +ATTACHMENT TO CIVIL COVER SHEET +FOR: Jane Doe 102 v. Jeffrey Epstein +VI: +RELATED/RE-FIELD CASE(S): +08-80069 +08-80119 +08-80232 +08-80380 +08-80381 +08-08804 +08-80811 +08-80893 +08-80993 +08-80994 +08-80469 +09-80591 \ No newline at end of file diff --git a/vision-fixhub/court-05/6ce52ad1e1dc8e433fc861f1e4abff97ae5d051f7032e80e03d247a7305d6740.receipt.json b/vision-fixhub/court-05/6ce52ad1e1dc8e433fc861f1e4abff97ae5d051f7032e80e03d247a7305d6740.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..43e23b1a0be7f1d7b909a9d448d82db122ae9b35 --- /dev/null +++ b/vision-fixhub/court-05/6ce52ad1e1dc8e433fc861f1e4abff97ae5d051f7032e80e03d247a7305d6740.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -258, + "dataset": "marble-joined", + "doc_id": "6ce52ad1e1dc8e433fc861f1e4abff97ae5d051f7032e80e03d247a7305d6740", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "477a0bb82289bcce86c830badc33318d8381545c5ceb18144e05389a4a9cc9e8", + "output_sha256": "cd737c266ee979799fcc00c568df321347e75ca7956edfad8c3bbfd7d0899d0f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6cf4a6ef06b74498fcfcd9fd023e6fe9c9c6a7c9d29bec7706fa9d78efa7631e.md b/vision-fixhub/court-05/6cf4a6ef06b74498fcfcd9fd023e6fe9c9c6a7c9d29bec7706fa9d78efa7631e.md new file mode 100644 index 0000000000000000000000000000000000000000..43587a031c917d4090d8c37e418b6063bd2d0c5d --- /dev/null +++ b/vision-fixhub/court-05/6cf4a6ef06b74498fcfcd9fd023e6fe9c9c6a7c9d29bec7706fa9d78efa7631e.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 311-58 Filed 08/25/23 Page 1 of 1 + +Filed Under Seal diff --git a/vision-fixhub/court-05/6cf4a6ef06b74498fcfcd9fd023e6fe9c9c6a7c9d29bec7706fa9d78efa7631e.receipt.json b/vision-fixhub/court-05/6cf4a6ef06b74498fcfcd9fd023e6fe9c9c6a7c9d29bec7706fa9d78efa7631e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..81651ca17977c6fca4e55a69830ebd47aa6d9511 --- /dev/null +++ b/vision-fixhub/court-05/6cf4a6ef06b74498fcfcd9fd023e6fe9c9c6a7c9d29bec7706fa9d78efa7631e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "6cf4a6ef06b74498fcfcd9fd023e6fe9c9c6a7c9d29bec7706fa9d78efa7631e", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "2941a9db529920226a364270e658697701a4c5beaccd22d5bc7d73e87d0d378a", + "output_sha256": "b7976e68caf3f4b97fc8b10ceaa96ec52a40eb0df50fc8fe9d6c34bf714cec10", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6d0594b692e406eb60a68e0a8716a010c08128e895c40971cc2ef3b62b3992f8.md b/vision-fixhub/court-05/6d0594b692e406eb60a68e0a8716a010c08128e895c40971cc2ef3b62b3992f8.md new file mode 100644 index 0000000000000000000000000000000000000000..da2839a1fcc5ce50c6e250e8f3716b5cee0af66e --- /dev/null +++ b/vision-fixhub/court-05/6d0594b692e406eb60a68e0a8716a010c08128e895c40971cc2ef3b62b3992f8.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 241-26 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/6d0594b692e406eb60a68e0a8716a010c08128e895c40971cc2ef3b62b3992f8.receipt.json b/vision-fixhub/court-05/6d0594b692e406eb60a68e0a8716a010c08128e895c40971cc2ef3b62b3992f8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8f43f4bfb50e3490db8736409e14b88172e25d4c --- /dev/null +++ b/vision-fixhub/court-05/6d0594b692e406eb60a68e0a8716a010c08128e895c40971cc2ef3b62b3992f8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "6d0594b692e406eb60a68e0a8716a010c08128e895c40971cc2ef3b62b3992f8", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "bba6f0d4ef799d8bbe59377ea4a9aab5cffd43666d8e3d7c12a7d902d4eb1bc4", + "output_sha256": "c56bfec781e60a1eb6139ce34b4d0aec0c0e2f616ee2bb859332c0d94a592b01", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6d55a9495879821079e7c6f263e4cff96b2c2401ac432de77dd2b521e423287b.md b/vision-fixhub/court-05/6d55a9495879821079e7c6f263e4cff96b2c2401ac432de77dd2b521e423287b.md new file mode 100644 index 0000000000000000000000000000000000000000..992765d927e7693e8bc1c4095ba9c13eaeeb35b7 --- /dev/null +++ b/vision-fixhub/court-05/6d55a9495879821079e7c6f263e4cff96b2c2401ac432de77dd2b521e423287b.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 267-64 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6d55a9495879821079e7c6f263e4cff96b2c2401ac432de77dd2b521e423287b.receipt.json b/vision-fixhub/court-05/6d55a9495879821079e7c6f263e4cff96b2c2401ac432de77dd2b521e423287b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..65ebe172c3f54d9f54523ca309ead2062325f492 --- /dev/null +++ b/vision-fixhub/court-05/6d55a9495879821079e7c6f263e4cff96b2c2401ac432de77dd2b521e423287b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "6d55a9495879821079e7c6f263e4cff96b2c2401ac432de77dd2b521e423287b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "f16dba242146cec940e3513508e347291da53d5a322e9a8d22f9380ab894861a", + "output_sha256": "aeca6ee81834c9e5d912d4e9385b842e767e5ba5617b253e052a6b2c1c063271", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6d7c09f8b9560b2f5c93c61abb65ce5c7bb4aea5c2eeadf65a2c00ba7fd7ac8e.md b/vision-fixhub/court-05/6d7c09f8b9560b2f5c93c61abb65ce5c7bb4aea5c2eeadf65a2c00ba7fd7ac8e.md new file mode 100644 index 0000000000000000000000000000000000000000..1e22842b96bcf44eeb92cd079c5e45ab007569d2 --- /dev/null +++ b/vision-fixhub/court-05/6d7c09f8b9560b2f5c93c61abb65ce5c7bb4aea5c2eeadf65a2c00ba7fd7ac8e.md @@ -0,0 +1,119 @@ +Case 1:22-cv-10904-JSR Document 326-149 Filed 09/08/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 326-149 Filed 09/08/23 Page 2 of 3 +Page 1 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +---------- +JANE +DOE 1, individually and on +behalf of all others similarly +situated, +Plaintiff, +-against- +JPMORGAN Chase BANK NA, +Defendants. +- - +---- +Case No. +1:22-cv-10019-JSR +--- +- x + +Videotaped oral deposition of +BONNIE +taken pursuant to notice, +was +held REMOTELY, commencing May 10, +2023, 9:39 a.m., on the above date, +before Leslie Fagin, a Court Reporter +and Notary Public in the State of New +York. +MAGNA LEGAL SERVICES +(866) 624-6221 +www.MagnalS.com +MAGNAO +LEGAL SERVICES + + +Case 1:22-CV-10904-JSR Document 326-149 Filed 09/08/23 Page 3 of 3 +Page 187 +1 +B +2 +3 +l. Was it your understanding that +Mr. Epstein was using large cash withdrawals +4 +5 +to pay for fuel expenses when he travels to +foreign countries? +6 +MR. BUTTS: Objection and objection +7 +to form. +8 +9 +You may answer, if you are able. +A. It's probably one of the only +10 +things I really remember because of -- fuel +11 +expenses for an airplane, I wouldn't even -- +12 I have no idea what it costs, but I thought +13 +that was interesting. +14 +Okay. I appreciate your answer. +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Can you just expand upon what you +mean by interesting? +MR. BUTTS: Objection to form. +You may answer. +A. I never thought about how much it +would cost to fuel an airplane and the answer +seemed reasonable. +R. +Does it seem +reasonable today that +Jeffrey Epstein was using 20,000 to $40,000 +in cash to pay for fuel expenses? +MR. BUTTS: Objection and objection +14:35:00 +14:35:08 +14:35:11 +14:35:13 +14:35:15 +14:35:15 +14:35:19 +14:35:20 +14:35:23 +14:35:27 +14:35:30 +14:35:33 +14:35:37 +14:35:38 +14:35:43 +14:35:45 +14:35:46 +14:35:46 +14:35:47 +14:35:51 +14:35:54 +14:35:56 +14:35:59 +14:36:03 +MAGNAO +LEGAL SERVICES diff --git a/vision-fixhub/court-05/6d7c09f8b9560b2f5c93c61abb65ce5c7bb4aea5c2eeadf65a2c00ba7fd7ac8e.receipt.json b/vision-fixhub/court-05/6d7c09f8b9560b2f5c93c61abb65ce5c7bb4aea5c2eeadf65a2c00ba7fd7ac8e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7fdb4a24348d9ab244eee9c8bd5bf57e8adeb7c1 --- /dev/null +++ b/vision-fixhub/court-05/6d7c09f8b9560b2f5c93c61abb65ce5c7bb4aea5c2eeadf65a2c00ba7fd7ac8e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -59, + "dataset": "marble-joined", + "doc_id": "6d7c09f8b9560b2f5c93c61abb65ce5c7bb4aea5c2eeadf65a2c00ba7fd7ac8e", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "5884102fa69d88fffd936f56fff4a544a39612254544acdcafbe0fa56e54edef", + "output_sha256": "4b10eeb5837f8946aed06f9e7048094170b56e772e6ef79109656038072e571b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6d86f19b0ff40e41a72aa3e4a7b98cf393ae04f67c1fb6c8bd0c45a26951b26c.md b/vision-fixhub/court-05/6d86f19b0ff40e41a72aa3e4a7b98cf393ae04f67c1fb6c8bd0c45a26951b26c.md new file mode 100644 index 0000000000000000000000000000000000000000..3a58c475d050b8ffc57b941670efd32ffe08bdcb --- /dev/null +++ b/vision-fixhub/court-05/6d86f19b0ff40e41a72aa3e4a7b98cf393ae04f67c1fb6c8bd0c45a26951b26c.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 263-57 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/6d86f19b0ff40e41a72aa3e4a7b98cf393ae04f67c1fb6c8bd0c45a26951b26c.receipt.json b/vision-fixhub/court-05/6d86f19b0ff40e41a72aa3e4a7b98cf393ae04f67c1fb6c8bd0c45a26951b26c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f8f6a2e59f97453f0dfdacf21f18a436ad82c4e4 --- /dev/null +++ b/vision-fixhub/court-05/6d86f19b0ff40e41a72aa3e4a7b98cf393ae04f67c1fb6c8bd0c45a26951b26c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "6d86f19b0ff40e41a72aa3e4a7b98cf393ae04f67c1fb6c8bd0c45a26951b26c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "c10b2ad0b313a00ac3dcb38601863286cb62a0d403aaabed95223f9e73511f3d", + "output_sha256": "fb2c083fa82a517f7628a0d654e6baf1befe2c883647fbc6d1fc2c37b88eba53", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6dc0edc8c94c0573ae9041d5060cad3444bb76e2982aeb72853bee4590962768.md b/vision-fixhub/court-05/6dc0edc8c94c0573ae9041d5060cad3444bb76e2982aeb72853bee4590962768.md new file mode 100644 index 0000000000000000000000000000000000000000..064613c8dadc30df4e21337e3395f198f4734b5f --- /dev/null +++ b/vision-fixhub/court-05/6dc0edc8c94c0573ae9041d5060cad3444bb76e2982aeb72853bee4590962768.md @@ -0,0 +1,823 @@ +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 17 Filed 12/19/19 + +1 +JopWnoeC +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +- X +UNITED STATES OF AMERICA, +V. +19 Cr. 830 (AT) +TOVA NOEL and MICHAEL +Defendants. +Conference +New York, N.Y. +November 25, 2019 +12:00 p.m. +Before: +HON. ANALISA +District Judge +APPEARANCES +GEOFFREY S. BERMAN +United States Attorney for the +Southern District of New York +BY: REBEKAH A. DONALESKI +NICOLAS I. ROOS +Assistant United States Attorneys +FOY & SEPLOWITZ LIC +Attorneys for Defendant Noel +BY: JASON E. FOX +MONTEL FIGGINS +Attorney for Defendant + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 17 Filed 12/19/19 Page 2 of 15 +JopWnoeC +2 +THE COURT: Good afternoon. +We're here in the matter of United States v. Tova Noel +and Michael +Would you make your appearances, please. +MS. DONALESKI: Good afternoon, your Honor. Rebekah +Donaleski and Nicolas Roos for the government. +MR. FOY: My name is Jason Foy, attorney for Ms. Noel. +Good afternoon, your Honor. +THE DEFENDANT: Good afternoon, your Honor. +MR. FIGGINS: Good afternoon, your Honor. Montel +Figgins on behalf of Michael +1, who is presently in court, +standing to my left. +THE COURT: Please be seated. +Has the prosecutor finished delivering discovery to +the defendants? +MS. DONALESKI: No, your Honor. +The defendants self-surrendered last Tuesday, on +November 19. They were presented and arraigned that day. We +notified defense counsel we would begin producing discovery +once a protective order is in place, and we will do so on a +rolling basis. +THE COURT: When do you expect to be finished? +MS. DONALESKI: We anticipate that we'll need a month +to complete production of the discovery currently in our +possession. +SOUTHERN DISTRICT REPORIERS, P.C. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 17 Filed 12/19/19 Page 3 of 15 +JopWnoeC +3 +THE COURT: When do you expect the protective order to +be in place? +MS. DONALESKI: Your Honor, we'll provide a draft to +defense counsel within the next day, and then depending on how +long it takes for them to comment on it and the parties to +reach a resolution, we'll provide it to the Court as +expeditiously as possible, so it's my hope that that can happen +within a week. +THE COURT: All right. By the end of December, +discovery should have been produced. Is that correct? +MS. DONALESKI: That's fine, your Honor. +THE COURT: It's not voluminous, is it? +MS. DONALESKI: Your Honor, it will consist of +hundreds of hours of video recording, so in that aspect it will +be voluminous, but the paper records, the bank records will not +be voluminous. +THE COURT: All right. It doesn't seem that you would +need more than a month to review the discovery so that by the +end of January, you should have made decisions as to whether +you're going to be filing motions. Correct? +MR. FIGGINS: Your Honor, if I may? +I also know that there's an ongoing inspector +general's report. I don't have any idea as to the time frame, +if and when that's going to be completed. I do believe that +there would be some pertinent information, relevant information + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 17 Filed 12/19/19 Page 4 of 15 | +4 +JopWnoeC +in that report, so if we could get some -- if they have any +idea as to when that's going to conclude, I do believe that +that may have some impact in terms of information that we +desire to have as well as I do believe that we're also going to +be subpoenaing some documents as well. But I don't think we +would need more than the end of January, presumably, to have an +idea to convey to the Court where we are with respect to moving +forward with motions. +MS. DONALESKI: Your Honor, we'll provide the +discovery in our possession to the defendants by the end of +December. I don't know of a basis to hold up a criminal case +based on a DOJ inspector general report, and I don't have a +time line of when that will be completed. +MR. FOY: Your Honor, I agree that by the end of +January we should be in a position to assess what motions, if +any, will be necessary. We'll also be in a position to +determine whether there are any issues regard to discovery or +additional information at that point. +MR. FIGGINS: And your Honor -- +THE COURT: One moment, please. +You'll return to court on January 30 at 11 a.m. - +that will be a control date -- and you'll let me know whether +you expect to file motions. +Now, with respect to a trial date, April 20. +MR. FIGGINS: That's fine for us. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 17 Filed 12/19/19 Page 5 of 15 +JopWnoeC +5 +MS. DONALESKI: That's fine for the government, your +Honor. +THE COURT: How long do you expect the trial to last? +MR. FOY: Your Honor, I would say it's fine. I mean, +as it looks right now, but based on some of the things I'm +anticipating, I don't know if that would be enough time and +maybe we want to wait and see, because I need to see the +discovery before I can say definitively that, yes, April 20 is +an appropriate date. But for now certainly that would be fair. +THE COURT: We're told that the discovery consists of +video and documents. I don't understand why you can't +anticipate whether you can go forward on the 20th. +MR. FOY: Because I haven't seen what those documents +are and what impact it might have on the defense of the case as +well as my thoughts on some additional documents that may go +beyond what they believe Rule 16 requires. I can imagine a +situation where we feel that there's more to be provided than +what the government provides. We're not there yet, so I'm not +suggesting that it's definitely going to be an issue, but I did +want to alert the Court early on of the possibility. But once +I get the discovery, I'll be in a position to say more +affirmatively. +THE COURT: What else are you expecting? +MR. FOY: You mean as far as discovery? +THE COURT: You're talking in vague terms about +SOUTHERN DISTRICI REPORTERS, P.C. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 17 Filed 12/19/19 Page 6 of 15 | +6 +JopWnoeC +something else coming up, and I'd like to know what that is. +MR. FOY: Well, your Honor, based on our view of the +case, I believe there are outside circumstances that are +driving this prosecution that may impact certain information +that's available to us in the regular discovery. +It's hard for me to say without seeing anything, so +right now it's just kind of in my mind, and I don't want to +mislead the Court to suggest it's all going to be finished in +time for April 20. It may be, and that may be fine, but it's +hard for me to say having not received or reviewed the +discovery. I've only seen the indictment. +I'm just alerting the Court. I'm not saying we can't +do it, but I don't want to not say it when it's something that +could potentially be an issue. I'm not saying we're trying to +hold it up or slow down the pace unnecessarily, but I can see +getting information that may impact on the defense in +particular, Brady material in particular. +THE COURT: Brady material? +MR. FOY: Correct, but it's hard to say specifically +without seeing the discovery. +THE COURT: All right. You have not persuaded me. +I'm setting the trial for April 20. +How long do you expect the trial to go? +MS. DONALESKI: Approximately a week, your Honor, for +the government's case. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 17 Filed 12/19/19 Page 7 of 15 +JopWnoeC +7 +MR. FIGGINS: Your Honor, I would think it would +probably be about five days on our case. +And your Honor, I did want to ask the Court or we +would like to at least get some type of idea with respect to +the status of the inspector general's report. I do think that +it's beyond relevant; it's an investigation into what happened +here. +There's going to be multiple details of information and +interviews and statements and things of that nature regarding +this particular case, so on and so forth. So I would ask at +least the Court to see if we can get a time frame from the +government if that report is going to be imminently due or what +type of time frame we're looking at, because I do believe there +are going to be a lot of relevant facts in that report, that we +would need that information. And then we would need time to +then maybe even investigate based on some of that information. +THE COURT: Does the government know anything about +that? +MS. DONALESKI: Your Honor, I don't. And I'll just +clarify that to the extent counsel's asking for a summary of +the results of the criminal investigation, obviously we'll be +turning over in discovery all of the underlying results of the +criminal investigation. So I'm a little puzzled as to what +defense counsel is saying that he needs. I don't have a time +frame on the inspector general report, but the government will +produce to the defense all of the relevant discovery materials + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 17 Filed 12/19/19 Page 8 of 15 +8 +JopWnoeC +in this matter, which includes the Rule 16 materials relevant +to the criminal charges that have been brought against the +defendants. +MR. FIGGINS: Your Honor, to be more specific, one of +the issues here is going to be the conditions and the +supervision and the policies that were upheld and advanced by +the Bureau of Prisons. That is what the inspector general's +report is investigating. That's very important information +that's relevant to this case and relevant to the defense. I'm +not saying we have to hold up our case forever, but we should +at least get some type of idea as to the status of that report +and when it's going to come out or when they're going to +complete the actual report because I believe that there's going +to be a lot of information that may be relevant to our defense, +and it may not be specifically just about this particular +investigation. +There's been multiple information in the media now +with respect to testimony by the head of the Bureau of Prisons, +information released by the U.S. Attorney himself regarding +this investigation with respect to this case, so I believe that +we will need that information. If we're hearing that those +people are making statements about that report with respect to +this case, clearly there's going to be information and +potentially statements and other information that we may need. +So I think it's important that we at least try to get an idea + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 17 Filed 12/19/19 Page 9 of 15 +9 +JopWnoeC +of when that report may be completed. +THE COURT: I'm putting the matter on for trial on the +20th of April. It's a firm date, and I am giving you two weeks +for trial. +Are there any further applications? +MS. DONALESKI: The government moves to exclude time +between today's date and April 20, 2020, in order to allow the +defendants to review discovery and prepare for trial. +MR. FOY: Yes, I do have another application, your +Honor. +As I alerted the Court prior to today's court +proceedings, I wanted to revisit the issue of the release +conditions for Ms. Noel at this time. +On November 19, we appeared before the magistrate +court. The government and Ms. Noel had an agreement with +regards to the bail package. After our interview with pretrial +services, they added additional conditions that were not a part +of the original agreement. Of the additional conditions, one +of them was travel restrictions. +One of the permissible areas at the time that was +stated on the record was the Eastern District of Pennsylvania. +Turns out that it should be the Middle District of Pennsylvania +instead of the eastern, so I'd like that to be corrected. But +the second issue, which is really the main subject of this +application, is with regards to the surrender of her firearms, + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 17 Filed 12/19/19 Page 10 of 15 +10 +JopWnoeC +which Ms. Noel has already complied with. +During the proceedings before the magistrate court, I +presented arguments in favor of her ability to keep her +firearm. I'm asking for this Court to reconsider that decision +and provide an individualized assessment of whether that +condition is appropriate under the circumstances of this case. +Your Honor, this case involves allegations of +nonviolent criminal conduct. I do not believe that there's a +controversy of whether she's a flight risk or danger to the +community. What has been said to me with regards to why the +application for the firearm has been made by pretrial services +is to make them more comfortable so when they come to the home +there's not a firearm in the home. +I do appreciate the fact that pretrial services needs +to be safe, and I don't deny that. However, when it comes to +infringing upon her Second Amendment right to possess her +firearm that she has legally, that's personal to her, I also +would like to make one correction in the record from my +previous presentation, because I indicated to the Court at that +time that she possessed it legally and that she just has it for +the home. +Well, it turns out she does have credentials to +actually carry her firearm in public as it relates to her job. +I suspect that that could change if something happened with her +job as a result of these proceedings, but that wouldn't change + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 17 +Filed 12/19/19 Page 11 of 15 +11 +JopWnoeC +her ability to actually possess her firearm should her job +status change, meaning there may become a change in her ability +to carry it publicly because of a change of job situation, but +it won't impact her constitutional right to actually bear arms. +Under 3142, the Court should consider the least +restrictive methods, in this case, I think, address the safety +issue being raised by pretrial services. +If you look at Ms. Noel's history and character, she +doesn't have a prior criminal record. She has no history of +violence or bad conduct that might indicate that she is a +physical threat, that she would use her firearm against another +unwarrantedly. +The pretrial services report was done by the person +who's going to supervise her. I've had an opportunity to speak +to pretrial services about this application, that I would be +making this application, and fortunately, having worked with +the pretrial services officer, he respectfully disagreed with +my position and mentioned to me that one of the concerns is +what happens if I come to the home and the gun is out? That's +a problem. +Well, it could be a problem, I suppose, but it's not +like a dog who has its own will and may go bite someone. In +fact, I submit to the Court that if my client had a dog that +wasn't friendly to strangers, that one of the remedies we would +say is when they come from pretrial services, you have to put + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT +Document 17 Filed 12/19/19 Page 12 of 15 +JopWnoeC +12 +the dog away. What I'm suggesting to your Honor in the least +restrictive manner is that we can make sure that if anyone from +pretrial services comes to the home, that she will secure the +gun away so that it's not out, since that seems to be their +concern. +She doesn't have any ill will towards the court staff +or anyone a part of this process. +She understands what she +needs to do. There is no actual, credible, competent threat +supported by evidence to suggest that at this time her +constitutional right to possess +her weapon should be infringed +at this time. +I suppose there could come a time where that could +change, but when we take it now, without an individual +assessment of her particulars, her background, the specific +circumstances of the case, then it gives the impression as if +the conclusion's foregone that she should be -- meaning in this +case -- a felon deprived of her firearm. She's not. She +remains innocent as we sit here today, and the fact that she's +here is disappointing, but we're here, so we have to deal with +it. +All I'm asking for is fair consideration in an +individualized way. Any concern that your Honor has about her +possessing a firearm, I'd welcome you to address it with me so +I have an opportunity to directly speak to your concerns. +THE COURT: I'll hear from the government. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 17 Filed 12/19/19 Page 13 of 15 +JopWnoeC +13 +MS. DONALESKI: Your Honor, with respect to modifying +the travel restrictions, we have no objection to including her +travel restriction to the Middle District of Pennsylvania. +With respect to the firearm, defense counsel raised +this in front of Judge Netburn last week, who had the +opportunity to consult with pretrial services. She denied this +request, as your Honor should do. +We respectfully submit it is due to the safety +concerns of pretrial services that the defendant should not be +permitted to possess her firearm. The pretrial services +officers have to go into the defendant's home, including at +unscheduled visits, and due to their safety concerns with +having a defendant who has access to a firearm and they may not +know where the firearm is in the home, it's entirely reasonable +for pretrial services to say as a policy defendants have to +surrender their firearms. +This is done in every case, your Honor, including law +enforcement officers who are on pretrial services supervision. +Defendants are required to give their firearms back or to +surrender their firearms simply for the safety of the pretrial +services officers who are going into their homes. And given +that safety concern, we believe that it is appropriate, as +Judge Netburn found, for that to be a condition of her release. +THE COURT: The removal of the firearm is a +commonsense safety measure. The application is denied. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 17 Filed 12/19/19 Page 14 of 15 +JopWnoeC +14 +Are there any further applications? +MR. FIGGINS: Yes, your Honor. +With respect to Mr. | +•. last week, we asked for a +week to get two additional cosigners. I would just ask the +Court to give us another seven days. I've submitted the +information to the U.S. Attorney's Office, but they still need +to conduct their interview. I just don't want there to be any +issues with respect to having it completed by tomorrow, so I +would just ask the Court to extend it another seven days with +respect to getting those signers and getting it approved. +MS. DONALESKI: We have no objection to that, your +Honor. +THE COURT: All right. That deadline is extended by a +week. And I certainly have no objection to the Middle District +of Pennsylvania being included in those areas where Ms. Noel is +permitted to travel. +Is there anything further? +MS. DONALESKI: We'll just request a ruling on our +application to exclude time, your Honor. +THE COURT: Yes. +The application is granted. Time is +excluded. +Is that without objection? +MR. FOY: That is without objection, your Honor. +MR. FIGGINS: That's fine, your Honor. +THE COURT: Time is excluded under the Speedy Trial +SOUTHERN DISTRICI REPORTERS, P.C. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 17 Filed 12/19/19 Page 15 of 15 +JopWnoeC +Act until April 20, 2020. I find that the ends of justice +served by excluding such time outweigh the interests of the +public and the defendants in a speedy trial because this will +allow time for the prosecution to produce discovery, for the +defense to consider it, to decide whether to prepare motions, +and for the parties to discuss a possible disposition. +The defendants' bail status shall remain the same. +The matter is adjourned. +(Adjourned) +15 +(212) +805-0300 \ No newline at end of file diff --git a/vision-fixhub/court-05/6dc0edc8c94c0573ae9041d5060cad3444bb76e2982aeb72853bee4590962768.receipt.json b/vision-fixhub/court-05/6dc0edc8c94c0573ae9041d5060cad3444bb76e2982aeb72853bee4590962768.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d853b636eab27611162b8526d7ace9f97d7da537 --- /dev/null +++ b/vision-fixhub/court-05/6dc0edc8c94c0573ae9041d5060cad3444bb76e2982aeb72853bee4590962768.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -811, + "dataset": "marble-joined", + "doc_id": "6dc0edc8c94c0573ae9041d5060cad3444bb76e2982aeb72853bee4590962768", + "engine": "marble-apple-vision", + "event_count": 17, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "4d3c7c2c00c63ac4b46b7686226cd4986888882fdcc38f7e948815c7a6b59ea1", + "output_sha256": "fd5be284aee5d7325576a2d555ff17a2089fc23488eecb0f148cb5e7c88d5b23", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6ded63cd4821ad2866556f4fb6c453c27dafb745609b0967dd2a5ff1bd2f13e2.md b/vision-fixhub/court-05/6ded63cd4821ad2866556f4fb6c453c27dafb745609b0967dd2a5ff1bd2f13e2.md new file mode 100644 index 0000000000000000000000000000000000000000..c9bfdde3d3db49670585b2d64263f1e71d9a7200 --- /dev/null +++ b/vision-fixhub/court-05/6ded63cd4821ad2866556f4fb6c453c27dafb745609b0967dd2a5ff1bd2f13e2.md @@ -0,0 +1,65 @@ +Case 1:22-cV-10904-JSR Document 326-67 Filed 09/08/23 Page 1 of 3 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-67 Filed 09/08/23 Page 2 of 3 +Jeffrey Epstein +Jes Staley wrote: +From: Jeffrey Epstein +To: Jes Staley +Sent: Wed Jun 16 16:34:02 2010 +Subject: Re: +call me +On Wed, Jun 16, 2010 at 4:32 PM, Jes Staley wrote: +Is she free tonight? +This email is confidential and subject to important disclaimers and +conditions including on offers for the purchase or sale of +securities, accuracy and completeness of information, viruses, +confidentiality, legal privilege, and legal entity disclaimers, +available at http://www.jpmorgan.com/pages/disclosures/email. +********************************************************* +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. +This email is confidential and subject to important disclaimers and conditions including on offers for the purchase +or sale of securities, accuracy and completeness of information, viruses, confidentiality, legal privilege, and legal +entity disclaimers, available at http://www.jpmorgan.com/pages/disclosures/email +******** +********** + +JPM-SDNYLIT-00008342 + + +The information confained in Chis communication 1 +Document 326-67 Fled 09/08/23 Pade 3 ot: +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. + +JPM-SDNYLIT-00008343 \ No newline at end of file diff --git a/vision-fixhub/court-05/6ded63cd4821ad2866556f4fb6c453c27dafb745609b0967dd2a5ff1bd2f13e2.receipt.json b/vision-fixhub/court-05/6ded63cd4821ad2866556f4fb6c453c27dafb745609b0967dd2a5ff1bd2f13e2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..23648ceb5e43affd3f9ed734af5f82a396ad782d --- /dev/null +++ b/vision-fixhub/court-05/6ded63cd4821ad2866556f4fb6c453c27dafb745609b0967dd2a5ff1bd2f13e2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -58, + "dataset": "marble-joined", + "doc_id": "6ded63cd4821ad2866556f4fb6c453c27dafb745609b0967dd2a5ff1bd2f13e2", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "5bd5e39cfe87a6720f5e3259d253da65823877c0af5741a90a7471bf219456c2", + "output_sha256": "ee71050b9fa52665a3205c02982ce1b0150f53b1433dfc17e4fd7c68b013e242", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6dffa3fdefafee641a63cd4a35ad0e90345a94223c18b7bb74b7f4284548c6cd.md b/vision-fixhub/court-05/6dffa3fdefafee641a63cd4a35ad0e90345a94223c18b7bb74b7f4284548c6cd.md new file mode 100644 index 0000000000000000000000000000000000000000..3185ccbf4f0bf77840828d1ac79d5204715a8b78 --- /dev/null +++ b/vision-fixhub/court-05/6dffa3fdefafee641a63cd4a35ad0e90345a94223c18b7bb74b7f4284548c6cd.md @@ -0,0 +1,181 @@ +Case 1:22-cV-10904-JSR Document 238-48 Filed 07/25/23 Page 1 of 5 + + + +Case 1:22-cV-10904-JSR Document 238-48 Filed 07/25/23 Page 2 of 5 +From: +To: +CC: +Sent: +Subject: +Attachments: +maria.a.hornak@jpmorgan.com +CSG_AO_DE_FM2@jpmchase.com +3/8/2007 5:46:33 PM +Fw: New Chase Credit Cards +JE - Chase Credit Cards.xs; pic22512.gif +-- Forwarded by Maria A Hornak/JPMCHASE on 03/08/2007 12:45 PM ----- +"Rich Kahn" +To +03/08/2007 12:31 PM +SubjectRe: New Chase Credit Cards +Please +call me with any +questions. +Thank you. +Rich Kahn +New York Strategy Group LIC +457 Madison Avenue +Fourth Floor +New York, NY 10022 +tel 212-891-6430 +fax 212-750-2408 +rkahn@nysgnail.com +-----Original Message----- +From: Bella Klein +Sent: Wednesday, March 07, 2007 4:13 PM +To: Rich Kahn +Subject: FW: CC +-----Original Message----- +From: maria.a.hornak@jpmorgan.com [mailto:maria.a.hornak@jpmorgan.com] +Sent: Wednesday, March 07, 2007 3:59 PM +To: Bella Klein +Ce: CSG_AO_DE_EM2@jpmchase.com +Subject: CC +There are a variety of cards available. Once you have the application +complete, we will need to submit a "special consideration form" along w/ +the application to ask for an exception. Therefore, fax me the app upon +completion. +http://www.chase.com/ccp/index.jsp?pg name=copmapp/card acquisitions/uns +olicited/page/PFSCreditChooseCategory&cat=business +To ensure a timely response, be sure to copy the following address on +all +emails: CSG_AO_DE_EM2@jpmchase.com +Regards, +Maria A Hornak +Associate +1-888-207-5225/302-634-5730 +Fax: 1-888-731-6608/302-634-5010 +EXHIBIT_ +15 +WIT: +Casey +DATE: 4-7-33 +RDR CAR CR #13921 + +JPM-SDNYLIT-00001494 + + +Case 1:22-cV-10904-JSR Document 238-48 Filed 07/25/23 Page 3 of 5 +This connunication 15 for informational purposes only. It 13 not +intended as an offer or solicitation for the purchase or sale of any +financial instrument or as an official confirmation of any transaction. +All market prices, data and other information are not warranted as to +completeness or accuracy and are subject to change without notice. Any +comments or statements made herein do not necessarily reflect those of +JPMorgan Chase & Co., Its subsidiaries and affiliates. | +This transmission may contain information that is privileged, +confidential, legally privileged, and/or exempt from disclosure under +applicable law. If you are not the intended recipient, you are hereby +notified that any disclosure, copying, distribution, or use of the +information contained herein (including any reliance thereon) is +STRICTLY PROHIBITED. Although this transmission and any attachments are +believed to be free of any virus or other defect that might affect any +computer system into which it is received and opened, it is the +responsibility of the recipient to ensure that it is virus free and no +responsibility is accepted by JPMorgan Chase & Co., its subsidiaries and +affiliates, as applicable, for any loss or damage arising in any way +from its use. If you received this transmission in error, please +immediately contact the +sender and destroy the material in its entirety, +whether in electronic or hard copy format. +Thank you. +(See attached file: JE - Chase Credit Cards.xls) + +JPM-SDNYLIT-00001495 + + +Case 1:22-cv-10904-JSR Document 238-48 Filed 07/25/23 + +Document Produced in +Native Format + +JPM-SDNYLIT-00001496 + + +Case 1:22-cv-10904-JSR Document 238-48 Filed 07/25/23 Page 5 of 5 +JEFFREY EPSTEIN +CHASE CREDIT CARDS +Cardholders +JEGE Inc. +C/o Jeffrey Epstein +457 Madison Avenue, 4th Floor +New York, NY 10021 +EIN # +S Corp +1 David Rodgers +2 Larry Visoski +3 Larry +4 William Hammond +Total JEGE Cards: 4 +NES LLC +C/o Jeffrey Epstein +457 Madison Avenue, 4th Floor +New York, NY 10021 +EIN #1 +/ Single Member LLC +1 Valdson Cotrin +SS #-> +2 +3 Brice M +4 +Rueda +5 Luciano Fontanilla +6 Janusz Banasiak +7 +8 +9 +10 +Social Security # +Card Limit +Notes +10,000.00 +10,000.00 +2,500.00 +2,500.00 +25,000.00 +Travels through Paris, Europe and US Virgin Islands and US monthly +Travels through Paris, Europe and US Virgin Islands and US monthly +Travels through Paris, Europe and US Virgin Islands and US monthly +Travels through Paris, Europe and US Virgin Islands and US monthly +5,000.00 +6,000.00 +6,000.00 +3,000.00 +5,000.00 +3,000.00 +10,000.00 +5,000.00 +10,000.00 +6,500.00 +59,500.00 +All charges in Europe are ok +New Mexico charges +New Mexico charges +New York charges +New York charges +Florida charges +Travels through Paris, Europe and US Virgin Islands and US monthly +Travels through Paris, Europe and US Virgin Islands and US monthly +Travels through Paris, Europe and US Virgin Islands and US monthly +All charges in Europe are ok +Total NES Cards: 10 +NOTES +1 Chase Business Card with Premier Cash Rebate. Earn 3% cash back on purchases at gas stations, restaurants, office supply stores, hardware & home +improvement centers, plus 1% back on purchases made elsewhere. No annual fee +2 The 3% cash back on purchases is maxed out at 4,000 points per month. No annual cap on 1% cash back on an annual basis. +3 Can access Cards at Chase.com - no limit on dollar redemptions - checks will be made to JE and we can deposit into his bank account +4 Rich Kahn to be proxy on account / Only JE can authorize credit line increases and close accounts +5 Cards take 2-5 business days to arrive once ordered. They will all be sent to 457 Madison Avenue + +JPM-SDNYLIT-00001496 diff --git a/vision-fixhub/court-05/6dffa3fdefafee641a63cd4a35ad0e90345a94223c18b7bb74b7f4284548c6cd.receipt.json b/vision-fixhub/court-05/6dffa3fdefafee641a63cd4a35ad0e90345a94223c18b7bb74b7f4284548c6cd.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5740a509648a94a47e56e3cb247c549aab024da4 --- /dev/null +++ b/vision-fixhub/court-05/6dffa3fdefafee641a63cd4a35ad0e90345a94223c18b7bb74b7f4284548c6cd.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -129, + "dataset": "marble-joined", + "doc_id": "6dffa3fdefafee641a63cd4a35ad0e90345a94223c18b7bb74b7f4284548c6cd", + "engine": "marble-apple-vision", + "event_count": 11, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "70bb584c7145f9a4c0bb59cdfbffb9527ab1fbaa472c4c39aa13c98115c4ecea", + "output_sha256": "6da7534e919394ad6034e183b2c6d1bd2bb8f2109b3cc006329ad4f9ddbe0137", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6e1210c5fc0e6ea4f27eb8b577384756319d67fb40f7231e1fad2f75bda3b96c.md b/vision-fixhub/court-05/6e1210c5fc0e6ea4f27eb8b577384756319d67fb40f7231e1fad2f75bda3b96c.md new file mode 100644 index 0000000000000000000000000000000000000000..0d50588c325b5927f9c9d70361442a33635d1d89 --- /dev/null +++ b/vision-fixhub/court-05/6e1210c5fc0e6ea4f27eb8b577384756319d67fb40f7231e1fad2f75bda3b96c.md @@ -0,0 +1,45 @@ +Case 1:22-cv-10904-JSR Document 186-66 Filed 06/14/23 + + + + +Case 1:22-cv-10904-JSR Document 186-66 Filed 06/14/23 Page 2 of 2 +Date: +From: +To: +CC: +Thursday, November 152012 08:07 PM +Subject: Re: Phone call - November 15, 2012 +Daphne Wallace +@gmail.com> +Jeffrey Epstein ; +Cecile de Jongh c +@yahoo.com.>; +Greetings Mr. Epstein, +Cecile says she thinks it is ok since you are giving a turkey to everyone. +Respectfully, +Daphne +On Thu, Nov 15, 2012 at 3:01 PM, Jeffrey Epstein wrote: +Ask Cecil if she thinks it ok if I give all 78 customs agents a turkey +On Thursday, November 15, 2012, Daphne Wallace wrote: +Greetings Mr. Epstein, +Ms. LeeAnn Greaux of the St. +Customs and Border Protection office just called. She says vou called +and requested to know the number of employees in their office - there are 78 employees in the St. +Respectfully, +Daphne +•**•******************************************************* +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved + +ESTATE_JPM016458 diff --git a/vision-fixhub/court-05/6e1210c5fc0e6ea4f27eb8b577384756319d67fb40f7231e1fad2f75bda3b96c.receipt.json b/vision-fixhub/court-05/6e1210c5fc0e6ea4f27eb8b577384756319d67fb40f7231e1fad2f75bda3b96c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..66a802879114f365bc9954d561a184fa6c0e02cb --- /dev/null +++ b/vision-fixhub/court-05/6e1210c5fc0e6ea4f27eb8b577384756319d67fb40f7231e1fad2f75bda3b96c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -58, + "dataset": "marble-joined", + "doc_id": "6e1210c5fc0e6ea4f27eb8b577384756319d67fb40f7231e1fad2f75bda3b96c", + "engine": "marble-apple-vision", + "event_count": 5, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "133f8146f3127894d11d0d11a6a510279483f1fe6be0485176417325a7f0daf6", + "output_sha256": "2b3692f1b5735913548a24056bcaa315c3d4321772aad97562c612910ce318dc", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6e2e74cd548ba2ba7a41351921abde65a40ff037ebc79317f4e9b75f97b122d5.md b/vision-fixhub/court-05/6e2e74cd548ba2ba7a41351921abde65a40ff037ebc79317f4e9b75f97b122d5.md new file mode 100644 index 0000000000000000000000000000000000000000..b727dea839553f10d5f6633bce4cb5a145915dc4 --- /dev/null +++ b/vision-fixhub/court-05/6e2e74cd548ba2ba7a41351921abde65a40ff037ebc79317f4e9b75f97b122d5.md @@ -0,0 +1,30 @@ +Case 1:22-cv-10904-JSR Document 44-4 Filed 02/08/23 Page 1 of 1 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904 JSR +ORDER FOR ADMISSION +PRO HAC VICE +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +The motion of Mimi Liu for admission to practice Pro Hac Vice in the above-captioned +action is granted. +Applicant has declared that she is a member in good standing of the bars of the state of +New York and the District of Columbia; and that her contact information is as follows: +Name: +Mimi Liu +401 9* Street NW, Suite 630 +City/State/Zip: Washington, D.C. 20004 +Telephone/Fax: (202) 386-9625 phone / (202) 386-9622 fax +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for +Plaintiff, Government of the United States Virgin Islands, in the above-entitled action; +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the +above-captioned case in the United States District Court for the Southern District of New York. +All attorneys appearing before this Court are subject to the Local Rules of this Court, including +the Rules governing discipline of attorneys. +New York, NY +February - +_, 2023 +JED S. RAKOFF, U.S.D.J. diff --git a/vision-fixhub/court-05/6e2e74cd548ba2ba7a41351921abde65a40ff037ebc79317f4e9b75f97b122d5.receipt.json b/vision-fixhub/court-05/6e2e74cd548ba2ba7a41351921abde65a40ff037ebc79317f4e9b75f97b122d5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..eb9ead48e99df6b0382a361ea329203f1c7d5acd --- /dev/null +++ b/vision-fixhub/court-05/6e2e74cd548ba2ba7a41351921abde65a40ff037ebc79317f4e9b75f97b122d5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "6e2e74cd548ba2ba7a41351921abde65a40ff037ebc79317f4e9b75f97b122d5", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "2d7c57d18313561270a7a6e3e760edcbebfd12edd1f75726c163f732865108a5", + "output_sha256": "a2193c29d55325752b9262c14e2a28afb07ac7bcea6fd6bd9f03ff7bc89c1e6e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6e3b73f9dba1be0342e1b67191d1df8bb7e7eb111f2c94e0193545877f088022.md b/vision-fixhub/court-05/6e3b73f9dba1be0342e1b67191d1df8bb7e7eb111f2c94e0193545877f088022.md new file mode 100644 index 0000000000000000000000000000000000000000..f6932b9479a912e92970809cae1ce8bf9cac075f --- /dev/null +++ b/vision-fixhub/court-05/6e3b73f9dba1be0342e1b67191d1df8bb7e7eb111f2c94e0193545877f088022.md @@ -0,0 +1,1059 @@ +Case 1:22-cv-10904-JSR Document 239-24 Filed 07/25/23 Page 1 of 21 + + + +Case 1:22-cv-1998618R @g4чment 23912(g|Filęd @URT/3dleRagea1of 21 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +1 +2 +3 +4 +5 +6 +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party +Plaintiff. +: Case Number: +: 1:22-cv- +: 10904-JSR +: +7 +8 +9 +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +: +JAMES EDWARD STALEY +Third-Party Defendant. +10 +11 +12 +- +MAY 24, +2023 +HIGHLY CONFIDENTIAL +- +13 +Videotaped deposition of +14 +STEPHEN CUTLER, taken pursuant to notice, +15 +was held at the law offices +of Boies +16 +Schiller Flexner ILP, 55 Hudson Yards, +17 +New York, New York, commencing at +18 +9:40 a.m., on the above date, before +19 +Amanda Dee Maslynsky- +• a Certified +20 +Realtime Reporter and Notary Public in +21 +and for the State of New York. +22 +23 +- +- +GOLKOW LITIGATION SERVICES, INC. +877.370.3377 ph| 917.591.5672 fax +deps@golkow.com +24 +Page 1 + + +Case 1:22-cv-1998bH&R @arment 239r7łgłFilęd QЪRҐ/Z3leRa9£a1of 21 +1 you know that there was a federal +2 non-prosecution agreement, you just don't +know when you knew that? +4 +A. +I know at a certain point I +5 understood that there was a federal +6 +non-pros agreement. I can't tell you +• exactly when. And I can't tell you that +8 +I knew precisely what the terms of it +9 +were. +10 +11 +12 +But you knew at some point +while you were general counsel at +JPMorgan and Jeffrey Epstein was a client +13 +14 +of the bank; is that fair? +A. +I believe I knew that there +15 +16 +was a non-pros agreement. +e. +Okay. You can put that +17 +document away. +18 +Do you recall, in 2008, +19 after Jeffrey Epstein pled guilty to the +20 child sex offenses, that private bank +21 +wanted to exit Jeffrey Epstein as a +22 +client of the bank? +23 +A. +I do not. +24 +- - +- +Page 150 + + +Case 1:22-cv-1998618 @944ment 239124g|Filed @URT/3 dieRage a1of 21 +1 +MR. GAIL: Objection. +2 +THE WITNESS: I don't know +3 +why you don't think it would make +4 +any sense, but I could -- I could +5 +conceive of -- if I had been +6 +involved in approval in '08, I +could also conceive, in 2011, +8 +having this view. +BY MS. LIU: +10 +Q. +What happened between +11 possibly your approving him in 2008 and +12 +your having this view in 2011, +13 Mr. Cutler? +14 +A. +Well, among other things, I +15 +think we would have +seen the non-pros +16 +agreement. We would have reviewed a lot +17 +of press that arose, I want to say in the +18 +2010, early 2011 period. We had some +19 +direct experience with him in connection +20 +with the claims that he was raising +21 +against Bear Stearns. +22 +And so I think whatever +23 +24 +judgment I had had in 2008, clearly by +this date in 2011, I did not believe that +Page 264 + + +Case 1:22-cv-1998bH&R @arment 239r2łgłFilęd QURT/Z3leRagea1of 21 +Jeffrey Epstein should be a client of the +2 firm. +3 +e. +The press that arose said he +4 was being investigated for child sex +5 trafficking and human trafficking, +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +correct? +A. +I don't remember the +precise, but -- the precise parameters of +the press, but I remember there was a +series of articles about a new +investigation. +There were articles that +I remember pointed that he was -- he had +resolved claims with - with a very large +number of women. +And, yeah, so I remember +those being among the articles, you know, +that we saw in 2010 or '11. +Who is Nina Shenker? +A. +At this point, she was the +general counsel of the asset management +business. +e. +She was Mary Erdoes's +general counsel, correct? +A. +I'd never put it that way, +Page 265 + + +Case 1:22-cv-1998618R @arment 239124g|Filęd @URT/3dleRagealof 21 +I'll represent to you, and you can -- you +2 can check me on this, 7/21/11, when you +say, I would like to put it and him +4 behind us, not a person we should do +5 business with period, was a Thursday. +6 +A. +Okay. +7 +And the him, just so it's +8 +perfectly clear for the record, is +9 +10 +Jeffrey Epstein, correct? +A. +I believe that's right. +11 +-- +- +12 +(Whereupon, Exhibit +13 +Cutler-23, +14 +JPM-SDNYLIT-00754982-984, 7/22/11 +15 +E-mail, was marked for +16 +identification.) +17 +- +- +- +18 BY MS. LIU: +19 +20 +l. +marked as Exhibit-23. +I'm showing you what's been +21 +So you'll see the top e-mail +22 +on Exhibit-23 is from Nina Shenker to +23 +Mary Erdoes on 7/22/2011 -- +24 +A. +I see it. +Page 268 + + +Case 1:22-cv-1998618R @grument 23924g|Filęd QURT/33eRage a71of 21 +1 +2 +e. +- the next day, correct? +She writes, Imagine lots to +do upon your return to U.s. and for next +4 week. +5 +Do you see that? +6 +A. +Yes. +7 +Q. +And then there's a redacted +8 +portion. And then the next line says, +9 +10 +FYI, Steve, at conclusion of JE approval, +asked when we are off-boarding JE. I +11 +reminded him that we have the other +12 +matter outstanding. +13 +Do you see that? +14 +15 +16 +A. +e. +A. +I do. +What was the JE approval? +I don't know. I mean, I +17 +could make an assumption that it related +18 +to this lawsuit, but I don't know. +19 +So the day before you said +20 to Mary Erdoes, I want to put him behind +21 +us? +22 +A. +Correct. +23 +Not a person we should do +24 +business with? +Page 269 + + +Case 1:22-cv-1§08ph&R @9чument 23924głF1|ęd ©У¾·⅔deRa9£ 81of 21 +1 +A. +Correct. +2 +e. +Do you believe that Nina +Shenker is referring to an approval of +Jeffrey Epstein that predated July 21st, +2011? +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +MR. GAIL: Objection. +MR. EDELMAN: Objection to +form. +THE WITNESS: I'm sorry, an +approval of him as a client? +BY MS. LIU: +l. +A. +Yes. +No. +2. +Okay. Let me understand. +What do you believe, FYI +Steve, at conclusion of JE approval, +asked when we are off-boarding JE? +A. +I -- I don't think I would +19 have said when are we off-boarding him if +20 +we were speaking about an approval of his +21 +account. It just -- the two things in +22 +conjunction don't make sense to me. +23 +I would think, just based on +24 +the juxtaposition of Exhibit-22 versus +Page 270 + + +Case 1:22-cv-1998618R @aqчment 2392(g|Filęd @URT/3dleRage 21of 21 +1 +Exhibit-23 that it's somehow the approval +2 of the settlement. +3 +I see. +4 +Steve, at the conclusion of +5 +• the Jeffrey Epstein settlement approval? +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +A. +I -- that makes more sense +to me. +l. +Okay. +A. +I don't remember it. +Okay. Fine. Just want to +try to understand what you think it +means. +So -- asked when we are +off-boarding Jeffrey Epstein. +That's consistent with your +telling Mary Erdoes and others in the +e-mail before this is not a person we +should be doing business with? +MR. GAIL: Objection. +THE WITNESS: Well, I think +the notion of off-boarding +somebody that I don't think we +should be doing business with, I +see how those things are +Page 271 + + +Case 1:22-cv-192 ph&n 2ºunen 23971ghlge 06523d8999 29 of 21 +1 +consistent, yes. +2 BY MS. LIU: +3 +e. +And it's also consistent +4 that JPMorgan retained Jeffrey Epstein as +5 a client to deal with the Bear Stearns +6 +litigation that Jeffrey Epstein had, +7 +correct? +8 +A. +I don't know that. +9 +10 +Because then she writes, I +reminded him that we have the other +11 matter outstanding. +12 +Do you see that? +13 +A. +I do. +14 +So we had the one, it's been +15 +16 +17 +18 +approved, settlement is done. But Steve, +from Nina, we've got that other +litigation with Jeffrey Epstein. +Do you recall that? +19 +A. +I don't. +20 +21 +e. +Highbridge +Do you recall the Zwirn +litigation? +22 +23 +A. +I've now seen documents that +remind me there was -- there was another +24 +claim that Epstein had. +Page 272 + + +Case 1:22-cv-192 ph&n 2ºfunen 23911ghlge 06523d8799 a1 of 21 +1 +embarked upon was the only reason, +2 +or even a primary reason, to exit +3 +Mr. Epstein. +4 BY MS. LIU: +5 +Q. +You had already decided +6 there were other reasons? +7 +A. +Yeah. +I don't think I was +8 +oblivious to the issue that William +9 +10 +raised. But I -- in my own mind, I don't +remember it as being the core of the -- +11 of the issue that drove my conclusion. +12 +l. +Do you recall William +13 Langford saying to you, AML +14 +investigations does not want -- believe +15 +we should retain Jeffrey Epstein as a +16 +client, in early 2011? +17 +A. +I don't remember him +18 +referring to AML investigations in +19 particular. I think what he communicated +20 to me was concern about the reputational +21 +issues. Those concerns are heightened, +22 if you will, by the human trafficking +23 initiative that we're doing, given that +24 +he was convicted of these crimes. +Page 343 + + +Case 1:22-cv-192%ph8n 2afunen 23971ghigd º6523d8a99 24 of 21 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +12 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +BY MS. LIU: +l. +You can put that document +away. +Mr. Cutler, are you aware +11 that in or around 2020, Deutsche Bank was +fined by the New York State Department of +13 Financial Services $150 million in +connection with its conduct related to +Jeffrey Epstein's +accounts? +A. +I believe I read about that. +- +- +(Whereupon, Exhibit +Cutler-39, No +• Department of +Financial Services Article, was +marked for identification.) +- +- +BY MS. LIU: +So I'm going to hand you the +Page 457 + + +Case 1:22-cv-182%ph&n Raunen 23971ghigd C8523d8799 23 of 21 +1 +press release that was issued by the New +2 York State Department of Financial +Services. It's Exhibit-39. +And at the same time, I'm +going to hand you the actual consent +order by the New York State Department of +Financial Services. And it's Exhibit-40. +- +- +(Whereupon, Exhibit +Cutler-40, No +, Consent Order +Under New York Banking Law 39 and +44, was marked for +identification.) +-- +- +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +20 +21 +22 +23 +24 +BY MS. LIU: +l. I would ask you to first +take a l00k at Exhibit-40 and see if you +recall that being the consent order that +19 you recall reading? +MR. GAIL: Objection. That +misstates. +THE WITNESS: I don't think +I ever read the consent order. +BY MS. LIU: +Page 458 + + +Case 1:22-cv-182€ph&n Raunen 23971ghigd C8F23d8799 21 of 21 +1 +e. +1, you -- +2 +A. +I think you -- +3 +e. +-- read about this at the +4 time? +5 +A. +I think you asked me if I +6 +was aware of it. And I believe I read +7 +about it. +8 +l. +Fair enough. I +9 +misunderstood you. +10 +A. +And I don't -- I don't +11 believe I've ever seen this document +12 +before. +13 +You can put that document +14 +15 +16 +away. I just want to look at the press +release, then. +A. +Okay. +17 +e. +So you'll see the title is, +18 +Superintendent Lacewell Announces DES, +19 Department of Financial Services, Imposes +20 a $150 Million Penalty on Deutsche Bank +21 in Connection with Bank's Relationship +22 with Jeffrey Epstein. +23 +And it also mentions +24 +something unrelated to Jeffrey Epstein. +Page 459 + + +Case 1:22-cv-192€ph&n Raunen 23971ghigd C8523d8799 25 of 21 +1 +Do you see that? +2 +A. +I do. +3 +Q. +And if you turn to the +4 +second page of the document and you go to +5 the first full paragraph, With respect to +6 the case of Jeffrey Epstein, before the +7 bullets. +8 +Do you see that? +9 +10 +A. +l. +Yes. +All right. The bank failed +11 +to properly monitor account activity +12 +conducted on behalf of the registered sex +13 +offender, despite ample information that +14 +was publicly available concerning the +15 +16 +circumstances surrounding Mr. Epstein's +earlier criminal misconduct. +17 +Do you see that? +18 +A. +I do. +19 +The bank -- The result was +20 that the bank processed hundreds of +21 +transactions totalling millions of +22 +23 +24 +dollars that, at the very least, should +have prompted additional scrutiny, in +light of Mr. Epstein's history. +Page 460 + + +Case 1:22-cv-192%ph8n Daunen 23971ghigd 06523d8ag9 ag of 21 +1 +And then it lists a number +2 +of things, correct? +3 +A. +Yes. +4 +All right. Payments to +5 individuals who were publicly alleged to +6 have been Mr. Epstein's co-conspirators +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +in sexually abusing young women. +Do you see that? +A. +8. +I do. +JPMorgan also made +payments - handled payments from +Mr. Epstein's accounts to individuals who +are publicly alleged to have been +Mr. Epstein's co-conspirators in sexually +abusing young women, correct? +MR. +GAIL: Objection. +THE WITNESS: Are you +referring to the non-pros +agreement, which refers to certain +people as potential +co-conspirators? +BY MS. LIU: +Yes. +A. +And I'm -- just based on +Page 461 + + +Case 1:22-cv-192€ph&n Raunen 23971ghigd C8523d8999 21 of 21 +1 +what you said here today and what you +2 have shown me, there are payments that +were made out of Epstein accounts to one +4 or more of those individuals. +5 +Next bullet, Settlement +6 +payments totalling over $7 million +7 dollars, +as +well as dozens of payments to +8 +law firms totalling over $6 million for +9 +10 +what appears to have been the legal +expenses of Mr. Epstein and his +11 +co-conspirators. +12 +Do you see that? +13 +A. +I do. +14 +And you recall earlier this +15 +16 +17 +18 +morning I showed you a spreadsheet that +contained many payments, many in the +amount of $100,000, from Jeffrey +Epstein's accounts to law firms and +19 +lawyers? +20 +Do you recall that? +21 +A. +I do. +22 +23 +24 +Q. +The next bullet, Payments to +Russian models, payments for women's +school tuition, hotel and rent +Page 462 + + +Case 1:22-cv-192€ph&n Raunen 23971ghigd C8523d8799 29 of 21 +1 +expenses - and rent expenses and, +2 consistent public allegations of prior +wrongdoing, payments directly to numerous +4 +women with Eastern European surnames. +5 +Do you see that? +6 +A. +I do. +7 +And you'll recall we looked +8 +at a document that showed payments to +9 +women whose names, you said, could be +10 +Russian or could be Eastern European. +11 +Do you recall that? +12 +A. +I should clarify, I mean, +13 they could be Americans with those names. +14 +But I get the point that +15 +there are certain names that you might +16 +associate with Russian heritage or +17 +Eastern European heritage. +18 +Next one, Periodic +19 +suspicious cash withdrawals, in total, +20 +more than $800, 000 over approximately +21 +four years. +22 +Do you see that? +23 +24 +A. +e. +I do. +Page 463 + + +Case 1:22-cv-1928ph8n @afunent 23921 ghilga 0765/23d8a99 29 of 21 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +And then if you turn to the +next page, you'll see the second sentence +begins, For example, certain conditions +imposed upon the Epstein accounts by a +bank reputational risk committee, +conditions that, if followed, might have +detected and prevented many subsequent +suspicious transactions were either not +transmitted to the majority of the +account relationship team or were +misinterpreted by a compliance officer. +Page 464 + + +Case 1:22-cv-192%ph&n Raunen 23971ghigd C8523d8799 39 of 21 +1 +Do you see that? +2 +A. +I do. +3 +e. +Okay. So you'll recall that +4 +I -- we talked about this condition that +5 +was imposed following rapid response +6 +meetings that Epstein was to be a banking +7 +only client. +8 +Do you recall that? +9 +A. +I do. +10 +And then you'll recall +11 +12 +later, in the Justin Nelson KYC, there +were numerous entries which referred to +13 him as an active brokerage client? +14 +A. +Right. +15 +I -- what I don't know is +16 +17 +whether that was contemplated within the +panoply of activities that could take +18 +place at the bank. +19 +And then -- +20 +A. +Nor do I know that any of +21 those activities or the -- you know, if +22 those activities hadn't been affected, +23 that would have allowed for detection and +24 +prevention of suspicious transactions as +Page 465 + + +Case 1:22-cv-192%ph&n Raunen 23971ghigd C8523d2799 31 of 21 +reflected in the sentence that you just +2 read. +3 +And then after this section +4 I just read, related to Epstein, it moves +5 on to a different account, Don Esconia, +6 +right? +7 +A. +Yes. I gather that the fine +8 +imposed here was both for Epstein and for +9 +other relationships that Deutsche Bank +10 +had. +11 +l. +You can put that document +12 +away. +13 +MR. GAIL: We've got you +14 +with one minute left. +15 +MS. LIU: I have no further +16 +17 +questions, Mr. Cutler. I +appreciate your time. +18 +MR. GAIL: Let me just +19 +20 +confer with my colleague, but I'm +sure we're done. +21 +VIDEO TECHNICIAN: Do you +22 +23 +want to go off the record? +-- +- +24 +(Whereupon, a discussion off +Page 466 \ No newline at end of file diff --git a/vision-fixhub/court-05/6e3b73f9dba1be0342e1b67191d1df8bb7e7eb111f2c94e0193545877f088022.receipt.json b/vision-fixhub/court-05/6e3b73f9dba1be0342e1b67191d1df8bb7e7eb111f2c94e0193545877f088022.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fd78f7c4d3312340020512ae1ecf95e63a53c9da --- /dev/null +++ b/vision-fixhub/court-05/6e3b73f9dba1be0342e1b67191d1df8bb7e7eb111f2c94e0193545877f088022.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -803, + "dataset": "marble-joined", + "doc_id": "6e3b73f9dba1be0342e1b67191d1df8bb7e7eb111f2c94e0193545877f088022", + "engine": "marble-apple-vision", + "event_count": 23, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "8beeeeb53b47add39fd47aa909184446c4ea09927a1df7e39cb6d3cf606b38ce", + "output_sha256": "a03d197443a2e133b2ca2726d7691e6939673033d5338a26f2f1a13769516826", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6e6e693a654121b0384c9c5c121428a761e679c8a36cb2595b4fe84748e7d599.md b/vision-fixhub/court-05/6e6e693a654121b0384c9c5c121428a761e679c8a36cb2595b4fe84748e7d599.md new file mode 100644 index 0000000000000000000000000000000000000000..57fbb559878f6ed712a0b80be349f2c59cca8f16 --- /dev/null +++ b/vision-fixhub/court-05/6e6e693a654121b0384c9c5c121428a761e679c8a36cb2595b4fe84748e7d599.md @@ -0,0 +1,38 @@ +Case 1:22-cv-10904-JSR Document 68 Filed 03/08/23 Page 1 of 1 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +-- X +GOVERNMENT OF THE UNITED STATES : +VIRGIN ISLANDS, +Plaintiff, +: +: +Case No. 22 Civ. 10904 (JSR) +-against- +: +JPMORGAN CHASE BANK, N.A., +: +Defendant. +- X +NOTICE OF APPEARANCE +PLEASE TAKE NOTICE that the following attorney appears as counsel on behalf of +non-party Jordana H. +the independent, neutral administrator of the Epstein Victims' +Compensation Program, in the above-captioned action: +Brian T. L +] Villazor LLP +250 West 55th Street, 30th Floor +New York, NY 10019 +Telephone: (212) 582-4400 +Emaimile: (347) 338-2532 +Dated: New York, New York +March 8, 2023 +Respectfully submitted, +By: s/ Brian I. +Brian T. +VILLAZOR LLP +250 West 55th Street, 30th Floor +New York, NY 10019 +(212) 582-4400 +tHerey for, bordea distrator of i +pstein Victims' Compensation Progran diff --git a/vision-fixhub/court-05/6e6e693a654121b0384c9c5c121428a761e679c8a36cb2595b4fe84748e7d599.receipt.json b/vision-fixhub/court-05/6e6e693a654121b0384c9c5c121428a761e679c8a36cb2595b4fe84748e7d599.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..45adde5c98db8069d478a5e53f6b7d4cef4ec487 --- /dev/null +++ b/vision-fixhub/court-05/6e6e693a654121b0384c9c5c121428a761e679c8a36cb2595b4fe84748e7d599.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "6e6e693a654121b0384c9c5c121428a761e679c8a36cb2595b4fe84748e7d599", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "f6ca4cc6c434bd77781f5674ddc5d8ba9c6d44b53aac6792a6da744eb8a3c71f", + "output_sha256": "cdef1063629a76730b689280dca468c3812c27edb567e31069c92c5ffc4d596e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6e7f51027725a2ff6a4b095929059d1e5ff671f9e1c0dac23c1af1e2a25290ed.md b/vision-fixhub/court-05/6e7f51027725a2ff6a4b095929059d1e5ff671f9e1c0dac23c1af1e2a25290ed.md new file mode 100644 index 0000000000000000000000000000000000000000..5317a160a7ef14d76745648e0de3d095306b6e94 --- /dev/null +++ b/vision-fixhub/court-05/6e7f51027725a2ff6a4b095929059d1e5ff671f9e1c0dac23c1af1e2a25290ed.md @@ -0,0 +1,42 @@ +Case 1:22-cv-10904-JSR Document 241-7 Filed 07/25/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 241-7 Filed 07/25/23 Page 2 of 2 +From: +Sent: +To: +Sensitivity: +Ryan, Maryanne X [/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MARYANNE.X.RYAN] +11/29/2011 5:32:01 PM +DeLuca, Phillip A [phillip.a.deluca@jpmchase.com] +Company Confidential +FBI Set to Reopen Epstein Case Based on Testimony of +John on March 7, 2011 at 5:30 am +The Daily Mail, which has been doing the investigative work the US press hasn't been, has learned that the FBI +may reopen the case based on the testimony of Epstein's underage "erotic masseuse" +The FBI is reportedly preparing to launch a new inquiry into Epstein after one of his under-age erotic +masseuses, +1 made a string of disturbing allegations about her role. +U.S. detectives are said to be furious that Epstein, 58, escaped with only 13 months in jail for child sex offences +after he struck a plea bargain with prosecutors. +The deal protected him from further prosecution for offences in Florida. But the significance of Miss +S +claims that under-age girls were moved abroad for sex is that she paves the way for the FBI to prosecute him for +offences committed outside Florida under the Trafficking Victims Protection Act. +Maryanne Ryan +Legal and Compliance +AML Operations +VP, Compliance Director +194 +Ave South +Iselin, NJ 08830 +Phone 732-452-8071 +DeLuca Deposition + +20 +334640-CAK +04/15/2023 + +JPM-SDNYLIT-00100689 diff --git a/vision-fixhub/court-05/6e7f51027725a2ff6a4b095929059d1e5ff671f9e1c0dac23c1af1e2a25290ed.receipt.json b/vision-fixhub/court-05/6e7f51027725a2ff6a4b095929059d1e5ff671f9e1c0dac23c1af1e2a25290ed.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d26caa058858a321bcb5159c045a16cd862430a6 --- /dev/null +++ b/vision-fixhub/court-05/6e7f51027725a2ff6a4b095929059d1e5ff671f9e1c0dac23c1af1e2a25290ed.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -54, + "dataset": "marble-joined", + "doc_id": 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@@ +Case 1:22-cv-10904-JSR Document 242-33 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/6e959950c5a0eeee5268d9e65ef2257299df258a1badad4d4a8c3fb3b7dd06b1.receipt.json b/vision-fixhub/court-05/6e959950c5a0eeee5268d9e65ef2257299df258a1badad4d4a8c3fb3b7dd06b1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e4994e850fd3456d91e6aa99e8f8d01c4bf95260 --- /dev/null +++ b/vision-fixhub/court-05/6e959950c5a0eeee5268d9e65ef2257299df258a1badad4d4a8c3fb3b7dd06b1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "6e959950c5a0eeee5268d9e65ef2257299df258a1badad4d4a8c3fb3b7dd06b1", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "883c62f0312fc29733b6667cfa6561f7f8bdc6be86fc7338f8c29b68bf85e38c", + "output_sha256": "5375de10a4487b4144b2a08820cb6660b37aff4dca5c39a4fc19b9972e23427e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6e9cbd3421b6e53b3d075813f8fbc119155b7336c9da53ac536e3d882d6f071f.md b/vision-fixhub/court-05/6e9cbd3421b6e53b3d075813f8fbc119155b7336c9da53ac536e3d882d6f071f.md new file mode 100644 index 0000000000000000000000000000000000000000..c78b96d500c0902360d9b444ff29853d629b3018 --- /dev/null +++ b/vision-fixhub/court-05/6e9cbd3421b6e53b3d075813f8fbc119155b7336c9da53ac536e3d882d6f071f.md @@ -0,0 +1,20 @@ +Case 1:22-cV-10904-JSR Document 238-35 Filed 07/25/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 238-35 Filed 07/25/23 Page 2 of 2 +Category +Financial Trust's Account ending in 5001 +Financial Trust's Account ending in 5001 +Financial Trust's Account ending in 5001 +Financial Trust's Account ending in 5001 +BegControl +JPM-SDNYLIT-00060873 +JPM-SDNYLIT-00061966 +JPM-SDNYLIT-00164225 +JPM-SDNYLIT-00164332 +EndControl +JPM-SDNYLIT-00060888 +JPM-SDNYLIT-00061972 +JPM-SDNYLIT-00164234 +JPM-SDNYLIT-00164343 diff --git a/vision-fixhub/court-05/6e9cbd3421b6e53b3d075813f8fbc119155b7336c9da53ac536e3d882d6f071f.receipt.json b/vision-fixhub/court-05/6e9cbd3421b6e53b3d075813f8fbc119155b7336c9da53ac536e3d882d6f071f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..81d707d9500421cf27017e8fc5c5da04d7b6297a --- /dev/null +++ b/vision-fixhub/court-05/6e9cbd3421b6e53b3d075813f8fbc119155b7336c9da53ac536e3d882d6f071f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "6e9cbd3421b6e53b3d075813f8fbc119155b7336c9da53ac536e3d882d6f071f", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "8d6adb488615f7101e2970ed3c4e0ab858c827fc69248ef6196747e0a7191620", + "output_sha256": "89755df4ac66c6170943087469ccd8b711864788c91e5f95cddfaf96e13f41f0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6ebbdec4a4aa51da6055f82322d9c9a626149652bbd673cee33b12ba721abc2d.md b/vision-fixhub/court-05/6ebbdec4a4aa51da6055f82322d9c9a626149652bbd673cee33b12ba721abc2d.md new file mode 100644 index 0000000000000000000000000000000000000000..7a92743e6cde16d54ab48eb40e47ca55f228ca28 --- /dev/null +++ b/vision-fixhub/court-05/6ebbdec4a4aa51da6055f82322d9c9a626149652bbd673cee33b12ba721abc2d.md @@ -0,0 +1,1489 @@ +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 1 of 37 + + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 2 of 37 +FEBRUARY 2006 +JPMorganChase O + +JPM-SDNYLIT-00274984 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 3 of 37 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 4 of 37 +INTRODUCTION +Our integrity and reputation depend on our ability to do the right thing, even when +it's not the easy thing. The Code of Conduct is a collection of rules and policy +statements intended to assist employees and directors in making decisions about +their conduct in relation to the firm's business. The Code is based on our +fundamental understanding that no one at JPMorgan Chase should ever sacrifice +integrity - or give the impression that they have -- even if they think it would +help the firm's business. +Each of us is accountable for our actions, and each of us is responsible for +knowing and abiding by the policies that apply to us. Managers have a special +responsibility, through example and communication, to ensure that employees +under their supervision understand and comply with the Code and other relevant +policies. +You can look to the Code of Conduct to guide your decisions in a variety of +circumstances. However, no rulebook can anticipate every situation. Ultimately, +the personal integrity and honesty of every JPMorgan Chase employee define the +character of our company. Never underestimate the importance of your own +ethical conduct to the business and success of JPMorgan Chase. + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 5 of 37 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 6 of 37 +TABLE OF CONTENTS +1. ADMINISTRATION OF THE CODE OF CONDUCT +1.1. Persons subject to the Code of Conduct +1.2. Consultants, agents and temporary workers +1.3. Consequences of violating the Code... +1.4. Questions about the Code.. +1.5. Obligation to report violations +1.6. Current version of the Code. +1.7. Affirmation... +2. DIVERSITY.. +3. CONFIDENTIAL INFORMATION +3.1. Information about the firm, its customers, its employees, and others.. +3.2. Prior employer's confidential information and trade secrets ..... +3.3. Special rules regarding customer information and data privacy legislation.. +3.4. Publications, speeches, and other communications relating to JPMorgan Chase's business +4. +• INSIDE INFORMATION AND THE CHINESE WALL POLICY +4.1. Inside Information +4.2. The Chinese Wall policy and other information barriers. +5. OTHER BUSINESS CONDUCT. +5.1. Assets of the firm +5.2. +Intellectual property +5.3. +5.4. +Telephones, e-mail, internet, and other electronic communications devices +Internal controls, record-keeping, and reporting +5.5. +Limits of your authority +5.6. +Business relationships +5.6.1. +Fair dealing +5.6.2. +Customer, supplier, and employee relationships +5.7. Money laundering and the USA PATRIOT Act +5.8. Tying of products +5.9. Bribery and the Foreign Corrupt Practices Act. +5.10. International boycotts and cconomic sanctions... +5.11. Post-employment responsibilities.. +5.12. Other professional obligations. +6. OUTSIDE ACTIVITIES, GIFTS, AND OTHER POTENTIAL CONFLICTS OF INTEREST +6.1. Personal relationships +6.2. Personal finances... +6.3. Outside business and not-for-profit activities; outside employment +6.3.1. General. +6.3.2 +Required pre-clearance of outside activities +6.4. Political Activities... +6.4.1. +Political campaign activities and contributions by employees +2 +2 +2 +4 +6 +6 +6 +7 +7 +8 +9 +.9 +.10 +10 +10 += +11 +12 +12 +12 +. 12 +13 +13 +13 +14 +15 +15 +• 16 +.16 +16 +18 + +JPM-SDNYLIT-00274988 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 7 of 37 +6.4.2. Political contributions and related activities by JPMorgan Chase +..19 +6.5. Accepting gifts, meals, and entertainment from customers, suppliers, and others doing business +with JPMorgan Chase.... +19 +6.5.1. What you may accept.. +20 +6.5.2. What you may not accept ...... +21 +6.5.3. Approval of nonconforming gifts +22 +6.5.4. Required reporting of gifts..... +22 +6.6. Providing gifts, meals or entertainment ........ +22 +6.7. Charitable solicitations at work; charitable contributions +.23 +7. PERSONAL SECURITIES AND OTHER FINANCIAL TRANSACTIONS +7.1. General investment principles..... +7.2. Persons and accounts subject to policies +7.3. Trading in JPMorgan Chase securities.. +7.3.1. Policies applicable to all employees. +7.3.2. Employees subject to the "window" and "Senior-level employees" +Trading in securities of clients and suppliers. +7.5. Additional policies for certain groups of employees. +23 +.23 +24 +24 +24 +.25 +25 +.26 +Definitions and Examples + +JPM-SDNYLIT-00274989 + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 8 of 37 +1. ADMINISTRATION OF THE CODE OF CONDUCT +The Code of Conduct (the "Code") sets forth certain minimum expeetations that JPMorgan Chase has for +you. You are expected to conduct the firm's business in full compliance with both the letter and the spirit +of the law, the Code, and any other policies and procedures that may be applicable to you. The "firm" +and "JPMorgan Chase" as used throughout the Code mean JPMorgan Chase & Co. and all its direct and +indirect subsidiaries. +The Code is intended to provide general guidance regarding your conduct as an employee or director of +JPMorgan Chase. Note that other policies and procedures are listed at the end of many Code sections, +with an electronic link on the intranet edition of the Code. These listed items provide more detailed +information about the relevant subject and may include additional requirements with which you must +comply. However, these lists are not an exhaustive consideration of all policies and procedures that may +be applicable to you, and you are responsible for knowing which policies and procedures (whether or not +listed here) apply to you, and for understanding and complying with them. You should refer to these +documents where appropriate. Consult any of the persons listed in Section 1.4 if you have questions. +At the end of the Code, you will find a section of Definitions and Examples. +Any waiver of the provisions of this Code for an executive officer or a director must be made by the +Board of Directors and will be promptly disclosed to JPMorgan Chase & Co. stockholders. +The Corporate Secretary may provide interpretations of the Code, in consultation with the General +Counsels where appropriate. +The Code of Conduct does not create any rights to continued employment and is not an employment +contract. +Related Links: +Operating Principles of the Firm +List of Executive Committee members +Code Contacts List (with list of Code Specialists) +1.1. Persons subject to the Code of Conduct +The Code applies to employees and directors of JPMorgan Chase & Co. and its direct and indirect +subsidiaries. Employees of joint ventures and entities in which JPMorgan Chase holds venture capital +investments are not subject to the Code except to the extent the Legal and Compliance Department +determines otherwise. The provisions of the Code described in Section 5.11 also apply to former +employees. +If any provision contravenes or is less restrictive than the applicable law of any jurisdiction, the local law +will apply. Similarly, certain business units have policies that are more restrictive than the Code, and + +JPM-SDNYLIT-00274990 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 9 of 37 +those more restrictive policies will apply to those units. You are responsible for understanding and +complying with these laws and policies. +1.2. Consultants, agents and temporary workers +In general, consultants, agents and temporary workers are expected to comply with the underlying +principles of the Code. Specific arrangements with such persons will vary depending on their relationship +to the firm. Consult your Compliance officer or your Code Specialist if you have questions about your +obligations or those of others. +1.3. Consequences of violating the Code +Compliance with the Code and with other policies and procedures applicable to you is a term and +condition of employment by JPMorgan Chase. Violations of any laws that relate to the operation of our +business, the Code, or other applicable policies and procedures, or failure to cooperate as directed by the +firm with an internal or external investigation, may result in corrective action, up to and including +immediate termination of employment. The firm will take all reasonable actions to enforce the Code. In +cases where a violation of the Code could cause the firm irreparable harm, it may seek injunctive relief in +addition to monetary damages. +1.4. Questions about the Code +Each line of business and support group has been assigned at least one "Code Specialist," generally a +Compliance officer, to act as a resource for all employees in the area on Code-related issues. Contact +information for these officers is included in the Code Contacts List, and employees can contact their Code +Specialist for assistance with any questions regarding the Code. +Employees who have questions about the Code or other policies and procedures, or about how a particular +rule applies in a specific situation, can also contact: +• their manager +• their local Compliance officer +• the Office of the General Counsel +• their Human Resources Business Partner +• the Office of the Secretary +Contact information is included in the Code Contacts List. +Related link: +Code Contacts List (with list of Code Specialists) +The following lists some of the common situations in which you may have obligations under the Code +and refers you to the relevant section(s) of the Code. You should not use this list as a substitute for +familiarity with all provisions of the Code. +2 + +JPM-SDNYLIT-00274991 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 10 of 37 +Situation +Unethical or illegal behavior: +You observe conduct by another employee, a supplier, a customer, or +another person doing business with the firm that you believe to be +unethical, illegal, or contrary to the Code of Conduct. +Discriminatory or harassing conduct: +You experience or observe conduct that you believe violates the firm's +policies prohibiting employment discrimination or harassment. +Confidential information: +You wish to disclose confidential information about the firm, a +customer, a fellow employee, or another person or entity doing business +Publications: +You wish to write and publish a book, article, or other work relating to +the business of JPMorgan Chase. +Speaking engagements and public testimony: +You wish to give a speech or provide testimony on a subject relating to +the firm's business. +Media inquiries: +You have received an inquiry from a member of the media on a subject +related to the firm's business, or in a situation in which you might be +seen as speaking for the firm. +Endorsements: +A customer, supplier, or other person or entity doing business with the +firm has asked you to provide an endorsement or testimonial. +Post-employment obligations: +ou anticipate leaving JPMorgan Chase. i +Cou aming all gains ma haVe at and you are oment an dad +Potential conflict of interest: +You are in a situation that presents a potential conflict of interest or +appearance of a conflict of interest. +Outside business or other for-profit activities: +You wish to become involved with an outside business or to accept a +second job. +Outside not-for-profit activities: +You wish to become a director, trustee, or officer of a not-for-profit +organization. +Holding political office or other governmental position: +You wish to run for political office or accept appointment to any +governmental position. +Political activities: +You wish to become involved with a political campaign, lobbying +effort, or other political activity. +Gifts or entertainment offered or provided by persons doing +business with JPMorgan Chase: +You are offered or receive a gift from a customer, supplier, or other +party doing business with JPMorgan Chase. +Code Section +1.5 +2 +3 and 4 +3.4 +3.4 +3.4 +3.4 +5.11 +6 +6.3 +6.3 +6.3 and 6.4 +6.4 +6.5 +3 + +JPM-SDNYLIT-00274992 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 11 of 37 +Situation +Gifts to customers, suppliers, or others doing business with +JPMorgan Chase: +You wish to make a gift or extend an invitation to a person doing +business with JPMorgan Chase. +Charitable solicitations at work: +You wish to ask co-workers, customers, or suppliers to contribute to a +charitable cause with which you are involved. +Personal investment activity: +You, or a member of your family, are making personal investments that +may be subject to the firm's policies and procedures regarding personal +account trading. +Code Section +6.6 +6.7 +1.5. Obligation to report violations +You must promptly report any known or suspected violation of the Code or any applicable law or +regulation, whether the suspected violation involves you or another person subject to the Code. In +addition, you should report any illegal conduct, or conduct that violates the underlying principles of the +Code, by any of our customers, suppliers, contract workers, business partners, or agents. If something +doesn't look right, say something. +Report violations as follows: +Matters involving harassment or discrimination must be reported to your manager, to the +Employce Relations Unit of Human Resources, or to your HR Business Partner. +Matters involving fraudulent acts, including acts by third parties against the firm or personal +dishonesty by an employee, must be reported to the Fraud Prevention and Investigation Unit of +the General Auditing Department. +If you believe that an official at a high level of the firm is involved, report to the General Auditor. +All other matters should be reported to the Legal and Compliance Department. +If the persons to whom you report a violation are not responsive, or if there is reason to believe that +reporting to the persons indicated above is inappropriate in a particular case, then you should contact one +of the firm's General Counsels, any other Executive Committee member, or the General Auditor. +To call the Fraud Prevention and Investigation Department, dial: +from within the U.S., Canada and Latin America (toll free) +1-800-727-7375 +from EMEA +all locations (toll call) ++44-207-325-9082 or 9261 or 1110 +UK, Belgium, Luxemburg, Spain, Switzerland, Italy, South Africa, Germany, Ireland, +and Russia (toll free) +00800 3247 5869 (confidential freephone) +all other EMEA locations (toll free) +4 + +JPM-SDNYLIT-00274993 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 12 of 37 ++44 207 325 9082 or 9261 or 1110 (reverse charge calls accepted during normal +business hours) +from Asia Pacific +all locations (toll call) ++852 2800 1656 or 8780 +China, Hong Kong, Japan, Malaysia, South Korea, Singapore, Thailand, Taiwan, and +Australia (toll free) +800 5784 5784 (confidential international freephone) +all other Asia Pacific locations (toll free) ++852 2800 1656 or 8780 (reverse charge calls accepted during normal business +hours) +You may also contact the Fraud Prevention and Investigation Department either +by mail: +from North America +from all other locations +or by e-mail: +from North America +from Asia Pacific +from all other locations +1 Chase Manhattan Plaza, 21ª Floor, New York, NY 10081 +125 London Wall, 16" Floor, London EC2Y5AJ England +fraud.prevention.and.investigation@jpmchase.com. +FPI-ASIAPACIFIC@jpmorgan.com +FPI-EMEA@jpmorgan.com +If you have a particular concern regarding accounting, internal accounting controls, auditing matters, or +financial reporting practices that you wish to bring to the attention of the Audit Committee of the Board +of Directors, you may do so by mail sent to: JPMorgan Chase & Co., Attention: Audit Committee +Chairman, c/o Fraud Prevention and Investigation Department at one of the addresses listed above, or by +calling the Fraud Prevention and Investigation Department at any of the telephone numbers listed above. +You may report your concerns anonymously, if you wish. We will respect the confidentiality of those +who raise concerns, subject to our obligation to investigate the concern and any obligation to notify third +parties, such as regulators and other authorities. We strictly prohibit retaliation against employees for +good faith reporting of any actual or suspected violations of the Code. +You must immediately report to your Human Resources Business Partner any misdemeanor (other than a +minor traffic violation), criminal charge, or arrest involving you personally, whether it relates to the +business of the firm or not. See HR's policy on Criminal Convictions, linked below. +Employees in France are subject to other reporting provisions, which are included in either the +Compliance Manual (linked below) or the +Code of Conduct (available from Human Resources in +France). +Related Links: +Whistleblowing Policies and Procedures for the UK +Escalation Guidelines - When to Escalate an Issue and How - Asia Pacific +SEC Rule 205 Compliance Policy - Up the Ladder Reporting (for lawyers) +Criminal Convictions +Compliance Manual +5 + +JPM-SDNYLIT-00274994 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 13 of 37 +1.6. Current version of the Code +The current edition of the Code is posted on the intranet. It may be amended from time to time, and all +amendments are effective immediately upon posting. It is your responsibility to review the Code from +time to time to ensure that you are in compliance. +1.7. Affirmation +You are required to affirm, either in writing or electronically, that you have read and understood the Code +and that you will comply with it. This affirmation is required of new employees when they are hired and +of new directors when they are elected to office. In addition, periodically all employees will be required +to re-affirm their understanding of and compliance with the then-current Code. +Related Link: +Affirmation +DIVERSITY +JPMorgan Chase is committed to providing an inclusive and nondiscriminatory working environment in +which all employees are valued and empowered to succeed. The firm prohibits discrimination or +harassment on the basis of race, color, national origin, citizenship status, creed, religion, religious +affiliation, age, sex, marital status, sexual orientation, gender identity, disability, veteran status, and any +other status protected under any applicable law. Each of us is responsible for ensuring implementation of +this policy and maintaining a business environment free of harassment and intimidation. +Likewise, you may not unlawfully discriminate in your dealings with current or prospective customers +and suppliers. +The firm's Travel and Entertainment Policies preclude reimbursement from, or payment by, JPMorgan +Chase for membership in or expenses incurred at organizations with discriminatory practices. +Related Links: +Diversity +U.S. Policies: +Harassment-free Workplace +Equal Employment Opportunity and Affirmative Action +Disability and Reasonable Accommodation +Memberships and Related Expenses +EMEA Policies: +Harassment Policy +Equal Opportunities +Travel and Entertainment Policies +9 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 14 of 37 +3. CONFIDENTIAL INFORMATION +We are all responsible for the safeguarding of confidential information, whether it is information +entrusted to us by our customers, information regarding JPMorgan Chase's businesses and activities, or +information about other employees. +3.1. Information about the firm, its customers, its employees, and others +You may have access to confidential information related to the firm's business. Information related to the +firm's business includes information about the firm, as well as information related to the firm's customers, +counterparties, or advisory clients (all of which the Code refers to as customers), business partners, +suppliers, and your fellow employees. +You may not, either during your period of service or thereafter, directly or indirectly use or disclose to +anyone any such confidential information, except as permitted by the Code and other policies applicable +to you. +You should observe the following principles when dealing with information relating to the firm's +business: +(a) +(b) +(c) +(d) +(e) +(f) +(g) +(h) +Assume that most information that you have about the firm and its business, or about its +past, present, or prospective customers, suppliers, and employees, is confidential, unless +the contrary is clear. +Treat all personal information about individuals as confidential. +Before sharing confidential information with others in the firm, be sure that you are +permitted to do so. Do not disclose confidential customer information to other employees +who are not involved with the transaction or service for which the information was +provided to the firm --- even if you believe the disclosure might be useful in the context +of other firm business --- unless you are authorized to do so. +Do not disclose confidential information to anyone outside the firm unless you are +authorized to do so. Where such disclosure is authorized, a confidentiality or privacy +agreement may be required; check with the Legal Department. +If you are permitted to share confidential information, use your judgment to limit the +amount of information shared and disclose it only on a need-to-know basis in order to +provide the services we are engaged to provide. Ensure that the recipient knows the +information is confidential and has been instructed about restrictions on further use and +dissemination. +Comment or provide information on matters related to the firm's business only if it is part +of your job function or you are otherwise authorized to do so. +Protect confidential information when communicating electronically -- for instance, by e- +mail or through the internet. +Remember that all forms of communication are covered, including written, telephonic, +and electronic communications such as website chatrooms, e-mail, and instant +messaging. +7 + +JPM-SDNYLIT-00274996 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 15 of 37 +(1) +Consult your manager or your Compliance officer if you have any question about +whether information can be shared +Related Links: +Use of Confidential Information +Communication on Matters Related to the Company's Business +Information Technology Risk Management Policies +3.2. Prior employer's confidential information and trade secrets +Do not disclose to JPMorgan Chase, or use during your employment at JPMorgan Chase, any confidential +information or trade secret of a prior employer, unless the information or trade secret is then public +information through no action of your own. +3.3. Special rules regarding customer information and data privacy legislation +Each of us has a special responsibility to protect the confidentiality of information related to customers. +This responsibility may be imposed by law, may arise out of agreements with our customers, or may be +based on policies or practices adopted by the firm. Certain jurisdictions have regulations relating +specifically to the privacy of individuals and/or business and institutional customers. Various business +units and geographic areas within JPMorgan Chase have internal policies regarding customer privacy. +You should be familiar with those that apply to you. Customer information should never be disclosed to +anyone outside the firm except as permitted by law and in the proper conduct of our business, where +disclosure is required by legal process, or where the Legal and Compliance Department otherwise +determines it is appropriate. +Related Links: +Use of Confidential Information +Communication on Matters Relating to the Company's Business +3.4. Publications, speeches, and other communications relating to JPMorgan Chase's business +You should be alert to situations in which you may be perceived as representing or speaking for the firm, +especially in public communications (including internet chatrooms, bulletin boards, etc.). You should not +make any statements on behalf of JPMorgan Chase, or regarding JPMorgan Chase, its business, or its +customers, unless it is part of your job or you are otherwise specifically authorized to do so. Refer all +media inquiries to the Media Relations Office. +Public testimony (as an expert witness or otherwise), publications and speaking engagements relating to +the firm's business are subject to pre-clearance. Subpoenas, media inquiries, supplier forums, and +requests from customers or suppliers for testimonials or endorsements should be handled in accordance +with applicable procedures. Before engaging in any of these activities, consult your Compliance officer +or your Code Specialist and the relevant policies and procedures. Procedures for pre-clearance of these +activities are included in the policy on Communication on Matters Relating to the Company's Business. +Related Links: +Communication on Matters Relating to the Company's Business +Use of Confidential Information +Intellectual Property Policy +8 + +JPM-SDNYLIT-00274997 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 16 of 37 +4. +INSIDE INFORMATION AND THE CHINESE WALL POLICY +Buying or selling securities while in possession of material non-public information is prohibited, as is the +communication of that information to others. +4.1. Inside Information +If you are aware of inside information, +(a) +you may not buy or sell securities (including equity securities, bonds and other debt +sccurities, convertible securities, derivatives, options, any L +index including any such +security as an element, and any other financial instruments) that may be affected by that +information, either for your own account or any account over which you exercise control, +alone or with others. +(b) +you may not pass along any inside information expressly or by way of making a +recommendation for the purchase or sale of such securities based upon inside +information. +"Inside information" is material, nonpublic information about the securities, activities, or financial +condition of a corporation, public entity, or other issuer of securities. Material, nonpublic information +concerning market developments may also be construed to be inside information. +Information is "material" if it could have an impact on the market price of securities involved or if it is +likely that a reasonable investor would consider the information important in deciding whether to +purchase or sell the securities. Information may be material to one issuer but not to another, or to certain +securities of an issuer but not to all securities of that issuer. +Information should be considered "nonpublic" unless it is clearly public. Information is deemed public +once it has been publicly announced or otherwise disseminated in a manner that makes the information +available to investors generally. +Likewise, you may not buy or sell securities if you have knowledge of proposed customer trades, trades +by JPMorgan Chase, or forthcoming research reports regarding those securities or the issuer of those +securities, and you may not pass along this information to others in any way. +These prohibitions are applicable no matter how you acquired the inside information. They are applicable +to the securities of JPMorgan Chase as well as to those of other companies. +hese prohibitions do not apply to qualified transactions pursuant to certain planned acquisition or sellin +rograms, such as so-called 10b5-1 programs. These prohibitions also do not apply to legally permissibl +4.2. The Chinese Wall policy and other information barriers +The firm's Chinese Wall policy refers to a system of information barriers designed to limit the flow of +inside information from areas that routinely have access to such information, such as Investment Banking, + +JPM-SDNYLIT-00274998 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 17 of 37 +Capital Markets, Commercial Lending, Credit, Restructuring, and Mergers and Acquisitions (**insider +arcas"), to those areas that trade in or sell securities or provide investment advice regarding securities, +such as Sales, Trading, Research, and Asset Management ("public areas"). The Chinese Wall policy +prohibits anyone in an insider area from communicating inside information, however obtained, to anyone +in a public area, subject to limited exceptions approved by the relevant Compliance officer. +In addition, some business areas within the firm require procedures that address more specifically the +information flows within those business areas. These are also sometimes referred to as Chinese Walls. +Employees subjeet to the firm's Chinese Wall policy, or to other information barriers designed to meet +specific business needs, are responsible for compliance with the provisions of applicable policies. +Related Link: +Chinese Walls and Other Information Barriers +5. +OTHER BUSINESS CONDUCT +We are all expected to conduct the firm's business in accordance with the highest ethical standards, +respecting the firm's customers, suppliers, and other business counterparties, dealing responsibly with the +firm's assets, and complying with applicable legal and regulatory requirements. +5.1. Assets of the firm +You are expected to protect the firm's assets as well as the assets of others that come into your custody. +The firm's assets include not only financial assets such as cash and securities and physical assets such as +furnishings, equipment and supplies, but also customer relationships and intellectual property such as +information about products, services, customers, systems and people. All property created, obtained, or +compiled by or on behalf of the firm --- including customer lists, directories, files, reference materials and +reports, computer sofiware, data processing systems, computer programs, and databases --- belongs to the +The firm's assets should be used only for the conduct of the firm's business, except where limited +incidental personal use is authorized by the Code or other applicable policies. +5.2. Intellectual property +Any invention, discovery, development, concept, idea, process, or work related to the firm's business, +written or otherwise, whether or not it can be patented or copyrighted, that you develop alone or with +others during your employment with the firm (all of which are referred to as "Company Inventions") +belongs to the firm. If a Company Invention is something that can be copyrighted and you create it as a +part of your job with the firm or because the firm asks you to create it, it is a "work made for hire." The +firm is not required to acknowledge your role in the creation of any Company Inventions or to have your +permission to modify, expand, or benefit from it. +As a condition of your employment, you assign exclusively to the firm all of your right, title and interest +in Company Inventions. You further agree to assist the firm in obtaining for its own benefit intellectual +10 + +JPM-SDNYLIT-00274999 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 18 of 37 +property rights, including any patents and copyrights, in the Company Inventions and agree to deliver any +documents that may be requested to assure, record or perfect your assignment of the Company Inventions +to the firm. +Related Links: +Intellectual Property Policy +Report of Prior Inventions +5.3. Telephones, e-mail, internet, and other electronic communications devices +Telephones, electronic mail (e-mail) systems and other electronic communications devices provided by +JPMorgan Chase, whether in the workplace or elsewhere, are the property of the firm and should be used +for business purposes; however, limited incidental personal use is permitted, consistent with the Code and +all other policies of the firm. +The use of e-mail, the firm's intranet and the internet must conform to the policies of JPMorgan Chase. +E-mail and internet systems may be used to transmit or provide access to confidential information only +when such information is adequately protected and transmitting such information is necessary for +business purposes. +Among other things, the following are prohibited in electronic communications: +statements, which, if made in any other forum, would violate any of our policies, +including policies against discrimination and harassment; participation in impermissible +or illegal activities (such as gambling or the use and sale of controlled substances); and +the misuse of confidential information. +(b) +accessing, downloading, uploading, saving, or sending sexually oriented or other +offensive materials. +JPMorgan Chase considers all data and communications transmitted through, received by, or contained in +the firm's electronic or telephonic equipment and systems to be JPMorgan Chase's property. Subject to +applicable laws and regulations, JPMorgan Chase reserves the right to monitor, review, and disclose all +such data and communications as it deems appropriate. You should have no expectation of privacy when +using such resources. +Related Link: +Information Technology Risk Management Policies +5.4. +Internal controls, record-keeping, and reporting +Internal accounting controls and record-keeping policies have been established in order for JPMorgan +Chase to meet both legal and business requirements. You are expected to maintain and adhere to these +controls and policies. +The falsification of any book, record, or account relating to the business of JPMorgan Chase, its +plan), is prohibited. + +JPM-SDNYLIT-00275000 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 19 of 37 +The firm's record-keeping policies include policies for records and document retention and destruction. +Notwithstanding any other provision of document retention policies, no document or record may be +destroyed if you have been advised or otherwise should recognize that it may be relevant to a pending or +threatened legal or regulatory proceeding, except in accordance with procedures approved by the head of +the Litigation Group in the Legal Department or one of his/her direct reports. +It is of critical importance that JPMorgan Chase's filings with regulatory authorities be accurate and +timely. Information provided to those involved in preparation of the firm's disclosures to regulators and +investors should be complete, accurate, and informative. +Related Links: +Corporate Accounts Payable +Global Finance Operations +Record Retention Policy +5.5. Limits of your authority +Your authority to act on behalf of JPMorgan Chase is limited by various laws, regulations, corporate +arters, bylaws, and board resolutions, and by internal policies and procedures. You may not sign at +cuments, or otherwise represent or exercise authority, on behalf of any JPMorgan Chase entity unle +you are specifically authorized to do so. Be aware of limits on your authority and do not take any action +that exceeds those limits. +Delegation of authority, where permissible under corporate policies and otherwise appropriate, should be +reasonably limited in scope and subject to appropriate ongoing oversight. +Related Links: +Office of the Secretary Home Page +Strategic Sourcing Guidelines +5.6. Business relationships +5.6.1. Fair dealing +You should always endeavor to deal fairly and in good faith with the firm's customers, suppliers, +competitors, business partners, regulators, and employees. It is our policy not to take unfair advantage of +others through manipulation, concealment, abuse of privileged information, misrepresentation of material +facts, or any other unfair dealing practice. +5.6.2. Customer, supplier, and employee relationships +During your employment you may not, directly or indirectly: +solicit for a competitor, or divert or attempt to divert from doing business with JPMorgan +(b) +or induce any employee, consultant, independent contractor, agent, or supplier to leave +JPMorgan Chase. +12 + +JPM-SDNYLIT-00275001 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 20 of 37 +5.7. Money laundering and the USA PATRIOT Act +JPMorgan Chase has established policies, procedures and internal controls designed to assure compliance +with international laws and regulations regarding money laundering and terrorist financing, including +relevant provisions of the Bank Secrecy Act and the USA PATRIOT Act in the United States and similar +legislation in other countries. You should be familiar with, and comply with, these policies, procedures +and controls. You should also understand your obligations to: +(a) know your customers and your customers' use of the firm's products and services. +get proper training if you are identified as being in a job that poses a risk of money +laundering or terrorist financing. +(c) +be alert to and report unusual or suspicious activity to the designated persons within your +line of business or region, including your Compliance officer or Risk Manager +responsible for anti-money laundering compliance. +Related Links: +Anti-Money Laundering Compliance Program - Global +Customer Identification Program - Global +Know Your Customer Policy - Corporate +Anti-Money Laundering Training Policy - Global +5.8. Tying of products +"Tying" arrangements, under which the availability or price of one product is conditioned on the +customer's purchase of another product, are illegal under some circumstances. United States Federal laws +govern tying arrangements involving bank subsidiaries of JPMorgan Chase & Co. +Related Link: +Anti-Tying Policy +5.9. Bribery and the Foreign Corrupt Practices Act +Federal law of the United States and the laws of many other countries prohibit bribes, kickbacks, or other +similar remuneration or consideration given to any person or organization, such as a domestic or foreign +government official, political party, or candidate for political office, or to any intermediaries, such as +agents, attorneys or other consultants, in order to attract or retain business or to influence any +governmental decision or action. Offering or paying such remuneration or consideration is strictly +prohibited. +In addition, you may not accept any such payments in connection with any business decision or +transaction, even if such payments are customary in the particular country involved. +Related Links: +Travel and Entertainment Policies (U.S.) +Travel and Entertainment Policies (Latin America) +Travel and Entertainment Policies (EMEA) +Travel and Entertainment Policies (Asia) +Foreign Corrupt Practices Act +13 + +JPM-SDNYLIT-00275002 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 21 of 37 +5.10. International boycotts and economic sanctions +The U.S. antiboycott law prohibits certain actions to comply with or support an unsanctioned foreign +boycott against a country friendly to the United States. The prohibited actions include refusing to do +business in a certain country, furnishing information about a person in response to a boycott-related +request, and implementing a letter of credit that contains a condition related to any of the prohibited +The U.S. economic sanctions regulations prohibit U.S. persons, including U.S. financial institutions and +their foreign branches and non-U.S. affiliates, from exporting financial services to certain foreign +governments and their specially designated nationals named by the Office of Foreign Assets Control. +These regulations also require that assets of these governments and persons be frozen. All JPMorgan +Chase branches and subsidiaries are required to establish policies and procedures to ensure that their +customers (and potential customers) are not on the OFAC list. You should be familiar with the policies +and procedures that apply to you. +Related Link: +OFAC Sanctions Law Policy: United States +5.11. Post-employment responsibilities +As a condition of continued employment with JPMorgan Chase, employees will have certain +responsibilities after their employment with JPMorgan Chase terminates. These responsibilities include +an obligation to return all firm assets in their possession, maintain the confidentiality of information, +refrain from insider trading based on information obtained in the course of employment by JPMorgan +Chase, and, if requested, assist JPMorgan Chase with investigations, litigation, and the protection of +intellectual property relating to their employment. Senior-Level Employees have additional obligations +for one year after they leave JPMorgan Chase, including prohibitions on the solicitation and hiring of +JPMorgan Chase employees and solicitation of certain customers. You are responsible for knowing +which post-employment restrictions and requirements apply to you. +Related link: +Responsibilities of Former Employees +5.12. Other professional obligations +Some employees have additional obligations relating to their positions with the firm, including employees +who are considered to be finance professionals, certain employees acting as attorneys for the firm, and +certain officers in the Investment Bank. If you are subject to any of these additional requirements, you +should be familiar with and comply with them. +Related links: +Code of Ethics for Finance Professionals +SEC Rule 205 Compliance Policy - Up the Ladder Reporting (for lawyers) +IB Americas Notice Period Policy +IB EMEA Notice Period Policy +IB Asia Notice Period Policy +14 + +JPM-SDNYLIT-00275003 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 22 of 37 +6. OUTSIDE ACTIVITIES, GIFTS, AND OTHER POTENTIAL CONFLICTS OF +INTEREST +Employees must never permit their personal interests to conflict with or to appear to conflict with the +interests of the firm. When faced with a situation involving a potential conflict, ask yourself whether +public disclosure of the matter could embarrass JPMorgan Chase or you, or would lead an outside +observer to believe a conflict exists, whether or not one actually does. You must disclose to the Office of +the Secretary all potential conflicts of interest, including those in which you may have been placed +inadvertently due to either business or personal relationships with customers, suppliers, business +associates, or competitors of JPMorgan Chase, or with other JPMorgan Chase employees. +6.1. Personal relationships +In general, you may not act on behalf of JPMorgan Chase in any transaction or business relationship +involving yourself, members of your family, or other persons or organizations with which you or your +family have any significant personal connection or financial interest. These matters should be handled by +an authorized unrelated employee. +You may not engage in self-dealing or otherwise trade upon your position with JPMorgan Chase or accept +or solicit any personal benefit from a client or supplier not generally available to other persons or made +available to you due to your position with JPMorgan Chase (except in accordance with our policies +regarding the occasional acceptance of gifts). +Negotiating with JPMorgan Chase on behalf of others with whom you or your family have a significant +connection should be avoided if there is a risk that your involvement would be perceived as self-dealing +or trading upon your position with the firm. +Hiring or working with relatives, or someone with whom you have a romantic relationship, is subject to +specific restrictions. You should be aware of those limitations if they apply to you. +Related Link: +Employment of Relatives +6.2. Personal finances +Because of the nature of our business, any improper handling of your personal finances could undermine +our credibility and that of JPMorgan Chase. Also, a precarious personal financial position might appea +• influence actions or judgments you make on behalf of JPMorgan Chas +You may not borrow money (other than nominal amounts) from or lend money to other employees, +customers spicio, or et a places. signe or sure or in any others organizations for +regularly lend money. If you borrow from any financial institution, the loan must be obtained on nonpreferential terms. +In general, you may not participate in any other personal financial transactions with fellow employees, +customers, or suppliers. This prohibition includes shared investments (unless they are either widely held +or held pursuant to firm sponsored co-investment plans) and investment clubs +15 + +JPM-SDNYLIT-00275004 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 23 of 37 +The foregoing limitations do not apply to: +(a) +borrowing from, or acting as guarantor, co-signer, or surety for, relatives or close +personal friends. +(b) borrowing on non-preferential terms from a customer that is in the financial services +business. +(c) +making consumer credit purchases on non-preferential terms from a customer or supplier +in the normal course of that customer/supplier's business. +6.3. Outside business and not-for-profit activities; outside employment +6.3.1. General +Your outside activities must not reflect adversely on JPMorgan Chase or give rise to a real or apparent +conflict of interest with your duties to the firm. You must be alert to potential conflicts of interest and be +aware that you may be asked to discontinue any outside activity if a potential conflict arises. You may +not, directly or indirectly: +accept a business opportunity from someone doing business or seeking to do business +with JPMorgan Chase that is made available to you because of your position with the +firm. +(b) +take for yourself a business opportunity belonging to the firm. +(c) engage in a business that competes with any of the firm's businesses. +In general, employees may not work for, or serve as a director or officer of or adviser to, a competitor of +the firm. Competitors include unrelated financial services companies of any kind, and others engaged in +any business JPMC is involved in, such as asset managers, depository institutions, credit unions, lenders, +investment banks, insurers, insurance agencies, and securities brokers, dealers, and underwriters. +Employees should also not invest in a competitor (other than investments in securities of publicly traded +companies). +Outside activities must not interfere with your job performance or require such long hours as to affect +your physical or mental effectiveness. Your job at JPMorgan Chase should always be your first work +You may accept appointments as a personal fiduciary only for family members and close personal friends. +However, you may not act as a personal fiduciary for a personal friend if the friendship developed in the +context of a JPMorgan Chase customer relationship. +6.3.2. Required pre-clearance of outside activities +Pre-clearance is required for certain outside activities by employees, as described below. +1. Outside business activities +Subject to the exclusions listed below, you are required to pre-clear: +16 + +JPM-SDNYLIT-00275005 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 24 of 37 +However, you are not required to pre-clear the following activities under this Section (although +these matters may be subject to clearance or reporting requirements of your business unit or of +other sections of the Code): +(a) +certain types of appointments specifically excluded from Section 6.3.2 by the +Office of the Secretary because they are undertaken at the request of JPMorgan +Chase in the normal course of a business in which the firm is routinely engaged. +Related Link: +List of Appointments Excluded from Section 6.3.2(D(a) by the Office of the Secretary +(b) +(c) +(d) +any affiliation with a trade association, professional association, or other such +organization related to your position at JPMorgan Chase. +positions with co-op boards, condominium associations, and similar entities the +sole business of which is to hold title to and/or manage real property in which +you can or do reside. +positions with holding companies, trusts, or other non-operating entities +established solely for purposes of your or your family's estate or tax planning or +to hold your or your family's real estate or other investments that would not +otherwise require pre-clearance under this Section 6.3.2. +Publications and outside speaking engagements relating or referring to the business of JPMorgan +Chase, if pre-cleared under Section 3.4 of the Code, do not require pre-clearance under this +Section. +2. Not-for-profit activities +Not-for-profit activities generally do not require pre-clearance. However, employees are required +to pre-clear any board or official position with a not-for-profit entity if +the not-for-profit entity is a customer of the firm, other than for routine banking +services (unless you are involved in providing those services). +(b) you have been requested to serve in that capacity by a customer or supplier of +your business unit. +(c) +your service would otherwise present a conflict of interest or the appearance of a +conflict of interest. +As noted above, positions with trade associations, professional associations, or other such +organizations related to your position at JPMorgan Chase need not be pre-cleared +3. Governmental activities +You are required to pre-clear any government position, including as an elected official and as a +nember, director, officer, or employee of a governmental agency, authority, advisory board, o +ther board (a public school or library board, for example). You must obtain pre-clearance befor +becoming a candidate for elective office. +Procedures and forms for pre-clearance of these activities are available in the JPMorgan Chase +Procedures and Forms for Pre-Clearance of Outside Activities. You must seek a new clearance for a +previously approved activity whenever there is any material change in relevant circumstances, whether +arising from a change in your job with JPMorgan Chase or in your role with respect to that activity or +17 + +JPM-SDNYLIT-00275006 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 25 of 37 +organization. You must also notify the Office of the Secretary when any approved outside activity +terminates. +Note also that publications and speaking engagements relating to the business of JPMorgan Chase must +be pre-cleared under Section 3.4 of the Code. +Related Links: +Procedures and Forms for Pre-Clearance of Outside Activities +Use of Confidential Information +Communication on Matters Related to the Company's Business +6.4. Political Activities +6.4.1. Political campaign activities and contributions by employees +Volunteering for a political campaign. If you wish to volunteer for a political campaign, you must do so +on your own time and as an individual, not as a representative of the firm or any of its affiliates. You may +not use any JPMorgan Chase staff, facilities, equipment, supplies, or mailing lists. +When acting as a fundraiser for a candidate or political event, be certain that your activities cannot be +viewed as connected with your position with JPMorgan Chase, especially when communicating with +colleagues, customers, or suppliers. Contact the Government Relations Department for further guidance +on such activity. +(Note that running for public office is covered by Section 6.3.2.) +Political contributions. You have the right to participate in the political process by making personal +contributions from personal funds, subject to applicable legal limits. However, you cannot be reimbursed +or otherwise compensated by JPMorgan Chase for any such contribution. +Certain lines of business (for example, Municipal Finance and Asset Management) may have additional +policies regarding employees' personal contributions; you are responsible for being aware of, and +complying with, any rules applicable to your business unit. +Additionally, you must contact the Government Relations Department or your local Compliance Officer +with respect to a personal political contribution that could violate, or create the appearance of a violation +of, the Foreign Corrupt Practices Act or local law. (See Section 5.9 for a discussion of the Foreign +Corrupt Practices Act.) Employees need to be especially sensitive when giving to officials who are part +of the decision-making process with respect to any matters relating to the firm. +Related Links: +Municipal Securities Compliance Manual +Foreign Corrupt Practices Act +Solicitation (U.S.) +18 + +JPM-SDNYLIT-00275007 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 26 of 37 +6.4.2. Political contributions and related activities by JPMorgan Chase +Political contributions and gifts. In the U.S., political contributions by corporate entities are strictly +regulated by laws at the federal, state and local levels. These laws often prohibit or limit direct monetary +contributions made from corporate funds (such as a contribution check or purchase of fundraising event +tickets) as well as in-kind contributions (such as the use of corporate facilities or staff, and even the +granting of loans or other products at preferential rates). Local law in jurisdictions outside the U.S. can +also impose restrictions. Therefore, both within and outside the U.S., +(a) +all requests for firm support (either through monetary or in-kind contributions) of +political events, political candidates and their campaigns, political parties, or political +committees must be pre-approved and processed by the Government Relations +Department. +(b) +political contributions proposed to be made by or on behalf of the firm must be precleared by the Government Relations Department. +(c) +all gifts to governmental officials to be made by or on behalf of the firm (including items +of value, transportation, lodging, meals, entertainment, and services), must be pre-cleared +Lobbying by or on behalf of JPMorgan Chase. All lobbying activities, including the retention of outside +lobbyists, must be pre-cleared through the Government Relations Department. Note that the federal +government and each state has its own definitions and regulations regarding lobbying of governmental +employees, and what might seem like a simple meeting could trigger a reporting requirement; if in doubt, +contact Government Relations. +Related Links: +Municipal Securities Compliance Manual +Foreign Corrupt Practices Act +Retaining Lobbyists +Accepting gifts, meals, and entertainment from customers, suppliers, and others doing +business with JPMorgan Chase +A gift may take many forms. For the purposes of the Code, the term "gift" includes anything of value for +which you are not required to pay the retail or usual and customary cost. A gift may include meals or +refreshments, goods, services, tickets to entertainment or sporting events, or the use of a residence, +vacation home, or other accommodations. +Gifts given by others to members of your family, to those with whom you have a close personal +relationship, and to charities designated by you, are considered to be gifts to you for purposes of the +Code. +You may never, except as provided in the Code: +solicit, for yourself or for anyone else (other than the firm), or accept anything of value +from anyone doing business with the firm. +solicit, for yourself or for anyone else (other than the firm), or accept anything of value +from anyone in return for any business, service, or confidential information of the firm. +19 + +JPM-SDNYLIT-00275008 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 27 of 37 +(c) +solicit, for yourself or for anyone else, or accept anything of value, directly or indirectly +(other than bona fide salary, wages, awards, and fees paid by or to the firm), from anyone +in connection with the business of the firm, either before or after a transaction is +discussed or consummated. +Note that the restrictions in this section 6.5 are not intended to apply to gifts based on obvious family +relationships (such as your parents, children, or spouse) or close personal friendships, where the +circumstances make it clear that it is the relationship rather than the firm's business that is the motivating +factor. +You are responsible for being familiar with any additional restrictions that may be applicable to your +business unit. +Related Links: +Federal Bank Bribery Act +Chase Home Finance Employee Conduct Standards +Private Client Services Line of Business Gift Policy Modification +6.5.1. What you may accept +Acceptance of gifts of any kind (including entertainment and hospitality) from persons that do business or +seek to do business with JPMorgan Chase (including identified prospective customers) is generally +prohibited. However, subject to the prohibitions in Section 6.5.2 and to any more restrictive policies +your business unit may have, the following gifts may be accepted on infrequent occasions from such a +person if it is clear that the person is not trying to influence or reward you inappropriately in +connection with any business decision or transaction and the gift is unsolicited: +(a) +(b) +(c) +(d) +(c) +(f) +gifts having a retail value not exceeding U.S. $100 (or such lesser amount as is +established by your local Compliance unit) that are given on an occasion when gifts are +customary (on a birthday or major holiday, or on the occasion of a promotion or +retirement, for example; note that gifts given in appreciation for good service, or as +thanks for our business, are not permitted). +advertising or promotional material having a retail value not exceeding U.S. $100 (or +such lesser amount as is established by your local Compliance unit), such as pens, +pencils, note pads, key chains, calendars, and similar items. +discounts and rebates on merchandise or services that are offered to the general public, or +to all employees under a plan negotiated by JPMorgan Chase. +customary mementos at closing dinners, permitted golf outings, and similar funetions. +civic, charitable, educational, or religious organization awards for recognition of service +and accomplishment having a retail value not exceeding U.S. $100 (or such lesser +amount as is established by your local Compliance unit). +meals, refreshments, and entertainment in the course of a meeting or other occasion +provided: +(i) +the purpose is business-related, +(il) +your host is present, +(iii) +your attendance is related to your duties with JPMorgan Chase, +(iv) +the level of expense is reasonable and customary in the context of your business +and the relationship with the host, and +20 + +JPM-SDNYLIT-00275009 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 28 of 37 +(g) +the frequency of such invitations from one host is not excessive. +If you have questions about whether a specific invitation may be accepted under this item +-- whether, for example, it is business-related, or reasonable and customary in the +context of your business with the host --- discuss it with your manager, your Code +Specialist, or your Compliance officer. +gifts of food or beverage items that are not easily returned, if they are: +given on an occasion when gifts are customary (on a birthday or major holiday, +or on the occasion of a promotion or retirement, for example; note that gifts +given in appreciation for good service, or as thanks for our business, are not +not extravagant, and +(iii) shared among members of your business unit. +If you have questions about whether a gift of food or beverage items is extravagant, +discuss it with your manager, your Code Specialist, or your Compliance officer. +Where this Section refers to "a retail value not exceeding U.S. $100," the relevant Compliance unit will +determine the approximate equivalent in local currency for use in jurisdictions outside the U.S. +Whenever you receive a gift, or an offer of a gift, that is not specifically permitted by this Section 6.5.1, +make every effort to refuse or return it. If that isn't possible, notify your Compliance officer or your +Code Specialist to discuss how to deal with the gift. +6.5.2. What you may not accept +Except as approved pursuant to Section 6.5.3, you may not accept the following from any current or +identified prospective customer, supplier, or other party doing business with JPMorgan Chase: +(a) +gifts of cash or cash equivalents (such as gift certificates, gift checks, or securities), in +(b) +(c) +(d) +(e) +any amount. +discounts not available to the general public or to all employees under a plan negotiated +by JPMorgan Chase. +gifts to be delivered in installments. +bequests or legacies. +invitations to parties, sports outings, and similar events solely for groups of more than ten +JPMorgan Chase employees sponsored by parties that do business with JPMorgan Chase, +(1) +member, with a copy to your Code Specialist. +travel or accommodation expenses, unless they have been approved in writing by a +member of the Executive Committee or an officer who reports directly to an Executive + +JPM-SDNYLIT-00275010 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 29 of 37 +(g) +tickets for professional sports, concerts or other events for your personal use, other than +as permitted under Section 6.5.1. +Related link: +samples of "no thank you" notes +6.5.3. Approval of nonconforming gifts +An Executive Committee member, your Compliance officer, and the Office of the Secretary together may +approve, on a case-by-case basis, the acceptance of a gift that is not specifically permitted under Section +6.5.1, or that is prohibited under Section 6.5.2. Any such approval must be in writing and pursuant to full +written disclosure of all relevant facts, including the name of the donor, the circumstances surrounding +the offer and acceptance, the nature and approximate value of the gift, and the reason why it cannot or +should not be returned. (Use the Nonconforming Gift Approval and Report Form filed under Section +6.5.4, signed by each of the Executive Committee member, your Compliance officer, and the Office of +the Secretary, for this purpose.) +6.5.4. Required reporting of gifts +You are required to file a Nonconforming Gift Approval and Report Form with respect to: +(a) +any gift that is not permitted under Section 6.5.1 or that is listed in Section 6.5.2, if the +gift has not been refused or returned (even if acceptance has been approved in accordance +with Section 6.5.3). (Note that you must refuse or return any such gift unless it has been +specifically approved in writing as specified in Section 6.5.3; the Nonconforming Gift +Approval and Report Form should be used to evidence that approval.) +(b) +the offer or receipt of any gift that is so lavish it could give rise to an inference of +impropriety, whether or not you refuse or return it. +(c) +the offer or receipt of frequent gifts from one source, whether or not you refuse or return +The Nonconforming Gift Approval and Report form, indicating the disposition of the gift, must be signed +by an Executive Committee member, your Compliance officer, and the Office of the Secretary. The +Office of the Secretary will maintain a record of all reported gifts. +Related link: +Nonconforming Gift Approval and Report Form +6.6. +Providing gifts, meals or entertainment +Local laws or industry-specific regulations often limit or prohibit the giving of gifts by JPMorgan Chase +to an employee of a current or prospective customer or supplier. For example, broker-dealers and asset +managers are generally subject to regulatory restrictions on providing gifts. +The giving of gifts to governmental officials is in most cases strictly limited by law or regulation. In this +instance, gifts include not only an actual item of value, but also the value of transportation, lodging, +meals, entertainment, services, or invitation to an event (even if it is for a non-profit entity to which you +extend an invitation to a governmental official). However, depending on the jurisdiction, there may be +exceptions. All gifts to governmental officials must be pre-cleared by the Government Relations +Department. +22 + +JPM-SDNYLIT-00275011 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 30 of 37 +Business-related gifts not prohibited by law should be reasonable and customary in the context of the +relationship with the recipient of the gift, appropriate for the occasion, and in conformity with the Code, +JPMorgan Chase's Travel & Entertainment Policies & Procedures, and all other applicable policies. +See also Section 5.9 regarding bribery and the Foreign Corrupt Practices Act and Section 6.4.2 regarding +pre-clearance of gifts to governmental officials. +Related Links: +Travel and Entertainment Policies (U,S.) +Travel and Entertainment Policies (Latin America) +Travel and Entertainment Policies (EMEA) +Travel and Entertainment Policies (Asia) +Memberships and Related Expenses ("gentlemen's" clubs, etc.) +6.7. Charitable solicitations at work; charitable contributions +While the firm encourages its employees to become involved with charitable organizations, there are +restrictions on solicitation of customers, suppliers, and fellow employees for contributions. You shoulo +become familiar with the relevant policies before engaging in any such activities +including consideration of whether the firm has already made a contribution to the organization. +Related Link: +Solicitation (U.S.) +PERSONAL SECURITIES AND OTHER FINANCIAL TRANSACTIONS +Your personal investment activities should always be conducted with the Company's reputation in mind +and in compliance with all applicable laws and regulations. +7.1. General investment principles +Employees are expected to devote their workdays to serving the interests of our clients and JPMorgan +Chase. Accordingly your personal securities and other financial transactions must be oriented towards a +philosophy of investment as distinguished from short-term or speculative trading. +In addition to complying with all other Code provisions and relevant policies and procedures, you should +obser inancial insinmens. i referees in seles ins shing ou perso to incide ain financies and +instruments, such as equity securities, bonds and other debt securities, convertible securities, derivatives, +options, and any +index.) +(a) +While in possession of inside information about the issuer of any securities or th +securities themselves, never buy, sell, or recommend the purchase or sale of sucl +securities for your account or the accounts of others, regardless of whether the inside +23 + +JPM-SDNYLIT-00275012 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 31 of 37 +information is gained through the scope of your employment or elsewhere. If in doubt, +don't trade. +(b) +Do not buy or sell securities with knowledge of proposed client trades, trades by +JPMorgan Chase or forthcoming research reports. +(c) +(d) +Your trading and investment activities must be within your financial means. +Do not ask for or accept any preferential terms or conditions in connection with any +personal trading or investments, unless the terms are available to all persons having +comparable portfolios and creditworthiness, or to all employees under a plan negotiated +by JPMorgan Chase. +(c) +Limit the risks in your personal account trading. Do not engage in excessive trading +activities that represent a high degree of financial risk. +(f) +Trading and investment activities should be for investment purposes and not for shortterm trading profits. +(g) Do not engage in speculative trading, such as trading based on rumors. +7.2. +Persons and accounts subject to policies +All personal investment policies that apply to you also apply to transactions for the account of your +spouse, your domestic partner, your minor children, and any other person to whom you provide +significant financial support, as well as to transactions in any other account over which you or any of +these persons exercise investment discretion, regardless of beneficial interest. These are referred to as +"employee-associated accounts". +7.3. Trading in JPMorgan Chase securities +7.3.1. Policies applicable to all employees +Purchases and sales of JPMorgan Chase & Co.'s common +or other securities are subject to the +general policies related to personal trading. These policies are applicable to the following transactions (as +they are to your other investment activities): +(a) +direct purchases and sales of JPMorgan Chase securities. +(b) +clections involving the JPMorgan Chase & Co. common +fund in your 401(k) plan, +deferred compensation plan, or Employee | +Purchase Plan, including decisions to +increase or decrease contributions or elections that result in increasing or decreasing +amounts credited to any common +_ account under an employee benefit plan. +(c) +sales of JPMorgan Chase securities to meet a margin call, with or without your personal +involvement. +(d) +(e) +lacing, canceling, or amending limit orders with respect to JPMorgan Chase securitie +intering into, canceling, or amending sales plans, sometimes referred to as 10b-5(1 +plans, with respect to JPMorgan Chase securities. +However, these policies do not affect automatic purchases of JPMorgan Chase +in accordance with +previously made benefits clections and acquisitions of JPMorgan Chase +through dividend +reinvestment. +Purchases and sales of JPMorgan Chase & Co.'s common | +or other securities are also subject to any +more restrictive personal trading policies applicable to your business unit. +24 + +JPM-SDNYLIT-00275013 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 32 of 37 +In addition, the following restrictions apply to transactions in JPMorgan Chase securities: +(a) You may not engage in short selling of JPMorgan Chase, except for short sales against a +long position already held by you (sometimes referred to as a short sale against the box). +(b) You may not engage in derivative transactions related to JPMorgan Chase securities +except as part of JPMorgan Chase's compensation and benefits programs, or when used +for bona fide hedging purposes against a long position already held by you, or as +otherwise approved by the Office of the Secretary. +(c) +No transactions in JPMorgan Chase securities, including derivative transactions, may be +made in fully managed accounts (accounts over which you have no trading discretion), +except dispositions of shares permissibly transferred to the account. Any transfer of +securities into a managed account is subject to any restrictions applicable to a sale of such +securities. +(d) +Subject to any other JPMorgan Chase policies on personal securities trading applicable to +you, you may enter, cancel, or amend limit orders for the purchase or sale of JPMorgan +Chase securities. +(e) +Your transactions in JPMorgan Chase securities may be halted at any time the Company +finds it necessary or advisable to halt trading by all employees or certain groups of +employees. +7.3.2. Employees subject to the "window" and "Senior-level employees" +Certain employees are restricted from engaging in transactions in JPMorgan Chase securities except +during quarterly window periods and are subject to certain other requirements with respect to transactions +n JPMorgan Chase securities. This policy affects only those persons who are specifically notified by +heir management or by the Office of the Secretary that thev are subiect to it +Senior-level employees (whether subject to the window restrictions or not) must discuss planned +transactions in JPMorgan Chase securities with a manager in advance. This requirement applies only to +those persons who are listed as "Senior-level employees" by Human Resources, whether by title such as +SVP/MD, or otherwise. +Related Links: +Transactions in JPMorgan Chase Securities: Policy Regarding +"Window" Restrictions and Trading by Senior-Level Employees +Global Personal Trading Policy and Procedure +U.S. Personal Trading Supplemental Policy and Procedure +7.4. Trading in securities of clients and suppliers +As a general rule, you should not invest in any securities of a client with which you have or recently had +significant dealings or responsibility on behalf of JPMorgan Chase if such investment could be perceived +as based on confidential information. You may be subject to broader restrictions imposed by your +business unit. +If organ hase you may nut invest ite securities dr negosaing a contract material to a supplier of +25 + +JPM-SDNYLIT-00275014 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 33 of 37 +If you own the securities of a company with which we are dealing and you are asked to represent +JPMorgan Chase in such dealings you must: +(a) +disclose this fact to your department head and your Compliance unit; and +(b) obtain prior approval from your Compliance unit before selling such securities. +7.5. Additional policies for certain groups of employees +Any area of JPMorgan Chase may impose more restrictive policies on its employees, and you should +consult your Compliance officer or your Code Specialist on whether any such policies apply to you. +Employees of the following areas are subject to the Global Personal Trading Policy and Procedure as well +as any applicable supplemental policies: +• +Investment Bank +Asset and Wealth Management +Commercial Banking +Private Equity +Audit +Office of the General Counsel +Executive Management and the Executive Committee +Risk Management +Global Technology Infrastructure, IT Risk Management, and Resiliency Risk +Management groups of Central Technology +: +Media Relations +any other business group specifically notified as being subject to the policy and/or a +supplemental policy +These policies establish trading limitations and include requirements for pre-clearance of personal +securities transactions and, in some jurisdictions (including the U.S.), the use of designated brokers. +Global Personal Trading Policy and Procedure +U.S. Personal Trading Supplemental Policy and Procedure +Asia Pacific Personal Trading Supplemental Policy and Procedure +EMEA Personal Trading Supplemental Policy and Procedure +Transactions in JPMorgan Chase Securities: Policy Regarding +"Window" Restrictions and Trading by Senior-Level Employees +Additional Personal Trading Supplemental Policies +26 + +JPM-SDNYLIT-00275015 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 34 of 37 +Definitions and Examples +Assets of the Firm: Examples of assets of the firm are: +• furnishings, equipment, supplies and services, such as telephone, the firm's intranet, internet, +and Bloomberg access +• JPMorgan Chase inventions +• any property created, obtained, or compiled by or on behalf of JPMorgan Chase, including +customer lists, directories, files, reference materials and reports, computer sofiware, data +processing systems, computer programs and databases +• trade secrets +• security and other business practices or processes, policies, procedures, and know-how +• cost, pricing, or financial information +• employee compensation, health, or personnel records +• business or marketing plans +• rescarch +• business relationships +• products and services +• any other information that the firm considers to be proprietary or confidential information +Chinese Wall: The term "Chinese Wall" usually refers to the policies that create a system of information +barriers designed to limit the flow of inside information from areas that routinely have access to such +information to those areas that trade in or sell securities or provide investment advice regarding securities. +Certain business areas within JPMorgan Chase require procedures that address more specifically the +information flows within such business areas. These are sometimes also referred to as Chinese Walls. +Code of Conduct: The Code of Conduct, also referred to as the Code, includes all other policies referred +to in the Code, and any supplemental policies and procedures that may be applicable to you. +Code Specialist: Each line of business and support group has been assigned at least one "Code +Specialist," generally a Compliance officer, to act as a resource for all employees in the area on Coderelated issues. Contact information for these officers is included in the Code Contacts List, and employees +can contact their Code Specialist for assistance with any questions regarding the Code. +Confidential information: Examples of confidential information: +• trade secrets, security and other business practices or processes, policies, procedures, or +know-how +• internal and external audit reports +• nonpublic portions of bank examination reports and other reports or information filed with +regulators +• sofiware, data processing programs, databases +• customer or supplier lists, telephone or other contact lists, and other information about +customers +• customer presentations +• information about employees of customers or suppliers +• cost, pricing, or financial information +• employee directories, lists, telephone numbers, or other information about employees +• employee compensation, health, or personnel records +i + +JPM-SDNYLIT-00275016 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 35 of 37 +• business or marketing plans and research +• information posted on the firm's internal websites +Examples of other confidential information about customers: +• the same kind of information that the firm considers confidential about itself +• information obtained from requests or applications for our products or services or as a result +of "know your customer" due diligence, such as a personal identification number (for +example, depending on the location, a passport, social security, or national health number), +birth date or financial information disclosed in a loan application +one tina eat mains rain me an ecom blames, more loans, or +other lending, capital markets, or trading transactions +• information obtained from consumer reporting agencies (credit bureaus), such as a person's +credit history +• information provided in connection with an advisory assignment, such as financial +projections +• any assessment by the firm of a customer's creditworthiness +• the fact that a person is a customer +• information collected through an information collection device from a web server (such as a +cookie or a beacon) +Supplier or other third party information that you should assume to be contidential +• the same kind of information that the firm considers confidential about itself +• information received from others such as financial reports or projections and informatior +about its business plans, customers, suppliers, or creditors +Firm: JPMorgan Chase & Co. and its direct and indirect subsidiaries. +Gift: Anything of value for which you are not required to pay the retail or usual and customary cost. A +gift may include meals or refreshments, goods, services, tickets to entertainment or sporting events, or the +use of a residence, vacation home, or other accommodations. +Inside information: Confidential information that is material, nonpublic information about the securities, +activities, or financial condition of a corporation, public entity, or other issuer of securities or financial +instruments. Material, nonpublic information concerning market developments may also be construed to +be inside information. +JPMorgan Chase: JPMorgan Chase & Co. and its direct and indirect subsidiaries. +• mergers, acquisitions, tender offers and restructurings +• substantial nonperforming loans or impending bankruptcy +• securities offerings and repurchases +• a change in earnings and dividends (or estimates of same) +• significant new business products, discoveries, and services, or the loss of any of these +• a change in an issuer's credit rating by a rating agency + +JPM-SDNYLIT-00275017 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 36 of 37 +• significant shifts in operating or financial circumstances, such as cash-flow reductions, major +write-offs, changes in accounting methods and strikes at major plants +• voluntary calls of debt or preferred +• significant litigation or litigation developments +• governmental developments that could affect securities markets +• changes in control or management +• developments regarding customers or suppliers (e.g. loss or acquisition of a contract) +Need-to-know: Persons with a "need-to-know" information require access to that information in order to +example, lawyers, accountants and other experts, Compliance officers, credit personnel, and senior +facts and circumstances; if in doubt, consult the Legal and Compliance Department. Justification of +communicating confidential information does not exist simply because the information is helpful to +another department in activities that are unrelated to the service or transaction for which the information +was obtained. In some circumstances, legal counsel may determine that limited disclosure is required by +law (in response to a subpoena, for example) or is otherwise appropriate. These decisions should be made +only by the Legal and Compliance Department. +Nonpublic/Public information: Information should be considered nonpublic unless it is clearly public. +Information is deemed public once it has been publicly announced or otherwise disseminated in a manner +that makes the information available to investors generally. For example, limited disclosure over a +private wire service for institutional investors is not considered full disclosure to the public. Information +disclosed in a press release distributed through a widely circulated news or wire service would generally +be considered public. +Personal fiduciary: A person who has undertaken to act primarily for another's benefit, such as a trustee, +executor, attorney-in-fact, or guardian, outside the scope of your normal job responsibilities at JPMorgan +Routine banking services: In general, branch banking services (checking or savings accounts, etc.) +would be considered routine banking services. Whether any other service is "routine" will be a casespecific determination, based on factors such as the size of the transaction, the extent of the relationship +with the customer, and whether the service(s) provided are subject to variable pricing for different +customers. If in doubt about whether a customer relationship with a not-for-profit organization triggers +the pre-clearance requirements of Section 6.3.2(2)(a), discuss the situation with your Code Specialist. +Senior-Level Emplovee: A Senior-Level Employee is any employee whose (a) annual base salary rate is +US$150,000 (or the local currency equivalent) or higher, OR (b) annual total cash compensation is +US$250,000 (or the local currency equivalent) or higher. "Annual total cash compensation" means the +employec's annual base salary rate plus job/shift differentials as of the last preceding August 1, plus cash +carnings under any incentive plans or programs (e.g., annual bonus, commissions, draws, overrides, and +special recognition payments or incentives) that are paid to or deferred by the employee during the 12- +month period ending the last preceding July 31. It does not include overtime pay. (For US employees, +annual total cash compensation is the same as benefits pay for medical purposes, as shown in the +employee's last annual benefits enrollment materials.) + +JPM-SDNYLIT-00275018 + + +Case 1:22-cv-10904-JSR Document 326-50 Filed 09/08/23 Page 37 of 37 \ No newline at end of file diff --git a/vision-fixhub/court-05/6ebbdec4a4aa51da6055f82322d9c9a626149652bbd673cee33b12ba721abc2d.receipt.json b/vision-fixhub/court-05/6ebbdec4a4aa51da6055f82322d9c9a626149652bbd673cee33b12ba721abc2d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3a66ef10dba92374a71aedcc1c12e9534e1f093f --- /dev/null +++ b/vision-fixhub/court-05/6ebbdec4a4aa51da6055f82322d9c9a626149652bbd673cee33b12ba721abc2d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -857, + "dataset": "marble-joined", + "doc_id": "6ebbdec4a4aa51da6055f82322d9c9a626149652bbd673cee33b12ba721abc2d", + "engine": "marble-apple-vision", + "event_count": 74, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "5d5915e6d3b993c8ff1ae26ad66bda35e17144b24d6471e1d7e6adab267c6b54", + "output_sha256": "3cba0c9d5eacac335ed21557c065393cae2bedb7e3f91bf4b214fbbda160c72c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6ec6c7172391ac9a2ac06a54686ca5eb7683dcfe87d432f864af333937f10742.md b/vision-fixhub/court-05/6ec6c7172391ac9a2ac06a54686ca5eb7683dcfe87d432f864af333937f10742.md new file mode 100644 index 0000000000000000000000000000000000000000..bc27c10035ebf9694224ec32b0c49f1c0c05fd82 --- /dev/null +++ b/vision-fixhub/court-05/6ec6c7172391ac9a2ac06a54686ca5eb7683dcfe87d432f864af333937f10742.md @@ -0,0 +1,886 @@ +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 1 of 24 + + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 2 of 24 +TABLE OF CONTENTS +CORPORATE RECORDS +Page 2 +PUBLICATIONS +Pages 3-17 +REGULATORY SANCTIONS +OFAC/CONTROL LIST SEARCH +Page 18 +Pages 19-23 +EXHIBIT_ +17 +WIT: Cray +DATE: 4-7-2 +C. +_ ADR CRR CSR #13921 +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +1 + +JPM-SDNYLIT-00037183 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 3 of 24 +CORPORATE RECORDS +File Number: +Entity Name: +Entity Details +THIS IS NOT A STATEMENT OF GOOD STANDING +IncorporatIon Date 07/14/2004 +/ Formation Date: (mm/dd/yyyy) +Residency: + +THS, LIC +LIMITED +LIABILITY +COMPANY +(LIC) +DOMESTIC +Entity Type: GENERAL +State: +DE +REGISTERED AGENT INFORMATION +Name: +Address: +City: +State: +Phone: +THE CORPORATION TRUST COMPANY +CORPORATION TRUST CENTER 1209 ORANGE STREET +WILMINGTON +County: NEW CASTLE +DE +T Postal Code: 19801 +(302) 658-7581 +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +2 + +JPM-SDNYLIT-00037184 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 4 of 24 +PUBLICATIONS +pyright 2006 Globe Newspaper Compar +the Boston Glot +• +SeptemberRo +15, 2006 Friday +EDITION +SECTION: LIVING; Pg. D2 +LENGTH: 747 words +HEADLINE: HARVARD TO KEEP EPSTEIN GIFT +BYLINE: CAROL BEGGY & MARK SHANAHAN +BODY: +Harvard has decided it'll hold onto the fat check it received from Jeffrey +billionaire financier who was +over the summer with soliciting sex from prostitutes. While +some others, notably New York gubernatorial candidate Eliot Spitzer and New Mexico Governor B111 +• have returned his gifts, +the World's Greatest University has concluded that returning +Epatein's $6.5 million donation would do more harm than good. +"Mr. Epstein's gift 1s funding +important research using mathematies to study areas such as evolutionary theory, viruses, +cancers," a Harvard spokesman told us yesterday. +"Harvard has no plans to return the gift." (Epstein +has pledged up to $30 million to support the +research being done by Harvard mathematical biologist +Nowak .) Epstein was charged with solicitation in July after several teenage girls told the +they'd given the silver-haired money manager massages in exchange for cash. +Epstein, who's being defended by Harvard law professor Alan Dershowitz, has pled not guilty. In +1979, Harvard prez Derek Bok explained his rationale for accepting controversial gifts this way: "I +would be inclined to accept such donations on the ground that the tangible benefits of using the +should overcome the more abstract, symbolic considerations that might lead us to turn +down such benefactions." +KYRA'S GAME FOR ROLE OPPOSITE ROCK +It'll be Kyra Sedgwick not Bebe Neuwirth playing opposite Dwayne "The Rock" +finally begins shooting "The Game Plan" later this month. +"The Rock" plays a fictitious NFL +quarterback in the big-budget football flick, +and Sedgwick is his hard-nosed agent. +supposed to shoot in Boston over the summer, +but had to be postponed when "The Rock" ruptured his +Achilles tendon preparing for the role.) Neuwirth, who is returning to Broadway in the musical +"Chicago, " dropped out because of scheduling conflicts, according to published reports. Previously +Local author +misses shortlist +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. + +JPM-SDNYLIT-00037185 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 5 of 24 +(3) Denis Leary is sure in demand. The star and executive producer of "Rescue Me" has Just inked +a comedy with Don Reo, one of the creators of ABC's "My Wife and +Kids. " The untitled project will be about a thieving 15-year-old boy who moves in with his +grandfather, who's also a thief. Speaking of Leary, the Emerson grad returned to his alma mater with +his band, the Popes, last night to celebrate the school's 30-year comedy tradition. ( Jay Leno, +Henry +•. Joely Fisher , Andrea y +•, and David Cross all spent time at +Етегвол. 1 +(2) Kevin and Joyce Lucey of Belchertown caught up with writer-director Patricia Foulkrod at a +screening of Foulkrod's documentary "The Ground Truth" at the Boston Film Festival. The Luceya, +whose Marine reservist son Jeffrey committed suicide after serving in Iraq, are active in the +organization Military Families Speak Out. +(1) Boston Lyric Opera stars past and present will perform tonight as part of the company's 30th +Names can be reached at namesfglobe.com or at 617-929-8253. +NOTES: WEEKEND ; NAMES David Mehegan of the Globe staff contributed. +GRAPHIC: PHOTO +LOAD-DATE: September 16, 2006 +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +4 + +JPM-SDNYLIT-00037186 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 6 of 24 +Copyright 2006 The New York Times +Company +The New York Times +Septenber +3, 2006 Sunday +Late Edition - Final +SECTION: Section 1; Column 1; National Desk; Pg. 19 +LENGTH: 1227 words +HEADLINE: Questions of Preferential Treatment Are Raised in Florida Sex Case +BYLINE: By ABBY GOODNOUGH +DATELINE: PALM BEACH, Fla. +BODY: +In the summer and autumn of last year, when most of the mansions here stood empty behind their +towering hedges, the police stealthily watched one at the end of a waterside lane. They monitored +the comings and goings of its owner's private jet, subpoenaed his phone records and riffled +through his trash. +billionaire clients. Months earliet, +ma oe er ent erred easter, se stepmother of a ivate edge a told ane Pain tease police +that a wealthy older man, whom the girl later identified as Mr. Epstein, might have had +inappropriate sexual contact with her. +a ranged for tate to Vito the Space 2 1e and and changes it into a a 1n +exchange for cash. +them snacks or rented them cars. +Mr. Epstein's prominence won him preferential treatment. +y the account of the police, they found probable cause to charge Mr. Epstein with much mo: +rious offenses: one count of lewd and lascivious molestation and four counts of unlawful sexu +activity with a minor. +Even before the indictment, the Palm Beach police chief, Michael Reiter, had accused +prosecutors of giving Mr. Epstein special treatment and asked the state attorney, Barry E. Krischer, +to remove himself from the case. +In an editorial, The Palm Beach Post attacked Mr. Krischer, a Democrat whose post 1s elective +ying the public had been left 'to wonder whether the system tilted in favor of a wealthy, well +connected alleged perpetrator and againat very young girls who are alleged victims of sex crimes.'' +The case has taken a toll on the reputation of Mr. Epstein, who owns a palatial home in +lanhattan, has pledged $30 million to Harvard and once flew former President Bill Clinton on his +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +5 + +JPM-SDNYLIT-00037187 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 7 of 24 +727. Politicians including Eliot Spitzer, a Democratic candidate for governor in New York, and Gov. +Bill +of New Mexico, also a Democrat, have returned campaign contributions from him. +But Mr. Epstein fought back, +assembling a team of star lawyers, including Gerald B. Lefcourt +and Alan M. Dershowitz, a friend of his, to look into the backgrounds of his young accusera. +Mr. Lefcourt says that the police acted ' outrageously' and that his client has been +wrongfully dragged through the mud. +•He disputes that he ever had sex with any under-age person or anything like that, " said Mr. +Lefcourt, whose clients have included | +• Crowe, Martha Stewart and Abbie Hoffman. +Neither the police nor the state attorney's office would discuss the case in detail. But the +Dale e released a thick report on the 13-month investigation after the indictment was unsealed in +The police started investigating Mr. Epstein in March 2005, almost immediately after they were +contacted by the stepmother of the 14-year-old, who, according to the report, was in a special +school for students with disciplinary problems. +The girl, the report said, told the police that an older friend had ''offered her an +opportunity to make money' and had driven her to Mr. Epstein's house one Sunday. The friend, +identified by the police as +a local community college student, told the girl to say +she was 18 if Mr. Epstein asked, the report said. +The girl told the police +that Mr. Epstein's assistant had led her upstairs to a room with a +massage table and that Mr. Epstein had come in and told her to remove her clothes. +She said Mr. +Epstein had masturbated as she massaged him, had pressed a vibrator against her underwear and had +given her $300 afterward. +In October, the police interviewed Ms. [ +then 19, who told them Mr. Epstein had routinely +paid her to bring teenage girls to his home. +The police then interviewed a total of 5 alleged +victims and 17 witnesses, many of whom +told similar stories about what they had observed or +participated in at Mr. Epstein's home. According to the report, at least one said Mr. Epstein had +engaged in intercourse with her. +Mr. Lefcourt, his lawyer, said one girl who told the police of having had sex with Mr. Epstein +as a minor had lied about both the sex and her age and had not shown up for grand jury questioning. +He also said Mr. Epstein had passed a lie-detector test clearing him of any sexual involvement with +A spokeswoman for the Palm Beach police said that early this year, the police went to Mr. +the state attorney, +intending to apply for warrants to arrest Mr. Epstein. +told that Mr. Krischer would convene a grand jury to examine the evidence and decide +if any, to bring. +Around that time, the police report said, Mr. Dershowitz met with prosecutors to share +information about the accusers, including statements they had posted on MySpace.com, the social +networking site, concerning use of drugs +and alcohol. According to the report, Mr. Krischer's office +then decided to delay the grand jury session for several months. +The Palm Beach police grew frustrated, the report said, and on May 1 the department asked +prosecutors to approve warrants to arrest Mr. Epstein. +list of possible charges. +Bruce J. Winick, a law professor at the University of Miami, said that while prosecutors in +Florida rarely referred noncapital cases to grand juries, they sometimes did so with sensitive cases +to be extra-cautious. +Mr. Lefcourt said the police were wrong to have released the report so soon, especially without +correcting information that later proved wrong. He cited his assertion that one accuser had lied +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. + +JPM-SDNYLIT-00037188 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 8 of 24 +about her age, adding that she had also been arrested on drug charges and had been fired by her +employer for stealing. +''What I'm trying to focus on, '' Mr. Iefcourt said, +'is, What's motivating the selective and +misleading release of information to the public?' +URL: http://www.nytimes.com +GRAPHIC: Photos: Mr. Epstein, a New York money manager, 1s said to have had teenage girls brought to +his home in Florida. (Photo by Scott Wiseman for The New York Times) +Jeffrey Epstein has pleaded not gullty to solfeiting prostitution. (Photo by Palm Beach County +Sheriff's Office) +LOAD-DATE: September 3, 2006 +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +7 + + +JPM-SDNYLIT-00037189 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 9 of 24 +Copyright 2006 The New Mexican +The Santa Fe New Mexican (New Mexico) +August 17, 2006 Thursday +SECTION: SANTA FE/EL NORTE; Pg. C-1 +LENGTH: 878 words +HEADLINE: ROUNDHOUSE ROUNDUP: WEB SITE AIMS TO MAKE POLITICAL FUNDING MORE TRANSPARENT +BYLINE: STEVE TERRELL +BODY: +Funding: So far only one candidate on site's 11st +If you want to know who is giving how much money to what politicians in New Mexico races during +most of the summer and early fall, you're pretty much out of luck. +The way state campaign laws are set up, +candidates for state and county offices don't file any +financial-disclosure reports between July 6 and Oct. 9. +However, a conservative blogger from Cedar Crest has created a Web site called Ethical Reporting -- +subtitled The Campaign Finance Reporting Blog for Politicians With Nothing to Hide -- on which +candidates can post their contributions, expenses and in-kind donations as they come in. +Burgos has been a critic of the secretary of state's Web site, saying it's difficult to use and +virtually impossible to search. +"I'm an active Republican with a conservative blog who has run for political office in the past," +Burgos +says on his site. "Now that we have that out in the +open, please know that this site will remain strictly nonpartisan." +He later told me: "Nothing would make me happier than for Dema to participate as well." +Burgos said he ran the idea by Matt Brix, executive director of New Mexico Common Cause. +"I think it's a pretty creative effort on Mario's part, " Brix said. "I would definitely encourage +candidates to use it." +far, only one candidate is on the site's List of Ethical Politicians. That's state Rep. Kathy +of Cedar Crest, +who won her seat in 2004 after defeating Burgos in the Republican primary. +She's posted all donations and expenditures she incurred since the July 6 report. +1s a member of the state task force that is recommending changes in ethics and campaign +laws. +"I thought it was appropriate as a task-force member to take this first step, " she said. +is running against Democratic challenger Janice Saxton of Placitas. +Burgos -- who spent about 20 hours over the past three weeks and less than $200 creating the site -- +said readers can add comments about individual contributions. +"If somebody's getting money from +someone who's dealing with the state, you can post a comment, " he said. Candidates in turn can +respond to the comments, he said. +But he admitted there is one +drawback: You can't click a button and total how much +future participants have raked in or spent. +"I'm not a programmer." Burgos said. +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +8 + +JPM-SDNYLIT-00037190 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 10 of 24 +Both Burgos and +• say they support the idea of the state requiring "real-time" reporting of +contributions as they come in. +over, he way it is now, by the time the publie can 1ook at our contribution lata, the election's +said. "This helps create cynicism in the public arena." +"I don't like the way the (ethics) task force is going with trying to set limits (on +contributions and gifts), " Burgos said. "I'm for 100-percent disclosure. If you have lunch with a +lobbyiat, put it out there." +Ethical Reporting can be found at www.ethicalreporting.com. Burgos' blog 1s at +www.marioburgos.com. +Man of Mystery: Speaking of campaign contributions, all the candidates I spoke to earlier this +Hok do had tany nay an off petitute add they nana met contain. +- the billionaire financier recently indieted +in +It kind of reminds me of what my mom told me about taking candy from strangers. +I also was struck by The Palm Beach Post's description of Epstein -- accused of having sex with a +string of teenage girls - "Epstein, now 53, was a quintessential man of mystery. He amassed his +fortune and frienda quietly, always in the background as he navigated New York high society." +'Ive years ago in this paper, former New Mexican reporter Elena Vasquez, writing about Epstein's +ligantic mansion in Santa Fe County, picked up on the "mystery-man" aspect of his character. +"Epstein is as mysterious today as he was when he began building his estate. He apparently is a +private man who has sworn his ranch employees to secrecy +-- making him an enigma to his 30 neighbors +in the sleepy town of Stanley. One resident said her curiosity died down after many of her questions +remained unanswered. +• "They wouldn't tell anybody anything, ' said (a neighbor), who has become friends with some of +Epstein's employees. '... Whatever they do there is their business, so I just let it drop.' " +Lamont/ +: So far at least 20 Democratic U.S. senators have said they will back +Connecticut Democratic Senate nominee Ned Lamont in the general election against Incumbent Sen. Joe +| who is running as an independent after losing to Lamont in the Democratic primary. Only +three Senate Democrats say they're sticking with | +Missing from both lists is New Mexico's junior senator, Democrat Jeff Bingaman. +"Jeff's not going to get involved, " Bingaman re-election campaign manager Terry Brunner said this +"He'll leave that decision to the voters of Connecticut. He's got his own race to worry +about." +Bingaman is running for a sixth term against Republican McCulloch of Farmington. +Other New Mexico Democrats haven't been shy about the Connecticut race. U.S. Rep. Tom Udall is +supporting the Democratic nominee, a spokeswoman said. Meanwhile, Gov. BIll +endorsed +Lamont last week and urged | +• to step aside. +Contact Steve Terrell at 986-3037 or sterrellfsfnewsexican.com. +LOAD-DATE: August 18, 2006 +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +9 + +JPM-SDNYLIT-00037191 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 11 of 24 +Copyright 2006 Associated Press +All Rights Reserved +The Associated Press State & Local Wire +August 17, 2006 Thursday +11:39 AM GMT +SECTION: STATE AND REGIONAL +LENGTH: 205 words +HEADLINE: Land commissioner candidate to return contribution +DATELINE: ALBUQUERQUE +BODY: +The Democratic candidate for state land commissioner says his campaign will return a $10,000 +contribution from a billionaire +financier charged with solicitation of prostitution after +authorities alleged he paid women for sex in his Florida mansion. +Jim Baca said his campaign doesn't have +enough cash on hand to return the money in one lump sum, +but will pay in $1,000 installments and will have returned all Jeffrey Epstein's money before the +end of the election. +Epstein who also has a home in Santa Fe County is alleged to have solicited sex between Aug. 1 +and Oct. 31 of last year, +according to an indictment charging him with one felony count of +solicitation of prostitution. +His attorney, Jack Goldberger, has said Epstein "would never knowingly break the law." +The 53-year-old money manager gave thousands to New Mexico political candidates, ineluding +$50,000 for to Gov. Bill +re-election campaign this year, +according to state campaign +contribution reports. +campaign said that money would be donated to charity. +Epstein also donated $15,000 to Democratic attorney general candidate Gary +plans to return the money- +Information from: The Santa Fe New Mexican, http://www.sfnewmexican.com +LOAD-DATE: Auquat 18, 2006 +who said he +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +10 + +JPM-SDNYLIT-00037192 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 12 of 24 +pyright 2006 Say Anythi +y Anythir +August 15, 2006 Tuesday +10:31 +EM EST +LENGTH: 183 words +HEADLINE: DA Who Went After Limbaugh Caught Going Light On A Democrat +BODY: +Aug. 15, 2006 (Say Anything delivered by Newstex) -- +And by "going light" I mean not being able to get even an indictment for multiple charges of +statutory rape in a +that boasts 17 witnesses against the defendent, two of them former +employees in the defendent's home. +Ace has the details: +Palm Beach Chief of Police Michael Reiter has asked Rush Limbaugh's foe, State Attorney Bruce +Krischer, to recuse himself from a case, believing he's in the tank for the defendant. The +is a dedicated Democrat, as is Krischer himself. The +accused Setter Beatin, has donated and +than a $100,000 to Democrats, Including Hillary! Clinton. +Reiter wants to charge Jeffrey Epstein for four counts of unlawful sexual conduct with a minor +with girls as young as fourteen. +Krischer was somehow only able to get a prostitution charge against Epstein from a grand Jury. +despite a house filled with hidden cameras and pictures of young girls. +Reiter is seeking the aid of the FBI. +If this were Rush Limbaugh he'd have been perp' walked already and the pictures would be the +subject of much lefty gloating. +NOTES: The views expressed on blogs distributed by Newstex and its re-distributors ("Blogs via +Newstex") are solely the author's and not necessarily the views of Newstex or its re-distributors. +Posts from such authors are provided "AS IS", with no warranties, and confer no rights. The material +and information provided in Blogs via Newstex are for general information only and should not, in +any respect, be relied on as professional advice. No content on such Blogs via Newstex is "read and +approved" before it is posted. +Accordingly, neither Newstex nor its re-distributors make any +claims, promises or guarantees about the accuracy, completeness, or adequacy of the information +contained therein or linked to from such blogs, nor take responsibility for any aspect of such blog +LOAD-DATE: September 4, 2006 +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +11 + +JPM-SDNYLIT-00037193 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 13 of 24 +Copyright 2006 N.Y.P. Holdings, Inc. +All Rights Reserved +The New York Post +August 14, 2006 Monday +SECTION: All Editions, Pg. 22 +LENGTH: 809 words +HEADLINE: MYSTERY MOGUL'S TEEN-SEX SECRET BARED IN PROBE +BYLINE: DAN MANGAN +BODY: +For years, a media-dodging financial adviser who owns Manhattan's largest pad has cultivated his +mysterious image, suggesting he creates big investment profits for billionaire clients without +revealing how he does it or whose portfolios he handles. +But now investment whiz Jeffrey Epstein's darkest personal secrets have allegedly been bared in +an explosive, seamy prostitution case involving underage girls. +Instead of marveling at his +I-market acumen, Epstein's celebrity friends are now hearing +sordid stories about his alleged obsession with getting massages in his Florida mansion from young +girls - one allegedly just 14 years old. +The tawdry tale came to light when Epstein, 53, was busted in Florida on July 23 after a grand +jury indicted him on a single felony charge of solicitation of prostitution. The grand Jury declined +to indict the silver-haired moneyman on charges of sexual contact with minors. +But a bitter rift between Palm Beach cops and prosecutors over how to handle the case has put +Epstein at risk of more serious charges. The FBI 1s weighing whether to investigate his alleged +contacts with underage girls. +Gerald Lefcourt, one of Epstein's high-powered lawyers, says his client is innocent and that his +polygraph test helps prove it. +"There was no sexual contact with anyone underage," Lefcourt said, arguing that that has been +"proved beyond a reasonable doubt" by evidence lawyers gave authorities. +Epstein owns what reportedly is Manhattan's largest home - a 51,000-square-foot Upper East Side +house - plus a sprawling New Mexico ranch and a 100-acre private island in the U.S. Virgin Islands. +He also owns a two-story pink mansion in Palm Beach, which became the focus of a nearly yearlong +police investigation. +Palm Beach police records show that on March 15, 2005 +spatein each one ree beder at the bon are 16, 2005, 1a regard salLege she had visited +Epstein's pad, she partially stripped and gave Epstein a massage. +At one point, "Epstein then pulled out a purple vibrator" and used it on her, police records +claim. +Epstein eventually paid the girl $300, and she left, the records allege. +masturbated and touched their genitals during massages, +baled and ghed their gee this alting a do el records state hose gd is inn hady wore +recruited by a woman named +, documents say- +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +12 + +JPM-SDNYLIT-00037194 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 14 of 24 +When cops confronted the 20-year-old | +the records show, she admitted that she had bee +ecruited at age 17 by a friend to give Epstein a massage while she was naked. +"He tried to touch me, and I stopped him," | +alleged. +Epstein allegedly paid her $200 for the rubdown. +After the massage, Epstein told her that he understood she wasn't comfortable but that "he would +pay her if she brought over some girls, " the police records state. +"He told her the younger the better, " the records claim. +I - who described herself as "like a leidi Fleiss" - alleges that, over time, she brought +six giris who were between 14 and 16 to Epstein's house, the police records state. +Police allege that Epstein's comely blond assistant, +, helped arrange the sesaions. +Several girls allege that | +, 26, led them to Epstein's | +| bedroom, where she would set +up a massage table and give them oils to rub on Epstein. +Cops wanted to charge +and +jury did not indict either women. I +could not be +reached for comment. +According to one girl, "Epstein asked for her real age, [and she] stated she was 16. Epsteir +advised her not to tell anyone her real age," the records say. +The girl alleged that Epstein paid her to have sex with his girlftlend, +police records state. +Epstein would then watch the women have sex and take photos of their trysts to diaplay at home, +the records claim. +declined to comment. +The teen told cops she always refused to have intercourse with Epstein, the report states. +But one time, she told cops, Epstein allegedly grabbed her and forced himself on her. +When the girl became upset and screamed, "No!" Epstein apologized, and he later paid her $1,000 +for the visit, the records allege. +unLawzul sexual ae prepa d a certain anone eth led and abet out in estatarged with +Instead, in a rare nove, prosecutors brought the evidence to a grand jury, which indicted Epstein +only on the prostitution charge. +conte ring ator to invo hat given the to polence that Man diving on hage dizza, +said Special Agent Judy Orihuela. +LOAD-DATE: August 14, 2006 +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +13 + +JPM-SDNYLIT-00037195 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 15 of 24 +opyright 2006 The Palm Beach Newspapers, Inc +'alm Beach Post (Florida +August 10, 2006 Thursday +FINAL EDITION +SECTION: OPINION; Pg. 20A +LENGTH: 428 words +HEADLINE: MASSAGING THE SYSTEM +BODY: +Palm Beach police say their 11-month investigation shows that 53-year-old part-time town +Jeffrey Epstein committed unlawful sex acts with and lewd and lascivious molestation on +five underage girls. +Defense attorney Jack Goldberger claims that his client, Jeffrey Epstein, had +no idea that the untrained girls he hired for massages were minora. +The Palm Beach Count State Attorney's Office could have let a jury decide whom to believe. +Instead, State Attorney Barry Krischer left the public to wonder whether the system tilted in favor +of a wealthy, well-connected alleged perpetrator and against very young girls who are alleged +Mr. Krischer took the unusual step of referring the case to a grand Jury, which last month +indicted Jeffrey Epstein on one +count of solicitation of prostitution. That decision căne +after Harvard law Professor Alan Dershowitz met with prosecutors +to undermine the credibility of +the 14- to 17-year-old girls who charged +that Mr. Epstein had paid them $200 to $300 to undress +and massage him in his five-bedroom, 7 1/2-bath home on the Intracoastal Waterway. +The girls, Mr. Dershowitz told prosecutors, +had written on myspace.com about smoking marijuana +and drinking alcohol. But if the girls have a credibility problem, +what about Jeffrey Epstein? +Mr. +Goldberger, told The Post: "Mr. Epstein absolutely insisted anybody who came to his house be over +the age of 18. How he verified that, I don't know." And prosecutors took him at his word? +Police collected evidence that refutes Jeffrey Epstein's defense. Police searched his home and +garbage and found phone messages about the girls' +school schedules and even a high school +transcript, suggesting that Mr. Epstein at least knew that the girls were teenagers. +The state attorney's office has responded to criticism from Palm Beach police and others by +noting the higher standard prosecutors +arrest. +face for conviction +than Law-enforcement officers do for - +But in this case, the state attorney bowed to the risk that a jury might look at both - +Jeffrey Epstein and the girls, and point fingers at both sides. +disc Jockey and teacher Moore was charged +Investigators +LOAD-DATE: August 12, 2006 +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +14 + +JPM-SDNYLIT-00037196 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 16 of 24 +Copyright 2006 The Palm Beach Newspapers, Inc. +Palm Beach Post (Florida) +ugust B, 2006 Tuesd +FINAL EDITI +SECTION: LOCAL, Pg. 1B +LENGTH: 638 words +HEADLINE: EPSTEIN CAMP CALLS FEMALE ACCUSERS ITARS +BYLINE: By LARRY | +| Palm Beach Post Staff Writer +BODY: +Attorneys and publicists for Palm Beach financier Jeffrey Epstein went on the offensive Monday, +that teenage girls who have accused Epstein of sexual shenanigans at his waterfront +home are liars and saying that the Palm Beach Police Department is "childish." +"There never was any sex between Jeffrey Epstein and any underage women, " his lead attorney, +Jack Goldberger, said from Idaho where he was vacationing with his family. +Epstein did have young women come to his house to give him massages, Goldberger said. "Mr. +Epstein absolutely insisted anybody who came to his house be over the age of 18. How he verified +that, I don't know. The queation is, did anything Illegal occur. The law was not violated here." +He had no explanation as to why Epstein would pay girls or women with no massage training - as +the alleged victims said was the case - $200 to $300 for their visits. "The credibility of these +witnesses has been seriously questioned, " Goldberger said. +Epstein, 53, was indicted by a county grand jury last month on a charge of felony solicitation of +prostitution. After an 11-month investigation that included sifting through Epstein's trash and +surveilling his home, Palm Beach police concluded there was enough evidence to charge him with +sexual activity with minors. When the grand Jury indicted Epstein on the less serious charge, Police +Chief Michael Reiter referred the case to the FBI to determine whether there were federal law +After a spate of stories about the case last week, New York publicist Dan Klores - whose client +1ist has included Paris Hilton and Jennifer +on Saturday that Epstein's camp was ready +"to get their story out." +They did that Monday via Goldberger and a Los Angeles publicist for Miami criminal defense +attorney Roy Black, who also has repreaented Epstein in the case. +"We just think there has been a distorted view of this case in the medla presented by the Palm +Beach police, " Goldberger said./ +Reiter has consistently declined to comment on the case and did not respond to a request for +comment Monday. +a grand fury atter than fating care directy agent in ye tong, fa byerger Baing the case to +odence think what appened is he here and py attach tether de gold to even the +press to embarrass Mr. Epstein." +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +15 + +JPM-SDNYLIT-00037197 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 17 of 24 +Rather than flat-out decline to charge Epstein, Krischer referred the case to the grand jury to +"appease" the chief, Goldberger said. +A state attorney's spokesman would say only that the office refers cases to the grand jury when +there are issues with the viability of the evidence or witnesses' credibility. +Both the state attorney and the grand Jury concluded there was not sufficient evidence that +Epstein had sex with minors, +according to Goldberger. "It was Just a childish performance by the +Palm Beach Police Department, " Goldberger said. +The defense attorney said one of the alleged victims who claimed she was a minor was in fact over +the age of 18. Another alleged victim who was subpoenaed to testify to the grand Jury failed to do +Epstein's accusers, +he added, have histories of drug abuse and thefts. "These women are liars. +We've established that." +But why would they all invent their stories about meeting Epstein for sexual massages? +"I don't have an answer as to what was the motivation for these women to come forward and make +these allegations," Goldberger said. +larry_kellerfpbpost.com +NOTES: +Ran all editions. +GRAPHIC: PHOTO (C) +Jeffrey Epstein (mug) +LOAD-DATE: August 10, 2006 +Confidential - This report is not to be disseminated or photocopied to any third +party without the express consent of Global Corporate Security. +16 + +JPM-SDNYLIT-00037198 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 18 of 24 +Copyright 2006 Newstex LIC +All Rights Reserved +Newstex Web Blog +Copyright 2006 Gawke: +Gawker +July +28, 2006 Friday 10:39 AM EST +LENGTH: 227 words +HEADLINE: Jeffrey Epstein's Strangely Falled Plea Bargain +BODY: +Jul. 28, 2006 (Gawker delivered by Newstex) - +agreed to plead +Sendergo petech atre/deadlean and have gravated assed chatte +minors. Epstein's then-counsel Guy Fronstin relayed that Epstein would accept the plea bargin and asked +that investigators "call off the grand Jury as they would accept this deal. " It could've resulted in a +somewhat smaller shitstorm, but the deal was never closed: +It is unclear why the plea bargain was not formally struck at that point, but the report indicates +that police investigators--who anticipated five felony counts being lodged against Epstein--were incensed +at what they clearly viewed as a sweetheart prosecution offer. +Strangely, in mid-May, Epstein was offered the plea bargain again, but papers indicate that the +prosecutor "was waiting" for an answer. Yet on Sunday, Epstein was unfairly arrested for a felony count of +soliciting prostitution. What kind of justice +is there in this world when even a billionaire can't take an +extra 3 months to get some massages while mulling over his legal options? +Cops: Pervy Billionaire Agreed to a Plea Bargain [TSG] +Earlier: Gawker's Coverage of Jeffrey Epstein +NOTES: The views expressed on blogs distributed by Newstex and its re-distributors ("Blogs via Newstex") +are solely the author's and not necessarily the views of Newstex or its re-distributors. Posts from such +authors are provided "AS IS", with no warranties, and confer no rights. The material and information +provided in Blogs via Newstex are for general information only and should not, in any respect, be relied +on as professional advice. No content on such Blogs via Newstex is "read and approved" before it is +posted. Accordingly, neither Newstex nor its re-distributors make any claims, promises or guarantees +about the accuracy, completeness, or adequacy of the information contained therein or linked to from such +blogs, nor take responsibility for any aspect of such blog content. All content on Blogs via Newstex shall +be construed as author-based content and commentary. Accordingly, +no warranties or other guarantees will +be offered as to the quality of the opinions, conmentary or anything else offered on such Blogs via +Newstex. Reader's comments reflect their individual opinion and their publication within Blogs via Newstex +shall not infer or connote an endorsement by Newstex or its re-distributors of such reader's comments or +Views. +Newstex and its re-distributors expressly reserve the right to delete posts and comments at its and +their sole discretion. +LOAD-DATE: September 4, 2006 +Confidential - This report is not to be disseminated or photocopied to any third party +17 + +JPM-SDNYLIT-00037199 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 19 of 24 +REGULATORY SANCTIONS +* * * THIS DATA IS FOR INFORMATION PURPOSES ONLY * * * +* * * COLLECTED AND COMPILED BY MORTGAGE ASSET RESEARCH INSTITUTE, INC. +*** +PARTY: EPSTEIN, JEFFREY +**** INCIDENT INFORMATION ****** * * * +CASE NUMBER: 02-03451 +JURISDICTION: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. +SOURCE: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. +DATE: 8/ 6/2003 +ther Incident Info: CASE NAME: RAYMOND, JAMES • ASSOCIATES, CLAIMANT, VS. +JEFFREY EPSTEIN, RESPONDENT. +'he individual (s) or company(les) listed in this report were party to a National Association of Securitie +(NASD) arbitration award. Being party to the arbitration award does not necessarily mean that the +individual (s) or company(ies) have been found to have violated any code or regulation. +EPSTEIN, JEFFREY +Action: NASD ARBITRATION +HARDCOPY: FOR A COPY OF THE SOURCE DOCUMENT (S), CONTACT MARI AT (703) 620-6262. +HARDCOPY ORDER NUMBER: NASA038G-01182857 +Confidential - This report is not to be disseminated or photocopied to any third party +18 + +JPM-SDNYLIT-00037200 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 20 of 24 +OFAC/CONTROL LIST SEARCH +INSIGHT +searchresults, 5 +yhs +Edit Profile | Change Password | Logout nicole landy +THY! +BUYE +free name check +Enter Full Name +Address (optional) +Name: +Address: +Country: +Country (optional) +Vote: This free name check is not a complete compliance solution. Learn more about Bridger Insight™, the +eading USA PATRIOT Act (sec 326) and OFAC compliance solution +Matches: +0 +@ 2OON CHOICEP OINT AS SET COMPANY, ALL RIGHTS RESERVED. +PRIVACY TERMIS +Confidential - This report is not to be disseminated or photocopied to any third party +19 + +JPM-SDNYLIT-00037201 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 21 of 24 +Edit Profile | Change Password | Logout n +landy +search results +y hs +free name check +Enter Full Name +Address (optional) +Name: +Address: +Country: +Country (optional) +Note: This free name check is not a complete compliance solution, Learn more about Bridger Insight™, the +leading USA PATRIOT Act (sec 326) and OFAC compliance solution. +Matches: +@ SOON CHOICEF CANT ASSET COMPANY. ALL RIGHTS RESERVED. + +PRIVACY TEEME +Confidential - This report is not to be disseminated or photocopied to any third party +20 + +JPM-SDNYLIT-00037202 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 22 of 24 +İNSIGHT +search results +y.h.s. +Edit Profile | Change Password | Logout nicole landy +TRYE +BUTT +free name check Enter Full Name +Address (optional) +Name: +Address: +Country: +Country (optional) +Note: This free name check is not a complete compliance solution. 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Learn more about Bridger Insight™, the leading +USA PATRIOT Act (sec 325) and OFAC compliance solution. +Matches: +0 +@ 20O% CHONCEPONT ASSET CONFANY, ALL RISHTS RESERVED. +PRIVAGY TERM +Confidential - This report is not to be disseminated or photocopied to any third party +22 + +JPM-SDNYLIT-00037204 + + +Case 1:22-cv-10904-JSR Document 238-12 Filed 07/25/23 Page 24 of 24 +İNSIGHT +search results +epstein +TRYI +BUT! +Edit Profile | Change Password | Logout nicole landy +free name check Enter Full Name +Address (optional) +Name: +Address: +Country: +Country (optional) +Note: This free name check is not a complete compliance solution. Learn more about Bridger Insight™, the leading +USA PATRIOT Act (sec 326) and OFAC compliance solution. +Matches: +0 +2OO4 CHOICEPOINT ASSET COMFANY. ALL RIGHTS RESERVED, +Confidential - This report is not to be disseminated or photocopied to any third party +23 + +JPM-SDNYLIT-00037205 \ No newline at end of file diff --git a/vision-fixhub/court-05/6ec6c7172391ac9a2ac06a54686ca5eb7683dcfe87d432f864af333937f10742.receipt.json b/vision-fixhub/court-05/6ec6c7172391ac9a2ac06a54686ca5eb7683dcfe87d432f864af333937f10742.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..91e71897e8fefc5c4c0db6ca249433050561bf19 --- /dev/null +++ b/vision-fixhub/court-05/6ec6c7172391ac9a2ac06a54686ca5eb7683dcfe87d432f864af333937f10742.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -2211, + "dataset": "marble-joined", + "doc_id": "6ec6c7172391ac9a2ac06a54686ca5eb7683dcfe87d432f864af333937f10742", + "engine": "marble-apple-vision", + "event_count": 53, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "99d3b8f16795b9d192dbd173f7b358d6122d3e15dcce2a3552d27dd8b73598d6", + "output_sha256": "90b7f2755880f6698500e23576e2bb50bc7afb9b43c8160ef97be40a7dcd5f58", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6eccf6bfa86c0a01ea7f1aa3779b3c2a1ac7d11018344ddec36149688d86467d.md b/vision-fixhub/court-05/6eccf6bfa86c0a01ea7f1aa3779b3c2a1ac7d11018344ddec36149688d86467d.md new file mode 100644 index 0000000000000000000000000000000000000000..b219aa7bc4941e76375a8d1a365d50712bbd3423 --- /dev/null +++ b/vision-fixhub/court-05/6eccf6bfa86c0a01ea7f1aa3779b3c2a1ac7d11018344ddec36149688d86467d.md @@ -0,0 +1,82 @@ +Case 1:22-cV-10904-JSR Document 285-12 Filed 08/15/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 285-12 Filed 08/15/23 Page 2 of 3 +NAME +MEETING DATE +AM Reputation Risk Committee Meeting Summary +Confidential - Attorney Client Privilege +Ghislaine Maxwell +CLIENT SPONSOR +MEETING LOCATION AND +December 6, 2013 +TIME +James Buckley +John Duffy's office- +11:00 am ET +SUBMITTING MD +Alma DeMetropolis (UHNW) +DESCRIPTION +• Ghislaine was originally referred to the PB by Jes Staley - and has been a client of the bank since 1985. +• She does not work, but volunteers for a charitable organization she founded, The TerraMar Project +(www.terramarproject.org). TerraMar's mission is to create and empower a global community of ocean citizens. It promotes +awareness, responsibility and transparency of the high seas. The web-based nonprofit empowers the global community +through citizenship, education and social engagement through The TerraMar Project. +• She is the daughter of the late Robert Maxwell +• Robert Maxwell was a Czechoslovakian-born British media proprietor and Member of Parliament. He +from +poverty to build an extensive publishing empire. +His death triggered the collapse of his publishing empire as banks called in loans. His sons briefly struggled to keep +the business together, but failed as the news emerged that Maxwell had stolen hundreds of millions of pounds +from his own companies' pension funds. The Maxwell companies applied for bankruptcy protection in 1992. +• Shortly before Maxwell's death, a former employee of Israel's Military Intelligence Directorate intelligence agency Ari Ben- +Menashe, had approached a number of news organizations in Britain and the United States with the allegation that Maxwell +and the Daily Mirror's foreign editor, Nicholas +_ were both long-time agents for Mossad. Ben-Menashe also claimed +that in 1986 Maxwell had told the Israeli Embassy in London that Mordechai Vanunu had given information about Israel's +nuclear capability to The Sunday Times, then to the Daily Mirror. Vanunu was subsequently kidnapped by Mossad and +smuggled to Israel, convicted of treason and imprisoned for 18 years. +REPUTATION ISSUES RAISED PRIOR AND DURING THE MEETING +Negative News: +• 2011 Media alleging Maxwell solicited young girls for then boyfriend Jeffrey Epstein. +• Jeffrey Epstein was convicted for solicitation of a prostitute and procuring a person under age 18 for prostitution. He was +the subject of a previous Management Review and is currentiv being exited from the Bank. +COMMITTEE DECISION AND REASONING +DECISION: Exit client +REASONING: +• Negative media - human rights issue. +CONDITIONS REQUIREMENTS +• Exit client - checking, brokerage, and +managed accounts +OTHER RRC RECOMMENDATIONS - N/A +CONDITION SIGN-OFF +RRC ATTENDEES +RESOLULTION TIMEFRAME +FOLLOW-UP OWNER +TBD - after review of +James Buckley +accounts +Committee Chair/CEO - John Duffy +Committee Chair/Deputy CEO - Kelly Coffey +Committee Vice-Chair/Head, GWM Business Risk - +Lencyk +General Counsel - Anne Verdon +Compliance Managing Director - Lisa Belle +COO U.S. Private Bank - David Wezdenko +CFO Private Bank - Jeff Whitaker +Business Quality Control/Managing Director - Kevin McCleerey +JPM-SDNYLIT-W-00037475 + + +Case 1:22-cV-10904-JSR Document 285-12 Filed 08/15/23 Page 3 of 3 +ADDITIONAL ATTENDEES +• Committee Secretary/ Business Quality Control Manager - Kathie Gruszczyk +Regional Director - Marc Sheridan +Managing Director - Alma DeMetropolis +• +Private Banker - James Buckley +Business Quality Control Manager - Bonnie +Business Quality Control Manager - Cindy Habig +• Compliance Manager - Tamer Yalav +JPM-SDNYLIT-W-00037476 diff --git a/vision-fixhub/court-05/6eccf6bfa86c0a01ea7f1aa3779b3c2a1ac7d11018344ddec36149688d86467d.receipt.json b/vision-fixhub/court-05/6eccf6bfa86c0a01ea7f1aa3779b3c2a1ac7d11018344ddec36149688d86467d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ab32bde7180eea4fde01aad036b6a615686f9cb0 --- /dev/null +++ b/vision-fixhub/court-05/6eccf6bfa86c0a01ea7f1aa3779b3c2a1ac7d11018344ddec36149688d86467d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -46, + "dataset": "marble-joined", + "doc_id": "6eccf6bfa86c0a01ea7f1aa3779b3c2a1ac7d11018344ddec36149688d86467d", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "2ec5b02996dbdfb8f4ef0441b03d3262ccdd7c5245abdda411b8d829730f6790", + "output_sha256": "a52baa1a8e53c01c67bccfb5ba89da79215e06565dd5f59c9a20f653f766d877", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6f14e4cc799ae152cd305c3783560c16868292f495801fb47c5dfe2d3264db2b.md b/vision-fixhub/court-05/6f14e4cc799ae152cd305c3783560c16868292f495801fb47c5dfe2d3264db2b.md new file mode 100644 index 0000000000000000000000000000000000000000..c6c5091d9505c56afa1bdb5ee6ec961d5cb8db78 --- /dev/null +++ b/vision-fixhub/court-05/6f14e4cc799ae152cd305c3783560c16868292f495801fb47c5dfe2d3264db2b.md @@ -0,0 +1,327 @@ +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 1 of 10 + + + +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 2 of 10 +GOVERNMENT OF THE TERRITORY OF THE VIRGIN ISLANDS +OF THE UNITED STATES +ECONOMIC DEVELOPMENT CERTIFICATE +EXTENSION +(Amended, effective January I, 2012) +FINANCIAL TRUST COMPANY, INC. +(Beneficiary) +Pursuant to the authority vested in me as the Chairman of the Virgin Islands Economic +Development Commission (hereinafter the "Commission") by Title 29 Virgin Islands +Code, Chapter 12 and in the name of the Government of the Virgin Islands of the United +States, I do hereby issue this certificate to Financial Trust Company, Inc. (hereinafter the +"Beneficiary") whose application for Economic Development Benefits was accepted by +the Chief Executive Officer of the Economic Development Authority on January 28, +2009. The Commission finds that the Beneficiary is an eligible Beneficiary pursuant to +§713(2)(b) of the Commission's Rules and Regulations. The grant of benefits hereinafter +described is for the Beneficiary or any successors approved by the Commission to +conduct the operation of a Category IIA designated service business that provides +financial and economic consulting to its clients which will include multinational business +organizations. All of its clients are located outside the U.S. Virgin Islands. +This certificate is subject to the acceptance of and full compliance by the +Beneficiary with all the following general, standard, and special conditions, and the +timely performance and observance of the same by the Beneficiary: +I. +The Beneficiary shall invest in this business in the Virgin Islands of the +United States not less than the amount of One Hundred Thousand U.S. Dollars +($100,000), excluding inventory, in the benefited business commencing in 2009 and +completed three (3) years thereafter. +Il. +The Beneficiary shall employ at least ten (10) full-time employees in the +eligible activity of the benefited business commencing April 1, 2009 and continuing +throughout the duration of the term of benefits. During the entire period of this grant of +benefits at least eighty percent (80%) of all employees shall be "Residents of the U.S. +Virgin Islands" as defined in Title 29, V.I. Code, §703(e) and provided that not less than +twenty percent (20%) in the area of management, supervisory and/or technical positions +shall be filled by residents of the Virgin Islands, pursuant to Title 29, Chapter 12, +§710(a). + +VI-JPM-000017983 + + +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 3 of 10 +UNITED STATES VIRGIN İSLANDS +Economic Development Certificate +III. The following standard conditions shall apply: +1. Beneficiary shall comply with any and all reasonable requests during +regular working hours of the Commission, the Virgin Islands Department of Finance, the +Virgin Islands Bureau of Audit and Control, Virgin Islands Department of Labor, Virgin +Islands Department of Licensing and Consumer Affairs, and the Virgin Islands Bureau of +Internal Revenue. +2. +This certiticate is conditioned upon the final determination of th +Secretary of the Treasury of the United States or his designee, of compliance of the +Beneficiary with the requirements of Section 934 of the United States Internal Revenue +Code of 1986, as amended, if applicable. +3. +Beneficiary shall fully and actually comply and continue to comply +with all the applicable provisions of Title 29, Chapter 12 of the Virgin Islands Code, the +regulations issued pursuant thereto, and all other applicable local and federal laws and +regulations, including but not limited to those dealing with non-discrimination and +veterans' employment rights. +Beneficiary shall particularly comply, and continue to comply with +federal and local laws, which establish standards of ecological and environmental +compatibility, with rules and regulations of the Director of the Virgin Islands Bureau of +Internal Revenue, and with the rules and regulations of the Economic Development +Program. +5. +Beneficiary shall particularly comply, with Section 8 of Act No +5768, which provides that the Beneficiary shall maintain payroll accounts, from which +local employees are paid, in a bank licensed and conducting business in the United States +Virgin Islands. +6. This certificate shall be effective only for so long as the Beneficiary +continues to observe and perform each and every condition in this certificate. +Upon a written finding by the Commission, after a hearing if +required, that the Beneficiary has failed to observe the conditions in this Certificate, or to +comply with any of the time limits provided in this certificate or otherwise provided by +law, and upon such further finding that such failure is not due to an act of God, a "force +majeure," (or to the reliance in good faith by the Beneficiary, (on a false statement by a +third party unrelated to the Beneficiary,) then the Certificate may be revoked, suspended +or modified by the Commission pursuant to 29 V.I.C. §722. If the Beneficiary is found to +have made false or fraudulent statements or representations or false claims for benefits, + +VI-JPM-000017984 + + +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 4 of 10 +Economic Development Certificate +then pursuant to 29 V.I.C. §725 the Beneficiary shall pay or refund, as the case may be, to +the Government of the Virgin Islands of the United States, the amount of every and all +benefits received under the Certificate after the commencement dates specified herein; +provided however that the Commission may for good cause shown, grant extensions of +any such time periods as may be permitted, such extensions to be evidenced by an +amendment to this certificate. The hearings and findings are referred to in the Code §722 +and Subchapter 722 of the Rules and Regulations. Nothing in this section shall be +construed to limit the Commission's rights, duties and responsibilities under Title 29 VI. +Code §722 or Subchapter 722 of the Regulations. +Beneficiary shall commence the active conduct of the business for +which this certificate was granted within five (5) years from the date the Chairman of the +Economic Development Commission signs this certificate, unless otherwise provided or +unless the business has already commenced +9. +Any new shareholders, partners, owners, members or beneficiaries +added to the entity after its application has been approved may not claim benefits under +the Economic Development Program without the prior written approval of the Economic +Development Commission. +IV. The following special conditions shall apply: +1. The Beneficiary will contribute One Hundred Thousand U.S. Dollars ($100,000) +or one percent (1%) of gross receipts tax exemption value, Whichever is greater, +annually to various Virgin Islands charities, youth sports organizations and clubs; +and symposiums held in the Virgin Islands. +2. The Beneficiary will fund an academic scholarship program for students of Ivana +Eudora Kean High School and Charlotte Amalie High School. The Beneficiary +will fund the program with a Twenty Thousand U.S. Dollars ($20,000) +contribution annually for a period of five (5) years. Each high school will receive +Ten Thousand U.S. Dollars ($10,000) annually to be awarded to a graduating +senior who intends to study and/or major in math or science at an accredited +college or university, and the Beneficiary will also contribute Twenty-Two +Thousand Five Hundred U.S. Dollars ($22,500) annually to Workforce +Development Fund established by the Economic Development Commission and +not less than Three Thousand U.S. Dollars ($3,000) annually to the Territorial +Scholarship fund pursuant to Title 29, VIC, §708(m). + +VI-JPM-000017985 + + +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 5 of 10 +Economic Development Certificate +3. The Beneficiary will continue to provide its employees with one hundred percent +(100%) employer paid health and dental insurance and will continue to permit +employees to purchase dependent coverage through the same provider witl +employer paying one hundred percent (100%) of the cost. +4. The Beneficiary will continue to provide its employees with employer-paid life +insurance in an amount equal to two times (2x) each employee's current base +salary. +5. The Beneficiary will continue to provide its full-time employees with a Simple +IRA plan or similar retirement plan with employer matching one hundred (100%) +of employee's elective deferral up to a limit of three percent (3%) of annual +compensation. +6. The Beneficiary will continue to provide its employees with two (2) weeks of +paid vacation during the first calendar year of employment for employees that are +hired prior to July and one (I) week paid vacation during the first calendar year of +employment for employees hired after July 1, 2009, three (3) weeks paid vacation +annually during the second (2"°) through the fifth (5) years of employment and +four (4) weeks paid vacation annually after five (5) years of employment. +Employees will also receive two (2) paid personal days annually; along with +holiday pay; five (5) personal emergency days annually; bereavement leave; jury +duty; voting; and medical leave. +7. The Beneficiary will comply with the management training program as approved +by the Economic Development Commission. +8. The Beneficiary will offer tuition reimbursement for short and long-term +coursework in subject areas directly related to an employee's current work. +9. In accordance with and subject to Virgin Islands law, Title 29 Virgin Islands Code +Chapter 12, §708(h) and applicable rules and regulations of the Economic +Development Commission, with regard to the Eligible Supplier Program, the +Beneficiary will purchase all goods and services from U.S. Virgin Islands entities +duly licensed and in good standing under the laws of the Virgin Islands, whenever +Item D: Specifically Excluded Trade or Business: +U.S. Virgin Islands clients are specifically excluded from the tax benefits. + +VI-JPM-000017986 + + +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 6 of 10 +UnITED STATES VIRGIN IsLAnDS +Economic Development Certificate +THEREFORE, pursuant to the public hearing on this Beneficiary's application on, +February 12, 2009 and the Commission meeting held April 27, 2009, May 7, 2009, May +28, 2009, and October 15, 2009, and based upon the representations of the Beneficiary +made orally and in writing and as agreed to herein, the Commission, with the prior +approval of the Governor of the Virgin Islands of the United States herein enters into this +Benefits Certificate with the Beneficiary that if the Beneficiary complies with the +in accordance with Title 29 V.l. Code §705(f) and all applicable laws and regulations of +the Territory of the Virgin Islands of the United States and of the United States of +America, then the Commission hereby grants the benefits stated in Appendices and Sub- +Appendices A to C inclusive to commence and terminate as stated in each signed +Appendix. +IN WITNESS HEREWITH, the parties hereunto set their hands and seals on the +dates noted below: +hec Lanchs +Witness +Yourt Dupet +Da: 3/20/12 +Economic Development Commission +Financial Trust Company, Inc. +Accepted by: Juanne Bursar +_conne +Name and Tile: Dan: 3/24/12 +Irsasurer +Witness +Nicde Mller +Witness + +VI-JPM-000017987 + + +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 7 of 10 +Inuestors Dream +GOVERNMENT OF THE TERRITORY OF THE VIRGIN ISLANDS +OF THE UNITED STATES +ECONOMIC DEVELOPMENT CERTIFICATE +APPENDIX A: +USVI INCOME, GROSS RECEIPT AND EXCISE TAXES +NAME, ADDRESS AND TELEPHONE NUMBER OF BENEFICIARY: +NAME: Financial Trust Company, Inc. +PHYSICAL LOCATION: 6100 Red Hook Quarter, B-3, St. +VAILING ADDRESS: 6100 Red Hook Quarter, B-3, St. +- VI 00802 +VI 00802 +TELEPHONE: (340) 775-2525 +Fax: (340) 775-2528 +NATURE AND EXTENT OF BENEFITS: +USVI Income Taxes: 81% percent exemption +USVI Gross Receipt Taxes: 90% percent exemption +USVI Excise Taxes (Raw Materials): 90% exemption from excise taxes (except gasoline +taxes) on raw materials and component parts used by the Beneficiary in its production +process. +USVI Excise Taxes (Equipment, Machinery): 90% exemption from excise taxes on +eidiary for ase in one pos convey, bet, i other asians or eile and up ic +physical plant or facilities of the Beneficiary. +COMMENCEMENT DATES OF BENEFITS: +USVI Income Taxes: April 1, 2009 +USVI Gross Receipt Taxes: April 1, 2009 +USVI Excise Taxes (Raw Materials): Not Applicable +USVI Excise Taxes (Equipment, Machinery): January 1, 2010 +TERMINATION DATES OF BENEFITS: +USVI Income Taxes: March 31, 2014 +USVI Gross Receipt Taxes: March 31, 2014 +USVI Excise Taxes (Raw Materials): Not applicable +USVI Excise Taxes (Equipment, Machinery): December 31, 2014 +AUTHORITY FOR BENEFITS: +Title 29 V.I. Code §713b, 713a (a) (2), 713a (a) (3); +Title 33 V.I. Code §43d + +VI-JPM-000017988 + + +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 8 of 10 +GOVERNMENT OF THE TERRITORY OF THE VIRGIN ISLANDS +OF THE UNITED STATES +ECONOMIC DEVELOPMENT CERTIFICATE +APPENDIX Al: +USVI WITHHOLDING TAX ON DIVIDENDS AND INTEREST +NAME, ADDRESS AND TELEPHONE NUMBER OF BENEFICIARY: +NAME: Financial Trust Company, Inc +PHYSICAL LOCATION: 6100 Red Hook Quarter, B-3, St. Thomas, VI 00802 +MAILING ADDRESS: 6100 Red Hook Quarter, B-3, St. +VI 00802 +TELEPHONE: (340) 775-2525 Fax: (340) 775-2528 +NATURE AND EXTENT OF BENEFITS: +Dividend Withholding Tax Exemption in accordance with Title 29 V.I. Code Section 713d +Interest Withholding Tax Exemption in accordance with Title 29 V.I. Code Section 713d +Member +Jeffrey E. Epstein +Address +Little St James Island +St. +VI +Owned +100% +COMMENCEMENT DATE OF BENEFITS: +Dividend Withholding Tax Exemption: April 1, 2009 +Interest Withholding Tax Exemption: April 1, 2009 +TERMINATION DATE OF BENEFITS: +Dividend Withholding Tax Exemption: March 31, 2014 +Interest Withholding Tax Exemption: March 31, 2014 +AUTHORITY FOR BENEFITS: Title 29 V.I. Code §713d +Date: 4/2/12 + +VI-JPM-000017989 + + +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 9 of 10 +Inuestors Dream +GOVERNMENT OF THE TERRITORY OF THE VIRGIN ISLANDS +OF THE UNITED STATES +ECONOMIC DEVELOPMENT CERTIFICATE +APPENDIX B: +USVI REAL PROPERTY TAXES +NAME, ADDRESS AND TELEPHONE NUMBER OF BENEFICIARY: +NAME: Financial Trust Company, Inc. +PHYSICAL LOCATION: 6100 Red Hook Quarter, B-3, St. +MAILING ADDRESS: 6100 Red Hook Quarter, B-3, St. +VI 00802 +VI 00802 +TELEPHONE: (340) 775-2525 Fax: (340) 775-2528 +NATURE AND EXTENT OF BENEFITS: +Real Property Taxes: 90% exemption of taxes on real property used for the business of +operating a designated service business. +PARCEL(S) EXEMPTED: +• None +COMMENCEMENT DATE OF BENEFITS: +Real Property Tax Exemption Starts: Not Applicable +TERMINATION DATE OF BENEFITS: +Real Property Tax Exemption Terminates: Not Applicable +AUTHORITY FOR BENEFITS: Title 29 V.I. Code §713a (a) (1) + +VI-JPM-000017990 + + +Case 1:22-cv-10904-JSR Document 186-32 Filed 06/14/23 Page 10 of 10 +GOVERNMENT OF THE TERRITORY OF THE VIRGIN ISLANDS +OF THE UNITED STATES +ECONOMIC DEVELOPMENT CERTIFICATE +APPENDIX C: +CUSTOMS DUTIES +NAME, ADDRESS AND TELEPHONE NUMBER OF BENEFICIARY: +NAME: Financial Trust Company, Inc. +PHYSICAL LOCATION: 6100 Red Hook Quarter, B-3, St. +MAILING ADDRESS: 6100 Red Hook Quarter, B-3, St. ' +_ VI 00802 +VI 00802 +TELEPHONE: (340) 775-2525 +Fax: (340) 775-2528 +NATURE AND EXTENT OF BENEFITS: +V.I. Customs Duties to be assessed on raw materials and component parts brought into +customs duty rate of one percent (1%). +COMMENCEMENT DATE OF BENEFITS: +Customs Duties Reduction Begins: Not Applicable +TERMINATION DATE OF BENEFITS: +Customs Duties Reduction Terminates Close of Business: Not Applicable +AUTHORITY FOR BENEFITS: Title 29 V.I. 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I certify that I am admitted to practice in this court. +Dated: New York, New York +May 25, 2023 +Respectfully submitted, +s/ Alan Schoenfeld +Alan Schoenfeld +WILMER CUTLER PICKERING +HALE AND DORR LLP +7 World Trade Center +250 Greenwich Street +New York, NY 10007 +Tel: (212) 937-7294 +alan.schoenfeld@wilmerhale.com +Attorney for JPMorgan Chase Bank, N.A. diff --git a/vision-fixhub/court-05/6f1c2a9ec29c04b6d67453f2e87c8c985156ceceb121d19b3dfe482f807bafec.receipt.json b/vision-fixhub/court-05/6f1c2a9ec29c04b6d67453f2e87c8c985156ceceb121d19b3dfe482f807bafec.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6a75141f30ff4ce1d2ad02a5779f60fe1ef22144 --- /dev/null +++ b/vision-fixhub/court-05/6f1c2a9ec29c04b6d67453f2e87c8c985156ceceb121d19b3dfe482f807bafec.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "6f1c2a9ec29c04b6d67453f2e87c8c985156ceceb121d19b3dfe482f807bafec", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e9857cb737265d947be0658edb2274d4ecc6e17bfa1bb3a2da6a0ea0600eb531", + "output_sha256": "738e1e6a5b06363162c06ae184f9b469e18889c7e023450d93b24a473c1adfbc", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6f7b762e27c30e3b77ca510b682df3591b159d0ad094b18cf794bda50a12438e.md b/vision-fixhub/court-05/6f7b762e27c30e3b77ca510b682df3591b159d0ad094b18cf794bda50a12438e.md new file mode 100644 index 0000000000000000000000000000000000000000..59049c94f147ddb748a969f0de6451ef379576a8 --- /dev/null +++ b/vision-fixhub/court-05/6f7b762e27c30e3b77ca510b682df3591b159d0ad094b18cf794bda50a12438e.md @@ -0,0 +1,1128 @@ +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 1 of 23 + + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 2 of 23 +Jes Staley appears to have a close relationship with Jeffrey Epstein, regularly communicating with him +and seeking advice from him including while Epstein is incarcerated. Other employees also +communicate with Epstein intermittently on a variety of matters. +• On July 10, 2008 Staley writes to Epstein, "I miss you. The world is in a tough place. Hang in +there." Epstein replies on July 11", "So am I." +• On July 16, 2008 Staley writes to Epstein: +• "Jamie wants me to tell him how much I should make this year, given the expected bank +results and my results. To put it in context, my business will be down around 15% this +year. What do you think? I hope you're managing. I miss our calls. Its boring without you +around? Do you have any books yet?" +• Epstein replies the next day, "Tell him a one million dollar increase to 25 mlllion... The +times are tougher and the market would pay more for you to be a trouble shooter at +one of the messes.. Plus options you can point out that your options aren;t worth +much, and that for two years you were underpaid.. He cannot reduce your salary... It +can't be stay with me and you'll be fine, and the future will take care of itself, and when +the future is tough ou get penalized... DO Not give in. I'll try to call later today" +• On July 18, 2008 Staley mentions to Epstein that he is in Miami three times in January and asks if +he can visit. Epstein replies "Yes,,don't give in to a reduction..." +• On July 31, 2008 Staley writes to Epstein "'''Hey boss, We just got done with Jamie's off site. I +think we did ok. The mortgage market continues to deteriorate. But with commodities coming +off we are betting that markets will start to improve.... I hope you are hangin there. Just think of +the island and my boat anchored in front. I do." +• On August 22, 2008 Staley writes to Epstein **'m trying to do two deals at the same time: buy +dimensional and sell american century. It's going to be an interesting fall. I will miss stopping by +your office for advice." +• On September 26, 2008 Staley writes to Epstein: +• "Wamu is an unbelievable deal. But thus is still going out of control. I need a break" +• Epstein replies the next day, "Ou'll have plent of time. Enjoy this, its a once in a lifetime +opportunity, make friends. Keep your eyes open for opportunity." +• Staley replies later on September 27, writing "I miss you. What a deal Jamie did. I'm +spending a lot of time with Treasury. The Private Bank has brought in $44 billion dollars +in the last two weeks. Unreal. Also, do u know +- I am throughing him +out of the bank on Monday. Thanks for the note." +• On September 29, 2008 Staley writes to Epstein "I hope you keep the island. We all may need to +live there." +• On October 10, 2008 Staley writes to Epstein * am dealing with the Fed on an idea to solve +things. I need a smart friend to help me think through this stuff. Can I get you out for a weekend +to help me (are they listening?). " +• On October 11-12, 2008 Staley forwards Epstein a term sheet that was sent to others at the +Treasury/Fed +• On November 9, 2008 Staley writes "My one exposure is if Glenn slips. He has to stay correct, +and show calmness." Glenn may be a reference to Glenn +who founded Highbridge. +• On December 30, 2008 Epstein writes to Staley, "sunday will not work for me ., everyone is +gone except the housekeepers, you are more than welcome to use the house. you will be well + +JPM-SDNYLIT-00901998 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 3 of 23 +looked after. the chef from paris is there." Staley replies the next day, I think I will head back. If +something changes, let me know. Otherwise I've asked Rosa to make a date free in early +January for me to visit the Palm Beach office and spend some time with you." +• On March 18, 2009 Staley writes to Epstein, "Sorry I missed you today. The TALF deal is a +big deal. Let's talk tomorrow." +• On April 24, 2009 Epstein writes to Staley, "American cemtury?" Staley replies the same day " +may have resolved it today. I will call u after lunch." +• On June 19, 2009 Staley writes to Epstein "We settled with Am Century. Details tomorrow. I +kept reminding myself of this being 'cute.' Thanks for your counsel." +• On July 22, 2008 Epstein writes to Staley "free and home." Staley replies the same day, "Three +solid days of reviewing our $20 b real estate portfolio" +• In September 2009, there are a number of e-mails in which it appears Epstein has advanced +knowledge of Staley's move into the IB CEO role: +• On September 3, 2009, Epstein writes to Staley "I am told you are on track." +• On September 11, 2009 Epstein writes to Staley, "slow thoughtful, un emotional... the +thought is that co=head of both asset and ib is ok,, steves really a dead man walking. so +little he can do." This appears to be a reference to Steve Black who was head of the +investment bank at JPMC until being named a Vice Chairman of the Firm in January +2010. Jes Staley became the sole CEO of the investment bank on the back of that move. +• On September 21, 2009 Epstein writes to Staley, "more edits? What day london?, keep +an eye on steve,, ithink he now knows" +• On September 25, 2009, Epstein writes to Staley, "message to be delivered THREE parts +1---| know this must be difficult for you....2.. I will really need you help. you've done a +great job …... 3. I would like this transistion to go as smooth as possible, and would +welcome any suggestions.==========Nothing more, short sweet in response to any +questions - there are lots of details to be worked out,.. you and I need to spend some +real time WHEN I GET BACK>" +• On September 27, 2009, Kristin Lemkau sends Staley a draft organizational +announcement regarding Steve Black becoming Executing/Vice Chairman and Staley +stepping into the CEO role. Staley then forwards to Epstein as "FYI." +• On September 28, 2009, Epstein writes to Staley, "Steve and you should agree +guidelines for comp,, so it protects you from him promising someone something for +next year that you will be forced to live with.. He and you should agree on comp., and +then he should execute.. stay out of it, but oversee it. your risk is he will make you look +like the bad guy, for people that you will have to win over/" +• On September 19-20, 2009 Epstein and Staley appear to exchange edits on a speech that Staley +is delivering which appears to be hosted by the Bahrain Economic Development Board, Central +Bank of Bahrain and Bahraini Association of Banks. +• On October 18, 2009 Epstein writes to Staley, "feel free to call often, it is difficult for the +quarterback to see the playing field. That's why he calls up to the box" +• On October 23, 2009, Epstein writes to Staley, "my suggestion Your first Great move, should be +a new CHina, initiative. first it was alternative investments now china., you should have a +dedicated china entity, with its own board of advisors, should include china politicos. they love +to travel. you should be their link to treasury.. or you can issue credit default swaps, for their + +JPM-SDNYLIT-00901999 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 4 of 23 +investment in us co, and you can ask the treasury to be the third party - just an example." +Staley replies, "Brilliant!" ( +• On October 25, 2009, Epstein writes to Staley, "One big problem that in china is how to maintain +good relationship (Guangxi) with the employees/ Chinese emphasize courtesy and face-saving. +This has to do with China's culture. Being courteous to government officials, and employees are +essential. Chinese people are hospitable, but it is easy to insult them..; like blacks who don't +want to be dissed This craziness is accentuated in the north, which has complex rules of 'facesaving'. I will send someone to you this week for a coffee, that will explain some of this" +On October 26, 2009, Epstein writes to Staley, "i have organized a quick tutorial for you +tomorrow any time,, oxford educated, speaks fluent chinese... the answer to" do you move your +trading op there is" ASK THEM... make the chinese part of the process.. i want to build a +relationship,, i seek your advice, we are in this for the long term. i have the greatest respect for +your culture, and will attempt to learn,, forgive me if i make mistakes early, it is only out of a +desire to learn,, BLAH BLAH BAH". Staley asks if they can be in London because he is there +"tonight and tomorrow night beginning the management changes I need to make." Epstein +writes that the individual is in New York and then "I will lay the groundwork" +• On October 27, 2009 Epstein writes Staley an extensive e-mail laying out the steps necessary for +JPMC to expand its business in China down to details surrounding culture, office locations and +suggestions for approaching government officials. +• On October 30, 2009 Staley asks Epstein "Any chance | can go to Santa Fe?" Then on November +1, 2009 Staley writes to Epstein "So when all hell breaks lose, and the world is crumbling, I will +come here, and be at peace. Presently, I'm in the hot tub with a | +of +wine. This is an +amazing place. Truly amazing. Next time, we're here together. I owe you much. And I deeply +appreciate our friendship. I have few so profound." +• On November 28, 2009, Epstein writes to Staley "I think you might want to approach abu dhabi, +and say as a key player in the world financial system, you will advise them for free. If and only if +they decide to implement your advicei.e. sale of assets. thats how you will be compensated. +just an idea" +• On November 29, 2009 Staley forwards Epstein what appears to be an internal e-mail regarding +discussions with senior officials in the Dubai and Abu Dhabi departments of finance. Brian +Sankey suggests that Jes Staley speak with Hani Deaibes who is a current JPMC employee +involved in Middle East Debt Capital Markets. +• On December 1, 2009 Epstein writes to Staley "The first most elegant deal that you can do. is to +have China buy Dubai World Ports. They want turnkey, ops where they can then use their +worldwide construction cos for building. would be a first great deal for the new ceo of the IB" +• On December 3, 2009, Staley writes to Epstein, "I realize the danger in sending this e-mail. But is +was great to be able, today, to give you, in New York City, a long heartfelt, hug. To my friend, +thanks. Jes" It appears that at this point in time Epstein was not permitted to leave the state of +Florida based on the terms of his sentence which provides context to the preface of Staley's e- +mail. +• On December 17, 2009 Epstein writes to Staley "do you think Jamie would consider upping the +amount paid to the small business fund by an additional 25. If the tax on bonuses was lowered?" +• On December 20, 2009, Staley sends an e-mail to Epstein which includes a lengthy list of bullet +points, some of which include confidential JPMC information, that appear to address questions + +JPM-SDNYLIT-00902000 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 5 of 23 +surrounding an internal discussion on compensation with JPMC (potentially for the Firm's Risk +Committee). +• On December 26, 2009 Epstein writes to Staley "I think your presentation to the risk commitee +should be made by others, and attended by you. " I've asked them to explain to US"... not you +explaining to them. its too early for you to be seen as lecturing. slowly slowly" +• On January 6, 2010 Staley writes to Epstein "Fun tonight. What do we do next?????" Jeffrey +Epstein e-mails Staley shortly after and writes my car and driver,, former dea armed. will pick +you up in st +we have all the on field permits.. helicopter also availble for a tour around, +... remember I own the two big marinas.. yacht haven grand, in st +and the marina at red +hook... you can use my atv's jet ski gym etc. , i will organize the harbor at Norman island if you +like, in the bvil. as well as lunch at guana." +• On January 11, 2010, Staley's Admin Assistant e-mails Epstein and writes "Hi Jeffrey: If +available, Jes would like to use the Yacht Haven Grand marina this Wednesday and Thursday +nights. At your convenience, can you please let me know who I can contact to arrange. Also, +can you please let me know if you have US Customs at the marina. Captain Bill Truesdale would +like to clear at the marina if possible. Many thanks, Rosa" +• On January 14, 2010, Staley writes to Epstein "Arrived at your harbor. Someday, we have to do +this together." +• On January 22, 2010, Epstein writes to Staley "As | said at dinner, you are perceived as too big. +however with the new campiagn finance law, you are also now seen as very very powerful. The +chancelor of the exchequer, Darling is willing to sit with you and discuss these issues in Davos. I +think you should decline, and set a real meeting. not a meeting squeezed between lunches and +others. We should talk." +• On January 25, 2010 Epstein writes to Staley "the more time you have to announce the better. +Ive set up you and peter to meet in davos with darling. it would be better afterwards to +announce. I would go slowly, this can set the stage for lots to come. Obama really wants a fight. +its crzy. " They took bailout money and then ....." the problems are all inherited, not of his +doing, he reached out a hand to help and was taken advantage of -, typical but problematic." +• On January 25, 2010 Staley sends Epstein an exact numerical breakdown of the number of JPMC +employees in the UK by office location. +• On January 27, 2010 Staley inquires with Epstein about whether he can assist in securing an +audience with either Peter Mandelson or Alistair Darling who was Chancellor of the Exchequer +at the time. +• On March 2, 2010, Staley's Admin Assistant e-mails Epstein (copying Lesley Groff at +Igroff@dkipllc.com) noting that Staley will "be there at 8:30pm". +• On March 18, 2010, Epstein writes to Staley "youre covered for the end of the month" to which +Staley replies "the stars align" +• On April 10, 2010 Tom Pritzker +has an e-mail exchange with Staley +about what appears to be a family office restructuring where they are engaged with JPMC. +Staley forwards the exchange to Epstein. +• On April 13, 2010 Staley writes to Epstein "Tom's handler for cash and investments is +John Stellato" +• On May 14, 2010 Staley's Admin Assistant e-mails Epstein meeting materials for a +meeting between Staley, Carlin and JPMC with Pritzker. + +JPM-SDNYLIT-00902001 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 6 of 23 +• On June 20, 2010 Epstein writes to Tom Pritzker and Staley "I spoke to the hutchinson +people, they prefer we waituntil the full year results are in. they definitely want out. +they want to show the spread between their 3g business and ports." +• On April 12, 2010, Epstein writes '1 +boyfriend, +woudl like to work at jpm..! +would very much appeciate it if we can get him in a training program for private banking,, he is +responsible 27, and very personable. he could be a great asset eventually to your florida office" +to which Staley replies "Have him send me his resume." [ +was the boyfriend of T +who was reported to be involved with Epstein's relationships with young women. He was +one of the most frequent visitors of Epstein while he was incarcerated in Palm Beach Florida. +• On May 5, 2010 Epstein writes to Staley "1 +is meeting with Charlie Farhoody and +Michael +tomorrow in palm beach" +• On May 10, 2010 Epstein writes to Staley "any word on +interview?" Staley replied +"It wasn't great. No role for now. They're letting him know." +• On June 9, 2010 Epstein writes to Staley "Do not sell cheap , it will look as you are trying to buy +goby" +• On June 12, 2010 Epstein writes to Staley "re. mgm. consider barry josephson , used ot run +paramount. good guy." +• On June 20, 2010 Staley forwards an internal guidance memo sent to senior executives at JPMC +regarding talking points around JPMC negotiations to buy Gavea Investimentos. Gavea was +acquired by JPMC with a strategic alliance with Highbridge. +• On September 2, 2010 Staley writes to Epstein "And I just had the most senior meeting JPM has +had save for Jamie meeting with +. I spent almost 2 hours with +of the +He will be in the +I will tell u what he offered/asked when we meet. Very cool. I'm seeing the Prince this +afternoon." +• On December 27, 2010 Epstein asks Staley where he is and Staley replies "In Bahia, on a beach +far from anything. No cell. Sporadic email. Nice break and no need for security. Back a week +from today. Scheduled dinner on Little St Jeff's on Jan 21st. I'm in Amerstdam on Jan 6 and +Zurich the 7 and 8th. Hope u r on the Island, and avoiding the foreign country called Palm Beach. +• On January 20, 2011 Tom Pritzker sends Epstein a photo and a note "A picture tells a thousand +words. Here is your happy birthday photo. What do all the people in this picture (save one) have +in common? tjp". Epstein forwards the email to Staley but it does not appear the photo comes +through. +• On January 21, 2011 Staley writes to Epstein "Anchored in Chrismas Cove. Heaven is being on +Bequia [Staley's boat]. Safe travels to Paris. And, as always, thanks for the friendship. Jes" +Epstein replies "You are welcome to use jet skis snorkels mpvies boats" +• On January 27, 2011 Epstein e-mails Staley an article E-Mails Show Bear Stearns Cheated Clients +out of Billions from The Atlantic. +• On February 13, 2011 Epstein asks Staley "Would you like heli in st barts" +• On March 3, 2011 Epstein writes to Staley, "Told you -.. family" to which Staley replies "family" +• On March 5, 2011 Epstein e-mails Staley "more bad press. Ignore it." Staley replies "The post?" +And Epstein replies "no, english papers have gone berserk,, claiming fbi re opening + +JPM-SDNYLIT-00902002 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 7 of 23 +investigation. not true,, publishinga phonebook that is not mine, butwas stolen by my +houseman cuurently in prison for doing so" +• On March 8, 2011 Epstein sends Staley a Vanity Fair article about Epstein and Ghislaine Maxwell +from that date. +• On March 10, 2011 Epstein writes to Staley "the English papers want andrews head, , tomorow +they will say the fbi investigation wants to talk to him,, its all bull, but it sells" +• On March 18, 2011 Epstein writes to Staley "Dear family member, don't fret," +• On June 13, 2011 Epstein writes to Paul Morris at JPMC regarding his interest (in the name of +Financial Trust) in a property in London at 11 Cadogan Gardens (appears to be $12m deposit or +purchase +• On June 13, 2011, Epstein writes to Paul Morris "can you have someone pull up all the details on +a co called OPERA in Norway,, I might want to make a run at it" +• On August 13, 2011 Staley writes to Epstein "we miss u" +• On May 2, 2012, Paul Morris of JPMC writes to Epstein "Jeffrey, separately, McGraw and I would +like to come see you and discuss your estate plan and what we are seeing with other clients." It +is unclear the extent to which JPMC employees were involved in Epstein's estate plans generally. +• On May 12, 2012 Epstein writes to Paul Morris "client buying a huge art work, what form should +he buy it in.. delaware trust. +. Ilc.. need answer mon night. (the scream, for your info +only)." Note that it was later publicized that Black had purchased the painting. A number of +e-mails are subsequently exchanged back and forth regarding the painting and logistics. On May +16, 2012 Paul Morris and Tom McGraw send Epstein a draft LLC structure for purchasing the +painting in the name of irrevecoble trusts on behalf of +• On June 1, 2012, David Giuffrida from JPMC (copying Paul +) wrote to Epstein "We gave +Larry Unrein your contact #s. He will be trying to get in touch with you." The subject was +"Jawbone" +• On June 30, 2012 Paul Morris writes to Epstein "Will get back to asap, if I can get a minute of +your time over the weekend that would be helpful. Many thanks Jeffrey." Epstein writes "what +is the question." Morris replies Jeffrey, sorry for being so limited on the emails but I guess I'm +too discreet. Anyway, I really appreciate everything you're doing and this is a fantastic +opportunity that you are opening the door to,. I briefed our ceo and think he will get a sense of +the LB relationship over the weekend. Come back to you asap and thank you again." Morris +replied a second time to Epstein's e-mail "No question just wanted to discuss conversation had +with our ceo about LB and that I wanted to get an indication out to you on an art loan. We will +circle up again Monday." +• On July 15, 2012 Jes Staley sends Epstein a draft organizational announcement regarding a move +by Jes Staley from IB CEO to focus on forming a Regulation and Technology council that would +"that will seek out and sponsor opportunities in technology and regulation that address the +evolving needs of global finance." The announcement is in draft and Epstein replies with his +proposed edits on the organizational announcement. +• On July 15, 2012, Epstein writes to Paul Morris "I would arpeciate it if someone in your shop put +together a sample portfolio of funds and products for a 100 million dollar. structured to yield +about 10%" Note that on September 20, 2012 Paul Morris writes to Epstein copying David +Giuffrida from JPMC "Jeffrey Would you like us to revisit the 100mm portfolio we discussed back +in July? Paul" + +JPM-SDNYLIT-00902003 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 8 of 23 +• On August 10, 2012 Epstein writes to Maurice Sonnenberg of JPMC "fun seeing you in san fran.. +Mr biology gurus at harvard all agree that the signal intelligence used by the various agencies, +could be put to work on breaking the dna code or protein signal problems. breaking foreign +codes is the expertise of the us and nsa. it would be great to know which agency button to +push" to which Sonnenberg replies "Hi Jeffrey. Good running into you. When you get back, give +me a ring and we might chat a little more about this." +• On November 8, 2012, Staley writes to Epstein "One challenge w oak tree is that deb doesn't +want to move to LA." +• On November 14, 2012, Staley writes to Epstein "Thanks for your friendship and generosity in +supporting this year's NY of Science fundraiser. The event was a great success and we could +not have done it without you." +• On October 30, 2013, Jes Staley sends a test e-mail to Epstein and a number of JPMC employees +and family members and friends from jstaley@bluemountaincapital.com. +Jeffrey Epstein appears to be helping Jes Staley with the graduate school admissions process for +• On April 27, 2009 Epstein E-mails Staley with the subject [ +which is +and +writes +can meet have dinner lunch a weekend with any of the following seth lloyd mit +quantum computing.. +gell-man, santa-fe institute, quarks , brian | +columbia - +string theory, leonard susskind ,, strings theory, +krause, origins institute phoenix +arizona.., lee smolin perimiter institute, loop quantum gravity , she can see the large hadron +collider in switzerland. private tour." +• On September 24, 2010 Staley forwards an e-mail thread between his wife +asking whether Epstein can get in touch with a Professor Robert +Mawhinney at Columbia University. Epstein replies he can do so "in a snap" +• On November 11, 2010 Staley sends +resume to Epstein and writes +" Epstein replies "she can sit with +Richard Axel when I get back, he won the Nobel prize... he has guaranteed me." Staley replies +" Epstein then writes back "john kluge gave 4 +billion to the school,, will you relax" +• On January 18, 2011, +writes to +Spoke with Jim today and he mentioned that +is what it is - not to worry - the score does not seem to be a problem according to my +sources...What's going on with your applications? Have you heard back from anyone? Any +thoughts or is +still high on your list? Look forward to hearing from you! Best, +"Huh?" on top of the e-mail, and then Staley forwards to Epstein and writes +• On January 19, 2011 Epstein writes to Staley "lee bollinger will come say hi, in davos as well". +Note that Lee Bollinger has been President of Columbia University since 2002. He has also +served on the Board of Directors of the Federal Reserve Bank in New York City. +• On January 19, 2011 Epstein writes "woody here from 7- 830,, richard axel sultan, leonwill stop +by, if you can, also alex is now 70-30 up from 45-55" + +JPM-SDNYLIT-00902004 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 9 of 23 +• On February 2, 2011 Staley writes to Epstein "spent an hour w the President." It is unclear if the +reference is to the President of Columbia, POTUS, or other. +• On March 5, 2011 Staley writes to Epstein "Deby and | were talking tonight about what you have +meant to me and to +_ You have paid a price for what has been accused. But we know what +u have done for us. And we count you as one of our deepest friends. And most honest of people. +Thanks, Jes" Epstein replies "family" +• On August 23, 2012 Staley writes to Epstein "I can't tell you how much your friendship has +meant to me. Thank you deeply for the last few weeks. All will be fine, and we have +. To my most cherished friend, Jes". Epstein replies "I appreciate you and your +thoughts" +• On December 9, 2012 +forwards the e-mail to Epstein and writes "FYI thanks" +• On April 15, 2014 +know about +are recipients of her e-mail among others. +[Jes "Got an A+ in QM." Jes Staley +e-mails a list of family and friends to let them +that she was involved in making. Both Epstein and Nikolic +Jeffrey Epstein makes limited references to his interest in women but no explicit references to age. +There are also some comments which, while unconfirmed, may have the appearance of relating to +inappropriate behavior with one reference between Epstein and Staley to a modeling agency: +• On August 27, 2009 Jes Staley writes to Epstein that he is on his (Staley's) boat and that he will +be "In London with Jamie, mid week." Epstein writes "how long london? Do you need anything +there?" Staley replies on August 29, 2009 with "Yep." +• On December 4, 2009 Epstein e-mails Staley and writes "you were with larry, and I had to put +up with..." Attached to the e-mail is an image of a young woman wearing a revealing outfit in a +modeling pose. Staley replies back the same day and writes "Don't tell me a | +wine." +• On December 20, 2009 Epstein e-mails Staley with a blank e-mail that includes an attachment +which appears to be a modeling photo of a young woman. +• On June 14, 2010 Staley writes to Epstein "he has a S&A next to him". Epstein replies "do you +mean t&a". Staley replies "Do u know a catherine keating (sp? _". Katherine Keating is daughter +of a former Australian Prime Minister who was shown in news reports leaving Epstein's home in +NYC while Prince Andrew waved to her while leaving. +• On June 16, 2010 Staley writes to Epstein "is she free tonight?" It is unclear what this is in +reference to. Epstein replies "call me" and Staley replies "I'm with A" which presumably may +have been Prince Andrew. +• On July 9, 2010 Staley writes to Epstein "Maybe they're tracking u?? That was fun. Say hi to +Snow +1." Epstein replies "what character would you like next" to which Staley replied +"Beauty and the Beast...." Epstein further replied "well one side is available" +• On November 24, 2010 Staley writes to Epstein "I'm here at some ball with +- She says u +slept with her!!" While Epstein was reported to have a social relationship with +it is unclear if this is the +being referenced. +• On December 31, 2010, Staley writes to Epstein "I'm here in brazil with three beautiful women. +Have a happy new year." Epstein replies that they have even more in common than he thinks. + +JPM-SDNYLIT-00902005 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 10 of 23 +• On March 11, 2011 Epstein writes to Staley "is there a problem with the letttr of credit in favor +of the modeling agency,, I was just told that PAul morris is not returning my guys calls. I called +him twice myself today, If you get a chance, nothing urgent" +Jeffrey Epstein appears to maintain relationships with a number of senior business executives and +senior government officials globally. +• On January 15, 2009, Epstein writes to Staley "...david gergen is coming to see me today.. we +should talk before twelve." David Gergen is the name of a former adviser to Presidents Nixon, +. Reagan and Clinton through 1994. +• On January 19, 2009, Andrew Farkas e-mails Epstein an update surrounding Turner +Construction's operations in Dubai. Andrew Farkas is a major real estate investor who founded +Island Capital Group and a is major donor to Harvard University. His family owned Alexander's +department stores. +• Farkas also appears to be friendly with Epstein and provides him with information on a sailboat +that has hit the market for purchase which Epstein forwards to Jes Staley. Recent news reports +have identified Farkas as an associate of Jeffrey Epstein who entered into a joint venture with +him to purchase the American Yacht Harbor at 6100 Red Hook Quarter in the USVI. The e-mail +address that appear to be affiliated with Farkas is +• Note that Epstein also appears to be close with Jonathan Farkas, another member of the Farkas +family, with whom he appears to have a business relationship. The e-mail address that appears +to be affiliated with Jonathan Farkas is +1. On April 2, 2009, Epstein forwards an e- +mail from Farkas to Jes Staley with a presentation on an investment management entity called +Asset Alliance. On April 6, 2009 Epstein asked Staley for his thoughts on the deck to which +Staley replied It raised more questions than answers. A diversified asset management business +with only $10 billion doesn't have much financial leverage. But, as you know, I like the business +of managing money." +• On March 29, 2012 Epstein writes to Paul Morris of JPMC "andrew farkas , can meet with you +on monday or tues,. to discuss the project" +• On August 9, 2009, Epstein writes to Staley "are you available to take a call from the chairman +of sal Oppenheim." Sal Oppenheim was a German Bank which became a subsidiary of Deutsche +Bank in 2010 and was rolled into the Deutsche Bank brand in 2017. +On September 20, 2009, Staley writes to Epstein "Meeting Blair in a few minutes" +• On October 16, 2009, Epstein writes to Staley "sorry, didn't get back to you last night.. had +sultan and one of putins people here" +• On April 4, 2010 Epstein asks Staley to call him. Staley replies "Apparently, Gates will be there +for dinner." Epstein replies "his right hand in boris nilolic.. and nathan, you should focus your +ques on boris" Epstein subsequently forwards an e-mail from Boris Nikolic that the meeting +scheduling is a mistake and that Bill Gates is in the Galapagos Islands and Boris is at other +meetings. +• On April 15, 2010 Staley and Epstein exchange e-mails regarding Steve Rattner who founded a +firm called Quadrangle. Based on the e-mail and an internat search Rattner was in the process +by being sued by the SEC for fraud while he was simultaneously looking to sue the Firm he +founded. + +JPM-SDNYLIT-00902006 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 11 of 23 +• On June 3, 2010 Epstein writes to Staley "Though it would be tough on her, I like the ida of +installing +- in london. for a couple of months at least. it could be seen aas a positive for the +fsa, and give her a real platform" +• On August 21, 2010 Epstein writes to Staley "ill be on my cell today at leons, going back to city +for dinner, coming back tomorow for movie +" +• On October 1, 2010 Epstein forwards an e-mail (sender unclear) to Staley with the subject line +"this is nuts" and the text: "jeffrey, please come. you may have private time with each. you +security clearance is approved. +• Bahrain, H.E. Shaikh Khalid bin Ahmed Al Khalifa +• Egypt, H.E. Mr. Ahmed Aboul Gheit +• Kuwait, H.E. Sheikh Dr. Mohammad Sabah al Salem al Sabah +Lebanon, H.E. Mr. Saad Harari, Prime Minister +• Luxembourg, H.E. Mr. Jean Asselborn +Morocco, H.E. Mr. Taieb Fassi-Fihri +• Nigeria, H.E. Henry Odein Ajumogobia +• Pakistan, H.E. Makhdoom Shah Mahmood Qureshi +Portugal, H.E. Mr. Luis Filipe Marques Amado +• Qatar, H.E. Sheikh Hamad bin Jassim bin Jabor Al-Thani +• South Korea, H.E. Mr. Yu Myung-hwan +• Spain, H.E. Mr. Miguel Ángel Moratinos Cuyaubé +• Switzerland, H.E. Ms. Micheline Calmy-Rey +• United Arab Emirates, H.R.H. Sheikh Abdullah bin Zayed Al Nahyan" +• On October 29, 2010, Epstein writes to Staley "some of the bigger players, and now sheik +mohammed from dubai, have asked for private talks. I need to decide how to gear up my +advisory business. grab a group from L +•. ? Hire 5-10 stars? . Larry?, peter? andrew?" +• On November 7, 2010 Epstein writes to Staley "Mohhamed alshayan was surprised you put so +much Tabasco on your meat" +• On January 3, 2011 Epstein writes to Staley "I am going to meet with Tim +_ Any ideas..?" +Staley replies "Oman." +• On January 7, 2011 Epstein writes to Peter Mandelson (copying Staley) "had breakfast with +Richard branson,, he is also a big fan of africa" +• On January 19, 2011 Laura Schreiner from JPMS writes to Epstein "Ace would love to speak to +Jeffrey. Can you please call Ace at 212-272-4605, or e-mail him a phone number where Jeffrey +can be reached?" +• On January 22, 2011 Epstein asks if Staley liked the kitchen. Staley replies "Terrific. Lots of +workers. What a paradise. When I retire, I'm going to put a mooring in front of your dock for my +boat. Amazing place. I think Larry is sad... Jes". Epstein then replies "do you want to join a gates +dinner in davos on wed.?" +• On January 31, 2011 Epstein writes to Staley "I will have gates alone for two days.. any input?" +Staley replies "As a start, I still like a lot your connection of Gates, nuclear energy, and the +middle east." +• On February 2, 2011 Epstein e-mails David Stern +copying +Staley "he is coming again today,?? any interest. Mr. Desmond Shum is the vice chairman and +CEO of Airport City Development Corporation and a member of the 11th session of Beijing's + +JPM-SDNYLIT-00902007 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 12 of 23 +Political Consultative Conference. Mr. Shum serves as a member of the standing committee of +the Institute of Finance and Banking, Chinese Academy of Social Sciences, and is the founder of +Kaifeng Foundation China. He is also an honorary trustee of Tsinghua University. He holds a +bachelor's degree in finance and accounting from University of Wisconsin, Madison, and an +executive MBA from a joint program of the Kellogg School of Business, Northwestern +University, and Hong Kong University of Science and Technology." Stern replies "I can meet with +him when I'm in Beijing next to see what to do with him" +• On February 5, 2011 Epstein forwards an e-mail to Staley that he appeared to receive from +Larry Summers +which says "What is real story on madoff? Shouldn't jpm +have known better? If they had no ob ligation to figure it out why should people private bank w +them." Staley replies "I can't reply in email. Will call." Staley writes to Epstein "Like taking +financial advice from the guy who single handily, create the biggest loss in the Harvard +Endowment's history." +On February 5, 2011 Epstein writes to Staley " +and sultan here for lunch" +• On February 10, 2011 Epstein writes to Staley "I told you this was crazy... His next stop is this +morning at my house 8 am for a couple of hours. Call me at home ny..." Epstein then links to +an article about Ehud Barak's schedule while visiting government officials in the United States. +• On February 14, 2011 Epstein writes to Staley "_ +I black and carl icahn will be on a boat in st +barts for the weekend" +• On February 16, 2011 Epstein writes to Staley "Bahrain, next up at bat. Heavy iranian input" +• On February 16, 2011 Epstein writes to Staley interesting call from glenn" +On March 15, 2011 David Stern wrote to Epstein "Today Fang Fang (JPM Vice Chairman Asia and +CEO China Investment Banking) called me because he believed we had a call scheduled. We did +not. He had nothing to say either. These guys are confused and need help...." Epstein forwarded +to Staley +• On March 23, 2011 Roy Navon writes to Jacob Frenkel and Jes Staley of JPMC "Against all odds, +we have been granted a meeting with Prime Minister Netanyahu." Staley then forwards the +note to Epstein and writes "Thanks." Epstein replies back "surprisee suprise" +• On April 10, 2011 Epstein writes to Staley "I will be back tomorow. Karim Wade son of the +senegalese president and one of the most important players in africa, will be at the house this +week, i think you will enjoy him." On April 16, 2011 Epstein sends another note to Staley "karim +wants to hedge a million barrels each quarter of oil buying. This is going to be fun" +• On May 3, 2011 Epstein writes to Staley "the son of the former primer minister will take you for +fun, i will send you his details". Later on May 3, 2011 Katherine Keating (referenced above and +daughter of former PM of Australia) sends Epstein her brother +Keating's +contact information. +• On July 28, 2011 Epstein writes to Mary Erdoes "motolla says he knows you forever" to which +Erdoes replies "Yup 15 yrs". Tommy Mottola has been referenced in prior identified +communications as someone with whom Epstein may have had a business relationship (Epstein +was on a call with JPMC relating to management of Mottola's money) +• On September 16, 2011 Epstein writes to Staley "eduardo tedodorni, , family head, and +member of agnelli family, owner of ferrari maserate and fiat will be with me next sat, save +time" + +JPM-SDNYLIT-00902008 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 13 of 23 +• On September 16, 2011 Epstein writes to Staley "co founder of facebook, and founder of +spotify, sean +I will be at the house for dinner on sunday -come" +• On July 28, 2012 Epstein forwards Staley an e-mail that appears to come from the President of +the Maldives Mohammed Waheed Hassan who writes " Hi I talked to our finance minister. He is +looking around to borrow upto 500 million dollars to be repaid over a ten year period +preferably with a period of one year. Would be very helpful to know what can be +expected under the current market conditions. Thanks you. Warm regards. Waheed". Note that +on August 31, 2012 a Reuters article noted that China had made a $500 million loan to the +Maldives. +Jeffrey Epstein appears to maintain a particularly close relationship with Prince Andrew the of +York and Lord Peter Mandelson, a senior member of the British Government. He also appears to have +a close relationship with Sultan Ahmed bin Sulayem who is a senior UAE official involved in ownership +of the Dubai Ports. +Lord Peter Mandelson +• On June 5, 2009 Epstein writes to Staley, "well for all intends and purposes peter mandelson is +now deputy prime minister." Note that there are a number of references to Peter Mandelson, +who was a senior government official in the UK. Epstein and Staley both appear to speak with +him and meet with him on a number of occasions. +• On June 17, 2009 Epstein writes to Staley, "peter will be staying at 71 st over weekend, do you +want to organize either you, or you and Jamie, quiertly, up to you." +• On October 12, 2009, Epstein sends an article to Staley regarding | +and an +apparent intent to sell certain assets with a note that "This is why you should sit with Peter." +• On January 29, 2010 Staley writes to Epstein Saw "Peter last night. Darling in 20 minutes. Will +talk again with Peter this AM." Epstein replies "my view is sempra is an asset that comes up +once every ten years. How does it fit in the global strategy?. does it give energy expertise. That +is one of the big world needs" Later that day, Epstein writes "was petie helpful? another idea. +you can always portray the purchase as done bu the investment bank, it should be the primary +buyer, the argument might go that if we eventually are forced to split the IB will have a stronger +franchise." The discussions appear to be related to JPMC efforts to purchase the +Bank of +Scotland's stake in Sempra Energy. +• On March 29, 2010 Peter Mandelson L +e-mails Epstein "Took +250 last night, 500 today. Feeling better. Can Jes send me email on issues re Dodds/Volcker." +Epstein forwards the e-mail to Staley and notes "jeffrey wrote: youll have it late monday early +tues.. can we set up a 20 minute call/ jes/me ?sometime before your meeting. tonight? +tomorrow??jes, you should decide on the " ask".. meeting with you and/or jamie-cutlerr, etc" +• On May 10, 2010 Epstein e-mails Peter Mandelson and writes "I like to see my suggestions come +to fruition" and then forwards the e-mail to Staley. +• On May 11, 2010 Epstein e-mails Staley writing "Peties quitting". The timing appeared to be +correlated with an election loss for Mandelson's party around that time period in the UK. +• On May 13, 2010 Epstein writes to Staley "lets talk tomorrow about petie. and deutschbank". +Staley replied "He sent me a note. I'm in Lond in two weeks." +• On May 16, 2010 Epstein asks Staley about his schedule while in London and writes "what days +will you be there? do you have time for the prince andrew and or peter" + +JPM-SDNYLIT-00902009 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 14 of 23 +• On May 27, 2010 Peter Mandelson writes to Epstein "This is thing I am speaking to in Shanghai. +If you can open the attachments you will see that the entire Chinese banking fraternity is +attending. Isn't it something that JPM should be represented at if they want to spread their +wings in China?" Epstein forwards Mandelson's e-mail to Staley writing "I think he is right. you +should read the attachments" +• On June 21, 2010 Staley asked Epstein "How did Peter M like his meeting with Peter Scher?" +• On October 7, 2010 Epstein writes to Staley "petie said he will be back in londong around nov +9th same time as doug wirth." +• On October 7, 2010 Staley forwards Epstein an e-mail from Peter Mandelson who writes "In +Congo Brazzaville last week, I talked at length with President Sassou N'Guesso, including about +the above new mine. Exploration, he told me, has been undertaken by a consortium of investors +backed by JP +. The government is reaching a final decision on whether to issue a full +mining licence. I spoke to the Minister of Mines about this, who is favourable to the licence, but +the President wanted to discuss it further with me. No obligation but if there is anyone in JPM +who might want to talk to me privately about this, please shout. I would be grateful for no +approaches to other third parties about this in meantime. Hope you are well. Sorry not to see +you in London this week." +• On October 8, 2010 Epstein writes to Staley "would it make sense to have peter have a +relationship with cazanov," +• On October 20, 2010 Epstein writes to Staley "petie is just back from russia and now in london" +• On October 21, 2010 it appears Staley met with Peter Mandelson. On the same date Epstein e- +mailed Staley writing "ok , pritsker coming to dinner tonight. think about casenov with peter or +Andrew" +• On October 27, 2010 Staley forwards Epstein an e-mail he sent to Peter Mandelson that appears +to include internal JPMC information on a deal regarding privatization of businesses in Russia. +Staley offers to his colleagues "When Lord Mandelson can help, please let me know." +• On November 12, 2010 Epstein writes to Staley "petie, and others in paris this weekend. " +Staley replies "12:00 at u r place. Is set" to which Epstein replies "Youre set" +• On January 22, 2011 Epstein sends Staley an e-mail with the subject "peter in paris with me" and +a link to a financial times article [unable to access the article]. +• On February 2, 2011 Epstein writes to Staley "are we still on for tomw/thurs night... petie is +here". Staley replies "I may have to deal with Glenn on a HB issue.... So much going on. Spain is +interesting. Spoke with the two largest business families in Egypt. The team here likes Stern. I fly +back thurs morning." +• On March 16, 2011 a reporter from the Daily Mail named Daniel | +Le-mails Epstein's lawyer +Jack Goldberger and writes: +• Hello, My name is Daniel L +and I cover New York for the Daily Mail. We are +following up something in relation to your client, Jeffrey Epstein, and I wanted to ask +you some questions ahead of the piece going in the paper. Both relate to a British man +called Peter Mandelson. We have been told that in March 2009 Mr Epstein was +contacted by Mr Mandelson who asked him to speak to Jamie Dimon, the chief +executive of JP +,, with a view to setting up discussions between the two men of +important financial matters. Is that correct? And is that a correct summary of the +conversation? Secondly, did Mr Epstein contact Mr Dimon on behalf of Mr Mandelson? + +JPM-SDNYLIT-00902010 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 15 of 23 +What was the nature of the conversation between the two men? We understand that at +the time this took place Mr Epstein was on day release following his conviction. I just +want to double check with you that is factually correct as well. Please let me know as +soon as you can - an article is due to go in the paper tomorrow." +• Goldberg forwards to Epstein with a note "ignoring" which is then forwarded to Staley. +Prince Andrew, [ +of York +• On June 24, 2009 Epstein writes to Staley, "Ask Andrew about tje island, tell him about your +boat plans." This appears to be a reference to Prince Andrew, the +of York, with whom +Epstein and Staley appear to speak and meet with on a number of occasions. +• On April 15, 2010 Epstein writes to Prince Andrew the of York +"jes +staley will be in london on thurs the 22.. i think you should meet if you are in town.." Prince +Andrew replies that he is unavailable but will look to visit New York in the near future. +• On May 18, 2010 Epstein writes to Staley "anadrew will try to see you on your trip to london" +• On June 14, 2010 Epstein writes to Staley "Andrew just sat next to me at dinner. We will try to +connect this week. Any word on M? This is fun." +• On August 29, 2010 Epstein writes to Staley "andrew will call tim, if you give me the numbers". +It is a reference to Tim +. CEO of Ripplewood Holdings. +• On September 2, 2010 Epstein writes to Staley "About to connect with Andrew." +• On September 2, 2010 Lesley Groff writes to Epstein "Jes Staley's office called saying last night +Jes met up with Prince Andrew and Tim +. Tim | +office calles Jes' office asking for +Prince Andrew's contact number. Jes' office does not have Prince Andrew's number and have +called us requesting it. Please advise." Epstein forwards the note to both Staley and Prince +Andrew. +• On September 28, 2010 Epstein writes to Staley "prince Andrew would like much more to +represent casanov in china than tim +". This may relate to JPMC Cazenove business in +London. +• On December 2, 2010 Jeffrey Epstein forwards an email to Staley from Prince Andrew with an +inquiry the Prince received from Aria Petroleum looking for a $200 million working capital line. +Since the company is based in the US Prince Andrew appeared to suggest Epstein connect them +with a US bank. +• On December 22, 2010 Prince Andrew writes to Jes "Wishing you a very happy Christmas and +New Year. Sorry to have missed you this week. I had to go to Afghanistan so couldn't be here +and couldn't tell you why or where I was. Hope to catch up sometime after the New Year. I will +be at Davos as usual." Staley replied "Be safe there. I bet it helps people that you're there. I will +get u the schedule of the JP +stuff. (Rosa - can u send the place and time of the +events in Davos). I must say, getting a Christmas note from The of York is sort of cool. +Sorry we missed in London. I was there to announce or deal in Canary Warf. We got pretty good +press. Maybe in London the next time I'm there, I could show u the building we bought. (The old +Lehman building). The mayor of London was funny as always." +• On February 28, 2011 Epstein writes to Staley "andrew asked for your london schedule" + +JPM-SDNYLIT-00902011 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 16 of 23 +Sultan Ahmed bin Sulayem +• Note that this relationship appears to play into references Epstein makes to Staley regarding a +suggestion for Staley to do a deal between the Chinese and UAE ports. +• On September 23, 2009 Sultan Ahmed bin Sulayem (senior official involved in Dubai ports and +Chairman/CEO of DP World) e-mails Epstein an article about a Liberian government minister, +Willis Knuckles, who lost his position when a picture was published of him engaged in sexual +relations with two women. Epstein then forwards the graphic image to Staley. +• On December 7, 2009 Epstein writes to Staley "if you can have a one on one off the record with +sultan, he will meet you..." +• On December 8, 2009 Epstein writes to Staley "no to china / ports yet... sultan will meet you +privately to give you guidance, on the players, the groundwork is well prepared. Remember you +are going as the senior statements, you do not need to talk about the nitty gritty of deals ,, leave +that to underlyings" +• On December 8, 2009 Epstein writes to Sultan bin Sulayem and writes "sultan, jes is free thurs,, +from 5-10pm. Where and when,, only the two of you please" +• On December 9, 2009 Epstein writes to Staley "sultan is laying the groundwork for you to +establish a serious presence... jpm reputation in the region is poor. I understand it comes from +not being fooled. However, I think it in your interest to rebuild. The swiss banks, are no longer +sacrosanct., the wealth management, and IB, are open opportunities and like china very much +personal." +• On December 10, 2009 Epstein asks Staley "having fun?" Staley replies " +. Just saw the +crown prince." +• On March 4, 2010 Sultan bin Sulayem e-mails Epstein a draft of a letter addressed to Jes Staley +regarding refinancing for Sulayem's ownership of +Hotel in London. Epstein replies that he +needs "to see the numbers" and then forwards the draft e-mail to Jes Staley. +Beginning in 2011 Jes Staley and Mary Erdoes have regular communication with Jeffrey Epstein +relating to certain strategic initiatives and business proposals. There are occasional personal e-mails +between Erdoes and Epstein interspersed within this time period. +• On February 6, 2011 Epstein writes to Staley "donor advised fund. :/ 1. you could tie it initally +just to thegates program,, minimum gift. 100 million. it could then be opend up later. IT will +be the largest foundation in the world. You need an advisroy board for 1, investments. 2. +distributions. . you will need an amministration, mirroring a mutual fund. 4. tax compiance +dept. dedicated to the operation. IT will underpin a trust and estate. dept, the size of which +will be enormous, 5. I would suggest, an irs auditor full time on site. 6, as a DAF, you will be +able to take in funky assets. (sub s, closely held c's, Art, ) valuation services.. sale and mgmt +D. done right its 100 billion dollars in 2 years. thetension is making money from +a Charitable Org. therefore the money making parts need to be arms length. salaries are +disclosable ,and closely watched. Farming the investments to a highbridge is no brainer, but +must be done with airtight opinions and reviewed by committees. I thought of University +Heads. Foundation Chairs,for the boards It will be the most sort after board in the country." +• On February 18, 2011 Epstein writes to Juliet Pullis from JPMC and Jes Staley and writes "It +would be a JPM donor advised fund,, A stellar board, broken down into investment committee +and distribution. There are a number of people that have pledged to give more than half of +their net worth to charity,, Bill gates and | +| Buffett Pledge program,, more than 60 billion + +JPM-SDNYLIT-00902012 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 17 of 23 +so far. .. The next step is unknown ,, They all have a tax advisor, but have no real clue on how +to give it away. ie. metrics re successful giving, review of broad areas etc. No set timeline, , +the cash pressure is enormous. , re anonymity,, not important but would not want to be seen as +supporting one bank. JPM would be an integral part. Not advisor, operator, compliance it +should be a jpm program to meet the needs of the pledgers. i would envision both already +received and yet to be received deductions. each donor individual, advises on type of +investment,, donor gets to suggest recipients as well as have ideas presented. Juliet,, please +review fidelity donor advised fund, for a similar structure, but without the very large minimums +that i would envision. ,." Staley replies only to Epstein "We need to talk." +• On February 25, 2011 Epstein writes to Staley "gates guys here today. - no reporters. I took care +of that. - stay calm and focused. we need to speak, I am staying until very late tonight.. seeing +gates re donor a f. on tues thru fri.. wed set aside for two -three hours. to discuss just this." +• On March 4, 2011 Staley sends Epstein a JPMC internal comparison of the Gates and +family +foundations. +• On August 2, 2011 Erdoes' Admin Assistant sends her a note "Called from Paris. He thought +you'd appreciate that he just got out of the pool at the Ritz. He'll call you back later." Erdoes +forwarded the note to Epstein writing "Rude and insensitive" +• On August 10, 2011 Epstein writes to Staley and Erdoes: +"for the meeting with Dick, we should have a complete presentation..IT needs to +address how it enhances current giving by GF. vaccines, maternal care,, These should +be two of the donor silos.. IT should have a structure, that for example purposes only, +has, the best investors in the role of advisors. ( we should decide whether being on the +investment commmitee, automatially disqualifies an investment in ones particular fund +, tor example if L +sat on the advisory board, should there be no apollo investments. ( +legal issue as well as optical ).. JPM acts as fiduciary in every capacity,,It should deal with +hard to value assets.. appreciated real estate., ( a real estate group, should be +available ). valuation firms, trust and estate experts. . The web based, investor access to +information, could set an example for simple user interface. click or touch an +investment silo to retrieve all relevant data, in many forms. This will be very HIGH +profile. I propose a minimum of 100 million donation . It will be the most exclusive of +clubs, In addition, though membersip in the "club" could be known . the gifts can be +given anonymously. This will fulfill the wishes of many that have spoken to bill about +wanting to do things but not wanting the publicity. For example funding Gay, Aids, +Jewish, orgs, that otherwise might bring unwanted attention to the giver by both the +press and its competing groups. For example, If someone wants to give money to a +program that in any way competes with their self or perceived image. Another school., +program etc. many have expressed reservations that giving publicily woudl send a +complex message to those institutions that have already close relations with the donor." +• Erdoes replies "Got it. We should fine a way to go through over next week or so when +• On August 11, 2011 Epstein writes to Erdoes "The| +bank rumor problem, i fear is only the +begginng.. as twitter and facebook have spurred the riots in the middle east., it is open to +abuse where a cybermessage goes to thousands to buy or sell X. or spread rumor a or b". Erdoes +replies to Epstein and Staley's gmail account +"We are trying to stem +rumors ourselves. But the BoFA, socgen stuff is rapid" +• On August 27, 2011 Epstein writes to Staley and Erdoes "Careful, the people at Gates- Gabriella +Fitzgerald is a a public advocacy person,, no real experience in anything but,, jennifer alcon is +very junior, Connie Colligswrth, and Dick. are the senior people, and they say they are getting + +JPM-SDNYLIT-00902013 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 18 of 23 +confusing messages from JPM. They say that JPM wants to use the current foundation to do +other things. Bill is at his country house. and most likely will not deal with it before wed. There +are too many people without direction. lets speak,," +• On August 28, 2011 Erdoes writes to Epstein "Jackie Elias, a young woman who is part of +philanthropy group, has been taking to Alcorn around the concept of a healthcare daf (this is on +the back of the healthcare summit) for months. Then about a month ago, Jackie, the Ray +and Gates foundation met and discussed importance and viability of on the health +care facility. That is not the same thing as what we have been working on for the meeting with +Dick, and I'm sorry that Gates people are confused. As for the meeting Wed, we do have a full 18 +page external book and a 138 page internal book. I will be speaking with cutler and jes this week +to discuss how to properly deal with you arranging this. Jes is likely more focused on Irene +attacking his boat at the current moment. " Epstein replies "I suggest you postpone the meeting, +your audience is not conditioned properly and i strongly believe it will do more harm than good +at the moment.. further details when we speak" +• On August 28, 2011 Erdoes e-mails Epstein and Staley a formal deck outlining their efforts +surrounding the creation of a Donor Advised Fund within the confines of the Gates Foundation. +It appears the initiative was named "Project Molecule" within JPMC. Staley e-mails Epstein an +updated version of the presentation on August 30, 2011. +• On August 31, 2011 Epstein e-mails Staley and Erdoes and writes "RE financail deal. ideas.. 1. I +think there will be many diverse and interesting opportunities to turn over almost turnkey +transactions to JPM.. The Middle East, as it re-forms. will be a gold mine of new transacations, +people, govt needs. I;m not sure of interest in places people , like syria, egypt, libya., though +there will be great needs and serious wealth and support. I am aware of the paramount need +for sunshine. The new issues is these leaders are wary, of a strictly JPM approach as it +represents to them a quasi- Us govt arm. +a. There can be a relation with JPM and me. Jpm +and a new or current investment boutique . ( Pritsker?, David Stern?, ( prince Andrew?, he is +now allowed to make money)) or Joint venture with IAn Osbourne, ( Bloomberg would +eventually join, if not otherwise occupied. -. There could be a fee / sharing. ( a bit boring but +standard for hedge funds. ( the money gets 1/2% - 1 out of the 2 fee,, and ussally 5 of the 20 +carry. I am well aware of my current unfortunate rainbow . I am also aware that JPM has a +colorful array of clients. so a client relationship is much less problematic than a instiutiioall +joint venture... on the flip side the G20 issues,, regulation, in europe. ( last time Great Britain +Jetc. was successfully handled. wiht no blow back, and i would argue great value to JPM. As +mary kinldy pointed out, last time with Highbridge, the outcome was less than perfect. I +would appreciate your/cutler thoughts., and as both of you have not jumped with enthusiasm +at the prospect of me sitting with him face to face, I leave it in your hands" +• On September 20, 2011 Epstein writes to Erdoes "I think the structure could be as simple as FTC +my co. getting ten percent of your profit. on the daf and its offshoots.... I am willing to put up +ten percent of the costs of formation.. It was my idea.. I will help see it through, It should be an +ongoing arrangement, I am aware that the private bank does not pay for its clients. I am +looking forward to seeing a written proposal soon as there will be an internal gates meeting +soon, and I would suggest we try to have an agreement if not finalized at least quite a way down +the path before that meeting. thanks hope you are swimming at the berkeley" +• On September 22, 2011 Epstein writes to Staley and Erdoes "IF you do decide to go to Seatle, I +think it might be helpful to review your plans". Erdoes replies "Team is going to go out next +thursday (I am in rome) so l am going to dial in. I can go out the following week but they want to +meet before an oct 1 meeting with Bg/Mg." + +JPM-SDNYLIT-00902014 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 19 of 23 +• On September 26, 2011 Epstein writes to Erdoes "I would suggest you bounce your ideas off me +before it goes too far down a road that might not be acceptable .. I met with Bill over two +months ago to set up the jes dick meeting, I know you are trying to come up with something +that is fair and balanced. and I appreciate it. I assume you mean tomorrow you will call ? If that +is not the case please let me know. Thanks" +• On September 28, 2011 Epstein writes to Staley and Erdoes "The proposal that Bill gets reduced +fees, and then channels the discount to me, is an idea that is still born for many of the reasons +that we discussed. I think the solution is quite simple. JPM engage an entity, ( a law firm, bank, +trust co.etc) that it pays a percentage of its profits on the DAF every year. This amount could +be supplemented or decreased by other business directly related to that entity (kazzak govt for +example ).. The only issues would be what type of entity and the relevant rules and reporting +requirements. and the amounts and how they are calculated. AS I had proposed, I stand willing +to pay my share of costs . legal etc. / An early iteration was that A bill entitty simply hired JPM +to do the administration for his DAF. I didnt think that was the right structure, as the profits +would mostly stay in his entity,, but maybe that can be revisited." +• On September 29, 2011 Epstein writes to Staley and Erdoes "A entity that passes all the tests +will be created. thats my responsiblity. We should agree on the fee structure, calculations +‚payments and we can easily move forward,,, i.e imagine you were paying pritskers investment +bank, I suggest that Jpm cacluate its profit. (method to be clearly enumerated), on the DAF, +first,, we can then add other types of transactions. I would start at 15%, you would start at 5, +we can after many back and forths now agree at 10%.. and move forward." +• On October 2, 2011 Epstein writes to Staley "JES ,, the daf is dying. due to cross purposes.....we +need to speak." +• On October 2, 2011 Epstein writes to Staley: +• "I saw Bill on Aug 16.. that was a year after my raising with him the DAF idea for the +first time. Since then, seperate from helping to tweak your presentation, there has +been little interaction between your team and me. I was very cognizant re settling our +legal issues to take that out of the equation. It is not going well. and at the moment +the chances of success are 50/ 50 at best. that is down from 95-5. This is not about +SOCIAL INVESTING". +Erdoes replies "I'm not following your thoughts below. Everyone is marching together to +create something very powerful and we will solve the comp issues. We worked on it this +weekend and have some thoughts on taking your last proposal and using revs not +profits and doing years 1-3. Not sure what makes this all only a 50/50 shot. ME" +Epstein writes "the comp issue is seperate.. the presentation, is not tailored to bill.. +He is the only person, the only one, that counts. and the feedback is not good. Your +side does not fully understand and cannot deal with the foundation internal politics. +This is a deal that can only really be done with Jes directly with Bill.. The comp issue will +be moot, anyway if this continues on this path. that being said, I see no reason that with +a ramp up as you are aware will be the greatest between years 3 and 5. any deal should +only be limited to the startup years." +• On October 3, 2011 Epstein writes to Staley and Erdoes "The pyramid of the DAF deal, is upside +down, with a wide swath of low level foundation people all attempting to drive /participate, / +screw it up. That being said I would like to see a real proposal today if possible. thanks." +• On October 4, 2011 after a number of follow up messages from Epstein to Erdoes Staley tells +Epstein to "stop pushing." Epstein replies to Staley "I m sure you are swamped. did not get your +schedule from roza. On mary, I will ease off, I thought I was following plan" + +JPM-SDNYLIT-00902015 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 20 of 23 +• On January 20, 2012 Erdoes writes to Epstein, "Not sure where you are celebrating it, but I hope +you have a great birthday weekend." Epstein replies, "Thanks, Boris said you were terrific" +• On September 14, 2013, Epstein writes to Erdoes "lets try to speak soon, before your Gates +meeting." Erdoes replies "Happy to talk early tomorrow am. What timezone will you be on?" +• On September 20, 2013 Epstein writes to Erdoes "answers?" Erdoes replies "I spoke to john +yesterday who has been in London, hence the delay. He will be calling you this am." +• On September 20, 2013 John Duffy writes to Epstein "Jeffrey - I have your answers happy to +discuss. I called earlier and will try you again before 3 and then before 4. In a mtg from 4 to 5." +The two exchanged additional e-mails coordinating a time for a phone call. +Certain messages appear to relate to lawsuits and litigation involving Epstein, JPMC, Bear Stearns, +Highbridge, Zwirn etc. or the Firm's maintenance of a relationship with Epstein in general. +• On August 26, 2010 Epstein writes to Staley "steve cutler sent alan greenberg a note, telling +him, you and isettled. ??? i haven't seen anything since our conversation.??" +• On September 16, 2010 Epstein writes to Staley (copying attorneys Darren Indyke and Harry +Susman) "I am having my attorneys now prepare my version of settlement. documents. 16 +million dollars. (35% 46m) --releases, that are clear and delineate the issues." +• On September 23, 2010 Epstein writes to Staley "can i send to steve cutler the terms under +which we would sign,, and then review the numbers". Later that day Epstein writes to Staley "im +told that FTC invested 15 in high grade but then rolled it into enhanced leverage for 21 million, +ftc invested ten million in abs, and couq invested 10 million in abs, for a total of 41 million,, the +lawsuit contained interest calculations, that I assume are not releveant... therefore total invested +41 million". He then forwards a draft settlement agreement to Staley asking that Staley forward +to Steve Cutler. +• On September 24, 2010 Epstein writes to Staley "i received a call from cutler.. I said thanks, i just +hung up with your boss., and he snidely replied JES is not my boss.. a difficult character". Staley +replies "He was head of SEC enforcement. He is a good guy at heart" +• On January 14, 2011 Epstein writes to Staley "thanks for today, , kenstarr, dershowitz... +lefkowitz at Kirkland. All very famililar with the nonsense. each, all, whatever, cutler wants or +needs." +• In February and March 2011, there appear to be a number of discussions involving Steve Cutler +where Epstein and his attorneys are looking to speak with him. There appears to be a call finally +scheduled for February 17, 2011 where Epstein writes to Staley "shwartz not cutler on call" +• On February 2, 2011 Epstein e-mails Staley and writes "did Cutler call Starr. ? I would be happy +to meet with him before or after a call" +• On February 7, 2011 Epstein writes to his attorney Kenneth Starr +"Kenny, Steve Culter at JPM , says he has left a number of messages for you.. I would really +appreciate it if you could call him. As I had mentioned to you,- He is the lead counsel for +, and needs to be reassured that I am a good egg - Steve's cell:| +• Thanks +in advance, and can't wait to see you face to face." Starr replied "Yikes. Will do. I got one +message, but not multiple. Apologies. Tomorrow first thing. Best, Ken." Starr then wrote "News +flash: We called late today. Left a message. Will try again tomorrow. Best, Ken." +• Staley wrote to Epstein on February 9, 2011 in regard to Starr's efforts to reach Steve Cutler, +"Anything more you would like me to do.? I will be in new york tomorrow at 1 thru Sunday." +Staley then writes "They must have the wrong numbers. Steve says he hasn't heard anything. +Can I have Rosa set up a call?" Epstein replied "Give steve kens email , I want him super +comfortable." Staley then e-mails Starr with Cutler's e-mail address and contact info. + +JPM-SDNYLIT-00902016 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 21 of 23 +• On March 20, 2011, Epstein writes to Staley "I m working on getting steve cutler the comfort he +needs". Staley replies "Agree" +• On March 24, 2011 Epstein writes to Staley "take photos.. call if you get a chance. I will be back +in ny 30-31, cutler? Shwartz? I m ready" +• On March 28, 2011 Epstein forwards Staley an e-mail with unclear sources that says "Jeffrey, It +should now be apparent to both you and Glenn's own counsel that there is a serious problem. +In today's email it states that Glenn now admits to knowing about the Zwirn plane in Sept or +Oct of 06.- both before your withdrawal notice of Nov 13.06. His protestations and rantings at +our last meeting, witnessed by his counsel confirmed "Had he known, he would never have +convinced you to only put in for your 80 million withdrawal". He is in a box. We know that +Schulte Roth was called in in May 06 , so that is really when he first found out. The money for +the plane was taken from the Highbridge managed acct. Highbridge was owned my JPM at that +time. This is ugly." +• On March 28, 2010, Epstein writes to Darren Indyke (dkiesq@aol.com) "detail for me glenns +involvement with zwirn mgmt. glenn and henry were limited partners of the gp management?" +Indyke replies "Will pull out lap top tonight but as I recall, dsam was Ip of db zwirn & co. Lp +which was investment manager of the fund. dsam was also member of db zwirn partners Ilc, the +fund's general partner, and a member of dbz gp, Ilc, which was the managing member of db +zwirn partners llc (the gp of the fund)." Epstein forwards the reply to Staley. +• On May 14, 2011 Epstein writes to Mary Erdoes "Wendall said he was not aware of the reason +to meet. ?? He knew it was something relating to Zwirn.?? Im available on my cell". Mary replies +"He knows" +• On May 23, 2011 Epstein writes to Erdoes "Thanks for today, Im not sure if you were aware that +I still have investments with Highbridge. As I have had since 2002. There is clearly a fiduciary +relationship that has existed since 02..* +• On May 24, 2011 Epstein writes to Erdoes "Is it possible to have nina at the wendel meeting at 4 +oclock with my attnys". Erdoes replies "Jeffrey - I am so sorry but 1 am just seeing this, having +been in an all day OC with Jamie. I hope the meeting went well. I'm anxious to hear." Epstein +replied "also, the SEC in its letter of reprimand , described Zwirn as a sub-advisor of +Highbridge." +• On May 24, 2011 Epstein writes to Erdoes "seperate and part from the money ,, fees were paid +to Zwirn/ - the total fees paid by FTC/JEEPERS to was $24,514,951 ($13,244,319 incentive +fees and $11,270,632 management fees)" +• On May 27, 2011 Epstein writes to Erdoes "IF you think right I am happy to meet with Jim +Condren, on the Highbridge issue as he said it was his area of responsibility... He is well aware +of the regs and is tough on plaintiffs". Erdoes replies "Yes great minds think alike. That is what +Nina and I discussed last night. Condren will join the team. ME" +• On May 27, 2011 Epstein left a message for Mary Erdoes and she replied that she is traveling +Tand will regroup after the Memorial Day weekend. +• On May 30, 2011 Epstein writes to Erdoes: +• "I think you should ask Wendall to recall the meeting he had with Sussman and Glenn. +Glenn was unequivocal., adamant ,and loud in front of them both - that had he known +about ziwrn taking money for the airplane (form the Highbridge acct no less, in dec of +04 ).. he would have immediatley told me to take all my money out. He said he would +have taken all his money out .. We only recently received the doc regarding the +schulte meeting., (shulte was called in in investigate the problem ), where though my +oral redemption request was in oct, and the written reduced demand on NOV. +13,schulte had a meeting in sept in which glenn attended, that informed Zwirn and + +JPM-SDNYLIT-00902017 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 22 of 23 +Glenn of the problem in detail. (wendall knows this!)/ I am aware of the issue being +legal vs moral duty. However, the legal is abundantly clear once all the documents are +reviewed, as opposed to only what wendalll has. I expressed in no uncertain terms in +talking with Condren that | view this as a dispute (Me vs JPM, in the Bear STearns case) +as a family disagreement,. hopefully not discounted, by my well stated desire, never to +file suit. that should not be a factor in a fair resolution of both issues. Im not sure if +Condren can say Jeffreys claim is worth x- million if he were to file a claim, and only x +minus, , now that we know he is unlikely to file". +• Erdoes replies "Yes, we are going to have Condren step in here on this issue as well as +the Bear issues. We will have everyone get together this week, if possible, and then we +will see what to do from there." +• Epstein replies "info needed, -- managed acct NAV at 10 /05 10/06. realized value,? .. +redemption schedule, we have documnets that schulte had a meeting to disclose +wrongdoing sept 06 BEFORE my withdrawal request and the discussions why I should +not redeem my entire 140 million. but reduce it to 80million. Managed acct should have +had virtually the same assets as the Fund.* +• On June 6, 2011 Epstein informs Erdoes that "we have asked for meeting with condren on +• On June 29, 2011 Epstein writes to Erdoes (copying Lesley Groff) "I think a call with you, me and +Condren today could be very helpful. I would like to try to resolve the Bear Stearns issues. Of +course it would be for settlement purposes only, and be held under our already agreed rules.- +preferably before 2pm" +• On June 30, 2011 Epstein, Condren and Darren Indyke are part of an e-mail chain surrounding +settlement discussions and the Bear High Grade Investment. +• On July 11, 2011 Epstein writes to Erdoes "the amount of my loss that i provided, did not +include pre-judgement interest that I would obviously ask for if we cannot agree. As l +suggested on our call- the 21 million, would / should make neither one of us happy, which i +think it does. I would appreciate a response. Thanks" +• On July 19, 2011, Epstein writes to Staley, Erdoes and Condren: +• "elim was very kind in offering me 5 million to settle the funds issue and 2.2 to settle +the +| claim. Again very professionally jim pointed out that jes had told him I agreed +to be treated like a retail client. Therefore..we we had in essence agreed to 5.. What I told +jim was that we were still in dispute over what amounts were in dispute. It is difficult +to understand how i would recieve the same settlement as a person who put 15 million +in the asset backed fund two weeks before the enhanced investment, though I had a +confirmantion that 20. 3 million was put in. Jims argumement that the increase value +that is reflected on my sunscription doc. should be totally ignored, does not seem fair. +I also asked jim, if in arbitration others had received an award greater than 30%, and he +told me he could not disclose that information. Mary when you and I are in the same +city, i would like to sit down and discuss,, Again, I have a great deal of respect for Jim , +and i have vocalized my appreciation for the way he has handled this to date." +Erdoes replies "Let talk by phone any time today" + +JPM-SDNYLIT-00902018 + + +Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 23 of 23 +• On July 20, 2011 Epstein writes "mary, Thank you for calling from dreary London today. +So that I may fully consider my options, please confirm in writing, the new offer. My +understanding is that you have agreed to use the full amount of subscription, 20 plus +million, and pay one third of that amount. In addiion you have offered ten cents on the +dollar for the claim.. I think it would be helpful if Jim could send the documents +he would want me to sign so that there are no misunderstandings.. Again, I sincerely +appreciate the good faith shown by your side." +Condren then replies: "So we're all clear, I think we should be using the exact numbers +instead of concepts -- the offer is for us to pay $9.2 million in exchange for a full release +concerning any claim (yet asserted or not) based on an investment in any Bear fund +(including High Grade, Enhanced Leverage and ABS) or in Bear +. If you want to think +of it as broken down into components, it's $7 million for High Grade/Enhanced Leverage +and $2.2 million for Bear +• As Mary mentioned, this is our final offer. I'll have one of +the lawyers in my group mark up the prior agreement and send it to Darren. JE, I have +personally very much appreciated how professional and candid you have been in our +dealings on these issues. We hope you appreciate (and believe you do) that this offer +represents an extraordinary effort on our part to resolve your claims. - Jim" +• On July 25, 2011 Condren sends a draft settlement agreement to Epstein and Darren Indyke +copying Mary Erdoes. Later that day Condren confirms to the same group "Jeffrey, thanks again +for the call and the kind thoughts. Just to let Mary know, we have a deal for $9.2 million. I will +work with Darren on whatever minor issues there may be with the settlement agreement (e.g., +as you mentioned, where we transfer the $). Best regards. - Jim" +• On October 17, 2011 Epstein writes to Staley "I would Ike to meet with steve cutler either thurs +or fri,?" +• On March 28, 2013, Paul +writes to Epstein "I would like you to meet John Duffy who is +the Private Bank CEO especially now that Jes has left. When are you next in NY? + +Ư9882H +60201Wr \ No newline at end of file diff --git a/vision-fixhub/court-05/6f7b762e27c30e3b77ca510b682df3591b159d0ad094b18cf794bda50a12438e.receipt.json b/vision-fixhub/court-05/6f7b762e27c30e3b77ca510b682df3591b159d0ad094b18cf794bda50a12438e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bad45cc72ba2371e71d59af076e270f2459df5a1 --- /dev/null +++ b/vision-fixhub/court-05/6f7b762e27c30e3b77ca510b682df3591b159d0ad094b18cf794bda50a12438e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -539, + "dataset": "marble-joined", + "doc_id": "6f7b762e27c30e3b77ca510b682df3591b159d0ad094b18cf794bda50a12438e", + "engine": "marble-apple-vision", + "event_count": 46, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "3bd2a94f601caeec3298a0795199d2c623852ea9c91dcc36fadbd8395e9b17ec", + "output_sha256": "d368c604fe6e41c19b5e5570fc8dc78d398fdf49282a99876372c415998ed9a4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6f7c5bfc43e20624a13683c312ade3e0ef2b5b67b407ef1a1cac0d9042a87ed7.md b/vision-fixhub/court-05/6f7c5bfc43e20624a13683c312ade3e0ef2b5b67b407ef1a1cac0d9042a87ed7.md new file mode 100644 index 0000000000000000000000000000000000000000..9b7fff3c8141ea38999f7df22a4f91441f464547 --- /dev/null +++ b/vision-fixhub/court-05/6f7c5bfc43e20624a13683c312ade3e0ef2b5b67b407ef1a1cac0d9042a87ed7.md @@ -0,0 +1,236 @@ +Case 1:22-cV-10904-JSR Document 194-16 Filed 06/20/23 Page 1 of 4 + + + +Case 1:22-cv-10904-JSR Document 194-16 Filed 06/20/23 Page 2 of 4 +United States Virgin İslands +ECONOMIC DEVELOPMENT COMMISION ANNUAL REPORT +Fiscal/Calendar Year Ending +December 31. 2013 +Southem Trust Company, Inc. +Teocatara Dra. Sales (Inelgible Sales) & Eigible for Tax Benefits... +Other Income (Ineligible) & Eligible for Tax Benafits +4,598.540 +Gross Wages Paid in the V.L. (Include vacation & sick pay, bonuses, overtime, etc.) +Averaga No. of Employees; Full Time & (Part Time/Other)... +Average No. of Residenis; Full Time & (Part Time/Other).. +Average No. of Non-Residents; Full Time & (Part Time/Other)... +Other Employee Costs (Unemploymont & hoath insurance, pension, allowance, elc.) +Employee Income Taxes Paid and Withheld +TAXES AND DUTIES (Provide dollar amount paid, end value of exemption/refund for each tax) +Gross Racelpts: +Real Property Tax: +Excise Taxes: +Amount Pald +Dollar Value of Examplion +Amount Paid +Dollar Value of Exemption +Total Paid +Dollar Value of Exemption/Flefund +Income Taxes: +Tola! Paid +Dollar Value of Exemption/Refund +Customs Duties: +Total Pald +Dollar Value of Exemplion/Refund +Other: +Hother Taxes. Kee Paid 10 V. Geverment +OTAL TAXES PAID +OTAL VALUE OF EXEMPTIONS AND OR REFUNDS +EXPENDITURES FOR GOODS, SERVICES, PLANT & EQUIPMENT +Eligible Supplier +V.l. Suppliers +Goods and Services: +Raw materials, components +Frog, chape +lities (tel, water, alect. etc. +terest & Olher Bank Ch +Supples +Rupairs/Maintenance +Other (List Separalely) +Subtotal, Goods and Svca: +Capital Expenditures: +Building & Improvoments +Leasehold Improvements +Machinery / Equipmant +Furniture / Fixtures +Vehicles +ther (List Separataly +iubtolaf, Capital Expend +GRAND TOTALS +CUMULATIVE CAPITAL EXPENDITURES UNDER EDC CERTIFICATE +Name/Signature of Preparer: +3,419 +6.670 +10.089 +3,185 +14,030 +56.051 +538 +6,157 +8,153 +113,380 +202,394 +7.232 +823 +8.055 +-210,449 +Non-Local +4,524 +762,714 +39 +4,183 +771,460 +10,089 +771,460 S +- Talephone Number: +10/14/15 +340-775-2525 +51,000,000 +9,834,115 +544,808 + +165811. +2,550,000 +2,143.371 +19,290,340 +1,297 +2.144.668 +21.840,340 +Totals +7,709 +778,744 +56,96T +_57Z +6,157 +11.572 +124,233 +983,943 +7232 +823. +2,065. +991,998 +4,055. +Page 1 +VI-JPM-000007315 + + +Case 1:22-cv-10904-JSR Document 194-16 Filed 06/20/23 Page 3 of 4 +Company Name: +Goods and Services: +Dues and subscriplions +Seminars and educalion +Postage and delivery +Travel and related +Meals and transportation +EDC Feen - Compliance, WDF +Rent +Office expanses +Business expenses +Other expenses +Subtatal, Goods and Sves: +Fiscal/Calendar Year Ending +Southern Truel Company, Ine. +EXPENDITURES FOR GOODS, SERVICES, PLANT & EQUIPMENT -Other +Eligible Supplier +V.l. Suppliers +135 +1,367 +067 +3,267 +5,500 +89.952. +6,670 +6,504 +5275. +713 +6,670 +113,380 +OTHER EMPLOYEE COSTS +December 31. 2013 +Non-Local +415. +599 +2,890 +4,184 +Totals +550 +387 : +3,267 +5,500 Y +89,662 +15,864 +5,275 +713 +124,234 +mployee benefits - health insurance and life insurance +imple IRA 3% employer contributions +: +117,531 +11,309 +Charitnble contributions +EXPENDITURES FOR CHARITABLE CONTRIBUTIONS -2013 +V.l. Public Education V.l. Charity +76.000 s +20,925 s +Totals +-96.924 +Name - recipient +D. O. E. Difice of Insultu Superintendent / +Aniversity of the Virgin bland +| Raformed Church +Community Foundation of the V. I. +Zero Tolerance Baskelball Org. inc. +Wasley Methodist Church +Total Chartistle Giving +Amount +56,000 +20,000 +76,000 +2000C +3,864 +500 +1,000 +10,000 +30027 +25.924 +Page 2 +VI-JPM-000007316 + + +UNTIED STATES VIRGIN ISLANDS +EDC ANNUAL REPORT +Value of Exemptions of Stockholders/Partners/Members +Case 1:22-cv-10904-JSR Document 194-16 Filed 06/20/23 +: Page 4 of 4 +Tuvestors Dream +BENEFICIARY. +Stockholders, +Partners or Members +Jeffrey E. Epstein +Social Security +No. +Physical +Address +Little Saint James +Island, St. Thomas +Southern Trust Company, Inc. +% +Distributable +Business +Shares +EDC Income +Activity +See page 1 of +See page 1 +100 +EDC Annual +of EDC +Annual +report. +Fiscal Year Ending Resember 31.2013 +Balance Tax +Total Tax Due EDC Credit +report. +TOTAL-S +Note: Totals of EDC Credit and Balance Tax Due must be carried forward to the EDC Annual Report and reported under Taxes and Duties (See instructions). \ No newline at end of file diff --git a/vision-fixhub/court-05/6f7c5bfc43e20624a13683c312ade3e0ef2b5b67b407ef1a1cac0d9042a87ed7.receipt.json b/vision-fixhub/court-05/6f7c5bfc43e20624a13683c312ade3e0ef2b5b67b407ef1a1cac0d9042a87ed7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..89e3a8267c50c2b4895c1a6319bb3b1eb64703d9 --- /dev/null +++ b/vision-fixhub/court-05/6f7c5bfc43e20624a13683c312ade3e0ef2b5b67b407ef1a1cac0d9042a87ed7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -209, + "dataset": "marble-joined", + "doc_id": "6f7c5bfc43e20624a13683c312ade3e0ef2b5b67b407ef1a1cac0d9042a87ed7", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "12fdece4249be0323b5995a9fa1154b9a5616fed298324ba217988dad65627c7", + "output_sha256": "09c5d55e6fbc947f7792687b7ed645d1d545df58670887aba0d42b15134a9a2c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6f91e053e7f8f8d2f25cf2e05092cf7b2f95f41082256a14fb5f341c0445df46.md b/vision-fixhub/court-05/6f91e053e7f8f8d2f25cf2e05092cf7b2f95f41082256a14fb5f341c0445df46.md new file mode 100644 index 0000000000000000000000000000000000000000..1e6ebaba7c777fa0e13070bf76bed458c941f3d1 --- /dev/null +++ b/vision-fixhub/court-05/6f91e053e7f8f8d2f25cf2e05092cf7b2f95f41082256a14fb5f341c0445df46.md @@ -0,0 +1,18 @@ +Case 1:22-cv-10904-JSR Document 11-2 Filed 01/06/23 Page 1 of 1 +Certificate of Admission +To the Bar of Illinois +1, Cynthia A. Grant, Clerk of the Supreme Court of Illinois, do hereby certify that +Elizabeth Paige Boggs +has been duly licensed and admitted to practice as an Attorney and Counselor at +Law within this State; has duly taken the required oath to support the +CONSTITUTION OF THE UNITED STATES and of the STATE OF ILLINOIS, and +also the oath of office prescribed by law, that said name was entered upon the Roll +of Attorneys and Counselors in my office on 11/05/2009 and is in good standing, so +far as the records of this office disclose. +IN WITNESS WHEREOF, I have hereunto +subscribed my name and affixed the +seal of said Court, this 29th day of +December, 2022. +Cynthia A. Grant +Clerk +Supreme Court of the State of Illinois diff --git a/vision-fixhub/court-05/6f91e053e7f8f8d2f25cf2e05092cf7b2f95f41082256a14fb5f341c0445df46.receipt.json b/vision-fixhub/court-05/6f91e053e7f8f8d2f25cf2e05092cf7b2f95f41082256a14fb5f341c0445df46.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ac7003b9ed1551f3d30dd74cab4a6c014229cb4b --- /dev/null +++ b/vision-fixhub/court-05/6f91e053e7f8f8d2f25cf2e05092cf7b2f95f41082256a14fb5f341c0445df46.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "6f91e053e7f8f8d2f25cf2e05092cf7b2f95f41082256a14fb5f341c0445df46", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "69b4a8cbb1dfaefc664e121637959b7a4041900791ba03777afd5f3f0dc87b43", + "output_sha256": "98f25e763ff0e34b1072289c6de1e4ddb9d113ec76967b3a41888d677199eb34", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6fa42bfa4b60b8d8cdca627a09bead56feab8f75b63ade5f577b0b2ec9a5c88a.md b/vision-fixhub/court-05/6fa42bfa4b60b8d8cdca627a09bead56feab8f75b63ade5f577b0b2ec9a5c88a.md new file mode 100644 index 0000000000000000000000000000000000000000..aa8822c1479e74b197082e040994f06e48e80568 --- /dev/null +++ b/vision-fixhub/court-05/6fa42bfa4b60b8d8cdca627a09bead56feab8f75b63ade5f577b0b2ec9a5c88a.md @@ -0,0 +1,107 @@ +Case 1:22-cV-10904-JSR Document 285-89 Filed 08/15/23 Page 1 of 4 + + + +From: +To: +CC: +Sent: +Subject: +Attachments: +Case 1:22-cv-10904-JSR Document 285-89 Filed 08/15/23 Page 2 of 4 +janet.e.young@jpmorgan.com +james.v.scurria@jpmorgan.com +CSG_AO_DE_NYC2@jpmchase.com +$100mm) fee schedule. Please let me know if that is something you can do via the update or if I +need to have CSS execute. +Thanks! +Магу +Mary +Managing Director +Private Bank +345 Park Ave. +New York, NY 10154 +tel: 212-464-0374 +fax: 212-464-1311 +-- Forwarded by Mary C +VIPMCHASE on 01/15/2009 06:04 PM ----- +J.P. +Securities Ine. Private Bank & PrivateClientServices Supervisory Management +Lisa E. +Waters/JPMCHASE +01/15/2009 01:24 PM +ToCatherine Keating/JPMCHASE@JPMCHASE, Mary C +JPMCHASE @ JPMCHASE, Marcus +sheridan/JPMCHASE @JPMCHASE, John R +Duffy/JPMCHASE@JPMCHASE, Jeffrey M +Matusow/JPMCHASE a JPMCHASE, Kevin +McCleerey/JPMCHASE @JPMCHASE +SubjectEpstein- brokerage coverage going forward +Jes has confirmed that Epstein will not have a brokerage relationship with PB. Brokerage will be handled by the +existing Bear PCS team. +Client will continue to maintain banking and custody accounts with PB. +Lisa E. Waters + +JPM-SDNYLIT-00004788 + + +Managing DirectCase 1:22-CV-10904-JSR Document 285-89 Filed 08/15/23 Page 4 of 4 +Securities Inc. +(212) 464-2048 diff --git a/vision-fixhub/court-05/6fa42bfa4b60b8d8cdca627a09bead56feab8f75b63ade5f577b0b2ec9a5c88a.receipt.json b/vision-fixhub/court-05/6fa42bfa4b60b8d8cdca627a09bead56feab8f75b63ade5f577b0b2ec9a5c88a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e2263625123edef4c5332e979468cd7ddb5df1f4 --- /dev/null +++ b/vision-fixhub/court-05/6fa42bfa4b60b8d8cdca627a09bead56feab8f75b63ade5f577b0b2ec9a5c88a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -71, + "dataset": "marble-joined", + "doc_id": "6fa42bfa4b60b8d8cdca627a09bead56feab8f75b63ade5f577b0b2ec9a5c88a", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "dca3f1fcf2eb84af006d353f6d96a1875c923d8aaef7c5fc92a693f709cf7828", + "output_sha256": "4f838d318cdb308b6d6cf513f181b87e6266f02a9de496cb8a910f7e692b0240", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6fae585856a3c1a825b3cb126ae6a04d82b82d00290d387d6f9e035b51a7c59f.md b/vision-fixhub/court-05/6fae585856a3c1a825b3cb126ae6a04d82b82d00290d387d6f9e035b51a7c59f.md new file mode 100644 index 0000000000000000000000000000000000000000..8c55abf3144452cd61de8ca06073f1dee13a3b8a --- /dev/null +++ b/vision-fixhub/court-05/6fae585856a3c1a825b3cb126ae6a04d82b82d00290d387d6f9e035b51a7c59f.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 311-32 Filed 08/25/23 + + +Filed Under Seal diff --git a/vision-fixhub/court-05/6fae585856a3c1a825b3cb126ae6a04d82b82d00290d387d6f9e035b51a7c59f.receipt.json b/vision-fixhub/court-05/6fae585856a3c1a825b3cb126ae6a04d82b82d00290d387d6f9e035b51a7c59f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..42bca8c16e34ea6eb5df78333dd961ed1c247d6b --- /dev/null +++ b/vision-fixhub/court-05/6fae585856a3c1a825b3cb126ae6a04d82b82d00290d387d6f9e035b51a7c59f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "6fae585856a3c1a825b3cb126ae6a04d82b82d00290d387d6f9e035b51a7c59f", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "1f119b67fc2b788d7373ade11093f5d167bcee9ce0080c68824bf1bec456c4c1", + "output_sha256": "c7e9abada14179fc8e903867ad7cae74a121ab8a7558aa0c0add632272647bcf", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6fcdaf4245dbf7be6376e812c779372f90bc3ee50c7f216c991e0e67c2d3f78b.md b/vision-fixhub/court-05/6fcdaf4245dbf7be6376e812c779372f90bc3ee50c7f216c991e0e67c2d3f78b.md new file mode 100644 index 0000000000000000000000000000000000000000..caef6d28ef79bd99dad20112f43dfc81dc59dfac --- /dev/null +++ b/vision-fixhub/court-05/6fcdaf4245dbf7be6376e812c779372f90bc3ee50c7f216c991e0e67c2d3f78b.md @@ -0,0 +1,103 @@ +Case 1:22-cV-10904-JSR Document 186-21 Filed 06/14/23 Page 1 of 2 + + + +Tuition Bill +Case 1:22-cv-10904-JSR Document 186-21 Filed 06/14/23 Page 2 Bege 1 of l +SKIDMORE +Bank Information +Account # Lockbox Type + +AMOUNT DUE +$24,955.50 +DATE DUE +08/01/2011 +AMOUNT PAID +$ +Bursar's Office +www.skidmore.edu/bursar +Skidmore ID: +Please make your check payable to +skidmore College and remit to: +Stidmore College +PO Box 374 +Saratoga Springs NY 12866-0374 +Please do not send any other correspondence with this +payment. Please mail all other correspondence to: +Skidmore College Bursar's Office +815 N Doadway +Saratoga Springs NY 12866-1632 +(Cut along dotted line and return top portion with your payment) +SKIDMORE +STATEMENT OF STUDENT ACCOUNT +Bursar's Office ~ 815 N Broadway ~ Saratoga Springs NY ~ 12866-1632 +Phone +m Fax +~ www.skidmore.edu/bursar +Name: Rene delongh +Account #: 219534 +BIll Date: 07/01/2011 +STUDENT ACCOUNT ACTIVITY (Charges & Credits) +Transaction details for activity occurring between 03/01/2011 and 07/01/2011 +Bill #: 78992 +Date +Term +Transaction # Description +103/23/2011 + +Direct Payment +05/19/2011 Spring 10-11 389571 +Library Fine +06/24/2011 Spring 10-11 391519 +Bullding Damage Fee +06/28/2011 Fall 11-12 + +Tuition +05/28/2011 Fall 11-12 + +Residence Fee - Scribner Village Ap +Fall 11-12 +Required Fees +06/29/2011 + +Returning Deposit Transfer +Balance Forward +CHARGES +$3,252.10 +CREDITS +$.00 +$3,252.10 +$5.00 +$75.50 +$20,760.00 +$4,085.00 +$430.00 +TOTAL +CHARGES +$28,607.60 +$400.00 +TOTAL +CREDITS +ACCOUNT +BALANCE +$3,652.10 +[$24,955.50 +PLANNED FINANCIAL AID CREDITS (Anticipated Financial Ald Disbursements) +Baling for Fall term will display Fall planned fancial aid only. Bling for Spring term wil display Fall & Spring financial ald. +Term Description +Planned Credit Amount +LANNE +INANCIA +AID +$.00 +AMOUNT DUE (ACCOUNT BALANCE LESS PLANNED FINANCIAL AID) $24,955.50 +DATE DUE 08/01/2011 +PLEASE REMIT PAYMENT BY AUGUST IST TO AVOID A LATE FEE +FALL 2011 +$20,760.00 +Due +8|1/11 +Student ID: +https://bosebill.salliemae.com/NetPay/EBPP/SC/Main/Tuition+and+Fees/999/ViewBill.as... 7/27/2011 + +ESTATE_JPMO24549 diff --git a/vision-fixhub/court-05/6fcdaf4245dbf7be6376e812c779372f90bc3ee50c7f216c991e0e67c2d3f78b.receipt.json b/vision-fixhub/court-05/6fcdaf4245dbf7be6376e812c779372f90bc3ee50c7f216c991e0e67c2d3f78b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ab9f6ba45bb326106c1b63fd30f5b67f3a16cc60 --- /dev/null +++ b/vision-fixhub/court-05/6fcdaf4245dbf7be6376e812c779372f90bc3ee50c7f216c991e0e67c2d3f78b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -76, + "dataset": "marble-joined", + "doc_id": "6fcdaf4245dbf7be6376e812c779372f90bc3ee50c7f216c991e0e67c2d3f78b", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "e355a68b8f3fc49aa5e82fc8a74882c8a55426e4987c01d5b3d5e9ae98a52295", + "output_sha256": "0cebbf146ca450db11020670bd65659473d28d5bc82b5515b8290d2880f780fe", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/6fe632a907760237fdca4618286fa14e830e6555d15fed411d677647a273e3f3.md b/vision-fixhub/court-05/6fe632a907760237fdca4618286fa14e830e6555d15fed411d677647a273e3f3.md new file mode 100644 index 0000000000000000000000000000000000000000..2b0e8aea65887126f10cd152fd9761d1b573f0c4 --- /dev/null +++ b/vision-fixhub/court-05/6fe632a907760237fdca4618286fa14e830e6555d15fed411d677647a273e3f3.md @@ -0,0 +1,42 @@ +Case 1:22-cv-10904-JSR Document 333 Filed 09/19/23 Page 1 of 2 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +JANE DOE 1, Individually and on Behalf of +All Others Similarly Situated, +Plaintiff, +22-cV-10019 (JSR) +-V- +JPMORGAN CHASE BANK, N.A., +Defendant/Third-Party Plaintiff, +-y- +JAMES EDWARD STALEY, +Third-Party Defendant. +GOVERNMENT OF THE UNITED STATES VIRGIN +ISLANDS, +22-cv-10904 (JSR) +ORDER +Plaintiff, +-V- +JPMORGAN CHASE BANK, N.A., +Defendant/Third-Party Plaintiff, +-V- +JAMES EDWARD STALEY, +Third-Party Defendant. +JED S. RAKOFF, U.S.D.J.: +On July 26, 2023, third-party defendant James Staley moved to +compel the production of certain requested documents from JPMorgan +Chase Bank, N.A. ("JPMorgan") withheld on privilege grounds. See Dkt. +1 + + +Case 1:22-cv-10904-JSR Document 333 Filed 09/19/23 Page 2 of 2 +248. After full consideration of letter briefing submitted by Staley +and JPMorgan, the Court hereby denies Staley's motion. +The Clerk is respectfully directed to close entry number 248 on +the docket of Government of the United States Virgin Islands v. JP +Chase Bank, N.A., 22-cv-10904. +SO ORDERED. +New York, ny +september f7, 2023 +• U.S.D.J. +2 diff --git a/vision-fixhub/court-05/6fe632a907760237fdca4618286fa14e830e6555d15fed411d677647a273e3f3.receipt.json b/vision-fixhub/court-05/6fe632a907760237fdca4618286fa14e830e6555d15fed411d677647a273e3f3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..95e68ba6671cf715b4bb444b00164e1eaf7123b9 --- /dev/null +++ b/vision-fixhub/court-05/6fe632a907760237fdca4618286fa14e830e6555d15fed411d677647a273e3f3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "6fe632a907760237fdca4618286fa14e830e6555d15fed411d677647a273e3f3", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "96de1407d449a2df06665c02a974c5f20e31729fa23b44f267b40626a70dbd7d", + "output_sha256": "5418bd79180dc1d0d7d6363776916e41b25331eaa4f1278c8e26d7385e68be86", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7023600a231a9bd0cbc8d3d8ac8d070273578eec8c9ecaaed8e78d31fbb6fc64.md b/vision-fixhub/court-05/7023600a231a9bd0cbc8d3d8ac8d070273578eec8c9ecaaed8e78d31fbb6fc64.md new file mode 100644 index 0000000000000000000000000000000000000000..6a688176a586fc6427705889fd87c6615ceb0f5d --- /dev/null +++ b/vision-fixhub/court-05/7023600a231a9bd0cbc8d3d8ac8d070273578eec8c9ecaaed8e78d31fbb6fc64.md @@ -0,0 +1,41 @@ +Case 1:22-cv-10904-JSR Document 28-3 Filed 01/20/23 Page 1 of 2 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +[PROPOSED] ORDER FOR MOTION FOR ISSUANCE OF +LETTER OF REQUEST (LETTER ROGATORY) +Upon consideration of the Motion for Issuance of Letter of Request (Letter Rogatory) dated +January 20, 2023, the exhibits annexed thereto, and any oppositions or replies filed with respect to +the Motion, and it appearing that the testimony of and documents in the possession of Miles +Alexander, a resident of South Africa, is material and necessary to the issues of this action, the +Court hereby GRANTS the Motion and ORDERS as follows: +1. The Court will sign and shall issue the Letter of Request (Letter Rogatory) attached as +Exhibit 1 to the Motion to facilitate the taking of the deposition upon oral examination +of Miles Alexander as a witness in this action, as well as the production of documents +described in the Plaintiff's Motion and exhibits annexed thereto; +2. The Clerk of Court is hereby directed to take all necessary steps to ensure the Letter of +Request (Letter Rogatory) is transmitted to Plaintiff in a form sufficient to obtain the +described testimony and documents; and +1 + + +Case 1:22-cv-10904-JSR Document 28-3 Filed 01/20/23 Page 2 of 2 +3. The appropriate judicial authority in South Africa is hereby authorized to take and +report the deposition of Miles Alexander and shall have the power by virtue of the +Letter of Request (Letter Rogatory) to administer any necessary oath and to take and +report testimony. +SO ORDERED. +Dated: +New York, New York +The Honorable Jed S. Rakoff +Senior Judge +The United States District Court +for the Southern District of New +York +2 diff --git a/vision-fixhub/court-05/7023600a231a9bd0cbc8d3d8ac8d070273578eec8c9ecaaed8e78d31fbb6fc64.receipt.json b/vision-fixhub/court-05/7023600a231a9bd0cbc8d3d8ac8d070273578eec8c9ecaaed8e78d31fbb6fc64.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1b747140f5ba9c5d443fde1db6f502b1da81a700 --- /dev/null +++ b/vision-fixhub/court-05/7023600a231a9bd0cbc8d3d8ac8d070273578eec8c9ecaaed8e78d31fbb6fc64.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "7023600a231a9bd0cbc8d3d8ac8d070273578eec8c9ecaaed8e78d31fbb6fc64", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "d864f1c1156d9759f3e3ba82ecc059542a23499ce95b0ed48d645fb8b9d45f58", + "output_sha256": "6157ba8b2fe6ed9f52704f55dcf05a98b3b0d857eeb582e95b5c38cb0733d919", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7037b6e3f035aeb5427505e157456b8c58b7d3014dea60ebec25371c5d4ca6e2.md b/vision-fixhub/court-05/7037b6e3f035aeb5427505e157456b8c58b7d3014dea60ebec25371c5d4ca6e2.md new file mode 100644 index 0000000000000000000000000000000000000000..0b56d198f0c9531535c1177dc0e70cd297d009cd --- /dev/null +++ b/vision-fixhub/court-05/7037b6e3f035aeb5427505e157456b8c58b7d3014dea60ebec25371c5d4ca6e2.md @@ -0,0 +1,35 @@ +Case 1:22-cV-10904-JSR Document 268-31 Filed 08/07/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 268-31 Filed 08/07/23 Page 2 of 2 +Date: +Thursday, May 162013 08:51 PM +Subject: Re: +From: +Cecile de Jongh < +@yahoo.com> +To: +Jeffrey Epstein : +Yes, I think it will. +With warm regards, +Cecile +Sent from my iPhone +On May 16, 2013, at 4:01 PM, Jeffrey Epstein wrote: +I can inroll +and +if that helps the school +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved + +ESTATE_JPM024119 diff --git a/vision-fixhub/court-05/7037b6e3f035aeb5427505e157456b8c58b7d3014dea60ebec25371c5d4ca6e2.receipt.json b/vision-fixhub/court-05/7037b6e3f035aeb5427505e157456b8c58b7d3014dea60ebec25371c5d4ca6e2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b576800d6cef2bef2aa55e758a875a1c57b9a866 --- /dev/null +++ b/vision-fixhub/court-05/7037b6e3f035aeb5427505e157456b8c58b7d3014dea60ebec25371c5d4ca6e2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "7037b6e3f035aeb5427505e157456b8c58b7d3014dea60ebec25371c5d4ca6e2", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "5bdc54835e0e50b034433b8b62d9a6172ec6f5f8f74a4d3c63ad4bfaf2bff795", + "output_sha256": "9f6490d55441701474a6587bd9e5166ec309ae0aa3656ca05ac01043946fb222", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/70551c4cb40145fb0869080d99a5b9a737cf3e834af4ebbc4d92f77f59cd1fe8.md b/vision-fixhub/court-05/70551c4cb40145fb0869080d99a5b9a737cf3e834af4ebbc4d92f77f59cd1fe8.md new file mode 100644 index 0000000000000000000000000000000000000000..669aeb2d343e70e513ac0c6d922029abbba6ff89 --- /dev/null +++ b/vision-fixhub/court-05/70551c4cb40145fb0869080d99a5b9a737cf3e834af4ebbc4d92f77f59cd1fe8.md @@ -0,0 +1,1371 @@ +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 1 of 42 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +) +Case Number: 1:22-cv-10904-JSR +ACTION FOR DAMAGES +JURY TRIAL DEMANDED +JAMES EDWARD STALEY +Third-Party Defendant. +SECOND AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL +Plaintiff Government of the United States Virgin Islands ("Government") files this +Complaint against JPMorgan Chase Bank, N.A. ("JP +) for violations of Trafficking +Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and +Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and +Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges as +follows: +PARTIES +The Attorney General of the United States Virgin Islands (hereinafter "Virgin +Islands") brings this parens patriae action on behalf of the Plaintiff, Government of the Virgin + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 2 of 42 +Islands, pursuant to 15 U.S.C. § 1595(d) and 3 V.I.C. § 114 and her statutory authority to enforce +the laws of the Virgin Islands and protect public safety. +2. +The Attorney General, pursuant to her authority to represent the Government of the +United States Virgin Islands, also acts on behalf of, and with the lawfully delegated authority of, +the Virgin Islands Department of Licensing and Consumer Affairs under 12 V.I.C. § 327 in regard +to Count Four of the Government's Complaint alleging violations of the Virgin Islands Consumer +Fraud and Deceptive Business Practices Act. +3. +This action stems from an enforcement action the Government filed against the +Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey +Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations +Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke et al., Case No. ST-20- +CV-14 (Super. Ct. V.I. Jan. 15, 2020). The Attorney General brings this action, after presenting +her findings to JP +in September 2022, in her ongoing effort to protect public safety and to +hold accountable those who facilitated or participated in, directly or indirectly, the trafficking +enterprise Epstein helmed. The investigation revealed that JP +knowingly, negligently, and +unlawfully provided and pulled the levers through which recruiters and victims were paid and was +indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial +institutions can connector choke-human trafficking networks, and enforcement actions filed +and injunctive relief obtained by attorneys general are essential to ensure that enterprises like +Epstein's cannot flourish in the future. +Defendant JPMorgan Chase Bank, N.A. is an American multinational investment +bank and financial services company headquartered in New York City and incorporated in +Delaware. +2 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 3 of 42 +5. +At all relevant times, JP +engaged in business in the Virgin Islands, +including, but not limited to, the acts and practices described herein. +6. +As described below, based on documents reviewed and interviews conducted by +the Government, JP +knowingly facilitated, sustained, and concealed the human trafficking +network operated by Jeffrey Epstein from his home and base in the Virgin Islands, and financially +benefitted from this participation, directly or indirectly, by failing to comply with federal banking +regulations, +facilitated +and concealed wire and cash transactions that raised suspicion of-and were in fact part of-a +criminal enterprise whose currency was the sexual servitude of dozens of women and girls in and +beyond the Virgin Islands. Human trafficking was the principal business of the accounts Epstein +maintained at JP +Upon information and belief, JP +I turned a blind eye to evidence of human +trafficking over more than a decade because of Epstein's own financial footprint, and because of +the deals and clients that Epstein brought and promised to bring to the bank. These decisions were +advocated and approved at the senior levels of JP +, including by the former chief executive +of its asset management division and investment bank, whose inappropriate relationship with +Epstein should have been evident to the bank. Indeed, it was only after Epstein's death that JP +belatedly complied with federal banking regulations regarding Epstein's accounts. +JURISDICTION, VENUE, AND RELATED CASE +8. +This action is brought pursuant to and based on federal and Virgin Islands statutes, +including the federal Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595 ("TVPA"), +and the federal Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336 and its implementing regulations +("'BSA"). +3 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 4 of 42 +9. +This Court has federal question subject-matter jurisdiction pursuant to 28 U.S.C. +§ 1331 because the Government's TVPA and BSA-based causes of action arise under federal law. +10. +This Court has supplemental jurisdiction over the Government's Virgin Islands law +claims pursuant to 28 U.S.C. § 1367(a) because these claims are so related to those arising under +or based on federal law as to form part of the same case or controversy under Article III of the +United States Constitution. +11. +This Court is an "appropriate district court of the United States" in which for the +Government to obtain appropriate relief under 18 U.S.C. § 1595(d) and venue is proper under 28 +U.S.C. § 1391(b)(2) because Defendant maintains its principal place of business within this +judicial district, so that this Court may exercise general personal jurisdiction over Defendant, and +because many of the alleged acts and omissions of Defendant giving rise to the Government's +claims took place within this judicial district, so that this Court may exercise specific personal +jurisdiction over Defendant. +12. +Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is +related to Doe / v. JP +Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because +both actions arise from a common nucleus of operative fact involving Defendant JP +alleged participation, directly or indirectly, in Epstein's sex-trafficking venture by facilitating +payments to women and girls, channeling funds to Epstein to fund the operation, and concealing +Epstein's criminal conduct by failing to comply with federal banking regulations. +BACKGROUND +I. +Federal and State Legal Requirements +13. +is subject to federal laws, including the BSA and the Uniting and +Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct +4 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 5 of 42 +Terrorism Act of 2001, Pub. L. No. 107-56, 115 Stat. 272 ("USA PATRIOT Act"), which amended +certain BSA regulations. +14. +Under both the BSA and USA PATRIOT Act, JP L +is required to implement +adequate, risk-based anti-money laundering ("AML") policies and systems to detect and prevent +money laundering or other use of the institution's services to facilitate criminal activities. This +includes, but is not limited to, maintaining a due diligence program, filing suspicious activity +reports ("SARs") when the financial institutions detect suspicious behavior and currency +transaction reports ("TRs") for currency transactions or series of currency transactions that +exceed $10,000 in a 24-hour period, preventing structuring or assistance with structuring of +transactions undertaken for the purpose of evading federal reporting requirements, and maintaining +systems to prevent money laundering. +15. +The FDIC and the other federal banking regulators, including the Federal Reserve +Board and Office of the Comptroller of the Currency, formed an interagency organization known +as Federal Financial Institutions Examination Council ("FFIEC"). +16. +To provide further guidance to banks on what BSA compliance requires, FFIEC +published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). +The BSA Manual explains that an effective SAR program is essential: +Suspicious activity reporting forms the cornerstone of the BSA reporting system. It +is critical to the United States' ability to utilize financial information to combat +terrorism, terrorist financing, money laundering and other financial crimes +Examiners and banks should recognize that the quality of SAR content is critical t +the adequacy and effectiveness of the suspicious activity reporting system.! +17. Pursuant to the BSA Manual, "[p]roper monitoring and reporting processes are +' FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual, Suspicious Activity +Reporting at 1 (2014) +https://bsaaml.ffiec.gov/docs/manual/06_AssessingComplianceWithBSARegulatoryRequirement +s/04.pdf. +5 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 6 of 42 +essential to ensuring that the bank has an adequate and effective BSA compliance program. +Appropriate policies, procedures, and processes should be in place to monitor and identify unusual +activity. "2 When a bank detects suspicious activity, it is required to report that information within +30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network +(FinCEN"). The reporting requirement ensures that the government is able to monitor and act +when alerted to potential illegal conduct. +18. +Appendix F of the BSA Manual includes examples of suspicious transactions that +may indicate money laundering, terrorist financing, or fraud, including: +a. +Funds transfer activity is unexplained, repetitive, or shows unusual patterns; +The currency transaction patterns of a business show a sudden change +inconsistent with normal activities; +c. +Unusual transfers of funds occur among related accounts or among accounts +that involve the same or related principals; +d. +Currency is deposited or withdrawn in amounts just below identification or +reporting thresholds; +e. +Regarding nonprofit or charitable organizations, financial transactions +occur for which there appears to be no logical economic purpose or in which +there appears to be no link between the stated activity of the organization +and the other parties in the transaction; +f. +Funds are sent or received via international transfers from or to higher-risk +locations. +19. +In addition, the CICO Act, 14 V.I.C. § 600, incorporates violations of Virgin Islands +" Id. at 2. +6 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 7 of 42 +Law and federal felonies, which includes the BSA's criminal-liability provisions. +Il. +Jeffrey Epstein's Criminal Conduct +20. Jeffrey Epstein was a resident of the Virgin Islands. +21. +In 2008, Epstein pled guilty to one count of solicitation of prostitution with a minor +in Palm Beach, Florida. As a result of that conviction, Epstein was forced to register as a sex +offender in the Virgin Islands. +22. +Epstein was a Tier 1 offender under Virgin Islands law based upon his Florida +conviction of procuring a minor for prostitution. +23. +On January 15, 2020, the Government filed a lawsuit against Jeffrey Epstein's +estate and related individuals and entities for violation of the CICO Act, 14 V.I.C. §§ 600 to 614, +and civil conspiracy, which the Government recently settled. As laid out in the Government's +Second Amended Complaint, ST-20-CV-14, ("SAC) (attached as Exhibit 1), Epstein created a +network of companies and individuals who participated in, directly or indirectly, and conspired with +him in a pattern of criminal activity related to the sex trafficking, forced labor, sexual assault, child +abuse, and sexual servitude of these young women and children. SAC 9*l 43-75. Epstein and his +associates trafficked underage girls to the Virgin Islands, held them captive, and sexually abused +them, causing them grave physical, mental, and emotional injury. Id. +24. +To accomplish this criminal activity, Epstein formed an association in fact with +both companies and non-profit organizations that he owned and operated, as well as individuals, +who were willing to participate in, directly or indirectly, facilitate, and conceal Epstein's criminal +activity in exchange for Epstein's bestowal of financial and other benefits, including sexual +services and forced labor from victims. Id. 9I at 157-195. +25. +In October 2012, the Southern Trust Company—one of the companies Epstein +7 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 8 of 42 +owned—applied for economic benefits from the Virgin Islands Economic Development +Commission ("EDC") so the company could provide "cutting edge consulting services" in the area +of "biomedical and financial informatics." Id. 99l 157-158. Southern Trust Company received a 10- +year package of economic incentives running from February 1, 2013 until January 31, 2023 that +included a 90% exemption from income taxes and 100% exemptions from gross receipts, excise, +and withholding taxes in the Virgin Islands. Id. I 159. +26. +Southern Trust, in fact, appeared to perform no informatics or data-mining services +during this period. Instead, Southern Trust funded the Epstein Enterprise (defined below), acting as +a conduit for payment to foreign women, credit cards, airplanes and other instrumentalities. Id. +99 167-173. +27. +This illicit association of Epstein, businesses, and his associates constitutes what is +referred to herein as the "Epstein Enterprise." Specifically included in the Epstein Enterprise were +the following companies and non-profit organizations, all of which had accounts with JP +2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, +Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, +LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. +28. +Epstein used his wealth and power to create the Epstein Enterprise, which engaged +in a pattern of criminal activity by repeatedly procuring and subjecting underage girls and young +women to unlawful sexual conduct, sex trafficking, and forced labor. +29. +Many of these women, particularly after Epstein's conviction in 2008, were +trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, +these women were recruited and, in several instances, required to marry other Epstein victims in +order to maintain their immigration status and their availability to Epstein. Id. I9l 62- 63, 78, 86. +8 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 9 of 42 +30. +As also alleged in the Second Amended Complaint, recruiters and victims were paid +in cash or through entities set up by Epstein and/or his associates. Id. 9I 100. Many of these companies +were shell companies, that existed merely to transfer money to other accounts, or to shelter Epstein's +assets from judgment. Id. Il 116. +31. +Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co- +Executors of Epstein's Estate, authorized or directed many of the transactions in JP +accounts +held by Epstein or related entities. Id. 9l 8-10, 76-117. +32. +Epstein and the Epstein Enterprise continued trafficking and sexually abusing +young women and female children until Epstein was arrested by federal law enforcement +authorities on July 6, 2019 on federal charges for the sex trafficking of minors. +33. +Epstein was found dead on August 10, 2019 while in custody in a federal detention +center in New York on charges for sex-trafficking crimes. Id. 91 7. +ALLEGATIONS +Jeffrey Epstein Was an Extremely High-Risk Customer +34. Jeffrey Epstein's reputation as a sex trafficker and abuser of women and girls was +well-known and well-publicized for more than a decade before his death. +35. Between 2005 and 2013, there were numerous press reports that Epstein sexually +abused women and girls. +36. +In March 2005, there were press reports that Epstein paid a 14-year old girl in Palm +Beach, Florida for a "massage" and then molested her. Following these allegations, multiple +underage girls, many of them high school students, told police that Epstein also hired them to give +sexual massages. +37. +Throughout 2006—when Epstein was arrested in Palm Beach, Florida for +9 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 10 of 42 +solicitation of a minor-there was extensive press regarding the nature and extent of Epstein's +sexual offenses, including the existence of dozens of victims. +38. +In 2008, Epstein pled guilty to sexual offenses in Palm Beach, Florida, including +solicitating a minor for prostitution. Epstein was sentenced to 18 months in jail and was required +to register as a sex offender. +39. +In 2009, the non-prosecution agreement between Epstein and the United States +became public. It revealed allegations that Epstein may have used interstate commerce to induce +minors to engage in prostitution, engaged in illicit sexual conduct with minors, and trafficked +minors. +40. In 2010, press reports noted allegations that Epstein was involved with Eastern +European women in particular and that a modeling agency he helped fund brought "young girls.. +. often from Eastern Europe" to the United States on Epstein's private jets.? +II. +Trafficker +Knew Epstein Was a Felon, Registered Sex Offender, and Alleged Child +41. +did business with Jeffrey Epstein from as early as 1998 to 2013. In that +time, JP +serviced approximately fifty-five Epstein-related accounts collectively worth +hundreds of millions of dollars. +42. +On information and belief, based on the Government's review of financial records, +information from and regarding victims of Epstein's trafficking, and other publicly available +information, at least 20 individuals paid through JP +accounts were victims of trafficking +and sexual assault in Little St. James, New York, and/or other Epstein properties. These women +were trafficked and abused during different intervals between at least 2003 and July 2019, when +I. Jeffrey Epstein Pedophile Billionaire and His Sex Den, The Daily Beast (July +22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. +10 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 11 of 42 +Epstein was arrested and jailed, and these women received payments, typically multiple payments, +between 2003 and 2013 in excess of $1 million collectively. Epstein also withdrew more than +$775,000 in cash over that time frame from JP| +accounts, especially significant as Epstein +was known to pay for "massages," or sexual encounters, in cash. Financial information also +reflects payments drawn from JP +accounts of nearly $1.5 million to known recruiters, +including to the MC2 modeling agency, and another $150,000 to a private investigative firm. +43. +knew early on that Epstein was an extremely high-risk client but +decided, at multiple points during the relationship, to continue servicing Epstein's accounts +because of his vast wealth and connections with other high net worth individuals. +44. In 2006, JP +Global Corporate Security Division found "IsJeveral +newspaper articles ... that detail the indictment of Jeffrey Epstein in Florida on felony charges of +soliciting underage prostitutes." At that time, JP +decided to continue doing business with +Epstein but concluded his account "should be classified as high risk" and require special approval. +45. In a 2010 internal email, JP +risk management division discussed new +allegations against Epstein: "See below new allegations of an investigation related to child +trafficking - are you still comfortable with this client who is now a registered sex offender." +Another JP +employee responded: "In my short tenure working on the account these stories +pop up including these from the summer." +46. +In January 2011, JP +AML compliance director requested re-approval for +the bank's relationship with Epstein from JP +then-General Counsel "in light of the new +allegations of human trafficking ..." Another JP +employee responded: "I thought we did +that in approving a $50 million new line of credit last month?" +47. +In JP +January 2011 review of Epstein's accounts, the bank concluded + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 12 of 42 +there were "no material updates" but noted: +A few news stories during 2010 connects Jeffrey Epstein to human trafficking. The +coverage team ... all met to discuss the situation and agreed to enhance monitoring +and document a discussion with the client. Jes Staley discussed the topic with +Jefirey Epstein who replied there was no truth to the allegations, no evidence and +was not expecting any problems. We will continue to monitor the accounts and cash +usage closely going forward. +48. +In March 2011, JP +Global Corporate Security Division reported: +"Numerous articles detail various law enforcement agencies investigating Jeffrey Epstein for +allegedly participating, directly or indirectly, in child trafficking and molesting underage girls. +Jeffrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding solicitation +for an undisclosed amount." The report also identified the following "derogatory information": +. "Jean Luc Brunel, owner of MC2 Model Management and Jeffrey Epstein +engaged in racketeering that involved luring in minor children for sexual play for +money. In addition, Brunel was a frequent passenger on Epstein's private jet and +often visited Epstein in jail." +b. "MC2 Model Management received $1 million from Epstein in 2005. It is +unknown if the money was given as a secret investment or payment for services +as a procurer." +49. +In August 2011, when conducting a Know-Your-Customer review, JP +flagged an account relating to Ghislaine Maxwell—Epstein's former companion who recently was +sentenced to 20 years in prison for conspiring with Epstein to sexually abuse minors. Maxwell +wanted to set up an account for her "personal recruitment consulting business." In an internal +email, JP +AML Director asked: "What does she mean by personal recruitment?? Are +you sure this will have nothing to do with Jeffrey? If you want to proceed, I suggest that we flag +this as a High Risk Client." +12 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 13 of 42 +50. +In 2013-the year that JP| +terminated its relationship with Epstein-JP +flagged in Epstein's history that "[pler bank policy, felons [like Epstein] are considered +high risk and require additional approval." +51. +banking relationship with Epstein was known at the highest levels of +the bank. For instance, an August 2008 internal email states, "I would count Epstein's assets as a +probable outflow for '08 ($120mm or so?) as I can't imagine it will stay (pending Dimon review)." +III. Head of JP +Private Bank Had Close Personal Relationship With Epstein +52. +Former senior executive, Jes Staley ("Staley"), developed a close relationship with +Epstein when Staley was the head of JP +Private Bank, which is a segment of JP| +business dedicated to extremely wealthy clients with at least $10 million in assets. +53. +Between 2008 and 2012, Staley exchanged approximately 1,200 emails with +Epstein from his JP +email account. These communications show a close personal +relationship and "profound" friendship between the two men and even suggest that Staley may +have been involved in Epstein's sex-trafficking operation. They also reveal that Staley +corresponded with Epstein while Epstein was incarcerated and visited Epstein's Virgin Islands +residence on multiple occasions. Epstein even advised Staley in connection with Staley's salary +negotiations at JP +in July of 2008. +54. +On December 30, 2008, Epstein and Staley discussed via email Staley's visit to +Epstein's residence in Palm Beach, Florida. Epstein wrote that he would not be home the following +Sunday, but that Staley was welcome to use the house. Staley replied that he would instead make +arrangements to visit Epstein in Palm Beach in early January. On January 8, 2009. +-around the +time of Staley's scheduled visit to Palm Beach—Epstein wired $2,000 from his JP +account +to a woman with an Eastern European surname. +13 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 14 of 42 +55. +Between August 27 and 29, 2009, Staley communicated via email to Epstein that +he would be in London in a week. Epstein inquired whether Staley would need anything while in +London, and Staley replied, "Yep." On August 31, 2009, Epstein wired $3,000 from his JP +account to the same Eastern European woman Epstein paid in January 2009. +56. +Staley sent an email to Epstein on November 1, 2009, when Epstein was +incarcerated and Staley was presumably visiting Little St. James, saying: +So when all hell breaks lo[o]se, and the world is crumbling. I will come here, and +be at peace. Presently, I'm in the hot tub with a +wine. This is an +amazing place. Truly amazing. Next time, we're here together. I owe you much +And I deeply appreciate our friendship. I have few so profound +57. On December 4, 2009, Staley told Epstein via email: "I realize the danger in +sending this email. But it was great to be able, today, to give you, in New York City, a long +heartfelt, hug." +58. The next day, Epstein wrote to Staley, "you were with Larry, and I had to put up +with ..." and attached a picture of a young woman (shown below). Staley quipped, "don't tell me +wine." Epstein replied, "always thoughts of alcohol." +14 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 15 of 42 +59. +On December 20, 2009, Epstein sent an email to Staley that was blank except for a +picture of a young woman (shown below). +60. +On January 15, 2010, Staley emailed Epstein, referring to Little St. James, "Arrived +at your harbor. Someday, we have to do this together." +61. +In July 2010, Staley sent an email to Epstein, saying: "Maybe they're tracking u? +That was fun. Say hi to Snow +" Epstein responded: "[W]hat character would you like next?" +When Staley said "Beauty and the Beast", Epstein replied: "well one side is available." +62. +None of the emails between Epstein and Staley were flagged in connection with +risk reviews of Epstein's accounts. Moreover, JP +allowed Staley to remain a decisionmaker on Epstein's accounts. JP +even tasked Staley to discuss the human trafficking +allegations with Epstein. +63. +In July 2013—several months after Staley left JP +institution-JP +Compliance Officer terminated JP | +to join another financial +relationship with Epstein. +15 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 16 of 42 +64. +At the time of Epstein's death in 2019, Staley was the Chief Executive Officer of +Barclays; however, Staley stepped down from that position in November 2021 after British +financial regulators concluded an investigation into Staley's characterization of his relationship +with Epstein. +IV. JP +Ignored Obvious Red Flags Relating to Epstein's Accounts +65. Despite JP +claims that it would closely monitor Epstein's accounts, JP +ignored numerous red flags related to Epstein's accounts and failed to comply with federal +banking regulations. +66. +Between 2003 and 2013, Epstein and/or his associates used Epstein's accounts to +make numerous payments to individual women and related companies. 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. For example, Epstein paid more than +$600,0000 to Jane Doe 1, a woman who—according to news reports contained in JP +due +diligence reports—Epstein purchased at the age of 14. Like other women who received payments +from Epstein, Jane Doe 1 listed Epstein's apartments on 66th Street in New York City as her +address, which should have been a red flag to JP +67. +Epstein and/or his associates also made significant cash withdrawals and 95 foreign +remittances with no known payee. For example, Hyperion Air, Inc.—the Epstein-controlled +company that owned Epstein's private jet—issued over $547,000 in checks payable to cash +purportedly for "fuel expenses when traveling to foreign countries." Additionally, between January +2012 and June 2013, Hyperion converted more than $120,000 into foreign currency. Many of these +cash withdrawals either exceeded the $10,000 reporting threshold or were seemingly structured to +avoid triggering the reporting requirement. This is particularly significant since it is well known +16 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 17 of 42 +that Epstein paid his victims in cash. SAC I 100. +68. +In addition, Epstein and/or his representatives appeared to be misusing JP | +accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and +Enhanced Education. Epstein made payments from these accounts with no clear nexus to the +organization's charitable purpose. For example, Epstein and/or his representative used the +C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known +victims, and over $20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or +his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and +$15,000 to +and +a firm owned by Epstein's reportedly prior +girlfriend. +69. Each of these red flags was serious; together, they suggest a pattern of potentially +illegal conduct that should have prompted action by JP +Despite this, JP +2013 +compliance report describes "nothing unusual" in Epstein's account transactions, confirms that +Epstein's transaction activity appears "reasonable, normal, and expected for the type of business +or industry in which the client engages", and denies that any "unusual... activity" was detected, +noting that "Compliance reviews activity regularly." Moreover, the frequency of Epstein's +payments and the fact that the vast majority of account activity was payments to women and cash +withdrawals rather than business activity should have been enough to trigger action. +70. +Even as late as May 2013—mere months before JP +terminated Epstein's +account-JP +provided lines of credit to Epstein of up to $50 million. +V. Epstein Brought Additional High Net Worth Clients to JP| +71. +In addition to his own holdings with JP +, Epstein helped, or promised to +help, Staley recruit ultrawealthy clients to JP +A few examples are laid out below. +17 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 18 of 42 +72. +In 2004, Epstein introduced Staley to Glenn +the owner of Highbridge +Capital Management—one of the country's largest hedge funds. This laid the groundwork for JP +acquisition of Highbridge—a move that helped catapult Staley's career. +In 2011, Epstein and Staley had extensive discussions regarding the creation of a +"very HIGH profile" donor advised fund ("DAF"), which is an investment account established to +support charitable organizations, headed by the +Epstein pitched the +DAP +as an "exclusive club" with a minimum $100 million donation where JP +would act as the +fiduciary. +VI. +Reveals Systematic Failures +74. +75. +18 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 19 of 42 +76. Further, it does not appear from the Government's investigation that JP +engaged in any investigation of the source of Epstein's funds. For example, in 2012, an internal +email from JP +identified the following questions for Epstein regarding his account activity: +QUESTION: For checking account: +Review the activity for the period overall and explain how the client's transactions +profile agrees with or doesn't agree with expectations for the client based on the +client relationship (purpose of accounts, occupation, business activity, etc.D] +Compliance reviewed regularly +Questions for Asset/brokerage Account: +What is the purpose/intended use of the accounts)? Please provide a detailed +description of how the Client Direct Asset/Brokerage Accounts) will be used by +the client. +Investments/trading/wealth accumulation +**Review the activity for the period overall and explain how the client's transaction +profile agrees with or doesn't agree with expectations for the client based on the +client relationship (purpose of accounts, occupation, business activity, etc.): +Compliance reviewed regularly +Yet, there is no evidence that JP +I pursued or received a response from Epstein even though +was required to conduct this minimum level of due diligence pursuant to 31 C.F.R. +§ 1010.620(b)(3). +77. +also seemingly did no due diligence on the nature of the various business +entities for which it held accounts for Epstein, which appear to have no legitimate business purpose +and, upon information and belief, were part of Epstein's criminal enterprise in the Virgin Islands. +78. +In January 2013—the year JP +terminated Epstein's accounts- +-the Office +of the Comptroller of the Currency ("OCC") entered into a consent order with JP +regarding +deficiencies in the bank's overall program for BSA/AML compliance. The OCC foundconsistent with the Government's findings here—that JP +failed to develop adequate due +diligence on customers and failed to comply with federal banking regulations. In fact, the OCC +19 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 20 of 42 +noted that JP +"failed to identify significant volumes of suspicious activity" 4 +79. After JP I +terminated Epstein's accounts, Epstein moved his accounts to +Deutsche Bank from 2013 to 2018. +80. +The New York State Department of Financial Services ("NYSDFS") investigated +Deutsche Bank for failures to monitor Epstein's accounts. On July 6, 2020, the NYSDFS and +Deutsche Bank entered into a Consent Order with a $150 million penalty, which stated, in relevant +parts: +a. +"The Bank's fundamental failure was that, although the Bank properly +classified Mr. Epstein as high-risk, the Bank failed to scrutinize the activity +in the accounts for the kinds of activity that were obviously implicated by +Mr. Epstein's past. The Bank was well aware not only that Mr. Epstein had +pled guilty and served prison time for engaging in sex with a minor but also +that there were public allegations that his conduct was facilitated by several +named co-conspirators. Despite this knowledge, the Bank did little or +nothing to inquire into or block numerous payments to named coconspirators, and to or on behalf of numerous young women, or to inquire +how Mr. Epstein was using, on average, more than $200,000 per year in +cash." +b. +"Whether or to what extent those payments or that cash was used by Mr. +Epstein to cover up old crimes, to facilitate new ones, or for some other +purpose are questions that must be left to the criminal authorities, but the +fact that they were suspicious should have been obvious to Bank personnel +4 NYSDFS Consent Order at 2-4 (Jan. 14, 2013), https://www.occ.treas.gov/newsissuances/news-releases/2013/nr-occ-2013-8a.pdf. +20 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 21 of 42 +at various levels. The Bank's failure to recognize this risk constitutes a +major compliance failure." +C. +"These errors are unacceptable in the context of a major international bank +and inexcusable in the context of the heightened scrutiny that should have +occurred in the monitoring of a high-risk customer." +81. +The NYSDFS also found fault with Deutsche Bank's failure to obtain answers +regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May +2018 email, a compliance officer submitted an inquiry .... about payments to the accounts of +women with Eastern European surnames at a Russian bank, and asking for an explanation of the +purpose of the wire transactions and Epstein's relationship with the counterparties."S +82. JP +failures to appropriately monitor Epstein's accounts and comply with +federal banking regulations are even more egregious than Deutsche Bank's failures because JP +failed to demonstrate even basic due diligence and continued its relationship with Epstein +for over a decade, despite the glaring indications of criminal activity. +83. +84. +So, too, was JP| +decision to allow Jes Staley to serve as an investigator +and decision-maker with respect to Epstein's accounts, despite glaring red flags regarding Staley's +relationship with Epstein, was a blatant failure of compliance. +VII. JP| +Fraudulently Concealed Its Continuing Violations +85. +continuous illegal conduct has caused repeated and continuous injury. +SId. at 15. +21 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 22 of 42 +86. +knew—including at the highest level of the bank-that Epstein was an +extremely high-risk client. Between 2005 and 2013, there were myriad reports that Epstein +sexually abused women and girls. In 2008, Epstein pled guilty to sexual offenses and registered as +a sex offender. Despite JP +acknowledgement that it needed to closely monitor Epstein, +ignored numerous red flags and failed to comply with federal banking regulations until +years later after JP +was no longer benefiting from Epstein's business. +87. +also engaged in a course of conduct aimed at fraudulently concealing +its illegal conduct, including by failing to timely comply with federal banking regulations in order +to profit from Epstein's wealth and connections. +88. A key purpose of federal banking regulations is to give law enforcement real-time +information so that it can act to detect violations of the law and protect public safety. +89. The Government of the Virgin Islands did not know, and could not have known, +that Epstein used JP +to facilitate his trafficking enterprise or that JP +turned a blind +eye to unusual cash transactions and wires and failed to carry out or follow up on basic due +diligence and to timely comply with federal banking regulations, as required by the law. +90. +Over more than a decade, JP +clearly knew it was not complying with +federal regulations in regard to Epstein-related accounts as evidenced by its too-little too-late +efforts after Epstein was arrested on federal sex trafficking charges and shortly after his death, +when JP +belatedly complied with federal law. +91. The continued illegal conduct by JP +has caused repeated and continuous +injury. JP +illegal conduct was not completed nor were all damages incurred until the +wrongdoing ceased in August 2019 when JP +began belatedly complying with federal +banking regulations in regard to Epstein-related accounts. +22 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 23 of 42 +VIII. Additional Factual Allegations Regarding JP +Conduct +Obstruction +92. +In 2006, a JP +Rapid Response Team noted that Epstein "routinely" made +cash withdrawals in amounts from $40,000 to $80,000 several times per month, totaling over +$750,000 per year. +93. +In addition, Mary Erdoes admitted in her deposition that JP +was aware by +2006 that Epstein was accused of paying cash to have underage girls and young women brought +to his home. +94. In the years that followed, JP +employees, including senior executives, +emailed internally that Epstein was under investigation or had been sued for trafficking or sexual +abuse. This includes an email in 2010 between Mary Erdoes and Jes Staley regarding a federal +investigation of Epstein for child trafficking; a 2011 email summarizing a few 2010 news stories +connecting Epstein to human trafficking and promising to "monitor the accounts and cash usage +closely going forward;" and a 2011 compliance memo noting that "In]umerous articles detail +various law enforcement agencies investigating Jeffrey Epstein for allegedly participating in child +trafficking and molesting underage girls" and that "Epstein had settled a dozen civil lawsuits out +of court from his victims regarding solicitation for an undisclosed amount." Internal emails also +questioned who Epstein's clients were, circulating an article regarding whether Epstein was +running a Ponzi scheme. +95. +Indeed, Epstein's behavior was so widely known at JPMorgan that senior +executives joked about Epstein's interest in young girls. In 2008, for example, Mary Erdoes +received an email asking her whether Epstein was at an event "with miley cyrus." +96. +In her deposition, Mary Erdoes testified that JP +terminated Epstein as a +customer in 2013 after she became aware that the withdrawals were "actual cash." However, +23 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 24 of 42 +Epstein had made substantial cash withdrawals every year he banked with JP +including +more than $800,000 per year in 2004 and 2005. +97. +The cash activity continued in the years after Epstein's plea, though JP +accepted, without proof, that the cash was for fuel and landing fees associated with Epstein's +planes (even during the years when Epstein was incarcerated or under house arrest). Ms. Erdoes +has rightly dismissed this explanation. +98. +In 2010, JP +compliance officials decided that Epstein "should go." One +senior compliance official reviewing JP L +information on Epstein in 2011 declared that +there was: "Lots of smoke. Lots of questions." This included that: +• Epstein "is alleged to be involved in the human trafficking of young girls and law +enforcement is also allegedly investigating his involvement in this activity." +• "He is also an alleged personal associate of the CEO of the Investment Bank (Jes +Staley)" +• "AML Operations went to a [Private Bank] risk meeting late last week requesting +that we exit this relationship." +• "whether Epstein if further exposed could have a potential serious impact." +• "The one new concerning thing is the one article about the DOJ investigation is +via their contract or arrangement." The loan was a letter of credit provided by JP +to MC2 Model Management. +• In 2004, Epstein sponsored private bank accounts and credit cards for two 18 year +olds "that appear to be part of his inner entourage. One is mentioned in many of +the recaps of the escapades as a willing participant and assistant when hosting +visitors. She has received about 450,000 since opening from Epstein .... Both +can be put in Palm Beach during 2004, by way of debit charges, which was when +24 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 25 of 42 +most allegations were from .... He did pay other girls, many models no huge +amounts. Sugar Daddy!" +• "His foundation account did pay donations to the Palm Beach Police Dept as +reported just before the case started. The same foundation account did pay monies +direct to models and payments direct to specialty schools (massage, culinary) and +university's on behalf of models/aspiring actresses. Nothing was astronomical." +• "His business accounts Fiduciary we saw no client activity. I know his biggest +client, Wexner parted ways when he was convicted. His [Due Diligence Reports] +say he manages a few private clients money but never says who. I would like to +know if in fact he is managing anyone's money at this point or is it all his money. +We saw no evidence of disbursements even in the rocky years 08-09. When the +well to do were running to their mattresses, he did not have any distributions from +his accounts at Bear or JP. He does have money at other institutions so maybe it +happened there." +99. One internal document describes the account of Epstein's "assistant or young lady +he brought over from Prague (or some place like that)," clearly referring to Jane Doe 1. The +document describes charges in New York, Palm Beach, and St. +for lingerie and other +sexually explicit material. Elsewhere, JP +describes media reports referring to the fact that +Epstein purchased her at age 14. She remained a customer of JP +and Epstein paid her +more than $600,000, from his accounts at JP| +, including more than $165,000 after Epstein's +plea. A recruiter given immunity through Epstein's non-prosecution agreement was paid more +than $728,000 from Epstein's JP +accounts, virtually all of it after the same Florida +conviction. Epstein also transferred more than $23 million dollars to Ghislaine Maxwell between +1999 and 2002. +100. Concerns about the risks that Epstein posed were well known enough that numerous +senior executives, including Steven Cutler, Mary Erdoes, Catherine Keating, and Jes +Staley met in various groupings in July and October 2008, January 2011, August 2011, and July +25 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 26 of 42 +2013. +101. This is so even though memos from compliance meetings specifically referenced +articles regarding a federal investigation into "whether a modeling agency run by a friend... fed +his appetite for underage foreign girls" and noted that "Epstein was known to fly young women +from Eastern Europe to Palm Beach where they'd massage him, among other services." JP +had information that it knew was directly relevant to the federal investigation of Epstein's +suspected trafficking, including regarding Epstein's line of credit to the modeling agency and +payments to Eastern European women, and +CAUSES OF ACTION +COUNT ONE +Participating in a Sex-Trafficking Venture +Violation of Trafficking Victims Protection Act +18 U.S.C. $$ 1591(a)(2), 1595(d) (Parens Patriae) +102. The Government restates and realleges paragraphs 1 to 101 of this Complaint as if +fully set forth herein. +103. The Government brings this Count as parens patriae on behalf of the residents and +visitors of the United States Virgin Islands and pursuant to the Attorney General's express +statutory authority. +104. JP +knowingly and intentionally participated in Epstein's sex-trafficking +venture that was in and affecting interstate and foreign commerce, together and with others, in +violation of 18 U.S.C. § 1591(a)(2) by facilitating payments to women and girls, channeling funds +to Epstein to fund the operation, and concealing Epstein's criminal conduct by failing to comply +with federal banking law. +26 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 27 of 42 +105. +knowingly and intentionally benefitted financially from and received +value for its participation in the sex-trafficking venture in which Epstein and his co-conspirators, +with JP +knowledge or reckless disregard of the fact, would use means of force, threats +of force, fraud, coercion, and a combination of such means to sexually abuse young women and +underage girls, including by causing them to engage in commercial sex acts, in the Virgin Islands +and elsewhere. +106. +Among the financial benefits that JP +received for participating in and +facilitating Epstein's sex-trafficking venture was the deposit of funds that Epstein—a Virgin +Islands resident—and Epstein-controlled entities located in the Virgin Islands made to JP +profited from the use of these deposits. Epstein and Epstein-controlled entities located +in the Virgin Islands deposited these funds in exchange for JP +facilitation of and +participation in Epstein's sex-trafficking venture. +107. Also, among the financial benefits that JP| +received for participating in and +facilitating Epstein's sex-trafficking venture were referrals of business opportunities from Epstein +and his co-conspirators. JP +profited from, or expected to profit from, these referred +business opportunities. Epstein referred business entities and business opportunities to JP| +in exchange for its facilitation of and participation in Epstein's sex-trafficking venture. +108. +financially profited from the deposits made by Epstein and Epsteincontrolled entities located in the Virgin Islands and from the business opportunities referred to JP +by Epstein and his co-conspirators in exchange for its known facilitation of and implicit +participation in Epstein's sex trafficking venture. +109. JP +knew and recklessly disregarded and concealed the fact that it was +Epstein's pattern and practice to use the channels and instrumentalities of interstate and foreign +27 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 28 of 42 +commerce to recruit, entice, harbor, transport, provide, obtain, and maintain young women and +underage girls for purposes of causing them to engage in commercial sex acts in violation of 18 +U.S.C. § 1591(a)(1). +110. JP +and its employees had actual knowledge that they were facilitating +Epstein's sexual abuse and sex-trafficking conspiracy to recruit, entice, harbor, transport, provide, +obtain, and maintain young women and underage girls to engage in commercial sex acts through +the means of force, threats of force, fraud, abuse of process, and coercion. +111. Despite this knowledge, JP | +intentionally paid for, concealed, facilitated, +and participated in Epstein's and his co-conspirators' violations of 18 U.S.C. § 1591(a), which JP +knew and was in reckless disregard of the fact that Epstein and his co-conspirators would +use its bank accounts and financial transactions to coerce, defraud, and force young women and +underage girls to engage in commercial sex acts. +112. JP +through its employees and agents and their role in facilitating the +financial aspect of Epstein's enterprise, actively facilitated or participated in the sex-trafficking +conspiracy in which Epstein and his co-conspirators led young women and underage girls in the +Virgin Islands and elsewhere to believe that they would be rewarded if they cooperated with +Epstein and his co-conspirators and acquiesced to their demands. +113. +committed this affirmative conduct knowing or in reckless disregard of +the fact that Epstein would use cash transactions and financial support provided by JP +as +a means to defraud, force, and coerce commercial sex acts from young women and underage girls. +114. +In addition to having actual knowledge that it was participating in and facilitating +the Epstein sex-trafficking venture, JP +also knew that it was participating in and +28 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 29 of 42 +facilitating a venture that was engaged in coercive sex trafficking in violation of 18 U.S.C. § +1591(a)(1). +115. +In exchange for facilitating and covering up Epstein's commercial sex trafficking, +employees received financial benefits and career advancement from JP +116. +Facilitating and covering up Epstein's sex trafficking venture was a means for JP +employees to obtain economic success and promotion within JP +117. JP +knowing and intentional conduct has caused serious harm to the +Virgin Islands and its residents, including without limitation financial harm, by facilitating the +commission of sexual abuse against young women and underage girls, including their engagement +in commercial sex acts, in the Virgin Islands. +118. JP +tortious conduct in violating the TVPA was outrageous and intentional +because it was in deliberate furtherance of a widespread and dangerous criminal sex-trafficking +venture operated in and from the Virgin Islands. JP +tortious conduct also evidenced a +high degree of moral turpitude and demonstrated such wanton disregard for the safety of young +women and underage girls in the Virgin Islands and elsewhere as to imply a deliberate indifference +to its legal obligations. +119. By virtue of these knowing and intentional violations of 18 U.S.C. § 1591(a)(2), JP +is liable to the Government for all appropriate relief under 18 U.S.C. § 1595(d), including +damages suffered by the Government and/or Epstein's victims, punitive damages, restitution, +appropriate injunctive relief, fines, reasonable attorneys' fees, and all such other relief as the Court +deems appropriate. +29 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 30 of 42 +COUNT TWO +Criminal Activity—Participating, Directly or Indirectly, in a Sex-Trafficking Venture +Violation of Trafficking Victims Protection Act, 18 U.S.C. § 1591(a)(2), +actionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act, +14 V.I.C. §§ 604(e) and 605(a) +120. +The Government restates and realleges paragraphs 1 to 119 of this Complaint as if +funny set forth herein. +121. +The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail +criminal activity and lessen its economic and political power in the Territory of the Virgin Islands +by establishing new penal prohibitions and providing to law enforcement and the victims of +criminal activity new civil sanctions and remedies." 14 V.I.C. § 601. +122. At all times material herein, JP +I was a "person" identified in 14 V.I.C. S +604(I). +123. At all times material herein, Epstein and his co-conspirators were engaged in an +illicit sex-trafficking "enterprise" as defined in 14 V.I.C. § 604(h). +124. At all times material herein, JP +supported and/or was associated with the +Epstein sex-trafficking enterprise by providing banking and payment-processing services to +Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or +incorporated in the Virgin Islands. +125. +In providing banking and payment-processing services to Epstein and Epsteincontrolled entities in return for profits realized both from Epstein's and Epstein-controlled entities' +accounts and from receiving referrals by Epstein of other high-value banking clients, JP +knowingly, intentionally, and willfully benefitted financially and by receiving things of value from +its participation, directly or indirectly, in Epstein's sex-trafficking venture and enterprise, in +violation of 18 U.S.C. § 1591(a)(2). +30 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 31 of 42 +126. +knowing, intentional, and willful receipt of financial benefits and +things of value from its facilitation and participation in Epstein's sex-trafficking venture and +enterprise through the financial infrastructure it provided and concealed constitutes a felony under +18 U.S.C. § 1591(b) and "criminal activity" as defined in 14 V.I.C. § 604(e). +127. By knowingly, intentionally, and willfully receiving financial benefits and things +of value from its participation, directly or indirectly, via financing in Epstein's sex-trafficking +venture and enterprise, JP +enabled Epstein to have ready and reliable access to and use of +resources with which to recruit, entice, harbor, transport, provide, obtain, and maintain young +women and underage girls for purposes of causing them to engage in commercial sex acts in the +Virgin Islands and elsewhere. JP +thereby unlawfully conducted and/or participated in, +directly or indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal +activity in violation of 14 V.I.C. § 605(a). +128. JP +illegal activity has caused serious harm to the Virgin Islands and its +residents, including without limitation financial harm, by facilitating the commission of sexual +abuse against young women and underage girls, including their facilitation and participation, +directly or indirectly, in commercial sex acts, in the Virgin Islands. +129. By virtue of this pattern of illegal activity in furtherance of the Epstein sextrafficking enterprise, JP +is liable to the Government for all appropriate civil remedies +under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein's +victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive +relief, attorneys' fees and costs, and all such other relief as the Court deems appropriate. +31 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 32 of 42 +COUNT THREE +Criminal Activity—Willfully Failing To Comply With Federal Banking Law, +Violation of Bank Secrecy Act, 31 U.S.C. $ 5322(a), as it incorporates +_, actionable under Virgin Islands +Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. $S 604(e) and 605(a) +130. +The Government restates and realleges paragraphs 1 to 129 of this Complaint as if +fully set forth herein. +131. +The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail +criminal activity and lessen its economic and political power in the Territory of the Virgin Islands +by establishing new penal prohibitions and providing to law enforcement and the victims of +criminal activity new civil sanctions and remedies." 14 V.I.C. § 601. +132. At all times material herein, JP +I was a "person" as defined in 14 V.I.C. +§ 604(1). +133. At all times material herein, Epstein and his co-conspirators were engaged in an +illicit sex-trafficking "enterprise" as defined in 14 V.I.C. § 604(h). +134. At all times material herein, JP +was employed by and/or associated with +the Epstein sex-trafficking enterprise by providing banking and payment-processing services to +Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or +incorporated in the Virgin Islands. +135. +In providing banking and payment-processing services to Epstein and Epsteincontrolled entities, JPL +knowingly, intentionally, and willfully failed to comply with federal +banking regulations in violation of 31 U.S.C. § 5322(a), +32 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 33 of 42 +. From accounts maintained and served at JP +Epstein and Epstein-controlled entities received payments of large dollar amounts for no apparent +business or other lawful purpose and made repeated cash payments, sometimes in amounts and +patterns designed to evade federal reporting requirements, to young women and/or underage girls +who were sexually abused and coerced into engaging in commercial sexual acts in the Virgin +Islands and elsewhere. +136. JP +knowing, intentional, and willful failure to comply with federal +banking regulations constitutes a felony under 31 U.S.C. § 5322(a) and "criminal activity" as +defined in 14 V.I.C. § 604(e). +137. By knowingly, intentionally, and willfully failing to comply with federal banking +regulations, JP +enabled Epstein to have ready and reliable access to and use of resources +with which to recruit, entice, harbor, transport, provide, obtain, and maintain young women and +underage girls for purposes of causing them to engage in commercial sex acts in the Virgin Islands +and elsewhere. JP +thereby unlawfully conducted and/or participated in, directly or +indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal activity +in violation of 14 V.I.C. § 605(a). +138. +illegal activity has caused serious harm to the Virgin Islands and its +residents, including without limitation financial harm, by facilitating the commission of sexual +abuse against young women and underage girls, including their engagement in commercial sex +acts, in the Virgin Islands. +33 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 34 of 42 +139. By virtue of this pattern of illegal activity in furtherance of the Epstein sextrafficking enterprise, JP +is liable to the Government for all appropriate civil remedies +under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein's +victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive +relief, attorneys' fees and costs, and all such other relief as the Court deems appropriate. +COUNT FOUR +Unfair Methods of Competition +Violation of Virgin Islands Consumer Fraud +and Deceptive Business Practices Act, 12A V.I.C. $ 304 +140. The Government restates and realleges paragraphs 1 to 139 of this Complaint as if +fully set forth herein. +141. Section 304 of Title 12A of the Virgin Islands Code provides that "lilt is unlawful +for any person to engage in unfair methods of competition ... in the conduct of any trade or +commerce." +142. +is a "person" as defined in 12A V.I.C. § 303(h). +143. JP +provision of banking services and payment processing for Epstein and +Epstein-controlled entities constitutes "[t]rade or commerce" as defined in 12 V.I.C. § 303(k). +144. In return for knowingly and intentionally participating in, directly or indirectly, +facilitating, and concealing by failing to comply with federal banking regulations regarding +Epstein-related accounts, JP| +both profited from the use of the funds in their accounts and +received referrals of other high-value business opportunities from Epstein and his co-conspirators. +145. By receiving referrals of high-value business opportunities from Epstein and his +co-conspirators in return for participating in, directly or indirectly, facilitating, and concealing by +failing to comply with federal banking regulations regarding Epstein-related accounts, JP +unlawfully and unjustly enriched itself at the expense of other banks that complied with their legal +34 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 35 of 42 +obligations. This conduct constitutes an unfair method of competition in violation of 12A V.I.C. § +304. +146. +By virtue of its knowing, intentional, and repeated acts constituting unfair +competition, JP +is liable to the Government for all appropriate civil remedies under 12A +V.I.C. §§ 328 and 332, including damages, civil penalties awarded on a per-violation basis +pursuant to 12A V.I.C. § 328(b), appropriate injunctive relief, attorneys' fees and costs, and all +such other relief as the Court deems appropriate. +COUNT FIVE +Obstruction of Enforcement of Trafficking Victims Protection Act +19 U.S.C. $§ 1591(d), 1595(d) (Parens Patriae) +147. The Government restates and realleges paragraphs 1 to 146 of this Complaint as if +fully set forth herein. +148. The Government brings this Count as parens patriae on behalf of the residents and +visitors of the United States Virgin Islands and pursuant to the Attorney General's express +statutory authority. +149. JP +and its officers and employees knowingly and intentionally obstructed, +attempted to obstruct, interfered with, and prevented the enforcement of 18 U.S.C. §§ 1591(a)(1) +& (a)(2), all in violation of 18 U.S.C. § 1591(d). This activity is hereinafter referred to collectively +as "obstruction." +150. +obstruction of the enforcement of 18 U.S.C. §$ 1591(a)(1) & (a)(2) +was forbidden by 18 U.S.C. § 1591(d), and JP +thereby violated Chapter 77, Title 18. JP +obstruction described here and in the preceding paragraph directly, proximately, and +foreseeably harmed women and girls in the Virgin Islands by directly resulting in them being +caused to engage in commercial sex acts and in other ways. +35 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 36 of 42 +151. The United States Department of Justice (including the U.S. Attorney's Offices for +the Southern District of New York and the Southern District of Florida) was investigating +Epstein's federal criminal liability for violating (among other laws) the TVPA up to and following +the return of an indictment against Epstein on or about July 8, 2019. On or about that date, the +U.S. Attorney's Office for the Southern District of New York indicted Epstein (and unnamed +"associates") for violating the TVPA. Later, on or about July 29, 2020, the same Office indicted +Epstein's co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be +abused by Epstein. The federal criminal investigation of Maxwell included investigation of +possible violations of the TVPA. +152. By providing financing for Epstein's sex trafficking organization from at least 2000 +through about August 2013, and concealing its actions thereafter, JP +obstructed, interfered +with, and prevented the federal government's enforcement of the TVPA against Epstein. To the +extent that the federal government was able to ultimately charge Epstein with TVPA violations, +the filing of these charges was delayed by JP +actions. Because of that delay, women +and girls in the Virgin Islands were coercively caused to engage in commercial sex acts. +153. As one example of how JP| +obstructed, attempted to obstruct, interfered +with, and prevented the federal government's enforcement of the TVPA, JP +permitted +large withdrawals of cash to Epstein and his associates so that the coercive commercial sex acts +would escape the detection of federal law enforcement and prosecuting agencies. JP +permitted these large cash withdrawals to further the Epstein sex-trafficking venture and with the +purpose of helping Epstein evade criminal liability for violating the TVPA +154. +As another example of how JP +obstructed, attempted to obstruct, interfered +with, and prevented the federal government's enforcement of the TVPA, JP +did not follow +36 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 37 of 42 +anti-money laundering (AML) and anti-structuring reporting requirements found in the Bank +Secrecy Act and other laws. These requirements included an obligation that JP +would +review transactions in Epstein's JP +accounts for a determination of whether they involved +suspicious transactions. If JP| +had observed these requirements imposed by law, then it +would have prevented many of the subsequent transactions committed by the Epstein sextrafficking venture. JP +knowingly did not follow these requirements because it knew that +doing so would have prevented Epstein's secret cash transactions that were necessary to his sextrafficking operation from escaping knowledge of federal investigative and prosecuting agencies. +Without JP +cash, women and girls in the Virgin Islands would not have been coercively +forced to engage in commercial sex acts. +155. As another example of how JP +obstructed, attempted to obstruct, interfered +with, and prevented the federal government's enforcement of the TVPA, +156. +is not protected from liability for | +157. JP +spite of numerous red flags, was wrongful and purposeful. +about Epstein's sex-trafficking venture, in +37 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 38 of 42 +158. +If JP +had +the appropriate federal agencies would have been well +positioned to investigate Epstein's sex-trafficking venture and TVPA violations. JP +obstructed the federal government's ability to investigate +those TVPA violations, including violations harming women and girls in the Virgin Islands. If JP +had +I. it would have prevented the continuation of Epstein's +sex-trafficking venture, which required the ability to secretly use cash to pay of victims. +159. By permitting the large cash withdrawals by and for Epstein and his associates, JP +intended and knew that Epstein's coercive commercial sex acts would escape the detection +of federal law enforcement and prosecuting agencies for some period of time. JP +permitted cash withdrawals to further the Epstein sex-trafficking venture and with the purpose of +helping Epstein evade criminal liability for violating the TVPA. +160. JP +obstruction, attempted obstruction, interference with, and prevention +of the enforcement of the TVPA were all done intentionally and knowingly. For example, JP +knew that Epstein was high-risk-specifically, high-risk to violate the TVPA through +continuing criminal sex-trafficking activities. +161. JP +was well aware that Epstein had pleaded guilty and served prison time +for engaging in sex with a minor—a crime closely connected with sex-trafficking in violation of +the TVPA. JP +also was well aware that there were public allegations that his illegal +conduct was facilitated by several named co-conspirators. But JP +concealed from the +federal government its numerous cash payments to those co-conspirators. +continued +its affirmative conduct of allowing Epstein to access cash so that he could make those cash +payments to his co-conspirators with knowledge that such cash transactions did not produce a clear +38 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 39 of 42 +paper trail. JP +intentional conduct obstructed, attempted to obstruct, in many ways +interfered with, and prevented the enforcement of the TVPA by federal investigators and +prosecuting agencies. +162. +relationship with Epstein in allowing his sex-trafficking venture to +access large sums of cash each year went far beyond a normal (and lawful) banking relationship. +knew, and intended, that its relationship with Epstein would go far beyond a normal +banking relationship. JP +knew that its decision to go beyond a normal banking +relationship with Epstein obstructed the ability of federal law enforcement and prosecuting +agencies to enforce the TVPA. +163. JP +obstruction of the federal government's TVPA and other law +enforcement efforts was intentional and willful and, therefore, JP +intentionally and +willfully caused Epstein's commission of the forcible commercial sex acts with women and girls +in the Virgin Islands through its obstruction supporting the concealment of Epstein's sextrafficking venture. JP +knew that Epstein and his other co-conspirators would use means +of force, threats of force, fraud, coercion, and a combination of such means to cause women and +girls, including those in the Virgin Islands, to engage in commercial sex acts. +164. JP| +knew and acted in reckless disregard of the fact that its obstruction in +violation of 18 U.S.C. § 1591(d) would directly and proximately lead to unlawful coercive +commercial sex acts by Epstein with young women and girls, including those in the Virgin Islands. +165. +obstruction has caused women and girls in the Virgin Islands serious +harm, including, without limitation, physical, psychological, financial, and reputational harm. +That harm was directly and proximately caused by the obstruction and the harm resulting from +obstruction was foreseeable. +39 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 40 of 42 +166. +obstruction has caused women and girls in the Virgin Islands harm +that is sufficiently serious, under all of the surrounding circumstances, to compel a reasonable +person of the same background and in the same circumstances to perform or to continue +performing commercial sexual activity in order to avoid incurring that harm. +167. This case does not involve mere fraud. Instead, JP +criminal conduct in +obstructing enforcement of the TVPA was outrageous and intentional because it was in deliberate +furtherance of a widespread and dangerous criminal sex trafficking organization. JP +obstruction also evinced a high degree of moral turpitude and demonstrated such wanton +dishonesty as to imply a criminal indifference to its legal obligations. JP +obstruction +was directed specifically at women and girls, including those in the Virgin Islands, who were the +victims of Epstein's sex-trafficking organization. +168. +has caused serious harm to the Virgin Islands and its residents, including +without limitation, financial harm, by obstructing federal law enforcement which facilitated the +commission of sexual abuse against women and girls, including their engagement in commercial +sex acts, in the Virgin Islands. By virtue of these knowing and intentional violations of 18 U.S.C. +§ 1591(d), JP +is liable to the Government for appropriate relief under 18 U.S.C. § 1595(d). +REQUEST FOR RELIEF +The Government respectfully requests that the Court enter judgment in its favor, and +against JP +as follows: +A. +That the Court award the Government compensatory, consequential, general, and +nominal damages, as suffered by the Government and/or Epstein's victims, and +punitive damages, all against JP +| in amounts to be awarded at trial; +40 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 41 of 42 +B. That the Court award the Government punitive and exemplary damages against JP +in an amount to be determined at trial; +C. That the Court order JP | +to pay appropriate fines to the Government +pursuant to 18 U.S.C. § 1591(b) in amounts to be determined at trial; +D. That the Court order JP +E. +F. +G. +H. +to provide restitution of all ill-gotten gains to the +Government pursuant to 18 U.S.C. § 1593 and 14 V.I.C. § 607(a)(6) and pursuant +to 14 V.I.C. § 608(c)(4) to protect the rights of victims and innocent persons in the +interest of justice and consistent with the purposes of the CICO Act, in amounts to +be determined at trial; +That the Court award the Government treble damages against JP +pursuant +to 14 V.I.C. § 607(c) in an amount to be determined at trial; +That the Court order JP +to pay appropriate civil penalties to the +Government pursuant to 14 V.I.C. § 607(e) and 12A V.I.C. § 328(b) and pursuant +to 14 V.I.C. § 608(c)(4) to protect the rights of victims and innocent persons in the +interest of justice and consistent with the purposes of the CICO Act, in amounts to +be determined at trial; +That the Court enter an injunction pursuant to 14 V.I.C. § 607(a)(2) and 12A V.I.C. +§ 328(a)(2) to prevent further illegal conduct and any concealment of illegal +conduct; +That the Court order JP +to provide disgorgement of all ill-gotten gains to +the Government pursuant to 14 V.I.C. § 607(a)(6) and pursuant to 14 V.I.C. +§ 608(c)(4) to protect the rights of victims and innocent persons in the interest of +41 + + +Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 42 of 42 +justice and consistent with the purposes of the CICO Act, in amounts to be +determined at trial; +I. +That the Court award the Government attorneys' fees and costs pursuant to 18 +U.S.C. § 1595, 14 V.I.C. § 607(c), and 12A V.I.C. § 332 in amounts to be +determined after trial; and +That the Court award the Government and order JP +to provide all such +other relief as the Court deems appropriate. +JURY DEMAND +The Government demands a jury trial on all issues so triable. +Dated: April 3, 2023 +CAROL +_. ESQ. +ACTING ATTORNEY GENERAL +/s/ Linda +Linda +Mimi Liu (pro hac vice) +David I. Ackerman +Paige Boggs (pro hac vice) +MOTLEY RICE LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 / Fax: (202) 232-5513 +pboggs@motleyrice.com +Tel: (340) 774-5666 ext. 10101 +Attorneys for Plaintiff Government of the +United States Virgin Islands +42 \ No newline at end of file diff --git a/vision-fixhub/court-05/70551c4cb40145fb0869080d99a5b9a737cf3e834af4ebbc4d92f77f59cd1fe8.receipt.json b/vision-fixhub/court-05/70551c4cb40145fb0869080d99a5b9a737cf3e834af4ebbc4d92f77f59cd1fe8.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..99a38ffc603aae48daa2948b329d2eaa71daf14e --- /dev/null +++ b/vision-fixhub/court-05/70551c4cb40145fb0869080d99a5b9a737cf3e834af4ebbc4d92f77f59cd1fe8.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -622, + "dataset": "marble-joined", + "doc_id": "70551c4cb40145fb0869080d99a5b9a737cf3e834af4ebbc4d92f77f59cd1fe8", + "engine": "marble-apple-vision", + "event_count": 55, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "68ee6d68167e5b4b9583cc3b8adbc0040663801485a831002780a9171c9eb1e3", + "output_sha256": "1f02cd4879b226f05c0a74f100a66bb01146019cf0801d79f3a0b369589b4bd1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/706c14bda0b02c62771bbcfec59de0019e28da4f15367465eb133a49a5d5143d.md b/vision-fixhub/court-05/706c14bda0b02c62771bbcfec59de0019e28da4f15367465eb133a49a5d5143d.md new file mode 100644 index 0000000000000000000000000000000000000000..cb94a7c4372559b08b590746bb12a877f4abb897 --- /dev/null +++ b/vision-fixhub/court-05/706c14bda0b02c62771bbcfec59de0019e28da4f15367465eb133a49a5d5143d.md @@ -0,0 +1,56 @@ +Case 1:22-cv-10904-JSR Document 326-105 Filed 09/08/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 326-105 Filed 09/08/23 Page 2 of 3 +Date: +Sunday. March 28 2010 05:19 PM +Subject: Re: +From: +Jeffrey Epstein sieevacation@gmail.com> +To: +Jes +too much emphasis on succession.. too much we did this because we were requested as opposed to joined in the +effort. less 1 and more we. +On Sun, Mar 28, 2010 at 1:03 PM, ‹jes +wrote: +--Original Message-.-. +From: les Staley sies stalev@inmoman. com> +To: 'jes +Sent: Sun, Mar 28, 2010 1:01 pm +Subject: Fw: +From: Jamie Dimon +To: Operating Committee +Sent: Fri Mar 19 18:58:04 2010 +Subject FW: +Attached is a current draft of the shareholder letter for your weekend reading. As you read it, think about: +• Do we cover the businesses and key messages completely and clearly +Are the arguments rational and reasonable +• Are the statements made with enough clarity so as not to be taken out of context (I don'tmind saying what we believe) +You can e-mail me or call me with your final comments - either at home +or at work on Sat. & Sunday from Noon +- 5pm. +Thanks, Jamie +his email is confidential and subject to important disclaimers and conditions including on offers for the purchase or sale o +ecurities, accuracy and completeness of information, viruses, confidentiality, legal privilege, and legal entity disclaimers +available at http://www.jpmorgan.com/pages/disclosures/email. +0 50 0 00* +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thercof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and + +ESTATE_JPM003001 + + +Case 1:22-cv-10904-JSR Document 326-105 Filed 09/08/23 Page 3 of 3 +destroy this communication and all copies thereof, +including all attachments. + +ESTATE_JPM003002 diff --git a/vision-fixhub/court-05/706c14bda0b02c62771bbcfec59de0019e28da4f15367465eb133a49a5d5143d.receipt.json b/vision-fixhub/court-05/706c14bda0b02c62771bbcfec59de0019e28da4f15367465eb133a49a5d5143d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..42f0b0b67c34ad6a3f21a8f018b408447748b6b5 --- /dev/null +++ b/vision-fixhub/court-05/706c14bda0b02c62771bbcfec59de0019e28da4f15367465eb133a49a5d5143d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -71, + "dataset": "marble-joined", + "doc_id": "706c14bda0b02c62771bbcfec59de0019e28da4f15367465eb133a49a5d5143d", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "034cdec58b970db4fab00ad27154369183ac2c3a0c523b990745825e42b290e2", + "output_sha256": "287cf5958fc827ac08e0fad73b6b733aba003818d7310917ff12335fa5b47062", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7090ac98255db0f19d9f9c3092cb438511b1fef2c224a59fd573e4bf14bed1e3.md b/vision-fixhub/court-05/7090ac98255db0f19d9f9c3092cb438511b1fef2c224a59fd573e4bf14bed1e3.md new file mode 100644 index 0000000000000000000000000000000000000000..008d6e33018e893e11e5ed485a805229a878d55a --- /dev/null +++ b/vision-fixhub/court-05/7090ac98255db0f19d9f9c3092cb438511b1fef2c224a59fd573e4bf14bed1e3.md @@ -0,0 +1,6 @@ +Case 1:22-cV-10904-JSR Document 326-66 Filed 09/08/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 326-66 Filed 09/08/23 Page 2 of 2 +26L9000 ANSW diff --git a/vision-fixhub/court-05/7090ac98255db0f19d9f9c3092cb438511b1fef2c224a59fd573e4bf14bed1e3.receipt.json b/vision-fixhub/court-05/7090ac98255db0f19d9f9c3092cb438511b1fef2c224a59fd573e4bf14bed1e3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e7aa31ff86d62524d55d5b3b809b3f8d4a9efc91 --- /dev/null +++ b/vision-fixhub/court-05/7090ac98255db0f19d9f9c3092cb438511b1fef2c224a59fd573e4bf14bed1e3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "7090ac98255db0f19d9f9c3092cb438511b1fef2c224a59fd573e4bf14bed1e3", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "926fc273e380b47c4569463187d1f0fe105d18013682f9cf85f613a6dbde312a", + "output_sha256": "5bdead55294da690e7346d6663643659f0435e212fe1edc8c00f2dd7a5ed10ca", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/70a4507fdeb10f29512e0d43a6713d5fe3479c3fcb73c86878e77ee5fbfcd567.md b/vision-fixhub/court-05/70a4507fdeb10f29512e0d43a6713d5fe3479c3fcb73c86878e77ee5fbfcd567.md new file mode 100644 index 0000000000000000000000000000000000000000..8d32e6829555b94dc54dd5a8550069d5b9451ada --- /dev/null +++ b/vision-fixhub/court-05/70a4507fdeb10f29512e0d43a6713d5fe3479c3fcb73c86878e77ee5fbfcd567.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 268-7 Filed 08/07/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/70a4507fdeb10f29512e0d43a6713d5fe3479c3fcb73c86878e77ee5fbfcd567.receipt.json b/vision-fixhub/court-05/70a4507fdeb10f29512e0d43a6713d5fe3479c3fcb73c86878e77ee5fbfcd567.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c0e005409d43b4e3d2e10c45cc6d40b9a089b5c0 --- /dev/null +++ b/vision-fixhub/court-05/70a4507fdeb10f29512e0d43a6713d5fe3479c3fcb73c86878e77ee5fbfcd567.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "70a4507fdeb10f29512e0d43a6713d5fe3479c3fcb73c86878e77ee5fbfcd567", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "4873571af3295325dc2b7e284f2b084553a1e05f33a8a931c8dae7ba6433c47f", + "output_sha256": "406243a10bf4466eb6f335f7a14b4b901d495861d23632819e78a84ebaf1efc5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/70aee9c6b41d031211d5893ce6cefd8f64795bd91dcbe04fd0d7e7a6e14f7857.md b/vision-fixhub/court-05/70aee9c6b41d031211d5893ce6cefd8f64795bd91dcbe04fd0d7e7a6e14f7857.md new file mode 100644 index 0000000000000000000000000000000000000000..215ffedb2ce4690b240d65642f03a8cb11a1d192 --- /dev/null +++ b/vision-fixhub/court-05/70aee9c6b41d031211d5893ce6cefd8f64795bd91dcbe04fd0d7e7a6e14f7857.md @@ -0,0 +1,133 @@ +Case 1:22-cv-10904-JSR Document 270 Filed 08/07/23 Page 1 of 4 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintifi. +Case Number: 1:22-cv-10904-JSR +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +V. +JAMES EDWARD STALEY +Third-Party Defendant. +DECLARATION OF DAVID I. ACKERMAN IN SUPPORT OF +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +MEMORANDUM OF LAW IN OPPOSITION TO JPMORGAN CHASE BANK N.A.'S +MOTION FOR PARTIAL SUMMARY JUDGMENT +Pursuant to 28 U.S.C. § 1746, I, David I. Ackerman, declare under penalty of perjury as +follows: +1. +I am a member in good standing of the bars of the State of New York, the State of +New Jersey, and the District of Columbia, and am admitted to practice before this Court. I am one +of the attorneys representing the Government of the United States Virgin Islands in the abovecaptioned action. I am a Member of the law firm of Motley Rice LLC, and my office is located at +401 9th Street NW, Suite 630, Washington, DC 20004. I am familiar with the facts set forth herein +and if called as a witness, I could and would competently testify thereto. I submit this Declaration + + +Case 1:22-cv-10904-JSR Document 270 Filed 08/07/23 Page 2 of 4 +and the attached Exhibits in support of the United States Virgin Islands' Memorandum of Law in +Opposition to JPMorgan Chase Bank, N.A.'s Motion for Partial Summary Judgment. +Attached hereto are true and correct copies of the following: + +Number + + + + + + + + + + + +Description +Transcript excerpts of the Deposition of Assistant Attorney General Chris +Timmons (as 30(b)(6) designee), taken on July 14, 2023, in this Action. +Transcript excerpts of the Deposition of Commissioner, Department ol +Planning and Natural Resources Jean-Pierre Oriol (as 30(b)(6) designee) +taken on July 7, 2023, in this Action. +Document, "Bank Secrecy Act / Anti-Money Laundering Examination +Manual," 2006, and previously marked as Langford Exhibit 8 (excerpt). +Expert Report of Jonathan J. Rusch, June 16, 2023 (excerpts). +Document at +| JPM-SDNYLIT-00128583-00128713, JPM-SDNYLI- +00128583, 00128612-00128613 (excerpts) produced by JPMorgan in this +Action, designated Confidential by JPMorgan pursuant to the Protective Order +in this matter and filed under seal. [Sealed] +Document at JPM-SDNYLIT-00128084-00128099 produced by +JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the +Protective Order in this matter and filed under seal. [Sealed] +Transcript excerpts of the Deposition of Shani A. Pinney (as 30(b)(6) +designee), taken on July 18, 2023, in this Action. +Transcript excerpts of the Deposition of former Acting Attorney General +Carol I +1, taken on July 13, 2023, in this Action. +Transcript excerpts of the Deposition of former Attorney General Denise +L, taken on July 17, 2023, in this Action. +Transcript excerpts of the Deposition of former Governor of the U.S. Virgin +Islands John de Jongh, Jr., taken on May 30, 2023, in this Action. +Transcript excerpts of the Deposition of former Governor of the U.S. Virgin +Islands Kenneth E. Mapp, taken on May 24, 2023, in this Action. +2 + + +Case 1:22-cv-10904-JSR Document 270 Filed 08/07/23 Page 3 of 4 + + + + + + + + + + +Transcript excerpts of the Deposition of Governor of the U.S. Virgin Islands +Albert Bryan, Jr., taken on June 6, 2023, in this Action. +January 20, 2011, email JPM-SDNYLIT-00152833 and previously +marked as Langford Exhibit 40. +Transcript excerpts of the Deposition of former head of Compliance at +3. in this Actior +Morgan, indra anglord, taken Mo, dential this Actiomon +contained in these excerpts. +Transcript excerpts of the Deposition of former JPMorgan General Counsel +Stephen Cutler, taken May 24, 2023, in this Action. JPMorgan has withdrawn +its designation of Confidential for the testimony contained in these excerpts. +Transcript excerpts of the Deposition of former General Counsel of +JPMorgan's Investment Bank, Jonathan +1, taken July 14, 2023, in +this Action. JPMorgan has withdrawn its designation of Confidential for the +testimony contained in these excerpts. +The U.S. Department of Justice "Confidentiality and Media Contacts Policy," +available: https://www.justice.gov/jm/jm-1-7000-media-relations#1-7.400, last +accessed August 4, 2023. +Transcript excerpts of the JPMorgan 30(b)(6) Deposition of Senior Advisor, +Risk and Compliance, Francis Pearn, taken on March 29, 2023, in this +Action. JPMorgan has withdrawn its initial designation of Confidential for the +testimony contained in these excerpts. +xcel document at +I JPM-SDNYLIT-W-00026257 (excerpts) produced by +Morgan in this Action, designated Confidential by JPMorgan pursuant to tl +Protective Order in this matter and filed under seal. [Sealed] +Financial Crimes Enforcement Network, Section 314(b), available: +https://www.fincen.gov/section-314b, last accessed August 4, 2023. +Article by Joel Christie, et al., The busy life of Jeffrey Epstein: Group of +gorgeous Manhattan 'it' girls in and out of the billionaire sex offender's +mansion before Clinton pal flies off in private jet with comely brunette, +available: https://www.dailymail.co.uk/news/article-3405407/The-busy-life- +Jeffrey-Epstein-Group-gorgeous-Manhattan-girls-billionaire-pedophile-s- +mansion-flies-private-jet-attractive-brunette.html, last accessed August 4, 2023. +3 + + +Case 1:22-cv-10904-JSR Document 270 Filed 08/07/23 Page 4 of 4 +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true +and correct. +Dated: August 7, 2023 +No Leer- +David I. Ackerman +4 diff --git a/vision-fixhub/court-05/70aee9c6b41d031211d5893ce6cefd8f64795bd91dcbe04fd0d7e7a6e14f7857.receipt.json b/vision-fixhub/court-05/70aee9c6b41d031211d5893ce6cefd8f64795bd91dcbe04fd0d7e7a6e14f7857.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a6ada42d5b4e4b50fffb87d06bd7655db11ccf39 --- /dev/null +++ b/vision-fixhub/court-05/70aee9c6b41d031211d5893ce6cefd8f64795bd91dcbe04fd0d7e7a6e14f7857.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -258, + "dataset": "marble-joined", + "doc_id": "70aee9c6b41d031211d5893ce6cefd8f64795bd91dcbe04fd0d7e7a6e14f7857", + "engine": "marble-apple-vision", + "event_count": 27, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "bfe7e5f9e642ed852a4c0f850e8be8cd47acca3ff5bdc3da8267c2d0f994621b", + "output_sha256": "d14bfea4d44a5c3412a4836e90f005a273e4e5e9721d6b605cbdfbc0c5981ddd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/70c798ef279e22e42b5653aefeddf14450a6e9a7d39b70d8494ba24f3b403f80.md b/vision-fixhub/court-05/70c798ef279e22e42b5653aefeddf14450a6e9a7d39b70d8494ba24f3b403f80.md new file mode 100644 index 0000000000000000000000000000000000000000..f9abea175c6527fab0b79ee6fc6db6c160bf0651 --- /dev/null +++ b/vision-fixhub/court-05/70c798ef279e22e42b5653aefeddf14450a6e9a7d39b70d8494ba24f3b403f80.md @@ -0,0 +1,32 @@ +Government of the United States Virgin Islands +Plaintiff +Civil Action No.: 1:22-cv-10904-JSR +VS. +Chase Bank, N.A. +Defendant +AFFIDAVIT OF DUE DILIGENCE +1, Ericka Cremeans, a Private Process Server, having been duly authorized to make service of the Letter dated February 2nd, 2023, +Sube and uses Tecum with Exhibit , Protecive Order, and Non-Disclosure A rement in the above emiled cas, hereby +That I am over the age of eighteen years and not a party to or otherwise interested in this matter. +That after due search, careful inquiry and diligent attempts), I have been unable to serve Leslie Wexler with the above named +process. +That on February 8, 2023 at 8:10 AM, I attempted to serve Leslie Wexner at | Whitebarn Road, New Albany, Ohio 43054-9407. +On this occasion, 1 was unable to gain access to the property per security manned at the entry. Accordingly, I asked if Leslie +Wexner was available or if 1 could speak with him, however I was not provided with that information. +That on February 8, 2023 at 8:40 AM, 1 attempted to serve Leslie Wexner at 8000 Walton Parkway, Suite 100, New Albany, Ohio +43054-7075. On this occasion, I found that Suite 100 belongs to NA Property, Inc., and Leslie Wexner was not known at this Suite +upon my asking. Accordingly, I went to Suite 110, which I found belongs to the Wexner Foundation, but was locked and has +keycard access only. Furthermore, 1 found that Suite 110 did have an intercom on the wall outside of the door and I did try +contacting the business using the intercom. A woman came over the intercom and upon my asking, she stated that Leslie Wexner +was not in, and that he is rarely ever there because he only comes in two to three times a year. No further information could be +provided on Wexner's whereabouts at this time. +That on February 11, 2023 at 2:00 PM, I attempted to serve Leslie Wexner at | Whitebarn Road, New Albany, Ohio 43054-9407. +On this occasion, yet again, I was unable to gain access to the residence per the manned security at the entry to the property. +1 declare under penalty of perjury that this information is true. +2/14/2023 +Executed On +EukanCemeans +Ericka Cremeans +Client Ref Number:0636630.015 +Job #: 1613955 +Capitol Process Services, Inc. | 1827 18th Street, NW, Washington, DC 20009| (202) 667-0050 diff --git a/vision-fixhub/court-05/70c798ef279e22e42b5653aefeddf14450a6e9a7d39b70d8494ba24f3b403f80.receipt.json b/vision-fixhub/court-05/70c798ef279e22e42b5653aefeddf14450a6e9a7d39b70d8494ba24f3b403f80.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ff8e8772dabec309350e77298412215b28abe498 --- /dev/null +++ b/vision-fixhub/court-05/70c798ef279e22e42b5653aefeddf14450a6e9a7d39b70d8494ba24f3b403f80.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "70c798ef279e22e42b5653aefeddf14450a6e9a7d39b70d8494ba24f3b403f80", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "adf3fd51b723a6ae785d9d7fbd8cca4d92f3edcb2f0d052f40007e3f0bff308b", + "output_sha256": "393ddfd6d8ea83002d274d40809660d47e9902ec5ed0b75b70bbd8c8fa0ddf20", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/70cc653caf49626dd0b233edb5768bf571ff98f71d79c5e07913316e5c0a4c8c.md b/vision-fixhub/court-05/70cc653caf49626dd0b233edb5768bf571ff98f71d79c5e07913316e5c0a4c8c.md new file mode 100644 index 0000000000000000000000000000000000000000..46f67287bc0761396eed2aa5b3262af26aa8e24a --- /dev/null +++ b/vision-fixhub/court-05/70cc653caf49626dd0b233edb5768bf571ff98f71d79c5e07913316e5c0a4c8c.md @@ -0,0 +1,33 @@ +Case 1:20-cr-00330-PAE +Document 725 +Filed 07/12/22 Page 1 of 2 +HADDON +Haddon, +and +, P.C +Jeffrey S. Pagliuca +150 East 10th Avenue +Denver, Colorado 80203 +PH 303.831.7364 +FX 303.832.2628 +www.hmflaw.com +jpagliuca@hmflaw.com +November 28, 2021 +VIA EMAIL +The Honorable Alison J. Nathan +United States District Court +Southern District of New York +40 Foley Square +New York, NY 10007 +Re: +United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Dear Judge Nathan, + + +Case 1:20-cr-00330-PAE Document 725 Filed 07/12/22 Page 2 of 2 +The Honorable Alison J. Nathan +November 28, 2021 +Page 2 +Respectfully submitted, +Jeffrey S. Pagliuca +CC: Counsel of Record diff --git a/vision-fixhub/court-05/70cc653caf49626dd0b233edb5768bf571ff98f71d79c5e07913316e5c0a4c8c.receipt.json b/vision-fixhub/court-05/70cc653caf49626dd0b233edb5768bf571ff98f71d79c5e07913316e5c0a4c8c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..be5f9c5e95cc08b2dff87ff02fdada78aea3c650 --- /dev/null +++ b/vision-fixhub/court-05/70cc653caf49626dd0b233edb5768bf571ff98f71d79c5e07913316e5c0a4c8c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "70cc653caf49626dd0b233edb5768bf571ff98f71d79c5e07913316e5c0a4c8c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "44fb0c11363f0731f0d62faac2939bbd1dd405494e39a35878e5c77e1897148c", + "output_sha256": "4932202b06784c6a19a0fea6af34a04b5cc8722e764cf7a964ad5056f903ba86", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/70deac025372c14667eef35c21d91464bf4c14fd42280e01b55971c1c1c5adcf.md b/vision-fixhub/court-05/70deac025372c14667eef35c21d91464bf4c14fd42280e01b55971c1c1c5adcf.md new file mode 100644 index 0000000000000000000000000000000000000000..f4ae0478009e11ef25f26eaa37144dce80c7703a --- /dev/null +++ b/vision-fixhub/court-05/70deac025372c14667eef35c21d91464bf4c14fd42280e01b55971c1c1c5adcf.md @@ -0,0 +1,269 @@ +Case 1:22-cV-10904-JSR Document 285-80 Filed 08/15/23 Page 1 of 4 + + + +From: +To: +CC: +Sent: +Subject: +Attachments: +Case 1:22-cv-10904-JSR Document 285-80 Filed 08/15/23 Page 2 of 4 +Paul S < +@jpmorgan.com +Brad Wechsler ;Nelson, Justin D" Transfers and Payments > +DOMESTIC WIRE (USA DESTINATION) +WIRE: +Status: +From Account: +Processed - Confirmation Number is +Wire Fee: $12.50 +Saved as Model +Beneficiary +Bear Stearns & Company +New York +New York +Help +Currency: US Dollars +Bank +Name: CITIBANK NA +ABA: +Address: New York +New York +New York +Beneficiary's Account number: +Amount: $15,000,000.00 +Date of transfer(s): December 29, 2004 +Special Instructions: +f/f/c Financial Trust Company, +Inc. +Acct # +Process anather Wire +https://citibusinessonline.da-us.citibank.com/basprod/citiiwt/html/WTd80U.html + +12/29/2004 +JPM-SDNYLIT-00016246 + + +Case 1:22-cv-10904-JSR Document 285-88 Filed 08/15/23 Page 3 of 12 +FINANCIAL +TRUST +CO., INC. +ST. HOOK CUARTER, B3 +:. VI 00802-1343 +relephone: 340.775.2525 +facsimile: 340.775.2528 +e-mail: ftrusr@attglobal.net +December 28, 2004 +Mr. Ron Resnick +Highbridge Capital Management, LIC +9 West 57th Street +27th Floor +New York, NY 10019 +Fees for merger and acquisition advice: +OK to pay sumessing +Tour +Amount due: $15.000.000 +Please wire the funds as follows: +Bank Name: +ABA Routing No: +For the Benefit of: +Beneficiary Account: +For Credit to: +Account No: +Citibank, N.A. +New York, NY +Bear Steams & Company +Financial Trust Company, Inc. + +tova +JPM-SDNYLIT-00016247 + +Case 1:22-cv-10904-JSR Document 285-88 Filed 08/15/23 Page 4 of 12 +HIGHBRIDGE +CAPITAL MANAGEMENT, LLC +9 WEST 57TH STREET +27" FLOOR +NEW YORK, NEW YORK 10153 +TEL: 212/751-4510 +FAX: 212/759-6010 +FACSIMILE COVER SHEET +TO: +FROM: +DATE: +Darren Indyke +FAX NUMBER: +Financial Trust Company, Inc. +PHONE: +Ron Resnick +June 24, 2005 +FAX NUMBER: +PHONE: +# PAGES (incl. cover): 10 +(212) 750-0381 +(212) 750-1176 +(212) 287-4915 +(212) 287-4939 +Dear Darren: +The revised Consulting Agreement follows for your review (blackline version). +Please do not hesitate to contact me if you have any questions. +Thank you. +est wishes, +Ban +CC: +Glenn +Mark +Bill Shepherd +Bob Caruso +Yul Tobaly +Bill Bulmer + +JPM-SDNYLIT-00016248 + + +Case 1:22-cv-10904-JSR Document 285-88 Filed 08/15/23 Page 5 of 12 +CONSULTING AGREEMENT +This Consulting Agreement (this "Agreement") is effective as of June 1, 2005, between +Highbridge Capital Management, LLC, a Delaware company (the "Company") with its +principal office at 9 West 57th Street, 27th Floor, New York, New York 10019, and +Financial Trust Company, Inc., a United States Virgin Islands corporation ("Consultant"), +with its principal office at 6100 Red Hook Quarter, Suite B-3, St. +U.S.V.l. +00802. +In consideration of the mutual promises in this Agreement, the parties hereto agree as +follows: +ENGAGEMENT +(a) The Company hereby engages Consultant, and the Consultant hereby +accepts the engagement by the Company, to provide the Consulting Services (as +hereinafter defined) to the Company, upon, subject to and in accordance with the terms, +conditions and other provisions set forth in this Agreement. For purposes of this +Agreement, the "Consulting Services" shall mean those certain consulting services from +time to time requested by the Company as are identified on Schedule A hereto. The +Consultant will assign Jeffrey Epstein to perform all of the services contemplated herein. +(b) +In performing its obligations hereunder, the Consultant shall at all times +act in what it reasonably believes to be in the best interests of the Company and in +accordance with the highest standards of professional conduct and integrity. Except for +gross negligence, bad faith or willful misconduct, or violation of applicable law, neither +the Consultant nor any of its shareholders, officers, directors, employees, attorneys or +agents shall be liable hereunder or otherwise for any action performed or omitted to be +performed or for any errors of judgment in connection with the Consultant's performance +of this Agreement. In no event shall the Consultant be liable to the Company for any +lost profits or any indirect, consequential, special, incidental, and/or punitive damages of +any kind or nature whatsoever. +It is understood and agreed that the Company may accept or reject any +advice given by the Consultant. It is understood and agreed that the Company may +arrange for or engage other persons or entities to perform the same work that +Consultant performs hereunder. In no event shall the Consultant have any liability to +the Company based upon the Company's failure to follow any advice given by the +Consultant or the Company's following advice given to the Company by any person or +entity other than the Consultant. Neither the Company's failure to follow any advice +given by the Consultant, nor the engagement of any other advisors or consultants by +the Company, whether or not for compensation, shall relieve the Company of its +obligation to pay the fees due to the Consultant hereunder. +(d) It is understood that the Consultant now performs and, throughout the +Term, may perform financial and other consulting services, without limitation, those +similar to the Consulting Services, for various clients other than the Company. The + +JPM-SDNYLIT-00016249 + + +Case 1:22-cv-10904-JSR Document 285-88 Filed 08/15/23 Page 6 of 12 +Company acknowledges and agrees that all services to be provided hereunder by the +Consultant shall be performed on a non-exclusive basis and at times reasonably +convenient to the Company and the Consultant. +(e) The Company agrees that the Consultant may give advice and take action +in the performance of its duties with respect to any of its other clients which, depending +on the characteristics, requirements, directives and objectives of such other clients, may +differ from the advice given to the Company at any particular time. Nothing in this +Agreement shall be deemed to impose upon the Consultant any obligation to advise the +Company to take any action or to omit to take any action which the Consultant, its +principals, affiliates, employees or other clients may take or omit to take, as the case +may be, for the Consultant's own benefit or for the benefit of any other client of the +Consultant, if, in the sole discretion of the Consultant, such action or omission appears +unsuitable, impractical or undesirable for the Company. +(f) There shall be no minimum number of hours of Consulting Services which +the Consultant shall be required to provide under this Agreement. +(g) +Consultant may not assign its rights or subcontract its obligations +hereunder to others, without the express prior written consent of the Company. +(h) +The Company recognizes that the Consultant will perform some or all of +the Consulting Services from its offices in the United States Virgin Islands. +II. TERM +(a) Consultant shall provide services hereunder until the earlier of (i) +December 31, 2009, or (ii) the time this Agreement is terminated as set forth below. +(b) Either the Company or Consultant may terminate this Agreement by +providing ten (10) days' written notice to the other. If the Company terminates this +Agreement other than for Good Cause (as hereinafter defined), or the Consultant +terminates this Agreement for Good Cause, the Company shall promptly pay the +Consultant the then unpaid portion of the Consulting Fee. If the Company terminates +this Agreement for Good Cause or the Consultant terminates this Agreement without +Good Cause, then the Company shall pay the Consultant any then unpaid balance of +the prorated portion of the Consulting Fee calculated through the date of such +termination, but no further payment on account of the Consulting Fee shall be due or +payable to the Consultant for any period after such termination. Upon termination of +this Agreement, whether with or without Good Cause, the Company shall reimburse the +Consultant for all of the reasonable out-of-pocket expenses theretofore incurred by the +Consultant as provided in Section Il|(b) hereof. +(c) +For purposes of this Agreement, a party hereto will have "Good Cause" to +terminate this Agreement only in the event the other party hereto breaches any material +provision of this Agreement and such breach remains uncured for a period of thirty (30) +days after the breaching party is given written notice of such breach by the non- +2 + +JPM-SDNYLIT-00016250 + + +Case 1:22-cv-10904-JSR Document 285-88 Filed 08/15/23 Page 7 of 12 +breaching party hereto. In addition, the Company will have "Good Cause" to terminate +this Agreement in the event of the death or disability of Jeffrey Epstein. +Sections IV and V of this Agreement shall survive the termination of this +(d) +Agreement. +Ill. +COMPENSATION +(a) +Payments. As compensation for all services to be rendered by Consultant +pursuant to this Agreement and for the covenants and agreements of Consultant +contained herein, the Company agrees to pay the Consultant a fee of Two Million Two +Hundred Fifty Thousand Dollars ($2,250,000) (the "Consulting Fee"). The Consulting +Fee shall be payable annually in five (5) equal installments of Four Hundred Fifty +Thousand dollars ($450,000) per annum. The first such installment shall be paid as +soon as practicable after the execution of this Agreement by the parties hereto upon +presentation by the Consultant to the Company of an invoice therefor, and each such +subsequent installment shall be paid, upon presentation by the Consultant to the +Company of an invoice therefor, on the 15 day of June in each subsequent year of the +Term. Each invoice shall include a description of the services rendered to the Company +by the Consultant. The Consultant will deliver to the Company an IRS Form W-9. +(b) +In addition, the Qualified Funds (as hereinafter defined) will be permitted +to be invested in collective investment vehicles managed by the Company or any +affiliate thereof in an aggregate amount equal to 0.85% of the total amount of (i) assets +from time to time under management in Highbridge +L.P. ("HCC"), plus (ii) funds +engaged in an individual strategy within HCC, on the same fee basis (including with +respect to incentive fees, incentive allocations, management fees and administrative +fees) upon which employees of the Company would be able to invest in such funds. For +purposes of this Agreement, "Qualified Funds" means funds invested by (i) the +Consultant, (i) Jeffrey Epstein or (iii) any affiliate of the Consultant owned, directly or +indirectly, by Jeffrey Epstein, in each such case which are invested for such investors +and thus directly or indirectly for Jeffrey Epstein's own account. Consultant bears all +responsibility for paying applicable state and federal income or other taxes with respect +to any compensation paid to Consultant hereunder. Consultant hereby agrees to +indemnify and hold the Company harmless from and against any and all losses, claims, +suits or legal actions with respect to Consultant's legal employment or tax status. +Expenses. The Company shall reimburse Consultant for all of the +Consultant's reasonable out-of-pocket expenses properly incurred in connection with +providing services under this Agreement. Such reimbursement shall be made upon +submission to the Company of adequate and appropriate documentation of such costs +and expenses. +IV. SOLICITATION +The Consultant acknowledges and recognizes that Consultant will have access to +confidential and other proprietary information pertaining to the Company and its +3 + +JPM-SDNYLIT-00016251 + + +Case 1:22-cv-10904-JSR Document 285-88 Filed 08/15/23 Page 8 of 12 +businesses and the funds it manages. During the term of the Company's engagement +of the Consultant and for the one year period after the termination of this Agreement +(the "Non-Solicitation period"), the Consultant shall not directly or indirectly, induce, +encourage or suggest any employee or consultant of the Company to terminate +employment or consultancy with the Company, and shall not, directly or indirectly, +employ or engage, or offer employment or engagement, to any person, either +individually or as owner, agent, employee, director, partner, principal, investor, +shareholder, consultant, advisor or independent contractor or in any similar capacity or +otherwise, who during the Company's engagement of the Consultant is or was +employed by the Company. +V. CONFIDENTIALITY +(a) For purposes of this Agreement, the term "Confidential Information" shall +mean all information of any type which is commonly considered of a confidential nature, +and includes, but is not limited to, all materials or information (whether or not +protectable by patent or copyright) commonly considered to be confidential which (i) in +response to a specific problem or issue raised by the Company to the Consultant is +developed, furnished or prepared by or on behalf of Consultant for the Company +pursuant to this Agreement, whether originated, developed, made, conceived or +authored by Consultant alone or jointly with others, or (ii) constitutes Company trade +secrets, patents and copyrighted material, original or unique computer applications, +systems, software and programs created by the Company or exclusively for the +Company by third parties, original or unique financial models created by the Company +or by third parties exclusively for the Company, lists of Company clients and their +contacts and requirements (excluding any clients, contacts and requirements provided +by the Consultant which were not known to the Company, lists of referrals (excluding +any referrals provided by the Consultant which were not known to the Company, lists of +employees or consultants, vendors, suppliers, investing and trading strategies +developed by the Company or exclusively for the Company by third parties, confidential +business information of the Company, including strategic plans and business dealings, +and all other ideas, processes, designs, discoveries, inventions, improvements, +concepts, methods, procedures, techniques, written material, and other know-how, not +generally known in the Company's trade or industry (whether or not patentable or +entitled to trademark, copyright, or other protection), developed or used solely in +connection with the Company's business, but excluding information or materials which: +(i) were previously developed, conceived of, or known by Consultant through lawful +means, (ii) are known, independently ascertainable or readily available to experts, +experienced personnel or sophisticated practitioners in the Company's trade or industry, +(iii) are readily available to the public generally, or (iv) are subsequently disclosed to +Consultant by a third party who is not under any confidentiality obligation to the +Company. +(b) +Consultant hereby acknowledges that during the term hereof, Consultant +will be given access to Confidential Information. Consultant agrees that during and after +the term hereof, subject to the Consultant's right to comply with any lawful demand of +any court or governmental, regulatory or taxing authority having jurisdiction over the +4 + +JPM-SDNYLIT-00016252 + + +Case 1:22-cv-10904-JSR Document 285-88 Filed 08/15/23 Page 9 of 12 +Consultant and subject to the provisions of Section V(e) hereof, Consultant will disclose +Confidential Information to persons or entities, other than directors, officers, employees +or agents of the Company, only with, and strictly in accordance with the terms of, the +prior written authorization of the Company. Subject to the Consultant's right to comply +with any lawful demand of any court or governmental, regulatory or taxing authority +having jurisdiction over the Consultant and subject to the provisions of Section V(e) +hereof, Consultant agrees that he possesses no rights of ownership or use in, and shall +not at any time hereafter claim any rights of ownership or use in, any of the Confidential +Information. +(c) During and after the term hereof, Consultant shall not remove or cause to +be removed from the Company's premises or, subject to the Consultant's right to +comply with any lawful demand of any court or governmental, regulatory or taxing +authority having jurisdiction over the Consultant and subject to the provisions of Section +V(e) hereof, use any Confidential Information or other material whatsoever belonging to +the Company for purposes other than for authorized work Consultant performs +hereunder. +Subject to the Consultant's right to comply with any lawful demand of any +such court or governmental, regulatory or taxing authority having jurisdiction over the +Consultant and subject to the provisions of Section V(e) hereof, upon the earlier to +occur of (i) a request by the Company and (i) the termination of this Agreement, +Consultant will surrender to the Company all Confidential Information obtained by the +Consultant hereunder. Consultant agrees not to retain any copy of such Confidential +Information subsequent to the termination of this Agreement, except to the extent +necessary to keep accurate records of Confidential Information delivered by the +Consultant to any court or governmental, regulatory or taxing authority having +jurisdiction over the Consultant pursuant to a lawful demand of any such court or +governmental, regulatory or taxing authority. +(e) +In the event that the Consultant receives a request from any court or +governmental, regulatory or taxing authority with respect to the disclosure of any +information, knowledge or data subject to the confidentiality provisions of this +Agreement, the Consultant shall, if possible and legally permissible, promptly provide +the Company with written notice of such request and shall, at the Company's sole cost +and expense, cooperate fully with any efforts on the part of the Company to seek a +protective order or other relief intended to limit the scope of such disclosure or to ensure +that any information, knowledge or data so disclosed is accorded confidential treatment. +If, after compliance with the terms of the immediately preceding sentence, the Company +is legally obligated to disclose any such information, knowledge or data, the Company +shall be permitted to do so without being deemed to have violated this Agreement. +VI. INDEMNIFICATION +Each party hereto agrees to indemnify and hold the other party hereto and its +officers, directors, employees, agents and shareholders harmless from any claims or +liability resulting from the gross negligence or willful misconduct of the indemnifying +5 + +JPM-SDNYLIT-00016253 + + +Case 1:22-cv-10904-JSR. Document 285-88 Filed 08/15/23 Page 10 of 12 +party hereto in connection with or arising out of this Agreement, including tax or +withholding obligations, which indemnification by such indemnifying party shall cover all +loss or liability so incurred by the other party hereto, including, without limitation, +reasonable attorneys' fees and reasonable costs. +VIl. LEGAL RELATIONSHIP +(a) +Consultant is for all purposes hereunder an independent contractor, and +nothing in this Agreement shall be construed or inferred to imply that the Consultant is a +partner, joint venturer or employee of the Company or that, except as expressly +provided herein, Consultant is otherwise associated with the Company. Neither party +hereto shall have any authority to act as an agent of the other party hereto and neither +party hereto shall make any representation to the contrary to any other person or entity. +Consultant shall only consult, render advice and perform such tasks as the Consultant +determines are necessary to achieve the results specified by the Company. Neither +party hereto shall make any, or otherwise represent to any third party that such party +has the authority to make any, management decisions for the other party hereto or +undertake to commit the other party hereto to any course of action in relation to any +third party. +VIII. BREACH; NO ADEQUATE REMEDY AT LAW; INJUNCTIVE RELIEF +(a) +Each party hereto shall be entitled to recover damages, including, without +limitation, reasonable costs and reasonable attorney's fees, resulting from any breach of +this Agreement by the other party hereto. +(b) +Consultant hereby acknowledges that, subject to the provisions of Section +V(e) hereof, a violation by the Consultant of any of the covenants and agreements +contained in Sections IV and V of this Agreement will cause continuing irreparable injury +to the Company and that in such event money damages would not be readily calculable +and the Company would not have an adequate remedy at law. Accordingly, Consultant +hereby agrees and consents that, subject to the provisions of Section V(e) if the +Consultant violates any of said provisions of this Agreement, the Company, in addition +to any other rights and remedies available under this Agreement or otherwise, shall be +entitled to equitable relief, including, without limitation, an injunction to be issued by any +court or tribunal of competent jurisdiction restraining Consultant from committing or +continuing any violation of this Agreement. +(c) +If the Company shall institute any action or proceeding for such equitable +relief to enforce the terms of Sections IV and/or V hereof, Consultant hereby waives and +agrees not to assert the claim or defense that the Company has an adequate remedy at +law. +(d) +The rights and remedies of each party hereto provided for in this +Agreement shall be deemed to be cumulative and concurrent and in addition to and not +in limitation or exclusion of all other rights and remedies, whether at law or in equity or +otherwise, which may exist on the part of such party hereto by reason of any breach of +6 + +JPM-SDNYLIT-00016254 + + +Case 1:22-cv-10904-JSR Document 285-88 Filed 08/15/23 Page 11 of 12 +any provision of this Agreement. The exercise or attempted exercise by any such party +hereto of any such rights or remedies shall not preclude the simultaneous or later +exercise by such party of any or all other such rights or remedies. No course of dealing +by any party hereto, or any delay or omission of any party hereto in exercising any +rights or remedies under this Agreement, shall operate as a waiver of such right or +remedy or any other rights or remedies of such party hereto. +IX. MISCELLANEOUS +(a) +This Agreement represents the entire agreement and understanding of the +parties with respect to the subject matter hereof and supersedes all prior +representations, warranties, covenants, promises, undertakings, commitments, +conditions, agreements and other provisions, whether verbal or written, by any party +hereto with respect to the subject matter hereof, which representations, warranties, +covenants, promises, undertakings, commitments, conditions, agreements, and other +provisions are hereby canceled. Any modification hereof shall not be effective unless +contained in a writing signed by parties hereto. No waiver of any provision of this +Agreement shall be effective unless in writing signed by the party against whom such +waiver is sought to be enforced. No effective waiver of any right under this Agreement +shall preclude the further exercise of such right or the exercise of any other right under +this Agreement. Each such effective waiver shall only be effective in the specific +instance and for the specific purpose for which such waiver is given. +Each provision of this Agreement shall be considered severable such that +if any one provision or clause conflicts with existing or future applicable law, or may not +be given full effect because of such law, this shall not affect any other provision of this +Agreement, which can be given effect without the conflicting provision or clause. The +parties hereto agree that they will amend the terms of provisions determined to be +invalid or unenforceable, but only in the most minimal manner necessary to make such +terms valid and enforceable. +(c) +This Agreement shall inure to the benefit of the parties hereto and their +respective successors and assigns. +(d) +Each party hereto hereby represents that that such party has read and +understands the terms of this Agreement, has had an opportunity to ask any questions +and to seek the assistance of legal counsel regarding these terms, and is not relying +upon any advice from the other party hereto in this regard. +(e) +This Agreement shall be governed by the laws of the State of New York, +excluding its choice of law rules, regardless of where the Company's work is performed +and any litigation with respect to this Agreement may be brought in the federal or state +courts located in New York City. Each party hereto hereby irrevocably submits to the +non-exclusive personal jurisdiction of such courts and agrees that service to such party +of all process in connection with all proceedings relating to, arising out of or connected +with this Agreement before any of such courts will be effective if mailed to such party +postage pre-paid by certified mail, return receipt requested at the address of such party +7 + +JPM-SDNYLIT-00016255 + + +Case 1:22-cv-10904-JSR Document 285-88 Filed 08/15/23 Page 12 of 12 +set forth at the opening of this Agreement or to such other address as may be +designated by such party by notice given to the other party hereto in like manner. +Executed by the undersigned, effective as of the first date written above: +HIGHBRIDGE CAPITAL MANAGEMENT, LLC +By: +Glenn +Co-Chief Executive Officer +CONSULTANT +FINANCIAL TRUST COMPANY, INC. +By: +Jeffrey Epstein +President +8 + +JPM-SDNYLIT-00016256 diff --git a/vision-fixhub/court-05/70fdf20ae97270867f7263b70c16b965c3c21e5b651fe942f8fc75496f0e7817.receipt.json b/vision-fixhub/court-05/70fdf20ae97270867f7263b70c16b965c3c21e5b651fe942f8fc75496f0e7817.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..aac789c97840eddbff25ea530e9329650f2cbf3c --- /dev/null +++ b/vision-fixhub/court-05/70fdf20ae97270867f7263b70c16b965c3c21e5b651fe942f8fc75496f0e7817.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -275, + "dataset": "marble-joined", + "doc_id": "70fdf20ae97270867f7263b70c16b965c3c21e5b651fe942f8fc75496f0e7817", + "engine": "marble-apple-vision", + "event_count": 23, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "628cec2efff2cd67e405926f63b8e043e73ae4ebade34230a1b6a6bcdd64c3c8", + "output_sha256": "1aa1a4106876ec7507b1fa82945b8889b9cb8cc5f6ed9d87d8322a7fad2b494a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/711ae1558b4d4312bef95d01d268c148186216a0099cd725fb813927feb80eb7.md b/vision-fixhub/court-05/711ae1558b4d4312bef95d01d268c148186216a0099cd725fb813927feb80eb7.md new file mode 100644 index 0000000000000000000000000000000000000000..2b58567ff9331a54b7b9e3b4f65c0a2c7e6249f4 --- /dev/null +++ b/vision-fixhub/court-05/711ae1558b4d4312bef95d01d268c148186216a0099cd725fb813927feb80eb7.md @@ -0,0 +1,21 @@ +Case 1:22-cV-10904-JSR Document 268-23 Filed 08/07/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 268-23 Filed 08/07/23 Page 2 of 2 +Date: +Monday, December 24 2018 06:47 PM +Subject: VIPA +From: +Cecile de Jongh < +To: +JE ; +@yahoo.com> +Happy Holidays Jeffrey, +John wanted to know whether you would support Carlton Dowe's bid to go back to VIPA? He is under +consideration and worked his tail off on the campaign. He would be a good person for us at VIPA +With warm regards, +Cecile +Sent from my iPhone and misspellings courtesy of iPhone. + +ESTATE_JPM016521 diff --git a/vision-fixhub/court-05/711ae1558b4d4312bef95d01d268c148186216a0099cd725fb813927feb80eb7.receipt.json b/vision-fixhub/court-05/711ae1558b4d4312bef95d01d268c148186216a0099cd725fb813927feb80eb7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..30acdace99cf367215fc9dcc51ce011a2a6f4275 --- /dev/null +++ b/vision-fixhub/court-05/711ae1558b4d4312bef95d01d268c148186216a0099cd725fb813927feb80eb7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "711ae1558b4d4312bef95d01d268c148186216a0099cd725fb813927feb80eb7", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "d939309dcaba11c8e9c9bc785589170f38d162dc2e9a6dd6e1ca29e83d320098", + "output_sha256": "b44c524e554e6933b10d2945522a6b7376cd5028af97a24478feb327cc85e27f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7124dbcc2450ba1b0bbdf79fad5f1bd8871ef95420e34f4fc2825f685fa9ef13.md b/vision-fixhub/court-05/7124dbcc2450ba1b0bbdf79fad5f1bd8871ef95420e34f4fc2825f685fa9ef13.md new file mode 100644 index 0000000000000000000000000000000000000000..f55522355c98b89209d2df3eb949bbcd4f71f42f --- /dev/null +++ b/vision-fixhub/court-05/7124dbcc2450ba1b0bbdf79fad5f1bd8871ef95420e34f4fc2825f685fa9ef13.md @@ -0,0 +1,114 @@ +Case 1:22-cV-10904-JSR Document 267-57 Filed 08/07/23 Page 1 of 4 + + + +5/19/23, 6:17 PM +Case 1:22-cv-10904-JSR +Document 267-57 Filed 08/07/23 Page 2 of 4 +EPSTEIN'S TROPIC ISLE OF BABES | Page Six +Page Six +Comment: +CELEBRITY NEWS +EPSTEIN'S TROPIC ISLE OF +BABES +By PageSix.com Staff +October 29, 2007 | 9:00am +THE sordid sex scandals surrounding Jeffrey Epstein are making waves in the +Caribbean, where the billionaire owns a private 900-acre getaway and has deep +financial ties to the governor of the U.S. Virgin Islands. +Epstein - soon to cop a plea to soliciting sex from teen hookers at his Palm Beach +estate - is being sued by a drug-addicted, transgender model who claims he/she was +pressured into having sex with Epstein at the age of 16. +Sources say the former math teacher, who owns the lush, tropical island of Little St. +James, off the coast of St +regularly ferried boatloads of young women there. +Sources also say Epstein enjoys a warm relationship with USVI Gov. John P. de Jongh Jr. +"Epstein has donated as much as $1 million to the governor's election campaign," said +our source. In addition. Epstein, who runs the charitable J. Epstein Virgin Islands +Foundation, employs deJongh's wife, Cecile, as its director. He also pays for the +education of the governor's children at the exclusive Antilles School on St +"There is concern that the deJonghs will now be associated with a sexual predator," our +Insider said. +Epstein's spokesman, Howard Rubenstein, told Page Six that Cecile DeJongh has +worked for the foundation for nine years, making less than $125,000 annually. "There's +no one better to know the needs of charities on the island than this woman." he told us. +adding that all of Epstein's employees, not just the de Jonghs, are given free tuition for +their kids. +Rubenstein said de Jongh has never been to Epstein's island, although he wouldn't +comment on whether Epstein has imported platoons of young babes. +"Jeffrey is proud of what he gives to charity. He's really pleased to be able to able to +help people on the island with his foundation," Rubenstein said. +DeJongh's flack didn't return our call, but the governor has told the St. John Tradewinds +newspaper about his wife's position: "It's just a job; that's all. I think it's highly +appropriate she continue there." +READ NEXT MY LIFE AMONG STARS OF INDIA +POPULAR SHOPPING +We tested 31 leave-in +conditioners, and +these are the best.. +We tested the +Craftsman electric +riding lawnmower... +Taylor Swift's Gillette +ticket prices are +dropping big time.... +You won't believe +ticket prices for Dead +and Company's. +How much are lastminute tickets to see +Taylor Swift at.. + +20 +Page Six PODCAsT +https://pagesix.com/2007/10/29/epsteins-tropic-isle-of-babes/ +1/3 + + +5119/23, 6:17 PMase 1:22-CV-10904-JSR Document 267-57 Filed 08/07/23 + +EPSTEIN'S TROPIC ISLE OF BABES | Page Six +TRENDING NOW +Harry, Meghan got into car +chase because they're too +cheap for a hotel source +Alec Baldwin berates +shocked' female server at +gala +Bethenny Frankel roasts +Prince Harry and Meghan +Markle's 'drastic' car chase +Martha Stewart puts a spin +on Kate Middleton's gold +gown for Sports illustrated party +151,333 +89.054 +18,499 +14.826 +• NOW ON +Page Six Style +Alicia Keys shows off curves in a +colorful bikini while partying on yacht +Kate Bosworth channels 'Blue Crush +with playful Roxy collaboration +Khloe Kardashian wear +get +your f-king ass up and work meme +T-shirt +SEE ALL * +- NOW ON +DECIDER +Dirty Dozen" Star and NFL +Legend, Dead at 87 +https://pagesix.com/2007/10/29/epsteins-tropic-isle-of-babes/ +2/3 + + +5/19/23, 6:17 PM +Case 1:22-cV-10904-JSR Document 267-57 Filed 08/07/23 Page 4 of 4 +EPSTEIN'S TROPIC ISLE OF BABES | Page Six +MORE STORIES +Page Six +CONTACTUS +#HOW Us +https://pagesix.com/2007/10/29/epsteins-tropic-isle-of-babes/ +3/3 diff --git a/vision-fixhub/court-05/7124dbcc2450ba1b0bbdf79fad5f1bd8871ef95420e34f4fc2825f685fa9ef13.receipt.json b/vision-fixhub/court-05/7124dbcc2450ba1b0bbdf79fad5f1bd8871ef95420e34f4fc2825f685fa9ef13.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9324d7ca7e27b9e8be163b61ee96774c2195f8f0 --- /dev/null +++ b/vision-fixhub/court-05/7124dbcc2450ba1b0bbdf79fad5f1bd8871ef95420e34f4fc2825f685fa9ef13.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -79, + "dataset": "marble-joined", + "doc_id": "7124dbcc2450ba1b0bbdf79fad5f1bd8871ef95420e34f4fc2825f685fa9ef13", + "engine": "marble-apple-vision", + "event_count": 8, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "7979d7738f3ee67a2805ea2968798f0ce6eefd69fe7ef732da657c54d2cf5d9d", + "output_sha256": "df9137c8c9574402bd2d08ca120350bd278981d2215cfa8c69baf1362203c7e6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/719791a0df67cdc66e8de64867d1ddddfbed03335fe495e9ef5e9e15f82c560c.md b/vision-fixhub/court-05/719791a0df67cdc66e8de64867d1ddddfbed03335fe495e9ef5e9e15f82c560c.md new file mode 100644 index 0000000000000000000000000000000000000000..f993820f3b2d785078ad8cd612a966c43ca51df3 --- /dev/null +++ b/vision-fixhub/court-05/719791a0df67cdc66e8de64867d1ddddfbed03335fe495e9ef5e9e15f82c560c.md @@ -0,0 +1,338 @@ +Case 1:22-cV-10904-JSR Document 267-10 Filed 08/07/23 Page 1 of 6 + + + +Case 1:22-CV-10904-JSR Document 267-10 Filed 08/07/23 Page 2 of 6 +United States Virgin Islands +ECONOMIC DEVELOPMENT COMMISION ANNUAL REPORT +Fiscal/Calendar Year Ending +December 31, 2010 +Investora +Financial Trust Company, Inc. +Gruss sues (eligible Sales) & Eligible for Tax Benefits ... +Other Income (Ineligible) & Eligible for Tax Benefits +Gross Wages Paid in the V.l. (Include vacation & sick pay, bonuses, overtime, elc.) +49 +Average No. of Employees; Full Time & (Part Time/Other)... +Average No. of Residents; Full Time & (Part Time/Other)... +10 +10 +Average No. of Non-Residents; Full Time & (Part Time/Other).. +Other Emplayee Costs (Unemployment & health insurance, pension, allowance, elc.) $ +Employee Income Taxes Paid and Withheld +LA +TAXES AND DUTIES (Provide dollar amount paid, and value of exemption/refund for each tax) +Gross Receipts: +Amount Paid +Dollar Value of Exemption +Real Property Tax: +Amount Paid +Dollar Value of Exemption +Excise Taxes: +Total Paid +RECEIVED +Time: +Dollar Value of Exemption/Refund +Income Taxes: +Total Paid +OCT 14 2011 +Dollar Value of Exemption/Refund +Customs Duties: +Total Paid +Dollar Value of Exemption/Refund +toes +Other: +Hotel room taxes paid +Economic Devefopment omission/STT +Other Taxes, Fee Paid to V.I. Government +TOTAL TAXES PAID: +TOTAL VALUE OF EXEMPTIONS AND OR REFUNDS: +EXPENDITURES FOR GOODS, SERVICES, PLANT & EQUIPMENT +Eligible Supplier +V.I. Suppliers +Non-Local +Goods and Services: +Raw materials, components +Food, beverage +Freight Charges +insurance +Legal/ Accounting +Advertising / Promotion +Utilities (tel., water, elect. etc.) +Interest & Other Bank Chg +Supplies +Repairs/Maintenance +Other (List Separately) +Subtotal, Goods and Sves: +Capital Expenditures: +Building & Improvements +Leasehold Improvements +Machinery / Equipment +Furniture / Fixtures +Vehicles +Other (List Separately) +Subtotal, Capital Expend: +16202 +2943 + +23736 +1435 +44355 +4641 +5431 +35500 +61774 +20590 +3235 + + +1017 +11378 $ +700882 $ +18305 +17498 +15042 $ +18305 +1749฿ +GRAND TOTALS +80079 + +5 +15042$ +715924 $ +CUMULATIVE CAPITAL EXPENDITURES UNDER EDC CERTIFICATE +Name/Signature of Preparer: +Ladate +Signature +Jeanne +(Pant Namei +Date: +Telephone Number: +10/u/" +340-775-2525 + +-24347719 + + + +400 +3,600 +1297 +1297 +3600 +19145. + +1435 +44355 +26248 +8666 + + +50844 +50844 + + +VI-JPM-000006066 + + +Case 1:22-cV-10904-JSR Document 267-10 Filed 08/07/23 Page 3 of 6 +Company Name: +Goods and Services: +Dues and subscribtions +Seminars and education +Postage and delivery +Travel and related +Meals and transportaion +EDC Fees - Compliance, WDF, Renewal +BoE Territorial Scholarship Fund +Rent +Other expenses +Subtotal, Goods and Svcs: +Fiscal/Calendar Year Ending +December 31, 2010 +Financial Trust Company. inc +EXPENDITURES FOR GOODS, SERVICES, PLANT & EQUIPMENT -Other +Eligible Supplier +V.l. Suppliers +Non-Local +1070 +2305 +5149 +6339 +569 +10630 $ +32500 +3000 +69 +35500 + +586 + +78 +11378 $ +1639 +10630 +2305 +5250 +6339 +32500 +3000 + +664 + +Charitable contributions +EXPENDITURES FOR CHARITABLE CONTRIBUTIONS +V.I. Educational +3370 +V.l. Charity += 70764 +Acadenie Scholarship Program +20000 $ +20000 $ + + +VI-JPM-000006067 + +TOTALIS +Note: Totals of EDC Credit and Balance Tax Due must be carried forward to the EDC Annual Report and reported under Taxes and Duties (See instructions). +VI-JPM-000006068 +UNITED STATES VIRGIN ISLANDS +Case 1:22-cV-10904-JSR Document 267-10 Filed 08/07/23 Page 4 of 6 +EDC ANNUAL REPORT +Value of Exemptions of Stockholders/Partners/Members +BENEFICIARY Financial Trust Company, Ing. +Fiscal Year Ending December 31, 2010 +Tvestors Dream +Stockholders, +Partners or Members +Jeffrey E. Epstein +Soolal Security +No. +Physical +Address +Lite Saint James +St. Thomas U.S. Virgin +islands +% +Distributable +Shares +100 +Business +Aotivity +Balance Tax +- Due +EDC Income +Total Tax Due EDC Credit +See page 1 of Economic Development Commission Annual Report + + +CONFIDENTIAL SUBJECT TO PROTECTIVE Ol +VI-JPM-000006069 +Financial Trust Company +Summary of Jobs by Specific Classification +Management +Office Manager +Controller +President +Supervisory +Assistant Controller +Technical +Network Administrator +Senior Researcher +Case 1:22-cv-10904-JSR Document 267-10 Filed 08/07/23 Page 5 of 6 + + +Case 1:22-cV-10904-JSR Document 267-10 Filed 08/07/23 Page 6 of 6 +ECONOMIC DEVELOPMENT COMMISION ANNUAL REPORT +Fiscal/Calendar Year Ending +Financial Trust Company, Inc. +12/31/2010 +Date +Charitablo Organization +"' 01/22/2010 SI +Baseball Explorers +01/01/2010 Voided check All Saints School +03/16/2010 Virgin Islands Montessori School +03/16/2010 Aniles School, Ine. +03/16/2010 Sts. Peter & Paul Cathole School +03/16/2010 Sts. Peter & Paul Calhoic School +03/23/2010 Sprauve School Fundraiser +- 04/13/2010 The V. I Police Department +04/13/2010 Sts. Peler & Paul Cathole School +04/13/2010 Community Foundation of the V. I. +-05/14/2010 Wesley Methodist Church +05/25/2010 V.J. Tennis Association +05/25/2010 Awanda Project USVI, Inc +- 06/08/2010 Communty Foundation of the V.I. +06/15/2010 USVI Dept. ol Education +* - 06/15/2010 Friends of the +Pubic Libraries +- 06/17/2010 51 +Majoritas. Inc +06/22/2010 Friends of the SLThomas Pubic Libraries +06/22/2010 Beacon Schools of the Vi, Inc. +06/22/2010 Virgin Islands Ołympic Committee +07/13/2010 Prophecy Academy, Inc +- 07/26/2010 Elrod Hendricks Charter +08/D3/2010 V. I. Volleyball Federation +08/11/2010 St +Swimming Associations, Inc +0B/13/2010 V.I. Humanities Council +08/13/2010 Caribbaen Islands Education Foundation +08/13/2010 51. +•St John Chamber of Commerce +08/13/2010 Saint Croix Foundation +08/13/2010 V. I. Council for the Boy Scouts +08/13/2010 Lutheran Social Services of the V.I +08/13/2010 V.I. Dept. of Education +08/13/2010 Community Foundation of the V. I. +08/13/2010 Humane Society of St +08/13/2010 Habilat for Humanity of the U.S.V.I. +0SH01/2010 The Kingshit School +09/01/2010 Humane Society of St +08/14/2010 Anilles School, inc +09/14/2010 J.UJ,I.C.E. Flag Football Camp, Inc. +10/18/2010 Future Stars Baseball Organization +10/18/2010 Dept of Human Services - CFS +10/26/2010 Zero Tolerance Basketbal Org. Inc +10/26/2010 Schneider Regional Medical Center +11/15/2010 Rising Stars Youth Steel Orchestra +12/21/2010 The Good Hope School +12/21/2010 Uniled Way of St +-St. JAchn +12/21/2010 Lutheran Social Services of the V.t. +12/21/2010 We Grow Food, Inc. +Total chantable expendilures +Academic Scholarship Program +06/03/201D Old Dominion University « JEKHS scholarship +06/03/2010 North Carolina A & T University - CAHS Scholarship +Amount +10001 +-500 • +2900 +500D : +200 +800 • +500 +3500 2 +250 / +1500 L +100 % +5000% +... +3864= +1500% +300 # +2500: +3500 I +2850 +1000 + + +10000 +_ 10000 +20000 + +20: +2=: +VI-JPM-000006070 \ No newline at end of file diff --git a/vision-fixhub/court-05/719791a0df67cdc66e8de64867d1ddddfbed03335fe495e9ef5e9e15f82c560c.receipt.json b/vision-fixhub/court-05/719791a0df67cdc66e8de64867d1ddddfbed03335fe495e9ef5e9e15f82c560c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b1938c1b069c2fb599342d99397aaac1e5046906 --- /dev/null +++ b/vision-fixhub/court-05/719791a0df67cdc66e8de64867d1ddddfbed03335fe495e9ef5e9e15f82c560c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -412, + "dataset": "marble-joined", + "doc_id": "719791a0df67cdc66e8de64867d1ddddfbed03335fe495e9ef5e9e15f82c560c", + "engine": "marble-apple-vision", + "event_count": 29, + "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "7519030f3d6ff2e4b2ebd83b0399f3ec6003fa4e8398525a84eec6ffb8e45ad4", + "output_sha256": "037e4100ef8a7a11a82a30ecdf6d2b0547fb1f3e7b60ea417f05eb29155b50d9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/719aa36488f35f1e08140882817f9394f7cea647afc0082e211d5f22c57d7ea2.md b/vision-fixhub/court-05/719aa36488f35f1e08140882817f9394f7cea647afc0082e211d5f22c57d7ea2.md new file mode 100644 index 0000000000000000000000000000000000000000..e419375bcda51ed4a957e5dd213fff8ca7e26029 --- /dev/null +++ b/vision-fixhub/court-05/719aa36488f35f1e08140882817f9394f7cea647afc0082e211d5f22c57d7ea2.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 168-2 Filed 05/30/23 Page 1 of 1 + +(FILED UNDER SEAL) diff --git a/vision-fixhub/court-05/719aa36488f35f1e08140882817f9394f7cea647afc0082e211d5f22c57d7ea2.receipt.json b/vision-fixhub/court-05/719aa36488f35f1e08140882817f9394f7cea647afc0082e211d5f22c57d7ea2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1a6d589e5809413543985912bbe6bf535fd1a059 --- /dev/null +++ b/vision-fixhub/court-05/719aa36488f35f1e08140882817f9394f7cea647afc0082e211d5f22c57d7ea2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "719aa36488f35f1e08140882817f9394f7cea647afc0082e211d5f22c57d7ea2", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "1a387a191858c6aabc1cfddebc39c2dfc47a712cbfcea28f52979de3dc047d8c", + "output_sha256": "4c8bd51984201f9710a8ebf0cd7da7afa6a56bc0a1be2e9c4ff410cafaa6d75f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/71be25b23e766ba4ebaa874df9ce184e684b143f6d8b685958608b5b80926696.md b/vision-fixhub/court-05/71be25b23e766ba4ebaa874df9ce184e684b143f6d8b685958608b5b80926696.md new file mode 100644 index 0000000000000000000000000000000000000000..c1b42408288ec586f899463765eda1eb42d5fd55 --- /dev/null +++ b/vision-fixhub/court-05/71be25b23e766ba4ebaa874df9ce184e684b143f6d8b685958608b5b80926696.md @@ -0,0 +1,44 @@ +Case 1:22-cv-10904-JSR Document 326-139 Filed 09/08/23 Page 1 of 2 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-139 Filed 09/08/23 Page 2 of 2 +Prainito, Domenica +1/24/2011 9:03:13 PM +RE: Jeffrey Epstein-Ken Starr +Sorry for the delay - Steve is available from 10:30-11:30 and 5-6 on Tues. +From: Cutler, Stephen M +Sent: Sunday, January 23, 2011 11:06 AM +To: Langford, William D +Cc: Prainito, Domenica +Subject: RE: Jeffrey Epstein-Ken Starr +I'll ask Domenica to set it up for Tuesday, as I have an all-day OC mtg tomorrow. +From: Langford, William D +Sent: Sunday, January 23, 2011 11:05 AM +To: Cutler, Stephen M +Subject: RE: Jeffrey Epstein-Ken Starr +Friday got away from me. +Want me to ask Dominica to reserve a half hour Monday or Tuesday? +- W +From: Cutler, Stephen M +Sent: Thursday, January 20, 2011 7:03 PM +To: Langford, William D +Subject: Fw: Jeffrey Epstein-Ken Starr +You and I can call him tomorrow. +From: da Silva, Rosa M +To: Cutler, Stephen M +Sent: Thu Jan 20 19:00:04 2011 +Subject: FW: Jeffrey Epstein-Ken Starr +Steve, As promised, below please find a Tel # for Ken Starr. Thanks, Rosa +From: Lesley Groff [mailto:Igroff@dkipllc.com] +Sent: Thursday, January 20, 2011 6:56 PM +To: da Silva, Rosa M +Subject: Jeffrey Epstein-Ken Starr +Hi Rosa. Jeffrey requested I send you Ken Starr's office phone number at Baylor University: + +JPM-SDNYLIT-00274429 diff --git a/vision-fixhub/court-05/71be25b23e766ba4ebaa874df9ce184e684b143f6d8b685958608b5b80926696.receipt.json b/vision-fixhub/court-05/71be25b23e766ba4ebaa874df9ce184e684b143f6d8b685958608b5b80926696.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9a5ce86a79cffb8ffcfd1729e13ce0f3cd84e1f3 --- /dev/null +++ b/vision-fixhub/court-05/71be25b23e766ba4ebaa874df9ce184e684b143f6d8b685958608b5b80926696.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "71be25b23e766ba4ebaa874df9ce184e684b143f6d8b685958608b5b80926696", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "acbfc6cc2f60518512a111bf8197d10bc0fe20c6d4f299aacb7a327c640bb784", + "output_sha256": "195cb9a092d3e7333806cf3473f410cb18292b4f1a0acecdbadc9b3a4bdb6d29", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/71ee1478092cf87a83c7c092dc4c8fbd576ce4219e957b50d3573ed0b140c7a2.md b/vision-fixhub/court-05/71ee1478092cf87a83c7c092dc4c8fbd576ce4219e957b50d3573ed0b140c7a2.md new file mode 100644 index 0000000000000000000000000000000000000000..4af0bd589288d43a8041a71deab70a8d47f40af2 --- /dev/null +++ b/vision-fixhub/court-05/71ee1478092cf87a83c7c092dc4c8fbd576ce4219e957b50d3573ed0b140c7a2.md @@ -0,0 +1,95 @@ +Case 1:22-cV-10904-JSR Document 268-67 Filed 08/07/23 Page 1 of 4 + + + +Case 1:22-cV-10904-JSR Document 268-67 Filed 08/07/23 Page 2 of 4 +Message +From: +Sent: +To: +Subject: +I/O=USVIEDAEXCH/OU=EXCHANGE ADMINISTRATIVE GROUP +(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MAGARITA A. +10/2/2019 2:22:17 PM +Joy Penn [jpenn@usvieda.org]; Sandra Bess [sbess@usvieda.org] +FW: URGENT - NY Times INQUIRY: Follow-up questions for comment - NYT +Good Day Ladies, +Please see the recent request from NY Times. Your feedback on the response is appreciated. I personally think the +questions are opening us up to public scrutiny. +Margarita +Managing Director, Economic Development +Email: mabenjamin@usvieda.org +Phone: 340-714-1700 Ext 1611 +Fax: 340-774-8106 +www.usvieda.org +Economic Development Authority +8000 Nisky Shopping Center, Suite 620 +ST. +U.S. Virgin Islands 00802 +From: Kamal I. +Sent: Wednesday, October 2, 2019 1:45 PM +To: Shanell Petersen < spetersen@usvieda.org>; Tracy Bhola, Esq. ; Wayne Biggs, Jr. +; Margarita + +Cc: Henry C. Smock ; Kevin Rodriquez ; Semele A.C. L + +Subject: Re: URGENT - NY Times INQUIRY: Follow-up questions for comment - NYT +Good afternoon Colleagues, +Please have a response prepared for review as per our media response protocol. +Thank you. +Kind regards, +Kamal +Kamall. +Chief Executive Officer +Email: klatham@usvieda.org +Phone: 340-714-1700 Ext 1111 +Fax: 340-774-0990 +www.usvieda.org +VI-JPM-000017233 + + +Case 1:22-cV-10904-JSR Document 268-67 Filed 08/07/23 Page 3 of 4 +Economic Development Autharity +8000 Nisky Shopping Center, Suite 620 +St. +. U.S. Virgin Islands 00802 +On Oct 2, 2019, at 12:39 PM, Shanell Petersen wrote: +Good afternoon, +Please see the additional inquiry from New York Times in need of immediate review below. +Respectfully, +Shanell +Shanell Petersen +Managing Director, Marketing & 2040 Vision +Email: spetersen@usvieda.org +Phone: 340-714-1700 Ext 1511 +Fax: 340-777-1103 +www.usvieda.org +Economic Develogment Authority +8000 Nisky Shopping Center, Suite 620 +St. +U.S. Virgin Islands 00802 +From: Eder, Steve [mailto:steve.eder@nytimes.com] +Sent: Wednesday, October 02, 2019 11:44 AM +To: Shanell Petersen; Matthew +Subject: Follow-up questions for comment - NYT +Good morning, Shanell - We are planning an article relating to Mr. Epstein's finances and +businesses in USVI. The piece will raise the point that USVI has been criticized for not closely +overseeing beneficiaries of the tax incentive programs. I've included a couple questions below +for VIEDA: +- Was VIEDA comfortable with the answers it received from Mr. Epstein about his business +practices & activities over the years? Should VIEDA have pressed Mr. Epstein about his +business affairs? +- Was VIEDA satisfied with the return USVI's return on Mr. Epstein's businesses? +VI-JPM-000017234 + + +Case 1:22-cV-10904-JSR Document 268-67 Filed 08/07/23 Page 4 of 4 +Please send any responses today, 10/2, by 5 p.m. ET. +Thank you. +Steve and Matt +This electronle message is intended to be viewed only by the Individual or entity to whom it is addressed. It may contain Information that is +privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this communication is +strictly prohibited without our prior permission. If the reader of this message is not the intended recipient, or the employee or agent +responsible for delivering the message to the intended recipient, or If you have recelved this communication in error, please notify us +immediately by return e-mail and delete the original message and any coples of it from your computer system. +VI-JPM-000017235 \ No newline at end of file diff --git a/vision-fixhub/court-05/71ee1478092cf87a83c7c092dc4c8fbd576ce4219e957b50d3573ed0b140c7a2.receipt.json b/vision-fixhub/court-05/71ee1478092cf87a83c7c092dc4c8fbd576ce4219e957b50d3573ed0b140c7a2.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4c9d65cdf8613eafde3b3efaff6d04f6c1228c51 --- /dev/null +++ b/vision-fixhub/court-05/71ee1478092cf87a83c7c092dc4c8fbd576ce4219e957b50d3573ed0b140c7a2.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -183, + "dataset": "marble-joined", + "doc_id": "71ee1478092cf87a83c7c092dc4c8fbd576ce4219e957b50d3573ed0b140c7a2", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "135b3568d94416f55acf6c461cdda6940d6813c7d15bf2e4be8951e7b0b99faf", + "output_sha256": "9d0bad54829394f0e00a4245cffe7a15a1f8c966f91a4484ffa57011191a9ec6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/720d2cc63f9b554f00f6eb115403058ef823bfe4102dc77635d31dc5b289e752.md b/vision-fixhub/court-05/720d2cc63f9b554f00f6eb115403058ef823bfe4102dc77635d31dc5b289e752.md new file mode 100644 index 0000000000000000000000000000000000000000..8f1792a2250c76c8ca1a801ec0e05dce0692bd23 --- /dev/null +++ b/vision-fixhub/court-05/720d2cc63f9b554f00f6eb115403058ef823bfe4102dc77635d31dc5b289e752.md @@ -0,0 +1,3 @@ +Case 1:22-cV-10904-JSR Document 158-58 Filed 05/23/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/720d2cc63f9b554f00f6eb115403058ef823bfe4102dc77635d31dc5b289e752.receipt.json b/vision-fixhub/court-05/720d2cc63f9b554f00f6eb115403058ef823bfe4102dc77635d31dc5b289e752.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0e8a84fe103fd4906e1c97d688d6010afc6cfbeb --- /dev/null +++ b/vision-fixhub/court-05/720d2cc63f9b554f00f6eb115403058ef823bfe4102dc77635d31dc5b289e752.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "720d2cc63f9b554f00f6eb115403058ef823bfe4102dc77635d31dc5b289e752", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "5b96eedb43a05b5485917d6e80efec61801c99385db96bad1d126939a18313d5", + "output_sha256": "9af856fb0fae8f7a38556fcd2cd88bcbd9adcb26c3513d1331090fb01f2861d7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/72366587451454d733ecde9be166dd4db39b7cda882e0d6bcaf5438bd2e8332d.md b/vision-fixhub/court-05/72366587451454d733ecde9be166dd4db39b7cda882e0d6bcaf5438bd2e8332d.md new file mode 100644 index 0000000000000000000000000000000000000000..c1472336086892b0d16070f598127e22184720bd --- /dev/null +++ b/vision-fixhub/court-05/72366587451454d733ecde9be166dd4db39b7cda882e0d6bcaf5438bd2e8332d.md @@ -0,0 +1,107 @@ +Case 1:22-cv-10904-JSR Document 249-3 Filed 07/31/23 Page 1 of 4 + + + +Case 1:22-cv-10904-JSR Document 249-3 Filed 07/31/23 Page 2 of 4 +Marvin, Cynthia +From: +Sent: +To: +Cc: +Subject: +Tuttle +Jake +Tuesday, July 18, 2023 10:20 AM +Boggs, Paige; WHJPMCService +Ackerman, David; Arnold, Andrew P.; Austin, Brendan; Boggs, Paige; Botto, Jessica; +Camputaro, Elizabeth A.; Forster, Jenna; Fu, Abigail; Karafian, Nicole; Klink, Rachel; Liu, +Mimi Y; Loper, Charlotte; Marvin, Cynthia; Narwold, Bill; L +•. Meghan; Quirk, Michael; +Rublee, Laura; +• Linda; Wohlgemuth, Stephen; Schiffmann, Eden +RE: Friday's Production +CAUTION:EXTERNAL +Paige, +We have now had multiple meet-and-confers and email conversations, and, in the interest in trying to avoid a discovery +dispute, JPMC has produced voluminous data that we maintain it had no obligation to produce. +The assertions in your email are incorrect and/or misleading, but it's not constructive for us to continue fighting about +them. The salient point is that, from our perspective, the USVI has been moving goal posts on this issue with continual +requests for more and attempts to reopen closed issues. +If you have a narrow data request that fully resolves all open issues, we are willing to consider it with our client. But we +are not interested in re-opening discovery, entering into stipulations, or continuing to litigate discovery. +Let me know if you have interest in that, but we have otherwise reached impasse. +Jake +Jake Tuttle +he/him/his +617.526.6426 +| WilmerHale +From: Boggs, Paige +Sent: Monday, July 17, 2023 1:58 PM +To: WHJPMCService +Cc: dackerman@motleyrice.com; Arnold, Andrew P. ; Austin, Brendan +; pboggs@motleyrice.com; Botto, Jessica ; Camputaro, Elizabeth A. +; Forster, Jenna ; Fu, Abigail ; +Karafian, Nicole ; Klink, Rachel ; Liu, Mimi Y +; Loper, Charlotte ; Marvin, Cynthia ; +bnarwold@motleyrice.com; Meghan ; Quirk, Michael ; +Rublee, Laura ; Isinger@motleyrice.com; Wohlgemuth, Stephen ; +Schiffmann, Eden +Subject: Friday's Production +EXTERNAL SENDER + + +Case 1:22-cv-10904-JSR Document 249-3 Filed 07/31/23 Page 3 of 4 +Counsel, +We have had a chance to review the data produced Friday evening. Troublingly, the data reveals that JPMorgan +processed substantial payments to girls or women from Epstein even after Epstein was terminated by JPMorgan, +including numerous individuals for whom JPMorgan had not previously identified payments. As we have +previously noted, this information was responsive to numerous discovery requests, including Requests 13, 19, +20, 24, and 38-39, and should have been produced during the discovery period. +You have asserted that this information was not identified earlier because it was not in a custodial production +and/or did not relate to individuals identified by the USVI as Epstein-related accounts. As we have made clear, +JPMorgan had an obligation to search non-custodial sources and to search for documents related to individuals +it believed to be related to Epstein, whether or not the USVI identified that person. Moreover, your recentlydisclosed documents show that JPMorgan internally made the connection between Epstein and these +individuals years before the Government issued its discovery requests. +As this production made clear, JPMorgan has identified numerous girls or women to whom Epstein made +payments but did not produce their account statements or related information. To confirm that no other +responsive information has been missed, in light of this late disclosure, we would like JPMorgan to identify the +non-custodial sources it identified and searched and the individuals and entities, beyond those identified by the +USVI, that JPMorgan searched as Epstein-related. +Specifically, we want confirmation that financial records for the following individuals have either been +produced or shortly will be produced: +(Note that we do not limit our prior request to these individuals, but want to make sure that they are addressed +in your response.) +Please also confirm that all documents and data related to Project JEEP or any other investigation that occurred +after Epstein's 2019 arrest have now been identified and disclosed. To the extent that you are withholding any +information as privileged or otherwise, please explain what you have not produced and why. +In addition, we assume that JPMorgan has no objection to the USVI supplementing its expert reports to reflect +this information. Please let us know if that is not the case. +You previously indicated that you would not provide a deponent related to this data source. Please confirm that +this remains your position. If the USVI agrees not to seek an additional deponent, will you agree that you will +stipulate that the data you produced is admissible as a business record? +2 + + +Case 1:22-cv-10904-JSR Document 249-3 Filed 07/31/23 Page 4 of 4 +You also represented that you would further investigate whether any of the data related to the individuals +searched was not included in the data you sent. Have you reached resolution on that question? Relatedly, have +you concluded your investigation regarding additional payments to the girls or women identified above? To the +extent you identify additional individuals or additional payments from Epstein to previously disclosed +individuals, the USVI requests the relevant financial records. +Please provide your answers by 6 pm today, given tomorrow's briefing deadline. We are available this +afternoon to meet and confer. +Best, +Paige +MotleyRice.. +ATTORNEYS AT LAW +Paige Boggs Attomey at Law +401 9th St. NW, Suite 630, Washington, DC 20004 +о. 202.386.9629 c. 202.538.0540 f. 202.386.9622 +pboggs@motleyrice.com + +Jnless otherwise indicated or obvious from its nature, the information contained in this communication is attomey-client privileged and confidential +information/work product. This communication is intended for the use of the individual or entity named above. If the reader of this communication is not the +intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this +communication in error or are not sure whether it is privileged, please immediately notify us by return e-mail and destroy any copies--electronic, paper or +otherwise-which you may have of this communication. +3 diff --git a/vision-fixhub/court-05/72366587451454d733ecde9be166dd4db39b7cda882e0d6bcaf5438bd2e8332d.receipt.json b/vision-fixhub/court-05/72366587451454d733ecde9be166dd4db39b7cda882e0d6bcaf5438bd2e8332d.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f01ff57fe16eb6d65eb4882d1472c9f5111d0717 --- /dev/null +++ b/vision-fixhub/court-05/72366587451454d733ecde9be166dd4db39b7cda882e0d6bcaf5438bd2e8332d.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -84, + "dataset": "marble-joined", + "doc_id": "72366587451454d733ecde9be166dd4db39b7cda882e0d6bcaf5438bd2e8332d", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.privileged-attorney-work-product\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "d54083f7b3c777449d72c9a4383e91c82ffbd97ecbe34b8c6f484a13c1c21167", + "output_sha256": "5cd3cf7d5638c7d9cc3a10eb96d21c82bec1a955eaacd950f017e6224c982e7b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/723a663b753f9691d1173ebdf82034bb2cad843fb1e8c5756f6609d029936d54.md b/vision-fixhub/court-05/723a663b753f9691d1173ebdf82034bb2cad843fb1e8c5756f6609d029936d54.md new file mode 100644 index 0000000000000000000000000000000000000000..a6d078fdbd9f469fadb213e6884245dc15a2d667 --- /dev/null +++ b/vision-fixhub/court-05/723a663b753f9691d1173ebdf82034bb2cad843fb1e8c5756f6609d029936d54.md @@ -0,0 +1,44 @@ +Case 1:22-cV-10904-JSR Document 268-27 Filed 08/07/23 Page 1 of 2 + + + +Case 1:22-cv-10904-JSR Document 268-27 Filed 08/07/23 Page 2 of 2 +Date: +Thursday, November 152012 08:07 PM +Subject: Re: Phone call - November 15, 2012 +From: +Daphne Wallace +@gmail.com> +To: +Jeffrey Epstein ; +CC: +Cecile de Jongh c +@yahoo.com.>; +Greetings Mr. Epstein, +Cecile says she thinks it is ok since you are giving a turkey to everyone. +Respectfully, +Daphne +On Thu, Nov 15, 2012 at 3:01 PM, Jeffrey Epstein < jeevacation@ gmail.com > wrote: +Ask Cecil if she thinks it ok if I give all 78 customs agents a turkey +On Thursday, November 15, 2012, Daphne Wallace wrote: +Greetings Mr. Epstein, +Ms. LeeAnn Greaux of the St. +Customs and Border Protection office just called. She says vou called +and requested to know the number of employees in their office - there are 78 employees in the St. +Respectfully, +Daphne +********************************************************** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved + +ESTATE_JPM016458 diff --git a/vision-fixhub/court-05/723a663b753f9691d1173ebdf82034bb2cad843fb1e8c5756f6609d029936d54.receipt.json b/vision-fixhub/court-05/723a663b753f9691d1173ebdf82034bb2cad843fb1e8c5756f6609d029936d54.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e030a507a94c2d25a8a05e0fb1e3fac93916fe60 --- /dev/null +++ b/vision-fixhub/court-05/723a663b753f9691d1173ebdf82034bb2cad843fb1e8c5756f6609d029936d54.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -47, + "dataset": "marble-joined", + "doc_id": "723a663b753f9691d1173ebdf82034bb2cad843fb1e8c5756f6609d029936d54", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "bd7adf368a641eab543179b1b66578ed24fa9510fedffe2e485c794aa505a5bb", + "output_sha256": "f09bbd513aa9d2c061630844bb48517ce9e18d9d636f6e309f8e3d0cdf5bb204", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/72441788cf9c5adbb757322f8f849e83ee3d95314e152384654d220ce74763da.md b/vision-fixhub/court-05/72441788cf9c5adbb757322f8f849e83ee3d95314e152384654d220ce74763da.md new file mode 100644 index 0000000000000000000000000000000000000000..e16fb92e8b3cde87d9fb1b037a1617b52adf82d8 --- /dev/null +++ b/vision-fixhub/court-05/72441788cf9c5adbb757322f8f849e83ee3d95314e152384654d220ce74763da.md @@ -0,0 +1,35 @@ +Case 1:22-cV-10904-JSR Document 285-95 Filed 08/15/23 Page 1 of 2 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 285-95 Filed 08/15/23 Page 2 of 2 +Jeffrey Epstein +Jes Staley +:Erdoes, Mary E" +8/26/2011 10:13:53 AM +I am more than happy to meet with anyone you think moves this along . cutler. jamie. . etc. As mary said it +need to be PROPER. . please consider , there are four major areas of huge opportunity for some mutually +satisfactory arrangement. Gates and his entourage (facebook, spotify (| +1). Middle East. Africa, China. +THe common thread is they all want private advice.. The opportunities like the DAf idea , originates with me, i +it slowly, adding various ingredients almost fully +it. and then want to turn it over to you. As I said to +mary , if Tom Pritsker established an investment bank and I did most things with tom, could that be a beginning of' +a solution. ? +•HƯâ Bưà Bưốc đưốc đõốc HỘc •Hố Ộc ủ H H •ố. đ ố đừc đHỘc ốc đ ốơ Hơ đHơ đựơ đốơ đỘơ đ₩ố đũc đừơ đốơ đựố đ₩ố đựố đ₩. đ₩ đ₩ đ₩ đ₩đ....*₩ đ............*....****** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved diff --git a/vision-fixhub/court-05/72441788cf9c5adbb757322f8f849e83ee3d95314e152384654d220ce74763da.receipt.json b/vision-fixhub/court-05/72441788cf9c5adbb757322f8f849e83ee3d95314e152384654d220ce74763da.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7299135e781520822228a4e14de4062492db4239 --- /dev/null +++ b/vision-fixhub/court-05/72441788cf9c5adbb757322f8f849e83ee3d95314e152384654d220ce74763da.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -35, + "dataset": "marble-joined", + "doc_id": "72441788cf9c5adbb757322f8f849e83ee3d95314e152384654d220ce74763da", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "dbae7ef1754b7a0a47af6ecb900d1f5a1ac7758c5e9e3ad0a631bc5de3494758", + "output_sha256": "be31771342b97041b0db67347fe77b068ed46e2b2c3c72918ca1936041344bd3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/72532dd30343166688bedf2e57256c583ee6a73b46c058283a14e4634e01f3b6.md b/vision-fixhub/court-05/72532dd30343166688bedf2e57256c583ee6a73b46c058283a14e4634e01f3b6.md new file mode 100644 index 0000000000000000000000000000000000000000..0aac2748db8855b1637793d0c68d80fe07e05835 --- /dev/null +++ b/vision-fixhub/court-05/72532dd30343166688bedf2e57256c583ee6a73b46c058283a14e4634e01f3b6.md @@ -0,0 +1,845 @@ +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 Filed 02/10/20 + +klu2NoeC kjc +1 +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +- X +UNITED STATES OF AMERICA, +V. +TOVA NOEL and MICHAEL +New York, N.Y. +19 Cr. 830(AT) +Defendant. +-x +Conference +January 30, 2020 +11:00 a.m. +Before: +HON. ANALISA +District Judge +APPEARANCES +GEOFFREY S. BERMAN +United States Attorney for the +Southern District of New York +BY: JESSICA R. LONERGAN +NICOLAS I. LANDSMAN-ROOS +REBEKAH A. DONALESKI +Assistant United States Attorneys +FOY & SEPLOWITZ, LIC +Attorney for Defendant Noel +BY: JASON E. FOY +ERIC SAGARRA +LAW OFFICES OF MONTELL FIGGINS +Attorney for Defendant +BY: MONTELL FIGGINS + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 +Filed 02/10/20 Page 2 of 15 +klu2NoeC kjc +2 +(Case called) +THE COURT: Good morning. We are here in the matter +of the United States v. Tova Noel and Michael +Would you make your appearance, please. +MS. LONERGAN: For the government, Jessica Lonergan. +With me at counsel table are my colleagues Nicholas Roos and +Rebekah Donaleski. Good morning, your Honor. +MR. FOY: May it please the court, your Honor, Jason +Foy, for Ms. Tova Noel, standing to my right. Also with me at +counsel table is associate counsel Eric Sagara. Good morning, +your Honor. +MR. SAGARA: Good morning, your Honor. +MR. FIGGINS: Good morning your Honor. Montell +Figgins on behalf of Michael +who stands to my right. +I, representing my client, +THE COURT: I understand that the defense is +requesting that I adjourn the trial because of the volume of +discovery. I will hear you on that. +MR. FOY: Yes, your Honor. We are asking that the +trial date of April 20, 2020, be moved to sometime in October +or a date thereafter that's convenient to the court. The +reason for the request is because +• it is necessary in order to +provide an adequate and effective assistance of counsel. Why? +Yes, because of the voluminous discovery. But also because of +the amount of time it is going to take for us to conduct our + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 +Filed 02/10/20 Page 3 of 15 +kluzNoeC kjc +3 +own investigation, which can't really fully get started until +we appreciate what information has already been provided. +That's really the crux of the reason. +Now, I noted in the government's opposition, although +they agree that some adjournment is warranted, I guess the +issue is of how long the adjournment should be. The defense is +in the best position to assess how much time we need to perform +our important function on behalf of our clients. I say that +because we are not making a request for the purpose of simply +delaying the proceedings. +We are doing it because it is +actually necessary to accomplish our goals as counsel. +Also, which I did not reference in my letter, is it +also takes into account my trial schedule, at least why my +request was. Last week, I was scheduled to start a trial +before Judge Ramos in 40 Foley Square in July. And part of +what I discussed with Judge Ramos in setting that trial date +was that I knew that this trial may need to be accommodated in +some way. He selected July 20 for that date mostly because of +the court's availability at that time. That's also part of the +reason. And in that particular case, my client's been +incarcerated for almost two years. He is facing a mandatory +life sentence. So I do need to spend some of my time getting +ready for that as well, and I expect that to be our trial date. +THE COURT: What's the date? +MR. FOY: What's the date? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 26 Filed 02/10/20 Page 4 of 15| +4 +kluzNoeC kjc +THE COURT: In July. +MR. FOY: July 20 for that trial. +So really it's so we can perform our functions, and of +course there are other things going on as far as +responsibilities, and that would give us sufficient time to be +ready. It is not an unreasonable request. To say a case that +started on November 19, 2019, to be tried in less than a year I +don't think is an unusual circumstance. I don't think anyone +can say it is delayed justice. My client, who is free, she is +not incarcerated, so we don't have any of the interests of an +incarcerated defendant who wants to get a speedy trial. It is +necessary, not an option, not just something we just feel like. +This isn't about us laying back, taking our time. It's about +doing a diligent job. In order to do that, we do need the +time, and I would ask that you grant the request. +THE COURT: How long is the Judge Ramos trial? +MR. FOY: The government represented that they expect +it to be about two weeks. +THE COURT: Starting on July 20 you said, yes? +MR. FOY: That's correct. +MR. FIGGINS: Your Honor, I also join in the motion. +The court has had a chance to read my letter with respect to +requesting an adjournment. It is very early for us at this +point even to have a full appreciation as to what's going to +happen in this matter. I have only had the discovery for + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 +Filed 02/10/20 Page 5 of 15 +klu2NoeC kjc +5 +approximately two weeks. It's going to take -- I think there +was at least 25 witness statements that we not only need to +review, but then we need to try and follow up and maybe contact +those witnesses. There are some people who were incarcerated, +may have been released. There are numerous things that must be +done in terms of at least us tracking down specific details +that our clients are demanding that we do in their defense. +It took the federal government 90 days to investigate +this case and to come up with an indictment. Accordingly, a +law firm with one or two attorneys, without the resources of +all the federal agencies, it is going to take us more than 90 +days to do the same amount of work. So I don't think that it +is an unreasonable request. +Not to mention, I believe that if the court were not +to grant some type of an adjournment, we are going to find +ourselves back here again, but the defense will just be in a +better position to give you more specifics as to why we need +more time á la maybe we can't track down this witness or we +spoke to this witness and now we have to find another one. +There are numerous things like that that I think would come +about, and that's why we would try and suggest to give the +court a bird's eye view of that early on, so that maybe we can +delay -- or avoid having to come back repeatedly just to make +those additional requests. +Additionally, your Honor, I do believe that there is a + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 26 Filed 02/10/20 Page 6 of 15 +6 +kluZNoeC kjc +high likelihood that I'm going to file a motion to dismiss the +indictment based on selective prosecution. I do believe that +if certain portions of that motion are granted, then that's +going to entitle the defense to additional discovery that we +haven't even received yet. +So with the request that we are asking for, we are +also having an opportunity to kind of see -- I know kind of the +things that are going to happen or potentially will happen, so +instead of just trying to come back here three or four times to +say this is happening, we can kind of just do this now and +realize that that motion will probably be filed. That may +create other issues with respect to discovery. +Also, your Honor, I have also made a specific request +under Rule 16 that the defense wants whatever investigation was +done and whatever information there is that is discoverable +with respect to the Inspector General's report. It is my +position that we are entitled to that information. It is an +investigation of the same incident. It is an investigation of +the circumstances with which my client is being charged. With +that being said, I do think that we are entitled to whatever +information was generated in those reports, so I believe that +also is going to cause a delay in the trial wherever we go with +that issue. +THE COURT: We already addressed that the last time. +(Pause) + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 +Filed 02/10/20 Page 7 of 15 +klu2NoeC kjc +7 +THE COURT: I will hear from the government. +MS. LONERGAN: Yes, your Honor. As we put in our +written submission to the court, we agree that a brief +adjournment is appropriate, but we do not think that a +six-month adjournment is necessary or warranted. +First, the amount of discovery in this case is not +particularly voluminous nor complex in light of the cases tried +in this district; and, in addition, the further investigation, +I want to focus the court on the facts that are going to be at +issue in this trial occurred over a 14-hour period. It is true +that, as part of our discovery, we provided information outside +of that 14-hour period, anticipating many of the types of +requests that the defense counsel has already begun to make. +But again, your Honor, this is a very focused, single-incident +indictment that is about what happened over the period of 14 +hours. A much larger investigation about, for example, the +working conditions at the MCC, it is just not relevant to what +is going to be the issues on trial here. +I want to also touch on something that plaintiff said +about the need to interview witnesses. As we explained to the +court, we have done something that's unusual here, which is +that we have provided witness statements with our initial +discovery almost four months in advance of trial. As the court +is aware, we typically provide what we call 3500 material much +closer to trial. So the need to review those witness + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-Cr-00830-AT Document 26 Filed 02/10/20 Page 8 of 15 +8 +klu2NoeC kjc +statements and interview additional -- interview those +witnesses, that can't possibly weigh in favor of an adjournment +when in fact the defense counsel has so much more time with +those materials than they would in a typical trial schedule +where they might have those materials just a few weeks before +trial, your Honor. +So for those reasons, we think that we are hard +pressed to identify areas of additional investigation that +would touch on the 14-hour time period that is going to be at +issue in this trial; and so, for those reasons, while we agree +that a short adjournment is warranted, that six months is not +required. We do understand of course that that may be +difficult with Mr. Foy's trial schedule with having the July +trial, but it seems like there may be a possibility of putting +this trial before Mr. Foy's July trial and still giving him +sufficient time to prepare for both. +THE COURT: And how long do you expect this trial to +go? +MS. LONERGAN: Your Honor, if this trial is confined +to that 14-hour time period, setting aside jury selection, I +can't imagine it lasting more than a week. +THE COURT: Okay. The trial is set for June 8. +With respect to the motion to dismiss, the motion is +due on March 9, opposition is due by April 6, and the reply is +due on April 20. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT +Document 26 +Filed 02/10/20 Page 9 of 15 +klu2NoeC kjc +9 +Are there any further applications? +MR. FIGGINS: Yes, your Honor. +You said we dealt with +the issue with respect to the Investigator General's report. +This court has never addressed it at all. You never said +anything with respect to that. So I just want to make that +clear. Do I need to file a motion with respect to that? +THE COURT: You may file a formal motion. +MR. FIGGINS: Thank you. +THE COURT: Anything further? +MR. FIGGINS: Your Honor, can I have an additional two +weeks? Can we push the motion schedule back at least an +additional two weeks? Because I have my 80-something-year-old +relative coming to visit me from February 23 through March 1, +so I kind of won't be working during that time. So if you +could just make it like -- if you could make it something +around like the 18th or the 21st. +THE COURT: All right, then. You can file your motion +by March 20. +How long does the prosecution need to oppose? +MS. LONERGAN: Your Honor, three weeks, please. +THE COURT: So the prosecution will file opposition on +April 10, and the reply will be April 24. +Is there anything further? +MS. LONERGAN: Yes, your Honor, at this time the +government moves to exclude time between now and the trial + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 +Filed 02/10/20 Page 10 of 15 +kluzNoeC kjc +date, which has now been set for June 8, for the following +reasons: +10 +It will allow the parties to discuss potential +pretrial dispositions, to allow defense counsel to review the +discovery, make and file motions, the court to resolve those +motions, and for the defense counsel to conduct the additional +discovery that they have been discussing today in court. +MR. FOY: Your Honor, I don't oppose the government's +position. +I wanted to just go back to one thing. I understand +you have ruled. I accept that it is June 8. Hopefully there +are no delays because I anticipate being out of the country -- +we haven't set a specific date, but I'm traveling with family +at the end of June. So if there is any delay, that could be an +issue. +THE COURT: You are talking about leisure travel? +MR. FOY: Well, leisure. My family, first-priority +travel. That's what it is. So I don't know if it's just +leisure. It is not business, but it is the business of having +family business. +THE COURT: Well, you should work your family schedule +around your professional obligations, counsel. +MR. FOY: Well, if there is a delay in the +professional schedule of trial, because it is not unusual for +sometimes there to be delays, because if we start a week later + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 +Filed 02/10/20 Page 11 of 15 +kluZNoeC kjc +11 +for some +reason, then it's going to create a conflict. +THE COURT: You will not be starting a week later. We +are starting on the 8th of June. +MR. FOY: Okay. Here is the issue. The government +has represented to you that this is just about a 14-hour +period. +I suspect that, when the trial comes around, that the +only thing that won't come up during the trial is the 14-hour +period, right? Because it's not as if we are not here because +of other things having nothing to do with the defendants in +this case, and the working conditions at MCC are directly +related to why things happened in that 14-hour period. The +years of conduct, the culture of the institution, the failures +in security measures beyond counts. +We have been provided with three videos of the 192 +that exist. In the SHU there are nine video cameras. Only one +has been produced, and it shows almost nothing. And why that +is, the circumstances, what it means, is relevant. +So maybe it will be a one-week trial. That's +possible. But what I am trying to avoid is some type of +conflict that we can see now that - you know, because, you +know, I understand professional obligations, but if I had to +choose between family and my professional obligations, it's -- +THE COURT: All right. Well, counsel, I am directing +that you be here on June 8 to start trial. +MR. FOY: I will be here. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT +Document 26 +Filed 02/10/20 Page 12 of 15 +kluzNoeC kjc +12 +THE COURT: That is my order. +MR. FOY: And I will be here. I just don't want there +to be any delay that creates that issue. +MR. FIGGINS: Your Honor -- sorry to cut you off. +Your Honor, I'm thankful Mr. Foy said that about the +family vacation. I am actually going to be in Italy on a +cruise June 1 through June 14. +We fly back on the 15th of +June. +THE COURT: And you just forgot about it? +MR. FIGGINS: Your Honor, I don't keep my social +calendar. Luckily he said that and I realized that in June we +do have a cruise scheduled, and I didn't even know the date, so +I had to find out just now. +THE COURT: When do you return? +MR. FIGGINS: The 15th, and I don't even know what day +of the week that is, but . . . +THE COURT: We will start on the 22nd of June. +MR. FOY: Well, Judge, that's the time I was just +talking to you about. Right? That I'm trying to make +arrangements to travel with my family. Right? +THE COURT: Well, I understand that it is desirable to +have family time, but you also have an obligation to zealously +represent your client, and so we are going to start on the +22nd. +MR. FOY: So I don't understand. I mean, I have no + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 +Filed 02/10/20 Page 13 of 15 +kluzNoeC kjc +13 +problem zealously representing my client, and I will do so. If +my daughter is going to be in Italy, ironically, and my wife +and my other daughter are going to travel there at the end of +her program so we can spend time, how is that an issue for us +to take that into consideration in a professional setting? +Like, I don't understand. +THE COURT: Counsel, you will use Skype. Is there +anything - +MR. FOY: No, no, no, no, no, no, no, no. +THE COURT: Is there anything further? +MR. FOY: I'm not going to use -- +THE COURT: Counsel, I have heard enough. Is there +anything further? +MR. FOY: Well, look, I'm not - +THE COURT: Sit down, counsel. +MR. FOY: Can I be heard? +THE COURT: You will sit down. +MR. FOY: And then be heard from the seat? +THE COURT: No. You will sit down. +Is there anything further unrelated to the vacation +plans - +MR. FOY: This is not just vacation, your Honor. +THE COURT: Counsel, I have had it. Now, you sit down +and stop - +MR. FOY: Before -- + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 +kluzNoeC kjc +Filed 02/10/20 Page 14 of 15 +14 +THE COURT: -- with this nonsense. +MR. FOY: Before +I sit down, your Honor -- +THE COURT: No. +MR. FOY: -- you said June 8. +THE COURT: Counsel, I have directed -- +MR. FOY: My co counsel -- +THE COURT: -- you to sit down. +MR. FOY: My co-counsel says -- +THE COURT: Sit down, counsel. +MR. FOY: -- he has vacation and -- +THE COURT: Sit down. +MR. FOY: -- we are going to interrupt -- +THE COURT: Sit down. +MR. FOY: -- my family -- +THE COURT: Counsel. +MR. FOY: —- obligations -- +THE COURT: Counsel. +MR. FOY: -- for a nonviolent -- +THE COURT: Sit down, counsel. +MR. FOY: -- criminal case with no mandatory jail -- +THE COURT: Counsel, sit down. +MR. FOY: -- that's not even -- +THE COURT: Sit down. +MR. FOY: -- based on their conduct? +THE COURT: Sit down. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:19-cr-00830-AT Document 26 Filed 02/10/20 Page 15 of 15 +15 +kluzNoeC kjc +MR. FOY: It's based on what some other man did? +THE COURT: Counsel, you don't have a jury here. +stop +performing. +MR. FOY: No. I'm not -- there is no jury here. I'm +trying to address the unfairness -- +THE COURT: Sit down. +MR. FOY: -- of proper consideration of a +professional -- +THE COURT: You are trying my patience, counsel. Sit +down. +All right, then. The matter is adjourned. +MS. LONERGAN: Your Honor, sorry. We are going to +amend our application to exclude time now until June 22, which +is the date the court has now set for trial for the reasons we +previously stated on the record. +THE COURT: The matter is adjourned until June 22. +The time is excluded under the Speedy Trial Act for the reasons +already stated by the prosecution. +O00 \ No newline at end of file diff --git a/vision-fixhub/court-05/72532dd30343166688bedf2e57256c583ee6a73b46c058283a14e4634e01f3b6.receipt.json b/vision-fixhub/court-05/72532dd30343166688bedf2e57256c583ee6a73b46c058283a14e4634e01f3b6.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..435fb8c6b1d1d37268007bf1a9e91bfc8c1c57bf --- /dev/null +++ b/vision-fixhub/court-05/72532dd30343166688bedf2e57256c583ee6a73b46c058283a14e4634e01f3b6.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -928, + "dataset": "marble-joined", + "doc_id": "72532dd30343166688bedf2e57256c583ee6a73b46c058283a14e4634e01f3b6", + "engine": "marble-apple-vision", + "event_count": 17, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "4a1f722dd0d58ef4d6db98b0a20e3f69ca17d4cec66575f57f01a7d67ceb6cae", + "output_sha256": "e7503a87d1ea88929a6cb19aeacb6516ef652d85f2e81e2e48f3a36c5c889e7b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7286431af0cb37453e16fadd212e3f9857cfe99a4f885a9e79ed0982b4768d98.md b/vision-fixhub/court-05/7286431af0cb37453e16fadd212e3f9857cfe99a4f885a9e79ed0982b4768d98.md new file mode 100644 index 0000000000000000000000000000000000000000..b9181d233d7c211845fa9e06a7c51632028c5799 --- /dev/null +++ b/vision-fixhub/court-05/7286431af0cb37453e16fadd212e3f9857cfe99a4f885a9e79ed0982b4768d98.md @@ -0,0 +1,24 @@ +Case 1:22-cV-10904-JSR Document 326-62 Filed 09/08/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 326-62 Filed 09/08/23 Page 2 of 2 +Date: Wednesday. September 2 2009 11:46 AM +From: Jeffrey Epstein +To: +jes staley is staying at the berkeley hotel in london tonight +****** +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeitrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. + +ESTATE_JPM002773 diff --git a/vision-fixhub/court-05/7286431af0cb37453e16fadd212e3f9857cfe99a4f885a9e79ed0982b4768d98.receipt.json b/vision-fixhub/court-05/7286431af0cb37453e16fadd212e3f9857cfe99a4f885a9e79ed0982b4768d98.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..83463dbbe6cddf9b4a6da01b6c9b763eb2ffc5bf --- /dev/null +++ b/vision-fixhub/court-05/7286431af0cb37453e16fadd212e3f9857cfe99a4f885a9e79ed0982b4768d98.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -46, + "dataset": "marble-joined", + "doc_id": "7286431af0cb37453e16fadd212e3f9857cfe99a4f885a9e79ed0982b4768d98", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "0df569b9fda42862732e023a240ab53c21a8a263c2d121120cc957211d5d2d04", + "output_sha256": "b235f025cf1e5128fd7f760cbf9d6b506440506a0e3da92c8f3814d96761f5a9", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/72a204f8e2a495faa8eb63fe0208ace8d497200a0feb86e8485d965e483dc627.md b/vision-fixhub/court-05/72a204f8e2a495faa8eb63fe0208ace8d497200a0feb86e8485d965e483dc627.md new file mode 100644 index 0000000000000000000000000000000000000000..46c8e60dc36c80f27692813b4ab707672bee02c0 --- /dev/null +++ b/vision-fixhub/court-05/72a204f8e2a495faa8eb63fe0208ace8d497200a0feb86e8485d965e483dc627.md @@ -0,0 +1,45 @@ +Case 1:20-cr-00330-PAE Document 680 +Filed 06/26/22 Page 1 of 3 +LAW OFFICES OF BOBBI C. STERNHEIM +212-243-1100 • Main +917-912-9698 • Cell +888-587-4737 • Fax +225 Broadway, Suite 715 +New York, NY 10007 +bcsternheim@mac.com +June 26, 2022 +Honorable Alison J. Nathan +Sitting By Designation +United States District Court +40 Foley Square +New York, NY 10007 +Re: United States v. Ghislaine Maxwell +S2 20 Cr. 330 (AJN) +Dear Judge Nathan: +In connection with the upcoming sentencing proceeding and supplementing Ms. +Maxwell's Sentencing Memorandum (Dkt. 663) as Exhibit K, enclosed please find a letter from +an MDC inmate in general population expressing her positive impressions of Ms. Maxwell. +Very truly yours, +/sl +BOBBI C. STERNHEIM +Enc. +cc: Counsel of Record + + +Case 1:20-cr-00330-PAE Document 680 Filed 06/26/22 Page 2 of 3 + + + +When Ghislane Maxwell first arrived +in the unit, she introduced herself to everyone +With a handshake. " Hi l'am Maxwell" She says +With a Smile genuine and Kind. +It took all of us by surprise. +Within one week of Maxwell arriving. +She had volunteered to teach ESL. +Teach loga, and help women with their +GED. I believe Its important to know +that there are also positive opinions, +Some of which are among inmates +in the Unit. I believe that is also good +to point out the good in people. - Tatiana Veneyaj diff --git a/vision-fixhub/court-05/72a204f8e2a495faa8eb63fe0208ace8d497200a0feb86e8485d965e483dc627.receipt.json b/vision-fixhub/court-05/72a204f8e2a495faa8eb63fe0208ace8d497200a0feb86e8485d965e483dc627.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e207623faf69dd7f19ee8f2e4eda9a8c89e00db3 --- /dev/null +++ b/vision-fixhub/court-05/72a204f8e2a495faa8eb63fe0208ace8d497200a0feb86e8485d965e483dc627.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -45, + "dataset": "marble-joined", + "doc_id": "72a204f8e2a495faa8eb63fe0208ace8d497200a0feb86e8485d965e483dc627", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "9efa0e2d8ccc13d95bc6261f098999a969aeac9a81dfd623357bae73a602e264", + "output_sha256": "023ebdc4261c8d722733e60da742cc5e3e2b3a6623e7c37d5cc33e22bb728aa2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/72ec6b64fa62d51cd79a78cc41c8454712342b0744192d197f39cd39249b1432.md b/vision-fixhub/court-05/72ec6b64fa62d51cd79a78cc41c8454712342b0744192d197f39cd39249b1432.md new file mode 100644 index 0000000000000000000000000000000000000000..1a5a23d17ad52faeb06f575303b408f5473d7a6a --- /dev/null +++ b/vision-fixhub/court-05/72ec6b64fa62d51cd79a78cc41c8454712342b0744192d197f39cd39249b1432.md @@ -0,0 +1,44 @@ +Case 1:22-cv-10904-JSR Document 60-1 Filed 02/24/23 Page 1 of 2 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904 JSR +AFFIDAVIT OF +BRENDAN AUSTIN +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +1, Brendan Austin, declare and state the following: +I have never been convicted of a felony; +2. +I have never been censured, suspended, disbarred or denied admission or +readmission by any court; and +3. +there are no disciplinary proceedings presently against me. +I make this Affidavit in support of my Motion for Admission Pro Hac Vice to appear as counsel +for Plaintiff, Government of the United States Virgin Islands, in the above-captioned action. +Dated: February 21, 2023 +ReCorti +BRENDAN AUSTIN +Motley Rice LIC +401 9th Street NW, Suite 630 +Washington, DC 20004 +(202) 386-9608 phone +baustin@motleyrice.com + + +Case 1:22-cv-10904-JSR Document 60-1 Filed 02/24/23 Page 2 of 2 +DISTRICT OF COLUMBIA +SWORN to and subscribed before me this 22\_ day of February 2023. +VOTARY PUBLIC +710 1 27 +RENE YOUNGE +KELLI +HOTAPA +EXP. +10~14-27 +DIETRIC +OF +2 diff --git a/vision-fixhub/court-05/72ec6b64fa62d51cd79a78cc41c8454712342b0744192d197f39cd39249b1432.receipt.json b/vision-fixhub/court-05/72ec6b64fa62d51cd79a78cc41c8454712342b0744192d197f39cd39249b1432.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5fa4cc74be1f746ee860b0febe585bc5460e544b --- /dev/null +++ b/vision-fixhub/court-05/72ec6b64fa62d51cd79a78cc41c8454712342b0744192d197f39cd39249b1432.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "72ec6b64fa62d51cd79a78cc41c8454712342b0744192d197f39cd39249b1432", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "8087c5015b7a71fdea58c2e897dc995ae45e7450208109d8ae2d9a624017e62d", + "output_sha256": "86c1082e852f709057dceb0624a7f473526b48f39ba8617f435c4465d238bc95", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/72f6f5353edc05fec524c830bec8b544c50d5237c5797df36ae2997e2d0d475c.md b/vision-fixhub/court-05/72f6f5353edc05fec524c830bec8b544c50d5237c5797df36ae2997e2d0d475c.md new file mode 100644 index 0000000000000000000000000000000000000000..97252804abce90abbf06dc0e628a9f08bfb78cc3 --- /dev/null +++ b/vision-fixhub/court-05/72f6f5353edc05fec524c830bec8b544c50d5237c5797df36ae2997e2d0d475c.md @@ -0,0 +1,877 @@ +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 1 of 18 + + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 2 of 18 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +Case No. 22-ev-10904-JSR +V. +JPMORGAN CHASE BANK, N.A., +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff, +JAMES EDWARD STALEY, +Third-Party Defendant. +JPMORGAN CHASE BANK, N.A.'S +FOURTH SUPPLEMENTAL INITIAL DISCLOSURES +Pursuant to Federal Rule of Civil Procedure 26(a)(I), Defendant/Third-Party Plaintiff +JPMorgan Chase Bank, N.A. ("JPMorgan") makes the following fourth supplemental initial +disclosures to Plaintiff Government of the United States Virgin Islands ("USVI" or "Plaintiff") and +Third-Party Defendant James Edward Staley ("Staley" or "Third-Party Defendant"). +The disclosures made herein are based upon information reasonably available to JPMorgan +at the present stage of this litigation and the issues as currently defined by the complaint. JPMorgan +reserves the right to supplement, revise, or otherwise amend the information contained herein as +-1- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 3 of 18 +discovery continues. +By making these disclosures, JPMorgan does not represent that it is identifying every +document, tangible thing, or witness that may be relevant to the issues in this action, or on which +JPMorgan may rely in support of its claims or defenses. Nor does JPMorgan waive its rights to +object to production of any document or tangible thing disclosed on the basis of any valid objection +(including but not limited to any privilege, the work-product doctrine, relevancy, hearsay, undue +burden, or any other proper ground) or its rights to object to the use of any information disclosed +for any purpose, in whole or in part, in any subsequent proceeding in this action or in any other +action. JPMorgan also reserves the right to object on any and all proper grounds to any other +discovery request or proceeding involving or relating to the subject matter of these disclosures +consistent with the Federal Rules of Civil Procedure and the Local Rules for the United States +District Court for the Southern District of New York. +JPMorgan's disclosures represent its good faith effort to identify information it reasonably +believes is required by Fed. R. Civ. P. 26(a)(I). The disclosures set forth below are made subject +to the above objections and qualifications. +I. +INDIVIDUALS WITH KNOWLEDGE +Based on information reasonably available at this time, JPMorgan identifies the following +individuals who may be likely to have discoverable information that JPMorgan may use to support +its claims or defenses, unless such use is solely for impeachment. In making these disclosures, +JPMorgan does not waive its right to object, pursuant to any applicable Federal Rule of Civil +Procedure or Local Rule, to the deposition or trial testimony of any of the individuals listed below. +JPMorgan does not consent to or authorize communication by the Plaintiff with the +individuals identified below. Each of the individuals identified below can be reached through +-2- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 4 of 18 +counsel for JPMorgan. +Because discovery, investigation, and analysis of these matters is ongoing, JPMorgan +reserves the right to supplement this information if additional information later becomes known +and to designate and/or call further witnesses at trial. JPMorgan also reserves the right to seek +discovery from, and relating to, other persons that may subsequently become known as persons +likely to have discoverable information relevant to the disputed facts. +Name +Corporate representative of JPMorgan +Chase Bank. N.A. +Corporate representative of JPMorgan +Chase Bank, N.A. +Corporate representative of JPMorgan +Chase Bank, N.A. +Corporate representative of JPMorgan +Chase Bank, N.A +Erdoes, Mary (CEO Asset & Wealth +Management) +Subject Matter +JPMorgan's onboarding, retention, and exit of +Jeffrey Epstein's accounts and accounts related +to Jeffrey Epstein. +JPMorgan's policies and procedures relating to +the private bank's recruitment, onboarding, and +retention of clients. +JPMorgan's policies and procedures relating to +monitoring and reporting account activity of +private banking clients. +JPMorgan's Anti-Money Laundering ("AML") +Compliance program and AML Compliance +policies and procedures. +JPMorgan's private banking client relationship +with Jeffrey Epstein. +Langford, William* (former Director +(Global Anti-Money Laundering); Global +Head (Compliance); Head (Enterprise +Financial Crimes Compliance); and +General Counsel (Global Compliance and +Regulatory Management)) +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein.' +AML compliance work that JPMorgan +performed relating to Jeffrey Epstein's accounts +and accounts related to Jeffrey Epstein +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +' JPMorgan has identified those individuals who, at this point in the litigation, may have +information uniquely related to its breach of fiduciary duty and faithless servant claims against Mr. +Staley. All witnesses may have information related to the underlying claims of the USVI for which +JPMorgan seeks contribution or indemnity. JPMorgan does not waive its rights to further amend or +supplement these disclosures through discovery. +-3- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 5 of 18 +McHugh, +(Executive Director, JP +Private Bank) +Morris, Paul* (former Banker (Private +Bank)) +Staley, James Edward (former CEO +(Private Bank); CEO (Investment Bank); +CEO (Asset Management); Global Head +(Asset & Wealth Management); Head +(Private Bank)) +Stephen Cutler* (former Executive Vice +President, General Counsel) +Mary L +Bank) +(Managing Director, Private +Justin Nelson (Managing Director and +Head of Asset Management and Financial +Principals Coverage, Private Bank) +Transaction information relating to Jeffrey +Epstein's account activity at JPMorgan and +accounts related to Jeffrey Epstein. +JPMorgan's private banking client relationship +with Jeffrey Epstein. +JPMorgan's private banking client relationship +with Jeffrey Epstein. +Jeffrey Epstein's involvement in recruiting other +private banking clients for JPMorgan. +Mr. Staley's involvement in JPMorgan's banking +relationship with Jeffrey Epstein. +Knowledge of Jeffrey Epstein's activities as +alleged by Plaintiff USVI and Jane Doe 1 (in +Case No. 22-cv-10019). +Third-Party Defendant. +JPMorgan's private banking relationship with +Epstein. +JPMorgan's retention and exit of Jeffrey +Epstein's accounts and accounts related to +Jeffrey Epstein. +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein +IPMorgan's private banking client relationship +with Jeffrey Epstein. +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +JPMorgan's private banking client relationship +with Jeffrey Epstein. +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +*These individuals no longer work at JPMorgan and may be separately represented. To the extent +these individuals are separately represented, JPMorgan will provide contact information for their +counsel when available. +-4- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 6 of 18 +Jonathan +* (former General +Counsel, Investment Bank) +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +Catherine Keating* (former CEO, Private +Bank) +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +John Duffy* (former CEO, Private Bank) +Mr. Staley's involvement in JPMorgan's +banking relationship with Jeffrey Epstein. +Anne Verdon (former General Counsel, +Private Bank) +1r. Staley's involvement in JPMorgan' +anking relationship with Jeffrey Epstei +Jane Doe 1 (Plaintiff in Case No. 22-cv- +10019) +Mr. Staley's alleged sexual abuse of Jane Doe 1 +and others through his relationship with Jeffrey +Epstein. +Jane Doe 1 (Plaintiff in Case No. 22-cv- +10018) +Mr. Staley's alleged sexual abuse of Jane Doe 1 +and others through his relationship with Jeffrey +Epstein. +Governor Albert Bryan, Jr. +Former Governor John de Jongh +Sebastiano Paiewonsky-Cassinelli +John McDonald +Tax exemptions and associated negotiations +made to and with Jeffrey Epstein. +Tax exemptions and associated negotiations +made to and with Jeffrey Epstein. +Epstein's contacts with USVI Government +officials including Former Governor John de +Jongh. +IBE licenses granted and associated +negotiations made to and with Jeffrey Epstein in +his capacity as Director of the Office of the +Lieutenant Governor, Division of Banking and +-5- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 7 of 18 +Cecile René Galiber-de Jongh +Jeanne +Representative of United States Virgin +Islands Water and Power Authority +Stacey Plaskett +Former Governor Kenneth Mapp +Dawn Henry +Ronald +James O'Bryan Jr. +Celestino +Carlton Dowe +Insurance. +Economic incentives and associated business +deals made or proposed to and with Jeffrey +Epstein. Donations Jeffrey Epstein made to +various officials and organizations in the United +States Virgin Islands. Complaints submitted to +Jeffrey Epstein's office about his associated +corporations or personal activity. Account +activity for Jeffrey Epstein's associated +organizations, including Southern Trust +Company• +Economic incentives and associated business +deals made or proposed to and with Jeffrey +Epstein. Account activity for Jeffrey Epstein's +associated organizations, including Southern +Trust Company and Financial Trust Company. +Permits and exemptions related to Jeffery +Epstein and his privately owned island in the +United States Virgin Islands. +Interactions with Epstein in individual capacity, +as General Counsel for Economic Development +Authority, and as United States Virgin Islands +Delegate. +Interactions with Epstein in individual capacity +and as Governor of USVI. +Interactions with Epstein in individual capacity +and as Commissioner of the USVI Department +of Planning and Natural Resources. +Interactions with Epstein and Epstein associates +in individual capacity and as State Senator in +USVI. +Interactions with Epstein and Epstein associates +in individual capacity and as State Senator in +USVI. +Interactions with Epstein in individual capacity, +as State Senator in USVI, Port Authority board +member, former USVI Chief of Police, and +member of Kenneth Mapp's transition team. +Interactions with Epstein in individual capacity +and as Executive Director of the Port Authority +and former State Senator in the USVI. +-6- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 8 of 18 +Gloria Lambert +Interactions with and supervision of Epstein in +her capacity as Cyril E. Airport +supervisor. +[First Name Unknown] Carpenter +Interactions with and supervision of Epstein in +his/her capacity as Cyril E. +Airport +supervisor. +JP Oriol +Interactions with Epstein in individual capacity, +as Director of Coastal Zone Management, and +Commissioner of Department of Planning and +Natural Resources. +Sandra Bess +Interactions with Epstein in individual capacity, +through audit of Epstein-related entity in 2014, +as Economic Development Commission +compliance officer with the USVI Economic +Development Authority. +Representative of United States Virgin +Permits issued to and investigations related to +Islands Department of Planning and Natural Jeffrey Epstein. +Resources +Alicia Barnes +Robert Mathes +Representative of United States Virgin +Islands Department of Justice +Wayne +Monica Carbon +Vincent Frazer +Denise +Carol +Interactions with Epstein in individual capacity, +as Assistant CEO of the EDA and as the former +Commissioner of the DPNR. +Interactions with Epstein in individual capacity, +and as the former Commissioner of the DPNR. +Information related to Jeffrey Epstein's status as +a registered sex offender and any complaints, +reports, investigations, interviews, and other +information received about Jeffrey Epstein. +Interactions with Epstein or his counsel +concerning Mr. Epstein's input on the language +of the USVI sex offender registration +legislation. +Interactions with Epstein or his counsel in +individual capacity and as an employee of USVI +DOJ involved in sex offender monitoring. +Interactions with Epstein or his counsel in +individual capacity and as Attorney General for +USVI under John de Jongh. +Interactions with Epstein or his counsel in +individual capacity and as Attorney General for +USVI under Governor Albert Bryan. +Interactions with Epstein or his counsel in +individual capacity and as Deputy Attorney +General and Acting Attorney General for USVI +under Governors Kenneth Mapp and Albert +-7- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 9 of 18 +Shanni Pinney +Kevin Augustin +Inais Borque +Merlyn Petty +T'Niqua Rogers +United States Virgin Islands Economic +Development Authority +Margarita +Stephanie Berry +Wayne Biggs +Clouden +Kamal +Tracy +Bhola +Jennifer Nugent- +Joy Penn +Bryan. +Interactions with Epstein in individual capacity +and as the Sex Offender Registry Program +Manager; Information related to Jeffrey +Epstein's status as a registered sex offender, and +any complaints, reports, investigations, +interviews, and other information received +about Jeffrey Epstein. +Interactions with Epstein in individual capacity +and as a Territorial Manager with the Sex +Offender Registry Office. +Interactions with Epstein in individual capacity +and as an investigator with the Sex Offender +Registry Office. +Interactions with Epstein in individual capacity +and as an employee with the Sex Offender +Registry Office. +Interactions with Epstein in individual capacity +and as a special agent for the USVI DOJ +involved in monitoring Epstein as a registered +sex offender. +Economic development tax incentives received +or requested by Jetfrey Epstein and any +attendant negotiations. +Economic development tax incentives received +or requested by Jeffrey Epstein. +Economic development tax incentives received +or requested by Jeffrey Epstein. +Economic development tax incentives received +or requested by Jeffrey Epstein. +Economic development tax incentives received +or requested by Jeffrey Epstein. +Economic development tax incentives received +or requested by Jeffrey Epstein. +Economic development tax incentives received +or requested by Jeffrey Epstein. +Economic development tax incentives received +or requested by Jeffrey Epstein. +Economic development tax incentives received +or requested by Jeffrey Epstein. +-8- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 10 of 18 +Shanell Petersen +Economic development tax incentives received +or requested by Jeffrey Epstein. +Semele +Economic development tax incentives received +or requested by Jeffrey Epstein. +Henry Smock +Economic development tax incentives received +or requested by Jeffrey Epstein. +United States Virgin Islands Police +Department +Complaints, reports, investigations, interviews, +and other derogatory information received about +Jeffrey Epstein. +United States Virgin Islands Department of | Information relating to Jeffrey Epstein +Human Services +United States Virgin Islands Department of Information relating to Jeffrey Epstein +Health +Financial Crimes Enforcement Network +U.S. Customs and Border Protection +Federal Bureau Of Investigation +United States Attorney's Office For The +Southern District Of New York +United States Attorney's Office For The +Southern District Of Florida +Palm Beach Sheriff's Office +Palm Beach Police Department +Information concerning reports of financial +transactions of Jeffrey Epstein and related +individuals and entities +Information concerning passengers on Jeffrey +Epstein's aircraft and visitors to his residence +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +nformation concerning law enforcemen +ctions and investigations into Epstein an +Virgin Islands Department Of Justice +Santa Fe County Sherriff's Office +New York Police Department +-9- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 11 of 18 +Manhattan District Attorney's Office +Information concerning law enforcement +actions and investigations into Epstein and +related entities. +The Epstein Estate +Information concerning Epstein and related +entities. +The Epstein Victims Compensation +Program +Andrew Farkas +Information concerning claims made by victims +against Epstein and their resolution. +Information concerning Epstein's activities in the +USVI including Epstein's involvement in the +ownership and management of entities that +received tax benefits from the USVI. +Maria Hodge +Information related to Epstein's activities in the +USVI as former personal attorney to Epstein. +Erika Kellerhals +Information related to Epstein's activities in the +USVI as former personal attorney to Epstein. +Clive Rivers +Information related to Epstein's activities in the +USVI as former personal attorney to Epstein. +In addition to the above-named individuals, all persons deposed in this case and other +persons identified in the documents described in Section II below may have discoverable +information that JPMorgan may use to support its claims or defenses. JPMorgan reserves the right +to modify and supplement the foregoing list and to identify and call as witnesses additional persons +if, during the course of discovery and investigation relating to this case, JPMorgan learns that such +additional persons have knowledge or information that JPMorgan may use to support its claims or +defenses. +Further, JPMorgan also reserves the right to call as witnesses individuals in addition to +those identified herein to the extent such witnesses are required to authenticate an exhibit offered +into evidence or to establish chain of custody of an exhibit offered into evidence. JPMorgan also +may rely on expert witnesses, to be disclosed in accordance with Federal Rule of Civil Procedure +26(a)(2), to support its claims or defenses. JPMorgan specifically reserves the right to call any +deponent or declarant in this action as a trial witness to testify regarding matters covered in his/her +-10- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 12 of 18 +deposition or declaration and/or to rely on any such testimony in support of its claims or defenses +in this case. JPMorgan further specifically reserves the right to call any individual(s) identified in +the Plaintiff's disclosures, including as amended. +II. CATEGORIES OF RELEVANT DOCUMENTS +At present, JPMorgan believes that the following documents, electronically stored +information, and tangible things may be used to support JPMorgan's claims or defenses, unless +such use is solely for impeachment. This disclosure does not include documents solely within the +Plaintiff's or the Third-Party Defendant's possession, custody, or control. This disclosure does +not include expert materials that may be or have been developed, which will be disclosed pursuant +to Federal Rule of Civil Procedure 26(a)(2). This disclosure does not constitute an admission as +to the existence, relevance, or admissibility of the identified materials or a waiver of any attorneyclient privilege, work product protection, or other applicable privilege or immunity. +1) Documents, communications, and electronically stored information relating to +JPMorgan's AML compliance program and other policies and practices. +2) Documents, communications, and electronically stored information relating to +Jeffrey Epstein's accounts and accounts related to Jeffrey Epstein at JPMorgan. +3) Documents, communications, and electronically stored information relating to +James Staley's employment, compensation, and duties at JPMorgan, including +JPMorgan policies and codes of conduct. +4) Documents, communications, and electronically stored information relating to +James Staley's communications with or about Jeffrey Epstein. +JPMorgan will make the foregoing documents available for inspection or copying at a time and +place to be mutually agreed upon by the parties, subject to any applicable privacy or other +-11- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 13 of 18 +restrictions and to the extent they are non-privileged and in JPMorgan's possession, custody, and +control. JPMorgan has produced Mr. Staley's personnel file which includes Mr. Staley's Code of +Conduct affirmations and information regarding Mr. Staley's compensation, and points Mr. Staley to +the following documents in support of its claims: +JPM-SDNYLIT-00178143-JPM-SDNYLIT-00178494 +JPM-SDNYLIT-00202227-JPM-SDNYLIT-00204753 +JPM-SDNYLIT-00204821-JPM-SDNYLIT-00204836 +In addition to the above-described documents, JPMorgan expects that, during the course +of discovery, experts will identify documents used to support their opinions pertaining to the +issues in this case. Further, JPMorgan may rely upon publicly available documents and documents +that have been identified in the initial disclosures of any other party or may be obtained through +discovery or are otherwise produced by the Plaintiff and/or third parties. +Because discovery, investigation, and analysis of these matters are ongoing, JPMorgan +expects to discover additional documents and/or tangible things upon which it may rely to support +its claims or defenses, including documents from the Third-Party Defendant, who has not yet +produced any documents in this case. JPMorgan therefore reserves the right to supplement this +information accordingly. +Notwithstanding this identification of these categories of documents, JPMorgan reserves the +right to object to any of the Plaintiff's discovery requests on related topics to the extent such requests +are overly broad, unduly burdensome, and/or call for documents beyond the scope of JPMorgan's +discovery obligations under the Federal Rules of Civil Procedure or the Local Rules, and/or any +other applicable basis for objection. +-12- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 14 of 18 +III. +CALCULATION OF DAMAGES +USVI v. JPMorgan: +Not applicable. +JPMorgan v. Staley: +As stated in its Third-Party Complaint, JPMorgan seeks the following damages from Staley: +1) All damages awarded to the USVI as discussed in Section 3 of USVI's Supplemental +Initial Disclosures dated March 22, 2023. +2) Damages for breach of fiduciary duty, including all damages awarded to the USVI as +discussed in Section 3 of USVI's Supplemental Initial Disclosures dated March 22, +2023, all costs of defending the USVI v. JPMorgan Chase Bank, N.A. litigation to be +determined after JPMorgan's liability has been decided, and reputational damage +from the litigation to be determined based on expert testimony.? +3) All compensation paid by JPMorgan to Staley from 2006 through 2013, which +JPMorgan has calculated at this time based on the documents it has produced (see +supra) to be approximately not less than $140,000,000. +4) Punitive damages in an amount to be determined at trial. +IV. +INSURANCE +Insurance agreements under which an insurance business may be liable to satisfy all or +part of a possible judgment in this action or to indemnify or reimburse for payments made to +satisfy any judgment in this action have been made available for inspection and copying and can +be found at the following +numbers: +2 JPMorgan is currently determining the damages it has suffered and will suffer as a result of this +litigation and will amend these disclosures when it has a reasonable calculation of those damages. +- 13- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 15 of 18 +JPM-SDNYLIT-00762790 +JPM-SDNYLIT-00762803 +JPM-SDNYLIT-00762885 +JPM-SDNYLIT-00762920 +JPM-SDNYLIT-00762932 +JPM-SDNYLIT-00762944 +JPM-SDNYLIT-00762958 +JPM-SDNYLIT-00762974 +JPM-SDNYLIT-00763005 +JPM-SDNYLIT-00763064 +JPM-SDNYLIT-00763075 +JPM-SDNYLIT-00763086 +JPM-SDNYLIT-00763104 +JPM-SDNYLIT-00763127 +JPM-SDNYLIT-00763149 +JPM-SDNYLIT-00763184 +JPM-SDNYLIT-00763199 +JPM-SDNYLIT-00763222 +JPM-SDNYLIT-00763224 +JPM-SDNYLIT-00763225 +JPM-SDNYLIT-00763231 +JPM-SDNYLIT-00763244 +JPM-SDNYLIT-00763257 +JPM-SDNYLIT-00763288 +JPM-SDNYLIT-00763326 +JPM-SDNYLIT-00763337 +JPM-SDNYLIT-00763352 +JPM-SDNYLIT-00763353 +JPM-SDNYLIT-00763357 +JPM-SDNYLIT-00763373 +JPM-SDNYLIT-00763375 +JPM-SDNYLIT-00763388 +JPM-SDNYLIT-00763395 +JPM-SDNYLIT-00763408 +JPM-SDNYLIT-00763526 +JPM-SDNYLIT-00763564 +JPM-SDNYLIT-00763565 +JPM-SDNYLIT-00763566 +JPM-SDNYLIT-00763596 +JPM-SDNYLIT-00763599 +JPM-SDNYLIT-00763608 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+JPM-SDNYLIT-00774626 +JPM-SDNYLIT-00774909 +JPM-SDNYLIT-00774933 +JPM-SDNYLIT-00774953 +JPM-SDNYLIT-00774973 +JPM-SDNYLIT-00774992 +JPM-SDNYLIT-00775011 +JPM-SDNYLIT-00775041 +JPM-SDNYLIT-00775081 +JPM-SDNYLIT-00775111 +JPM-SDNYLIT-00775118 +JPM-SDNYLIT-00775137 +JPM-SDNYLIT-00775172 +JPM-SDNYLIT-00775187 +JPM-SDNYLIT-00775219 +JPM-SDNYLIT-00775248 +JPM-SDNYLIT-00775278 +JPM-SDNYLIT-00775304 +JPM-SDNYLIT-00775311 +JPM-SDNYLIT-00775338 +JPM-SDNYLIT-00775352 +JPM-SDNYLIT-00775376 +JPM-SDNYLIT-00775404 +JPM-SDNYLIT-00787742 +-15- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 17 of 18 +Dated: May 30, 2023 +MASSEY & GAIL LLP +/s/ Leonard A. Gail +Leonard A. Gail (pro hac vice) +Rachel Morse (pro hac vice) +Caitlin Kovacs (pro hac vice) +50 East Washington Street, Suite 400 +Chicago, IL 60602 +(t) (312) 283-1590 +Igail@masseygail.com +rmorse@masseygail.com +ckovacs@masseygail.com +Respectfully submitted, +WILMER CUTLER PICKERING +HALE AND DORR LLP +/s/ Felicia H. Ellsworth +Felicia H. Ellsworth +John J. Butts +60 State Street +Boston, +02109 +(t) (617) 526-6000 +(f) (617) 526-5000 +felicia.ellsworth@wilmerhale.com +john.butts@wilmerhale.com +M. +III +Robert L. Boone +Hillary Chutter-Ames +7 World Trade Center +250 Greenwich Street +New York, NY 10007 +(t) (212) 230-8800 +(f (212) 230-8888 +robert.boone@wilmerhale.com +hillary.chutter-ames@wilmerhale.com +Ronald C. Machen +2100 Pennsylvania Avenue NW +Washington, DC 20037 +(t) (202) 663-6000 +(f (202) 663-6363 +ronald.machen@wilmerhale.com +Attorneys for JPMorgan Chase Bank, N.A. +-16- + + +Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 18 of 18 +CERTIFICATE OF SERVICE +I hereby certify that on May 30, 2023, the foregoing document, entitled "Defendant's +Fourth Supplemental Initial Disclosures to Plaintiff, Government of the United States Virgin +Islands," was served in accordance with the Federal Rules of Civil Procedure and/or the Local +Rules of the United States District Court for the Southern District of New York upon the attorneys +for the plaintiff in the above-entitled action by electronic mail. +DATED: +May 30, 2023 +Boston, +By: Is/ Felicia H. Ellsworth +-17- diff --git a/vision-fixhub/court-05/72f6f5353edc05fec524c830bec8b544c50d5237c5797df36ae2997e2d0d475c.receipt.json b/vision-fixhub/court-05/72f6f5353edc05fec524c830bec8b544c50d5237c5797df36ae2997e2d0d475c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6829228c5e2557eba08ee54759d707b28ef87ece --- /dev/null +++ b/vision-fixhub/court-05/72f6f5353edc05fec524c830bec8b544c50d5237c5797df36ae2997e2d0d475c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -228, + "dataset": "marble-joined", + "doc_id": "72f6f5353edc05fec524c830bec8b544c50d5237c5797df36ae2997e2d0d475c", + "engine": "marble-apple-vision", + "event_count": 20, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "eb35f0ad86b6b81467fcadb68672f86ef65135a60d989f5b321585c7137f3aef", + "output_sha256": "728aaee6aa64b4aa4ce51f449af1b3f9b1fac8f85c460ef24929217e37e12f36", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/73180711a1989eb25fa2185dbc05d3b006b1ebe2e74b6e386eb7f77037f5f39e.md b/vision-fixhub/court-05/73180711a1989eb25fa2185dbc05d3b006b1ebe2e74b6e386eb7f77037f5f39e.md new file mode 100644 index 0000000000000000000000000000000000000000..814c4e3542377d9e7a64c39bda13460dbf3b72f1 --- /dev/null +++ b/vision-fixhub/court-05/73180711a1989eb25fa2185dbc05d3b006b1ebe2e74b6e386eb7f77037f5f39e.md @@ -0,0 +1,1466 @@ +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 1 of 35 + + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 2 of 35 +May 2010 +JPMORGAN CHASE & Co. + +JPM-SDNYLIT-00275091 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 3 of 35 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 4 of 35 +INTRODUCTION +Our integrity and reputation depend on our ability to do the right thing, even when +it's not the easy thing. The Code of Conduct is a collection of rules and policy +statements intended to assist employees and directors in making decisions about +their conduct in relation to the firm's business. The Code is based on our +fundamental understanding that no one at JPMorgan Chase should ever sacrifice +integrity -- or give the impression that they have -- even if they think it would +help the firm's business. +Each of us is accountable for our actions, and each of us is responsible for +knowing and abiding by the policies that apply to us. Managers have a special +responsibility, through example and communication, to ensure that employees +under their supervision understand and comply with the Code and other relevant +policies. +You can look to the Code of Conduct to guide your decisions in a variety of +circumstances. However, no rulebook can anticipate every situation. Ultimately, +the personal integrity and honesty of every JPMorgan Chase employee define the +character of our company. Never underestimate the importance of your own +ethical conduct to the business and success of JPMorgan Chase. + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 5 of 35 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 6 of 35 +TABLE OF CONTENTS +1. ADMINISTRATION OF THE CODE OF CONDUCT +1.1. Persons subject to the Code of Conduct.. +1.2. Consultants, agents and temporary workers +1.3. Consequences of violating the Code ... +1.4. Questions about the Code..... +1.5. Obligation to report violations ….......... +1.6. Current version of the Code... +1.7. Training and Affirmation.... +2. DIVERSITY.. +3. CONFIDENTIAL INFORMATION, PUBLIC COMMUNICATION, AND DATA PRIVACY +3.1. Information about the firm, its customers, its employees, and others.. +3.2. Prior employer's confidential information and trade secrets ..... +3.3. Special rules regarding customer information, personal information and +data privacy legislation... +Publications, speeches, internet postings, and other communications relating to JPMorgan +Chase's business.. +4. INSIDE INFORMATION AND THE POLICY ON INFORMATION BARRIERS +4.1. Inside Information. +4.2. The Policy on Information Barriers and other restrictions on sharing information +5. OTHER BUSINESS CONDUCT +5.1. Assets of the firm +5.2. Intellectual property +5.3. +Telephones, e-mail, internet, and other electronic communications devices +5.4. +Internal controls, record-keeping, and reporting... +5.5. +Limits of your authority +5.6. +Business relationships. +5.6.1. Fair dealing; respect for human rights.. +5.6.2. Customer, supplier, and employee relationships +5.7. +Money laundering and the USA PATRIOT Act +5.8. Conduct with competitors; tying of products.. +5.9. Bribery and the Foreign Corrupt Practices Act. +5.10. International boycotts and economic sanctions +5.11. Post-employment responsibilities…...... +5.12. Other professional obligations of some employees +6. OUTSIDE ACTIVITIES, GIFTS, AND OTHER POTENTIAL CONFLICTS OF INTEREST +6.1. Personal relationships. +6.2. Personal finances... +6.3. Outside business and not-for-profit activities; outside employment. +6.3.1. +General..... +6.3.2. +Required pre-clearance of outside activities +2 +2 +3 +5 +. 6 +6 +7 +7 +..7 +8 +8 +9 +10 +10 +10 +11 +11 +11 +11 +12 +12 +5 5 +13 +. 13 +. 13 +13 +14 +. 14 +14 +. 15 + +JPM-SDNYLIT-00275095 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 7 of 35 +6.4. Political Activities.. +6.4.1. Political campaign activities and contributions by employees .... +16 +.16 +6.4.2. Political contributions and related activities by JPMorgan Chase +6.5. Accepting gifts, meals, and entertainment from customers, suppliers, and others doing business +or seeking to do business with JPMorgan Chase. +6.5.1. What you may accept..... +6.5.2. What you may not accept .. +6.5.3. Approval of nonconforming gifts +6.5.4. Required reporting of gift..... +6.6. Providing gifts, meals or entertainment +6.7. Solicitations at work; charitable contributions by the firm +21 +21 +7. PERSONAL SECURITIES AND OTHER FINANCIAL TRANSACTIONS +7.1. General investment principles.... +7.2. Persons and accounts subject to policies +7.3. Trading in JPMorgan Chase securities.. +.21 +21 +.22 +.22 +22 +.23 +24 +.24 +Definitions and Examples + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 8 of 35 +1. ADMINISTRATION OF THE CODE OF CONDUCT +The Code of Conduct (the "Code") sets forth certain minimum expectations that JPMorgan Chase has for +you. You are expected to conduct the firm's business in full compliance with both the letter and the spirit +of the law, the Code, and any other policies and procedures that may be applicable to you. The "firm" +and "JPMorgan Chase" as used throughout the Code mean JPMorgan Chase & Co. and all its direct and +indirect subsidiaries. +The Code is intended to provide general guidance regarding your conduct as an employee or director of' +JPMorgan Chase. Note that other policies and procedures are listed at the end of many Code sections, +with an electronic link on the intranet edition of the Code. These listed items provide more detailed +information about the relevant subject and may include additional requirements with which you must +comply. However, these lists are not an exhaustive consideration of all policies and procedures that may +be applicable to you, and you are responsible for knowing which policies and procedures (whether or not +listed here) apply to you, and for understanding and complying with them. You should refer to these +documents where appropriate. Consult any of the persons listed in Section 1.4 if you have questions. +On the Code home page (and at the end of the printed edition of the Code), you will find a section of +Definitions and Examples. +Any waiver of the provisions of this Code for an executive officer or a director must be made by the +Board of Directors and will be promptly disclosed to JPMorgan Chase & Co. stockholders. +The Corporate Secretary may provide interpretations of the Code, in consultation with the General +Counsel where appropriate. +The Code of Conduct does not create any rights to continued employment and is not an employment +contract. +1.1. Persons subject to the Code of Conduct +The Code applies to employees and directors of JPMorgan Chase & Co. and its direct and indirect +subsidiaries. Employees of joint ventures and entities in which JPMorgan Chase holds private equity +vestments are not subject to the Code except to the extent the Legal and Compliance Departme +termines otherwise. The provisions of the Code described in Section 5.11 also apply to form +employees. +complying with these laws and policies. +1.2. Consultants, agents and temporary workers +1 general, consultants, agents and temporary workers are expected to comply with the underlyir +rinciples of the Code. Specific arrangements with such persons will vary depending on their relationsh + +JPM-SDNYLIT-00275097 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 9 of 35 +to the firm. Consult your Compliance Officer or your Code Specialist if you have questions about your +obligations or those of others. +1.3. Consequences of violating the Code +Compliance with the Code and with other policies and procedures applicable to you is a term and +condition of employment by JPMorgan Chase. Violations of any laws that relate to the operation of our +business, the Code, or other applicable policies and procedures, or failure to cooperate as directed by the +firm or to provide complete and accurate information in connection with any internal or external +investigation or litigation matter relating to the firm's business, may result in corrective action, up to and +including immediate termination of employment. The firm will take all reasonable actions to enforce the +Code. In cases where a violation of the Code could cause the firm irreparable harm, it may seck injunctive +relief in addition to monetary damages. +1.4. Questions about the Code +Each line of business and support group has been assigned at least one "Code Specialist," generally a +Compliance Officer, to act as a resource for all employees in the area on Code-related issues. Contact +information for these officers is included in the Code Specialists List, and employees can contact their +Code Specialist for assistance with any questions regarding the Code. +Employees who have questions about the Code or other policies and procedures, or about how a particular +rule applies in a specific situation, can also contact: +• their manager +• their local Compliance Officer +• the Legal and Compliance Department +• their Human Resources Business Partner or Employee Relations +• the Office of the Secretary +Contact information is included in the Code Contacts List. +The following lists some of the common situations in which you may have obligations under the Code +and refers you to the relevant section(s) of the Code. You should not use this list as a substitute for +familiarity with all provisions of the Code. +Situation +Unethical or illegal behavior: +You observe conduct by another employee, a supplier, a customer, or +another person doing business with the firm that you believe to be +unethical, illegal, or contrary to the Code of Conduct +Discriminatory or harassing conduct: +You experience or observe conduct that you believe violates the firm's +policies prohibiting employment discrimination or harassment. +Confidential information: +You wish to disclose confidential information about the firm, a +customer, a fellow employee, or another person or entity doing business +with the firm. +Publications: +You wish to write and publish a book, article, or other work relating to +the business of JPMorgan Chase. +Speaking engagements and public testimony: +Code Section +1.5 +2 +3 and 4 +3.4 +3.4 +2 + +JPM-SDNYLIT-00275098 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 10 of 35 +Situation +You wish to give a speech or provide testimony on a subject relating to +the firm's business. +Media inquiries: +You have received an inquiry from a member of the media on a subject +related to the firm's business, or in a situation in which you might be +seen as speaking for the firm. +Endorsements: +A customer, supplier, or other person or entity doing business with the +firm has asked you to provide an endorsement or testimonial. +Post-employment obligations: +You anticipate leaving JPMorgan Chase, and you are not certain what +continuing obligations you may have after your employment is ended +Potential conflict of interest: +You are in a situation that presents a potential confliet of interest or +appearance of a conflict of interest. +Outside business or other for-profit activities: +You wish to become involved with an outside business or to accept a +second job. +Outside not-for-profit activities: +You wish to become a director, trustee, or officer of a not-for-profit +organization. +Holding political office or other governmental position: +You wish to run for political office or accept appointment to any +governmental position. +Political activities: +You wish to become involved with a political campaign, lobbying +effort, or other political activity. +Gifts or entertainment offered or provided by persons doing +business with JPMorgan Chase: +You are offered or receive a gift from a customer, supplier, or other +party doing business with JPMorgan Chase. +Gifts to customers, suppliers, or others doing business with +JPMorgan Chase: +You wish to make a gift or extend an invitation to a person doing +business with JPMorgan Chase. +Charitable solicitations at work: +You wish to ask co-workers, customers, or suppliers to contribute to a +charitable cause with which you are involved. +Personal investment activity: +You, or a member of your family, are making personal investments that +may be subject to the firm's policies and procedures regarding personal +account trading. +Code Section +3.4 +3.4 +5.11 +6 +6.3 +6.3 +6.3 and 6.4 +6.4 +6.5 +6.6 +6.7 +7 +1.5. Obligation to report violations +You must promptly report any known or suspected violation of the Code, any internal firm policy, or any +law or regulation applicable to the firm's business, whether the violation involves you or another person +subject to the Code. In addition, you should report any illegal conduct, or conduct that violates the +3 + +JPM-SDNYLIT-00275099 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 11 of 35 +underlying principles of the Code, by any of our customers, suppliers, contract workers, business partners, +or agents. If something doesn't look right, say something. +Report violations as follows: +Matters involving harassment or discrimination must be reported to your HR Business Partner or +Employee Relations. +Matters involving fraudulent acts, including acts by third parties against the firm or personal +dishonesty by an employee, must be reported to the Global Security and Investigation +Department. +If you believe that an official at a high level of the firm is involved, report to the General Auditor. +All other matters should be reported to the Legal and Compliance Department. +If the persons to whom you report a violation are not responsive, or if there is reason to believe that +reporting to the person, anticate above i in Coopriate in apart, ular General you should contact the +To call the Global Security and Investigations Department, dial: +from within the U.S., Canada and Latin America (toll free) +1-888-282-5867 +from EMEA +all locations (toll call) ++44-207-325-0492 or 1110 (reverse charge calls accepted during normal business +hours) +UK, Belgium, Luxemburg, Spain, Switzerland, Italy, South Africa, Germany, Ireland, +and Russia (toll free) +00800 3247 5869 (confidential freephone) +all other EMEA locations (toll free) +44-207-325-0492 or 1110 (reverse charge calls accepted during normal busines +ours if toll free calls are not permitted from your dialing location +from Asia Pacific +all locations (toll call) ++852 2800 1656 or 8780 (reverse charge calls accepted during normal business +hours) +China, Hong Kong, Japan, Malaysia, South Korea, Singapore, Thailand, Taiwan, and +Australia (toll free) +800 5784 5784 (confidential international freephone) +all other Asia Pacific locations (toll free) ++852 2800 1656 or 8780 (reverse charge calls accepted during normal business +hours if toll free calls are not permitted from your dialing location) +You may also contact the Global Security and Investigations Department either +by mail: +from North America +from Asia Pacific +from all other locations +575 Washington Boulevard, Floor 07 +Jersey City, NJ 07310-1616 +168 +1 Road, Floor 19 +Singapore, 068912, Singapore +60 Victoria Embankment, Floor GR +4 + +JPM-SDNYLIT-00275100 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 12 of 35 +London, EC4YOJP, United Kingdom +or by e-mail: +from North America +from Asia Pacific +from all other locations +fraud.prevention.and.investigation@jpmchase.com +Gsi.apac@jpmorgan.com +Gsi.emea@jpmorgan.com +If you have a particular concern regarding accounting, internal accounting controls, auditing matters, or +financial reporting practices that you wish to bring to the attention of the Audit Committee of the Board +of Directors, you may do so by mail sent to: JPMorgan Chase & Co., Attention: Audit Committee +Chairman, c/o Global Security and Investigations Department at one of the addresses listed above, or by +calling the Global Security and Investigations Department at any of the telephone numbers listed above. +You may report your concerns anonymously, if you wish. We will respect the confidentiality of those +who raise concerns, subject to our obligation to investigate the concern and any obligation to notify third +parties, such as regulators and other authorities. We strictly prohibit retaliation against employees for the +good faith reporting of any actual or suspected violations of the Code. +You must immediately report to your Human Resources Business Partner or Employee Relations any +misdemeanor (other than a minor traffic violation), criminal charge, or arrest involving you personally, +whether it relates to the business of the firm or not. See HR's policy on Criminal Convictions, linked +below. +Employees in France are subject to other reporting provisions, which are included in either the +Compliance Manual (linked below) or the +Code of Conduct (available from Human Resources in +France). +1.6. Current version of the Code +The current edition of the Code is posted on the intranet. It may be amended from time to time, and all +amendments are effective immediately upon posting. It is your responsibility to review the Code from +time to time to ensure that you are in compliance. +1.7. Training and Affirmation +2. +DIVERSITY +JPMorgan Chase is committed to providing an inclusive and nondiseriminatory working environment in +ensuring implementation of this policy and maintaining a business environment free of harassment and +intimidation. +5 + +JPM-SDNYLIT-00275101 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 13 of 35 +Likewise, you may not unlawfully discriminate in your dealings with current or prospective customers +and suppliers. +The firm's Travel and Entertainment Policies preclude reimbursement from, or payment by, JPMorgan +Chase for membership in or expenses incurred at organizations with discriminatory practices. +3. +CONFIDENTIAL INFORMATION, PUBLIC COMMUNICATION, AND DATA +PRIVACY +We are all responsible for the safeguarding of confidential information, whether it is information +entrusted to us by our customers, information regarding JPMorgan Chase's businesses and activities, or +information about other employees. +3.1. +Information about the firm, its customers, its employees, and others +You may have access to confidential information related to the firm's business. Information related to the +firm's business includes information about the firm, as well as information related to the firm's customers, +counterparties, or advisory clients (all of which the Code refers to as customers), business partners, +suppliers, and your fellow employees. +You may not, either during your period of service or thereafter, directly or indirectly, use or disclose to +anyone any such confidential information, except as permitted by the Code and other policies applicable +You must observe the following principles when dealing with information relating to the firm's business: +(a) +Assume that information that you have about the firm and its business, or about its past, +present, or prospective customers, suppliers, and employees, is confidential, unless the +contrary is clear. +(b) +(c) +Treat all personal information about individuals as confidential. +Before sharing confidential information with others in the firm, be sure that you are +permitted to do so. Do not disclose confidential customer information to other employees +who are not involved with the transaction or service for which the information was +provided to the firm --- even if you believe the disclosure might be useful in the context +of other firm business --- unless you are authorized to do so. +(d) +Do not disclose confidential information to anyone outside the firm unless you are +authorized to do so. Where such disclosure is authorized, a confidentiality or privacy +agreement may be required; check with the Legal and Compliance Department. +(e) +If you are permitted to share confidential information, use your judgment to limit the +amount of information shared and disclose it only on a need-to-know basis in order to +provide the services we are engaged to provide. Ensure that the recipient knows the +information is confidential and has been instructed about restrictions on further use and +dissemination. +Comment or provide information on matters related to the firm's business only if it is part +of your job function or you are otherwise authorized to do so. +(g) +Protect confidential information when communicating electronically -- for instance, by e- +mail or through the internet. +(h) +Remember that all forms of communication are covered, including written, telephonic, +and electronic communications such as website chatrooms, e-mail, and instant +messaging. (See Section 3.4 for more on internet communications.) +6 + +JPM-SDNYLIT-00275102 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 14 of 35 +(i) Consult your manager or your Compliance Officer if you have any question about +whether information can be shared. +3.2. Prior employer's confidential information and trade secrets +Do not disclose to JPMorgan Chase, or use during your employment at JPMorgan Chase, any confidential +information or trade secret of a prior employer, unless the information or trade secret is then public +information through no action of your own. +3.3. +Special rules regarding customer information, personal information and data privacy +legislation +Each of us has a special responsibility to protect the confidentiality of information related to customers. +This responsibility may be imposed by law, may arise out of agreements with our customers, or may be +based on policies or practices adopted by the firm. Certain jurisdictions have regulations relating +specifically to the privacy of individuals and/or business and institutional customers. Various business +units and geographic areas within JPMorgan Chase have internal policies regarding customer and/or +employee privacy. You should be familiar with those that apply to you. Customer information should +never be disclosed to anyone inside or outside the firm except as permitted by law and in the proper +conduct of our business, where disclosure is required by legal process, or where the Legal and +Compliance Department otherwise determines it is appropriate. +3.4. +Publications, speeches, internet postings, and other communications relating to JPMorgan +Chase's business +You should not comment on or provide information relating to JPMorgan Chase's businesses, or to any +subject matter that relates to your job responsibilities or expertise at JPMorgan Chase, in public forums +unless you are specifically authorized to do so. The concept of "relating to JPMorgan Chase's +businesses" is broadly defined and generally includes anything related to the financial services industry; +the firm itself and its businesses; such matters as the firm's security, technology support, procurement +practices, legal/regulatory/compliance issues, ete.; and the firm's customers, employees, or vendors. +Just as with any other form of communication, you may not comment on or provide information relating +to JPMorgan Chase's business (as defined above), in an internet chat room, guest book, bulletin board, +blog, social or business networking site or similar forum unless you are specifically authorized to do so. +In no event may you disclose confidential information unless you are authorized to do so. You should not +comment in such a forum on any subject matter as to which you have knowledge or expertise by virtue of +your duties with the firm. These rules apply whether or not you have identified yourself as a JPMorgan +Chase employee. +Employees' postings on internet sites, including social and business networking websites, may include the +fact that the employee works at JPMorgan Chase, his/her job title, a general job description, and his/her +office location. However, such postings should not include any information related to the firm's business, +as defined above, including references to, or information regarding, specific clients, suppliers, projects, +transactions, and/or applications or technologies the employee may be involved with in connection with +his/her job at the firm. Note that employees should not post, seek, or provide recommendations, +endorsements, or referrals by or of other employees, customers, or vendors (current or former). +You should also be alert to situations, in publie speaking engagements, on the internet, and elsewhere, in +which you may be perceived as representing or speaking for the firm. You should not make any +7 + +JPM-SDNYLIT-00275103 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 15 of 35 +statements on behalf of JPMorgan Chase unless you are authorized to do so. Refer all media inquiries to +the Media Relations Office. +Public testimony (as an expert witness or otherwise), publications and speaking engagements relating to +the firm's business are subject to pre-clearance. Subpoenas, requests from law enforcement or regulatory +authorities, media inquiries, product advisory boards, and requests from customers or suppliers for +testimonials or endorsements should be handled in accordance with applicable procedures. Before +engaging in any of these activities, consult your Compliance Officer or your Code Specialist and the +relevant policies and procedures. +Additional information on employees' communications, and procedures for required pre-clearance of +certain types of communications, are included in the policy on Communication on Matters Relating to the +Company's Business. +If you will be paid for any of these activities, you will also need pre-clearance under Section 6.3.2 +(outside activities); consult your Code Specialist. +4. INSIDE INFORMATION AND THE POLICY ON INFORMATION BARRIERS +Buying or selling securities while in possession of material nonpublie information is prohibited, as is the +communication of that information to others. +4.1. Inside Information +If you are aware of inside information, +(a) +(b) +information, either for your own account or any account over which you exercise control, +alone or with others. +you may not pass along any inside information expressly or by way of making a +recommendation for the purchase or sale of such securities based upon inside +information. +"Inside information" is material, nonpublic information about the securities, activities, or financial +ondition of a corporation, public entity, or other issuer of securities. Material, nonpublic informatio +oncerning market developments may also be construed to be inside informatio +securities of an issuer but not to all securities of that issuer. +Information should be considered "nonpublic" unless it is clearly public. Information is deemed publie +once it has been publicly announced or otherwise disseminated in a manner that makes the information +available to investors generally. +Likewise, you may not buy or sell securities if you have knowledge of proposed customer trades, trades +›y JPMorgan Chase, or forthcoming research reports regarding those securities or the issuer of those +securities, and you may not pass along this information to others in any way +8 + +JPM-SDNYLIT-00275104 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 16 of 35 +These prohibitions are applicable no matter how you acquired the inside information. They are applicable +to the securities of JPMorgan Chase as well as to those of other companies. +These prohibitions do not apply to qualified transactions pursuant to certain planned acquisition or selling +programs, such as so-called 10b5-1 programs. These prohibitions also do not apply to legally permissible +transactions with the issuer of the securities, or with other persons having the same information you have +(a circumstance likely to be relevant only in the context of private securities). Before engaging in any +transactions you believe to be permissible under this paragraph, you must consult with your Compliance +Officer. +4.2. The Policy on Information Barriers and other restrictions on sharing information +The firm's Policy on Information Barriers refers to a system of information barriers (also known as +Chinese Walls) designed to limit the flow of inside information from areas that routinely have access to +such information, such as Investment Banking, Capital Markets, Commercial Lending, Credit, +Restructuring, and Mergers and Acquisitions ("insider areas"), to those areas that trade in or sell securities +or provide investment advice regarding securities, such as Sales, Trading, Research, and Asset +Management ("public areas"). The Policy on Information Barriers prohibits anyone in an insider area +from communicating inside information, however obtained, to anyone in a public area, subject to limited +exceptions approved by the relevant Compliance Officer. +In addition, some business areas within the firm require procedures that address more specifically the +information flows within those business areas. These are also referred to as information barriers (or as +Chinese walls). +Employees subjeet to the firm's Policy on Information Barriers, or to other information barriers designed +to meet specific business needs, are responsible for compliance with the provisions of applicable policies. +5. OTHER BUSINESS CONDUCT +We are all expected to conduct the firm's business in accordance with the highest ethical standards, +respecting the firm's customers, suppliers, and other business counterparties, dealing responsibly with the +firm's assets, and complying with applicable legal and regulatory requirements. +5.1. Assets of the firm +You are expected to protect the firm's assets as well as the assets of others that come into your custody. +The firm's assets include not only financial assets such as cash and securities and physical assets such as +files, reference materials and reports, computer software, data processing systems, computer programs, +and databases --- belongs to the firm. +The firm's assets should be used only for the conduct of the firm's business, except where reasonable +personal use is authorized by the Code or other applicable policies. +9 + +JPM-SDNYLIT-00275105 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 17 of 35 +5.2. Intellectual property +Any invention, discovery, development, concept, idea, process, or work related to the firm's business, +written or otherwise, whether or not it can be patented or copyrighted, that you develop alone or with +others during your employment with the firm (all of which are referred to as "Company Inventions") +belongs to the firm. If a Company Invention is something that can be copyrighted and you create it as a +part of your job with the firm or because the firm asks you to create it, it is a "work made for hire." The +firm is not required to acknowledge your role in the creation of any Company Inventions or to have your +permission to modify, expand, or benefit from it. +As a condition of your employment, you assign exclusively to the firm all of your right, title and interest +in Company Inventions. You further agree to assist the firm in obtaining for its own benefit intellectual +property rights, including any patents and copyrights, in the Company Inventions and agree to deliver any +documents that may be requested to assure, record or perfect your assignment of the Company Inventions +to the firm. +5.3. Telephones, e-mail, internet, and other electronic communications devices +Telephones, electronic mail (e-mail) systems and other electronic communications devices provided by +JP +Chase, whether in the workplace or elsewhere, are the property of the firm and should be used +for business purposes; however, reasonable personal use is permitted, consistent with the Code and all +other policies of the firm. You are expected to use common sense and good judgment in determining +what is and what is not "reasonable personal use." +The use of e-mail, the firm's intranet and the internet must conform to the policies of JPMorgan Chase. +E-mail and internet systems may be used to transmit or provide access to confidential information only +when such information is adequately protected and transmitting such information is necessary for +business purposes. +Among other things, the following are prohibited in electronic communications: +statements, which, if made in any other forum, would violate any of our policies, +including policies against discrimination and harassment; participation in impermissible +or illegal activities (such as gambling or the use and sale of controlled substances); and +the misuse of confidential information. +(b) +accessing, downloading, uploading, saving, or sending sexually oriented or other +offensive materials. +JPMorgan Chase considers all data and communications transmitted through, received by, or contained in +using such resources. +5.4. Internal controls, record-keeping, and reporting +Internal accounting controls and record-keeping policies have been established in order for JPMorgar +chase to meet both legal and business requirements. You are expected to maintain and adhere to thes +controls and policies. +The falsification of any book, record, or account relating to the business of JPMorgan Chase, its +customers, or its suppliers, or to the disposition of assets of the firm, its customers, or its suppliers +10 + +JPM-SDNYLIT-00275106 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 18 of 35 +(including without limitation the submission of any false personal expense statement, claim for +reimbursement of a non-business expense or a false employee record or claim under an employee benefit +plan), is prohibited. +The firm's record-keeping policies include policies for records and document retention and destruction. +Notwithstanding any other provision of document retention policies, no document or record may be +destroyed if you have been advised or otherwise should recognize that it may be relevant to a pending or +threatened legal or regulatory proceeding, except in accordance with procedures approved by the head of +the Litigation Group in the Legal Department or one of his/her direct reports. +It is of critical importance that JPMorgan Chase's filings with regulatory authorities be accurate and +timely. Information provided to those involved in preparation of the firm's disclosures to regulators and +investors should be complete, accurate, and informative. +5.5. Limits of your authority +Your authority to act on behalf of JPMorgan Chase is limited by various laws, regulations, corporate +charters, by-laws, and board resolutions, and by internal policies and procedures. You may not sign any +documents, or otherwise represent or exercise authority, on behalf of any JPMorgan Chase entity unless +you are specifically authorized to do so. Be aware of limits on your authority and do not take any action +that exceeds those limits. +Delegation of authority, where permissible under corporate policies and otherwise appropriate, should be +reasonably limited in scope and subject to appropriate ongoing oversight. +5.6. Business relationships +5.6.1. Fair dealing; respect for human rights +In addition to strict compliance with applicable laws, rules, and regulations, JPMorgan Chase expects its +employees and directors to conduct themselves in accordance with general standards of ethical behavior. +In particular: +(a) +(b) +You should always endeavor to deal fairly and in good faith with the firm's customers, +suppliers, competitors, business partners, regulators, and employees. It is our policy not +to take unfair advantage of others through manipulation, concealment, abuse of +privileged information, misrepresentation of material facts, or any other unfair dealing +practice. +You should observe the firm's Human Rights Statement, where it is applicable to your +business dealings. +5.6.2. Customer, supplier, and employee relationships +During your employment you may not, directly or indirectly: +solicit for a competitor, or divert or attempt to divert from doing business with JPMorgan +Chase, any customer, identified prospective customer, supplier, or other person or entity +with whom JPMorgan Chase has or had a business relationship. +(b) +solicit JPMorgan Chase's employees for employment or engagement elsewhere or solicit +or induce any employee, consultant, independent contractor, agent, or supplier to leave +JPMorgan Chase. +11 + +JPM-SDNYLIT-00275107 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 19 of 35 +5.7. Money laundering and the USA PATRIOT Act +JPMorgan Chase has established policies, procedures and internal controls designed to assure compliance +with international laws and regulations regarding money laundering and terrorist financing, including +relevant provisions of the Bank Secrecy Act and the USA PATRIOT Act in the United States and similar +legislation in other countries. You should be familiar with, and comply with, these policies, procedures +and controls. You should also understand your obligations to: +(a) know your customers and your customers' use of the firm's products and services. +(b) +get proper training if you are identified as being in a job that poses a risk of money +laundering or terrorist financing. +(c) +be alert to and report unusual or suspicious activity to the designated persons within your +line of business or region, including your Compliance Officer or Risk Manager +responsible for anti-money laundering compliance. +5.8. Conduct with competitors; tying of products +United States antitrust laws and the laws of many other jurisdictions prohibit certain conduct that is +deemed collusive or anti-competitive, such as agreements among competitors to affect prices of goods or +services (price fixing), reduce competition in a bidding process (bid rigging), divide up customers or +markets, limit availability of products or services, or refuse to deal with a specific business counterparty. +If your work involves interacting with a competitor of JPMorgan Chase or if you communicate about +pricing with parties other than clients, you should be familiar with relevant firm policies. +"Tying" arrangements, under which the availability or price of one product is conditioned on the +customer's purchase of another product, are illegal under some circumstances. United States Federal laws +govern tying arrangements involving bank subsidiaries of JPMorgan Chase & Co. You are responsible for +being familiar with these rules if they apply to you. +If you have any question as to whether any conduct may be collusive or anti-competitive, or may violate +the prohibitions against tying, consult with the Legal and Compliance Department. +5.9. Bribery and the Foreign Corrupt Practices Act +Federal and other laws in the United States and the laws of many other countries prohibit giving, offering, +or promising, directly or indirectly, anything of value to corruptly influence any government official, +including any officer of a political party or a candidate for political office, for the purpose of obtaining or +retaining business or to secure an improper advantage (such as favorable regulatory or judicial action). +Offering or paying such remuneration to any such person, either directly or through any intermediaries +such as agents, attorneys or other consultants, is strictly prohibited. +Tradition, even i not ace any such payanis in pancian with try ibusines decision or +5.10. International boycotts and economic sanctions +12 + +JPM-SDNYLIT-00275108 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 20 of 35 +The U.S. economic sanctions regulations prohibit U.S. persons, including U.S. financial institutions and +their foreign branches and non-U.S. affiliates, from exporting financial services to certain foreign +governments and their specially designated nationals named by the Office of Foreign Assets Control +(OFAC). These regulations also require that assets of these governments and persons be frozen. All +JPMorgan Chase branches and subsidiaries are required to establish policies and procedures to ensure that +their customers (and potential customers) are not on the OFAC list. You should be familiar with the +policies and procedures that apply to you. +5.11. Post-employment responsibilities +As a condition of continued employment with JPMorgan Chase, employees will have certain +responsibilities after their employment with JPMorgan Chase terminates. These responsibilities include +an obligation to return all firm assets in their possession, maintain the confidentiality of information, +refrain from insider trading based on information obtained in the course of employment by JPMorgan +Chase, and, if requested, assist JPMorgan Chase with investigations, litigation, and the protection of +intellectual property relating to their employment. Senior-Level Employees have additional obligations +for one year after they leave JPMorgan Chase, including prohibitions on the solicitation and hiring of +JPMorgan Chase employees and solicitation of certain customers. Certain employees are subject to other +post-employment restrictions. You are responsible for knowing which post-employment restrictions and +requirements apply to you. +5.12. Other professional obligations of some employees +Some employees have additional obligations relating to their positions with the firm, including employees +who are considered to be finance professionals, certain employees acting as attorneys for the firm, and +certain officers in the Investment Bank and Asset Management. If you are subject to any of these +additional requirements, you should be familiar with and comply with them. +6. +OUTSIDE ACTIVITIES, GIFTS, AND OTHER POTENTIAL CONFLICTS OF +INTEREST +Employees must never permit their personal interests to conflict with or to appear to conflict with the +interests of the firm. When faced with a situation involving a potential conflict, ask yourself whether +public disclosure of the matter could embarrass JPMorgan Chase or you, or would lead an outside +observer to believe a conflict exists, whether or not one actually does. You must disclose to the Office of +the Secretary all potential conflicts of interest, including those in which you may have been placed +inadvertently due to either business or personal relationships with customers, suppliers, business +associates, or competitors of JPMorgan Chase, or with other JPMorgan Chase employees. +6.1. Personal relationships +In general, you may not act on behalf of JPMorgan Chase in any transaction or business relationship +involving yourself, members of your family, or other persons or organizations with which you or your +family have any significant personal connection or financial interest. These matters should be handled by +an authorized unrelated employee. +You may not engage in self-dealing or otherwise trade upon your position with JPMorgan Chase or accept +or solicit from a client or supplier any personal benefit that is not generally available to other persons or +that is made available to you due to your position with JPMorgan Chase (except in accordance with our +policies regarding the occasional acceptance of gifts). +13 + +JPM-SDNYLIT-00275109 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 21 of 35 +Negotiating with JPMorgan Chase on behalf of others with whom you or your family have a significant +connection should be avoided if there is a risk that your involvement would be perceived as self-dealing +or trading upon your position with the firm. +Hiring or working with relatives, or someone with whom you have a romantic relationship, is subject to +specific restrictions. You should be aware of those limitations if they apply to you. +6.2. Personal finances +Because of the nature of our business, any improper handling of your personal finances could undermine +your credibility and that of JPMorgan Chase. Also, a precarious personal financial position might appear +to influence actions or judgments you make on behalf of JPMorgan Chase. +You may not borrow money (other than nominal amounts) from or lend money to other employees, +customers or suppliers, or act as a guarantor, co-signer, or surety or in any other similar capacity for +customers, suppliers, or other employees. You should borrow only from reputable organizations that +regularly lend money. If you borrow from any financial institution, the loan must be obtained on nonpreferential terms. +In general, you may not participate in any other personal financial transactions with fellow employees, +customers, or suppliers. This prohibition includes shared investments (unless they are either widely held +or held pursuant to firm sponsored co-investment plans) and investment clubs. +The foregoing limitations do not apply to: +(a) +borrowing from, or acting as guarantor, co-signer, or surety for, relatives or close +personal friends (generally, friendships formed outside the context of any JPMC business +relationship). +(b) +borrowing on non-preferential terms from a customer that is in the financial services +business. +(c) making consumer credit purchases on non-preferential terms from a customer or supplier +in the normal course of that customer/supplier's business. +6.3. Outside business and not-for-profit activities; outside employment +6.3.1. General +Your outside activities must not reflect adversely on JPMorgan Chase or give rise to a real or apparent +conflict of interest with your duties to the firm. You must be alert to potential conflicts of interest and be +aware that you may be asked to discontinue any outside activity if a potential conflict arises. You may +not, directly or indirectly: +(a) accept a business opportunity from someone doing business or seeking to do business +with JPMorgan Chase that is made available to you because of your position with the +firm. +(b) +take for yourself a business opportunity belonging to the firm. +(c) engage in a business that competes with any of the firm's businesses. +In general, employees may not work for, or serve as a director or officer of or adviser to, a competitor of +the firm. Competitors include unrelated financial services companies of any kind, and others engaged in +any business the firm is involved in, such as banks, asset managers, depository institutions, credit unions, +lenders, investment banks, insurers, insurance agencies, and securities brokers, dealers, and underwriters. +Employees should also not invest in a competitor (other than investments in securities of publicly traded +companies). +14 + +JPM-SDNYLIT-00275110 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 22 of 35 +Outside activities must not interfere with your job performance or require such long hours as to affect +your physical or mental effectiveness. Your job at JPMorgan Chase should always be your first work +priority. +You may accept appointments as a personal fiduciary only for family members and close personal friends. +However, you may not act as a personal fiduciary for a personal friend if the friendship developed in the +context of' a JPMorgan Chase customer relationship. +6.3.2. Required pre-clearance of outside activities +Pre-clearance is required for certain outside activities by employees, as described below. +1. Outside business activities +Subject to the exclusions listed below, you are required to pre-clear: +any outside activity for which you will be paid, including a second job and any +paid service to a not-for-profit organization. +whether or not you will be paid, any affiliation with another business as a +director, officer, advisory board member, general partner, owner, consultant, +holder of 5% or more of the business' voting equity interests, or in any similar +position. +However, you are not required to pre-clear the following activities under this Section (although +these matters may be subject to clearance or reporting requirements of your business unit or of +other sections of the Code): +(a) +certain types of appointments specifically excluded from Section 6.3.2 by the +Office of the Secretary because they are undertaken at the request of JPMorgan +Chase in the normal course of a business in which the firm is routinely engaged. +(b) +any unpaid affiliation with a trade association, professional association, or other +such organization related to your position at JPMorgan Chase (however, if the +organization is involved in lobbying activities relating to the business of the firm +and you are either (i) an executive officer or board member of the organization, +or (ii) directly involved in the government relations activities of the organization, +you should discuss the affiliation with the Government Relations Department in +(c) +(d) +(e) +unpaid positions with co-op boards, condominium associations, and similar +entities the sole business of which is to hold title to and/or manage real property +in which you can or do reside. +unpaid positions with holding companies, trusts, or other non-operating entities +established solely for purposes of your or your family's estate or tax planning or +to hold your or your family's real estate or other investments that would not +otherwise require pre-clearance under this Section 6.3.2. +an unpaid position on the customer advisory board of a JPMorgan Chase +vendor/supplier that is approved in accordance with Section 3.4 and the policy on +Communication on Matters Relating to the Company's Business. +15 + +JPM-SDNYLIT-00275111 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 23 of 35 +2. Not-for-profit activities +Unpaid not-for-profit activities generally do not require pre-clearance. However, employees are +required to pre-clear any board or official position with a not-for-profit entity if: +(a) +the not-for-profit entity is a customer of the firm, other than for routine branch +banking services. +(b) +you have been requested to serve in that capacity by a customer or supplier of +your business unit. +(C) +your service would otherwise present a conflict of interest or the appearance of a +conflict of interest. +As noted above, positions with trade associations, professional associations, or other such +organizations related to your position at JPMorgan Chase need not be pre-cleared. +3. Governmental activities +You are required to pre-clear any government position, whether paid or unpaid, elected or +appointed, including as an elected official and as a member, director, officer, or employee of a +governmental agency, authority, advisory board, or other board (a public school or library board, +for example). You must obtain pre-clearance before becoming a candidate for elective office. +Procedures and forms for pre-clearance of these activities are available in the JPMorgan Chase +Procedures and Forms for Pre-Clearance of Outside Activities. You must seek a new clearance for a +previously approved activity whenever there is any material change in relevant circumstances, whether +arising from a change in your job with JPMorgan Chase or in your role with respect to that activity or +organization. You must also notify the Office of the Secretary when any approved outside activity +terminates. +Note that in addition to complying with the outside activity pre-clearance requirements under the Code, +employees must also comply with any other applicable clearance or reporting requirements, including the +supplemental personal trading policies linked at Section 7.5 and any additional reporting requirements +applicable to registered employees and those in designated functions. +Note also that publications and speaking engagements relating to the business of JPMorgan Chase must +be pre-cleared under Section 3.4 of the Code. +6.4. Political Activities +6.4.1. Political campaign activities and contributions by employees +When acting as a fundraiser for a candidate or political event, be certain that your activities cannot be +villed as entered of suppers. Contach the Gover Chen eatin y parent for ichier guidance +on such activity. +(Note that running for public office is covered by Section 6.3.2.) +16 + +JPM-SDNYLIT-00275112 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 24 of 35 +Soliciting others. Employees may not contact other employees during work hours or on firm premises to +solicit political contributions or volunteer political activity (including "grassroots" activity such as +encouraging others to contact elected representatives regarding specific legislation). Employees may not +use firm resources (stationery, e-mail or phones, facilities, client or employees lists, etc.) to contact +anyone, including employees, customers and vendors, for these purposes at any time. These prohibitions +do not apply to solicitations by the JPMorgan Chase Political Action Committees (the PACs) or to +candidate events, fundraisers, and other activities organized by Government Relations and approved by +Legal & Compliance. Any other exceptions to these prohibitions require the prior approval of both +Government Relations and the Government Entities Compliance Group of the Legal and Compliance +Department. +Political contributions. You have the right to participate in the political process by making personal +contributions from personal funds, subject to applicable legal limits. However, you cannot be reimbursed +or otherwise compensated by JPMorgan Chase for any such contribution. +Certain business units (for example, Tax Exempt Capital Markets, Investment Management, and others +that sell products and services to government entities) may have additional policies regarding employees" +personal contributions; you are responsible for being aware of, and complying with, any rules applicable +to your business unit. +Additionally, you must contact the Government Relations Department or your local Compliance Officer +with respect to a personal political contribution that could violate, or create the appearance of a violation +of, the Foreign Corrupt Practices Act or local law. (See Section 5.9 for a discussion of the Foreign +Corrupt Practices Act and the firm's Anti-Corruption Policy.) Employees need to be especially sensitive +when giving to officials who are part of the decision-making process with respect to any matters relating +to the firm. +6.4.2. Political contributions and related activities by JPMorgan Chase +Political contributions and gifts. It is improper to offer or give anything to a public official, either directly +or through an intermediary, in an effort to secure an advantage that would not have been granted if the +offer or gift had not been made. In the U.S., political contributions by corporate entities are strictly +regulated by laws at the federal, state and local levels. These laws often prohibit or limit direct monetary +contributions made from corporate funds (such as a contribution check or purchase of fundraising event +tickets) as well as in-kind contributions (such as the use of corporate facilities or staff, and even the +granting of loans or other products at preferential rates). Local law in jurisdictions outside the U.S. can +also impose restrictions. Therefore, both within and outside the U.S., +all requests for firm support (either through monetary or in-kind contributions) of +political events, political candidates and their campaigns, political parties, or political +committees must be pre-approved and processed by the Government Relations +Department. +(b) +political contributions proposed to be made by or on behalf of the firm must be precleared by the Government Relations Department. +(c) +all gifts to governmental officials to be made by or on behalf of the firm (including items +of value, transportation, lodging, meals, entertainment, and services, and including +invitations to non-profit or other special events for which the firm has paid) must comply +with rules applicable to the relevant jurisdiction and with JPMorgan Chase's policies. +Note that many jurisdictions prohibit or restrict such gifts. For information on gifts to +officials in the United States, see Government Entities Compliance (GEC); for +information on gifts to officials outside the U.S., see the Anti-Corruption Policy (which +17 + +JPM-SDNYLIT-00275113 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 25 of 35 +covers the Foreign Corrupt Practices Act). Contact the local Compliance unit in the +relevant jurisdiction(s) for further guidance. +Lobbying by or on behalf of JPMorgan Chase. All lobbying activities, including the retention of outside +lobbyists, must be pre-cleared through the Government Relations Department. Note that the federal +government and each state has its own definitions and regulations regarding lobbying of governmental +employees, and what might seem like a simple meeting could trigger a reporting requirement; if in doubt, +contact Government Relations. +6.5. +Accepting gifts, meals, and entertainment from customers, suppliers, and others doing +business or seeking to do business with JPMorgan Chase +A gift may take many forms. For the purposes of the Code, the term "gift" includes anything of value for +which you are not required to pay the retail or usual and customary cost. A gift may include meals or +refreshments, goods, services, tickets to entertainment or sporting events, or the use of a residence, +vacation home, or other accommodations. +Note that, where one of the firm's business units or groups has a business/"client" relationship with +another (e.g., trade executions by an IB desk for clients of another IB desk or an AM sales group) or +where one unit or group serves a control function for another (e.g., Legal & Compliance, Audit, Risk +Management, Operations), gifts between the two units/groups, or between individuals in the two +units/groups, are covered by the gift policies of this Section 6.5 (in addition to any other policies that may +be applicable to such units/groups). +Gifts given by others to members of your family, to those with whom you have a close personal +relationship, and to charities designated by you, are considered to be gifts to you for purposes of the +Code. +You may never, except as provided in the Code: +(a) solicit, for yourself or for anyone else (other than the firm), or accept anything of value +from anyone doing business with the firm. +solicit, for yourself or for anyone else (other than the firm), or accept anything of value +(c) +from anyone in return for any business, service, or confidential information of the firm. +solicit, for yourself or for anyone else, or accept anything of value, directly or indirectly +(other than bona fide salary, wages, awards, and fees paid by or to the firm), from anyone +in connection with the business of the firm, either before or after a transaction is +discussed or consummated. +Note that the restrictions in this section 6.5 are not intended to apply to gifts based on obvious family +relationships (such as your parents, children, or spouse) or close personal friendships developed outside +the context of a JPMorgan Chase customer or vendor relationship, where the circumstances make it clear +that it is the relationship rather than the firm's business that is the motivating factor. +You are responsible for being familiar with any additional restrictions that may be applicable to your +business unit. +6.5.1. What you may accept +Acceptance of gifts of any kind (including entertainment and hospitality) from any customer, supplier, or +other party doing or seeking to do business with JPMorgan Chase (including identified prospective +customers) is generally prohibited. However, subject to the prohibitions in Section 6.5.2 and to any +18 + +JPM-SDNYLIT-00275114 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 26 of 35 +more restrictive policies vour business unit may have, the following gifts may be accepted on +infrequent occasions from such a person if it is clear that the person is not trying to influence or +reward you inappropriately in connection with any business decision or transaction and the gift is +unsolicited +(a) +(b) +(c) +(d) +(e) +(g) +gifts having a retail value not exceeding U.S. $100 (or such lesser amount as is +established by your local Compliance unit) that are given on an occasion when gifts are +customary (the year-end gift-giving season, or on the occasion of a promotion or +retirement, for example; note that gifts given in appreciation for good service, or as +thanks for our business, are not permitted). +advertising or promotional material having a retail value not exceeding U.S. $100 (or +such lesser amount as is established by your local Compliance unit), such as pens, +pencils, note pads, key chains, calendars, and similar items. +discounts and rebates on merchandise or services that are offered to the general public, or +to all employees under a plan negotiated by JPMorgan Chase. +customary mementos at closing dinners, permitted golf outings, and similar functions. +civic, charitable, educational, or religious organization awards for recognition of service +and accomplishment having a retail value not exceeding U.S. $100 (or such lesser +amount as is established by your local Compliance unit). +meals, refreshments, and entertainment in the course of a meeting or other occasion, +provided: +(i) +the purpose is business-related, +your host is present, +your attendance is related to your duties with JPMorgan Chase, +the level of expense is reasonable and customary in the context of your business +and the relationship with the host, and +the frequency of such invitations from one host is not excessive. +If you have questions about whether a specific invitation may be accepted under this item +--- whether, for example, it is business-related, or reasonable and customary in the +context of your business with the host --- discuss it with your Code Specialist or your +gifts of food or beverage items that are not casily returned, if they are: +given on an occasion when gifts are customary (on a birthday or major holiday, +or on the occasion of a promotion or retirement, for example; note that gifts +given in appreciation for good service, or as thanks for our business, are not +permitted), +not extravagant, and +shared among members of your business unit. +If you have questions about whether a gift of food or beverage items is extravagant, +diseuss it with your manager, your Code Specialist, or your Compliance Officer. +Where this Section refers to "a retail value not exceeding U.S. $100," the relevant Compliance unit will +determine the approximate equivalent in local currency for use in jurisdictions outside the U.S. +Whenever you receive a gift, or an offer of a gift, that is not specifically permitted by this Section 6.5.1, +make every effort to refuse or return it. If that isn't possible, notify your Compliance Officer or your +Code Specialist to discuss how to deal with the gift. +19 + +JPM-SDNYLIT-00275115 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 27 of 35 +6.5.2. What you may not accept +Except as approved pursuant to Section 6.5.3, you may not accept the following from any current or +identified prospective customer, supplier, or other party doing business with JPMorgan Chase: +(a) +gifts of cash or cash equivalents (such as gift certificates, gift checks, or securities), in +(b) +(c) +(d) +(e) +(f) +any amount. +discounts not available to the general public or to all employees under a plan negotiated +by JPMorgan Chase. +gifts to be delivered in installments. +bequests or legacies. +invitations to parties, sports outings, and similar events solely for groups of more than ten +JPMorgan Chase employees sponsored by parties that do business with JPMorgan Chase, +including golf or other sports or similar outings, year-end parties, group dinners, or +departmental entertainment, unless they have been approved in writing by a member of +the Executive Committee or an officer who reports directly to an Executive Committee +member, with a copy to your Code Specialist. +travel or accommodation expenses, unless they have been approved in writing by a +member of the Executive Committee or an officer who reports directly to an Executive +Committee member, with a copy to your Code Specialist (travel and accommodations are +not considered gifts and may be accepted if they are agreed as part of a business +transaction between the party providing the travel or accommodations and JPMorgan +(g) +tickets for sports competitions, concerts, or other events for your personal use, other than +as permitted under Section 6.5.1, whether you pay for them or not. +6.5.3. Approval of nonconforming gifts +An Executive Committee member, your Code Specialist, and the Office of the Secretary together may +approve, on a case-by-case basis, the acceptance of a gift that is not specifically permitted under Section +6.5.1, or that is prohibited under Section 6.5.2. Any such approval must be in writing and pursuant to full +written disclosure of all relevant facts, including the name of the donor, the circumstances surrounding +the offer and acceptance, the nature and approximate value of the gift, and the reason why it cannot or +should not be returned. (Use the Nonconforming Gift Approval Request and Report Form filed under +Section 6.5.4, signed by each of the Executive Committee member, your Code Specialist, and the Office +of the Secretary, for this purpose.) +6.5.4. Required reporting of gifts +You are required to file a Nonconforming Gift Approval Request and Report Form with respect to: +(a) +any gift that is not permitted under Section 6.5.1 or that is listed in Section 6.5.2, if the +gift has not been refused or returned (even if acceptance has been approved in accordance +with Section 6.5.3). (Note that you must refuse or return any such gift unless it has been +specifically approved in writing as specified in Section 6.5.3; the Nonconforming Gift +(b) +Approval and Report Form should be used to evidence that approval.) +the offer or receipt of any gift that is so lavish it could give rise to an inference of +impropriety, whether or not you refuse or return it. +(c) +the offer or receipt of frequent gifts from one source, whether or not you refuse or return +them. +20 + +JPM-SDNYLIT-00275116 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 28 of 35 +The Nonconforming Gift Approval and Report form, indicating the disposition of the gift, must be signed +by an Executive Committee member, your Code Specialist, and the Office of the Secretary. The Office of +the Secretary will maintain a record of all reported gifts. +6.6. Providing gifts, meals or entertainment +Local laws or industry-specific regulations often limit or prohibit the giving of gifts, meals and +entertainment, and other items of value by JPMorgan Chase to an employee of a current or prospective +customer or supplier or any other person or entity doing business or seeking to do business with the firm. +For example, broker-dealers and asset managers are generally subjeet to regulatory restrictions on +providing gifts. +Some lines of business have very restrictive gift-giving policies, and others have prohibited gifts entirely. +You are responsible for knowing and complying with the policies that apply to you. +The giving of gifts and other items of value to governmental officials, including employees of stateowned enterprises, and labor union or public employee pension plan officials, is in many cases strictly +limited by law or regulation. Contact your Code Specialist for additional guidance. +Business-related gifts not prohibited by law or firm policies should be reasonable and customary in the +context of the relationship with the recipient of the gift, appropriate for the occasion, and in conformity +with the Code, JPMorgan Chase's Travel & Entertainment Policies & Procedures, and all other applicable +6.7. Solicitations at work; charitable contributions by the firm +While the firm encourages its employees to become involved with charitable organizations, there are +restrictions on solicitation of customers, suppliers, and fellow employees for contributions. You should +become familiar with the relevant policies before engaging in any such activities. +In general the firm's charitable contributions are made through the JPMorgan Chase Foundation. +Occasionally customers or suppliers ask that JPMorgan Chase make a contribution to a charity or not-forprofit organization. If it is necessary for business development purposes to make a contribution, please +refer to the approval guidelines specific to your line of business. You can contact Global Philanthropy if +you need assistance in determining the appropriate level of support, including consideration of whether +the firm has already made a contribution to the organization. +PERSONAL SECURITIES AND OTHER FINANCIAL TRANSACTIONS +Your personal investment activities should always be conducted with the Company's reputation in mind +and in compliance with all applicable laws and regulations. +7.1. General investment principles +21 + +JPM-SDNYLIT-00275117 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 29 of 35 +In addition to complying with all other Code provisions and relevant policies and procedures, you should +observe the following general investment principles in carrying out personal transactions in securities and +other financial instruments. (All references to securities should be understood to include all financial +instruments, such as equity securities, bonds and other debt securities, convertible securities, derivatives, +options, and any +(b) +(c) +(d) +(e) +(f) +(g) +(h) +While in possession of inside information about the issuer of any securities or the +securities themselves, never buy, sell, or recommend the purchase or sale of such +securities for your account or the accounts of others, regardless of whether the inside +information is gained through the scope of your employment or elsewhere. If in doubt, +don't trade. +Do not buy or sell securities with knowledge of proposed client trades, trades by +JPMorgan Chase or forthcoming research reports. +Your trading and investment activities must be within your financial means. +Do not ask for or accept any preferential terms or conditions in connection with any +personal trading or investments, unless the terms are available to all persons having +comparable portfolios and creditworthiness, or to all employees under a plan negotiated +by JPMorgan Chase. +Limit the risks in your personal account trading. Do not engage in excessive trading +activities that represent a high degree of financial risk. +Trading and investment activities should be for investment purposes and not for shortterm trading profits. ( +Do not engage in speculative trading, such as trading based on rumors. +In general, employees should not invest in a competitor (other than investments in +securities of publicly traded companies). Competitors include unrelated financial services +companies of any kind, and others engaged in any business the firm is involved in, such +as banks, asset managers, depository institutions, credit unions, lenders, investment +banks, insurers, insurance agencies, and securities brokers, dealers, and underwriters. +7.2. Persons and accounts subject to policies +All personal investment policies that apply to you also apply to transactions in any account, whether +domestic or foreign, +(a) that is established or maintained by you or by your spouse, domestic partner, minor children, +or any other person to whom you provide significant financial support, +(b) over which you, or any of the other persons referred to in (a), have the power, directly or +indirectly, to make investment decisions, regardless of beneficial interest, or +(c) that is established or maintained by you or with your consent or knowledge and in which you +have a direct or indirect financial interest. +These are referred to as "employee-associated accounts." +7.3. Trading in JPMorgan Chase securities +7.3.1. Policies applicable to all employees +Purchases and sales of JPMorgan Chase & Co.'s common | +or other securities are subject to the +general investment principles set forth above. These principles are applicable to the following +transactions (as they are to your other investment activities): +a) direct purchases and sales of JPMorgan Chase securities. +(b) +elections involving the JPMorgan Chase & Co. common +investment account (such as a 401(k) plan in the US), deferred compensation plan, or +Employee +Purchase Plan, including decisions to increase or decrease contributions +22 + +JPM-SDNYLIT-00275118 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 30 of 35 +or elections that result in increasing or decreasing amounts credited to any common | +account under an employee benefit plan. +(c) +sales of JPMorgan Chase securities to meet a margin call, with or without your personal +involvement. +(d) +placing, canceling, or amending limit orders with respect to JPMorgan Chase securities. +(e) +entering into, canceling, or amending sales plans sometimes referred to as 10b-5(1) plans +in the United States, with respect to JPMorgan Chase securities. +However, these principles do not affect automatic purchases of JPMorgan Chase +in accordance with +previously made benefits elections and acquisitions of JPMorgan Chase +reinvestment. +through dividend +Purchases and sales of JPMorgan Chase & Co.'s common | +more restrictive personal trading policies applicable to your business unit. +or other securities are also subject to any +In addition, the following restrictions apply to transactions in JPMorgan Chase securities: +(i) +You may not engage in short selling of JPMorgan Chase securities, except for short sales +against a long position already held by you (sometimes referred to as a short sale against +the box). +(ii) +You may not engage in derivative transactions related to JPMorgan Chase securities +except as part of JPMorgan Chase's compensation and benefits programs, or when used +for bona fide hedging purposes against a long position already held by you, or as +otherwise approved by the Office of the Secretary. +(ill) +No transactions in JPMorgan Chase securities, including derivative transactions, may be +made in fully managed accounts (accounts over which you have no trading discretion), +except dispositions of shares permissibly transferred to the account. Any transfer of +securities into a managed account is subject to any restrictions applicable to a sale of such +securities. +(iv) +Subject to any other JPMorgan Chase policies on personal securities trading applicable to +you, you may enter, cancel, or amend limit orders for the purchase or sale of JPMorgan +Chase securities. +(V) +Your transactions in JPMorgan Chase securities may be halted at any time the Company +finds it necessary or advisable to halt trading by all employees or certain groups of +employees. +7.3.2. Employees subject to the "window" and "Senior-level employees" +Certain employees are restricted from engaging in transactions in JPMorgan Chase securities except +during quarterly window periods and are subject to certain other restrictions and requirements with +respect to transactions in JPMorgan Chase securities. This policy affects only those persons who are +specifically notified by their management or by the Office of the Secretary that they are subject to it. +Senior-level employees (whether subject to the window restrictions or not) must discuss planned +transactions in JPMorgan Chase securities with a manager in advance. This requirement applies only to +those persons who are listed as "Senior-level employees" by Human Resources, whether by title such as +SVP/MD, or otherwise. +These requirements exist to ensure compliance with, among other things, our insider trading policies, and +are not intended to discourage appropriate investment diversification. +23 + +JPM-SDNYLIT-00275119 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 31 of 35 +7.4. Trading in securities of clients and suppliers +As a general rule, you should not invest in any securities of a client with which you have or recently had +significant dealings or responsibility on behalf of JPMorgan Chase if such investment could be perceived +as based on confidential information. You may be subject to broader restrictions imposed by your +business unit. +If you have information about or are directly involved in negotiating a contract material to a supplier of +JPMorgan Chase you may not invest in the securities of such supplier. +If you own the securities of a company with which we are dealing and you are asked to represent +JPMorgan Chase in such dealings you must: +(a) disclose your securities ownership to your department head and your Compliance unit; +and +(b) obtain prior approval from your Compliance unit before selling such securities. +7.5. Additional policies for certain groups of employees +Any area of JPMorgan Chase may impose more restrictive policies on its employees, and you should +consult your Compliance Officer or your Code Specialist on whether any such policies apply to you. +Employees of the following areas are subject to the Global Personal Trading Policy and Procedure as well +as any applicable supplemental policies: +Investment Bank +Asset Management +Commercial Banking +Private Equity +Audit +Legal and Compliance +Executive Management and the Executive Committee +Risk Management +Global Technology Infrastructure, IT Risk Management, and Resiliency Risk +Management groups of Central Technology +Corporate Resources and Media Relations Groups of Marketing & Communications +any other group or individual specifically notified as being subject to the policy and/or a +supplemental policy +These policies establish trading limitations and include requirements for pre-clearance of personal +securities transactions and, in some jurisdictions (including the U.S.), the use of designated brokers. +24 + +JPM-SDNYLIT-00275120 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 32 of 35 +Definitions and Examples +Assets of the Firm: Examples of assets of the firm are: +• furnishings, equipment, supplies and services, such as telephone, the firm's intranet, internet, +and Bloomberg access +• JPMorgan Chase inventions +• any property created, obtained, or compiled by or on behalf of JPMorgan Chase, including +customer lists, directories, files, reference materials and reports, computer software, data +processing systems, computer programs and databases +• trade secrets +• security and other business practices or processes, policies, procedures, and know-how +• cost, pricing, or financial information +• employee compensation, health, or personnel records +• business or marketing plans +• rescarch +• business relationships +• products and services +• any other information that the firm considers to be proprietary or confidential information +Information Barrier: The term "information barrier" usually refers to the policies that create a system of +information barriers designed to limit the flow of inside information from areas that routinely have access +to such information to those areas that trade in or sell securities or provide investment advice regarding +securities. Certain business areas within JPMorgan Chase require procedures that address more +specifically the information flows within such business areas. These are sometimes also referred to as +information barriers. +Code Specialist: Each line of business and support group has been assigned at least one "Code +Specialist," generally a Compliance Officer, to act as a resource for all employees in the area on Coderelated issues. Contact information for these officers is included in the Code Contacts List, and employees +can contact their Code Specialist for assistance with any questions regarding the Code. +Confidential information: Examples of confidential information: +• trade secrets, security and other business practices or processes, policies, procedures, or +know-how +• internal and external audit reports +• nonpublic portions of bank examination reports and other reports or information filed with +regulators +• software, data processing programs, databases +• customer or supplier lists, telephone or other contact lists, and other information about +customers +• customer presentations +information about employees of customers or suppliers +• cost, pricing, or financial information +• employee directories, lists, telephone numbers, or other information about employees +• employee compensation, health, or personnel records +• business or marketing plans and research + +JPM-SDNYLIT-00275121 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 33 of 35 +• information posted on the firm's internal websites +Examples of other confidential information about customers: +• the same kind of information that the firm considers confidential about itself +• information obtained from requests or applications for our products or services or as a result +of "know your customer" due diligence, such as a personal identification number (for +example, depending on the location, a passport, social security, or national health number), +birth date or financial information disclosed in a loan application +• information about transactions with the firm, such as account balances, mortgage loans, or +other lending, capital markets, or trading transactions +• information obtained from consumer reporting agencies (credit bureaus), such as a person's +credit history +• information provided in connection with an advisory assignment, such as financial +projections +• any assessment by the firm of a customer's creditworthiness +• the fact that a person is a customer +• information collected through an information collection device from a web server (such as a +cookie or a beacon) +Supplier or other third party information that you should assume to be confidential: +• the same kind of information that the firm considers confidential about itself +• information received from others such as financial reports or projections and information +about its business plans, customers, suppliers, or creditors +Firm: JPMorgan Chase & Co. and its direct and indirect subsidiaries. +Gift: Anything of value for which you are not required to pay the retail or usual and customary cost. A +gift may include meals or refreshments, goods, services, tickets to entertainment or sporting events, or the +use of a residence, vacation home, or other accommodations. +Inside information: Confidential information that is material, nonpublic information about the securities, +activities, or financial condition of a corporation, publie entity, or other issuer of securities or financial +instruments. Material, nonpublic information concerning market developments may also be construed to +be inside information. +JPMorgan Chase: JPMorgan Chase & Co. and its direct and indirect subsidiaries. +Material information: Information is "material" when it could have an impact on the market price of +securities involved or if it is likely that a reasonable investor would consider the information important in +deciding whether to purchase or sell the securities. Information may be material to one issuer but not to +nother. Information may be material to certain securities of an issuer but not material to all securities o +hat issuer (c.g., to equity, but not to debt). Examples of information that could be material include +• mergers, acquisitions, tender offers and restructurings +• substantial nonperforming loans or impending bankruptcy +• securities offerings and repurchases +• a change in earnings and dividends (or estimates of same) +• significant new business products, discoveries, and services, or the loss of any of these +• a change in an issuer's credit rating by a rating agency +• significant shifts in operating or financial circumstances, such as cash-flow reductions, major +write-offs, changes in accounting methods and strikes at major plants + +JPM-SDNYLIT-00275122 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 34 of 35 +• voluntary calls of debt or preferred +issues +• significant litigation or litigation developments +• governmental developments that could affect securities markets +• changes in control or management +• developments regarding customers or suppliers (c.g., loss or acquisition of a contract) +Need-to-know: Persons with a "need-to-know" information require access to that information in order to +perform the services we are engaged to provide to the party who provided the information to us --. for +example, lawyers, accountants and other experts, Compliance Officers, credit personnel, and senior +management personnel. Who "needs-to-know" any particular information will depend on the specific +facts and circumstances; if in doubt, consult the Legal and Compliance Department. Justification of +communicating confidential information does not exist simply because the information is helpful to +another department in activities that are unrelated to the service or transaction for which the information +was obtained. In some circumstances, legal counsel may determine that limited disclosure is required by +law (in response to a subpoena, for example) or is otherwise appropriate. These decisions should be made +only by the Legal and Compliance Department. +Nonpublic/Public information: Information should be considered nonpublic unless it is clearly public. +Information is deemed public once it has been publicly announced or otherwise disseminated in a manner +that makes the information available to investors generally. For example, limited disclosure over a +private wire service for institutional investors is not considered full disclosure to the public. Information +disclosed in a press release distributed through a widely circulated news or wire service would generally +be considered publie. +Personal fiduciary: A person who has undertaken to act primarily for another's benefit, such as a trustee, +executor, attorney-in-fact, or guardian, outside the scope of your normal job responsibilities at JPMorgan +Chase. +Routine branch banking services: In general, branch banking services (checking or savings accounts, +etc.) would be considered routine banking services. Whether any other service is "routine" will be a casespecific determination, based on factors such as the size of the transaction, the extent of the relationship +with the customer, and whether the service(s) provided are subject to variable pricing for different +customers. If in doubt about whether a customer relationship with a not-for-profit organization triggers +the pre-clearance requirements of Section 6.3.2(2)(a), discuss the situation with your Code Specialist. +Senior-Level Emplovee: A Senior-Level Employee is any employee whose (a) annual base salary rate is +US$150,000 (or the local currency equivalent) or higher, OR (b) total annual cash compensation is +US$250,000 (or the local currency equivalent) or higher. "Total annual cash compensation" means the +employee's annual base salary rate plus job/shift differentials as of the last preceding August 1, plus cash +earnings under any incentive plans or programs (e.g., annual bonus, commissions, draws, overrides, and +special recognition payments or incentives) that are paid to or deferred by the employee during the 12- +month period ending the last preceding July 31. It does not include overtime pay. (For US employees, +total annual cash compensation is the amount used for medical plan purposes, as shown on the Benefits +Web Center.) +Trade association, professional association, or other such organization: A not-for-profit organization +the main purpose of which is to make available to its members opportunities for education, exchange of +ideas and information, networking, etc., such as a bar association or industry professionals* group. The + +JPM-SDNYLIT-00275123 + + +Case 1:22-cv-10904-JSR Document 326-53 Filed 09/08/23 Page 35 of 35 +term does not apply to entities that engage in business activities, exchanges, trading platforms, or clearing +systems, for example. \ No newline at end of file diff --git a/vision-fixhub/court-05/73180711a1989eb25fa2185dbc05d3b006b1ebe2e74b6e386eb7f77037f5f39e.receipt.json b/vision-fixhub/court-05/73180711a1989eb25fa2185dbc05d3b006b1ebe2e74b6e386eb7f77037f5f39e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3336c50cf721658c8d894afd3e08b4ffdd744fdc --- /dev/null +++ b/vision-fixhub/court-05/73180711a1989eb25fa2185dbc05d3b006b1ebe2e74b6e386eb7f77037f5f39e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -825, + "dataset": "marble-joined", + "doc_id": "73180711a1989eb25fa2185dbc05d3b006b1ebe2e74b6e386eb7f77037f5f39e", + "engine": "marble-apple-vision", + "event_count": 73, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "d6fdcba8910b5e6d29905e5960a5c9eff9890116ffe7d4b839aae699eb01e12e", + "output_sha256": "5fc1f7e38a6180d226e75a60bd1646290aeaf157b3f619bc9f2065dca40f0e1a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/731855758b0d1cbfbc1c1478bfb59c8c843e9aaa8cd55a9df9352d76b0573126.md b/vision-fixhub/court-05/731855758b0d1cbfbc1c1478bfb59c8c843e9aaa8cd55a9df9352d76b0573126.md new file mode 100644 index 0000000000000000000000000000000000000000..2b541aff9804cff46a2e4f65372f1d38034966f3 --- /dev/null +++ b/vision-fixhub/court-05/731855758b0d1cbfbc1c1478bfb59c8c843e9aaa8cd55a9df9352d76b0573126.md @@ -0,0 +1,113 @@ +Case 1:22-cV-10904-JSR Document 241-27 Filed 07/25/23 Page 1 of 4 + + + +Case 1:22-cV-10904-JSR Document 241-27 Filed 07/25/23 Page 2 of 4 + +WIT:_ +maur +ATE: Y-2-2 +_ ADR CAR CSR #13921 +JPMORGAN CHASE & Co. +Legal and Compliance +POLICY DETAILS +POLICY TITLE +EFFECTIVE DATE +mm/dd/yyyy +LAST REVIEW DATE +mm/dd/yyyy +PRIMARY CONTACT +Name/SID +SECONDARY CONTACT +Name/SID +OWNER GROUP +POLICY LEVEL +APPLICABILITY +BUSINESS GROUP +LOCATION +FIRMWIDE CATEGORY +Private Bank UHNW - Anti-Money Laundering/Know Your Client +Policy - SECTION E: CLIENT CASH TRANSACTION +GUIDELINES +07/01/2006 +11/20/2012 +Melissa Everett (V093891) +Christine Farquhar (E011146), Jeanette Peplowski (A002119) +Legal/Compliance +Firmwide _ Business _ Regional X Sub-Business +Asset Management: Private Bank Ultra High Net Worth +North America: United States +Compliance and Regulatory +Private Bank (UHNW) +ANTI-MONEY LAUNDERING/KNOW YOUR CLIENT POLICY +SECTION E: +CLIENT CASH TRANSACTION GUIDELINES +Introduction +The receipt of large cash deposits and disbursements of cash withdrawals for other than client +casual spending needs is discouraged. +It is the primary responsibility of the Banker to obtain explanations on the source of the cash and +acceptability of the intended use of the cash, and to assess the plausibility of these explanations +for large cash transactions. +Cash transactions should be conducted on the Firm premises or through banks which the firm has +the requisite contractual relationship, known as "partner" banks. Any off premise pickup or +delivery of cash to clients or third parties made at the client's request must be reported to Risk +Management & Control or Compliance, and have the prior written approval of the appropriate +Area Head or designee. +U.S. locations that effect transactions involving currency, including deposits, withdrawals, +exchanges, check cashing and instrument purchases, shall report (FinCEN form 105 - Currency +Private Bank UHNW AML Policy -SECT. E CLIENT CASH TRANSACTION GUIDELINES.11-2012.docx + +JPM-SDNYLIT-00130224 + + +Case 1:22-cV-10904-JSR Document 241-27 Filed 07/25/23 Page 3 of 4 +Transaction Report) and record all such transactions in excess of (U.S.) $10,000. The Private +Bank may rely on another LOB (Retail Financial Services) to file the CTR where cash +transactions are conducted at a retail branch and maintain the listing of Private Bank clients with +a CTR Exemption. +Structuring is the breaking down of currency transactions below the reporting threshold (e.g., +U.S. >$10,000) in an attempt to evade reporting requirements. The Private Bank will not assist a +client in structuring any transaction for the purpose of evading the reporting requirements. +I. Cash Transactions In Locations Other Than The Booking Unit +A booking unit may, unless local procedures provide otherwise, accept cash transactions for +Private Bank clients whose accounts are held at another Private Bank location if the booking unit +is operationally in a position to do so. +In instances in which a client is making a cash deposit or withdrawal at a location other than the +booking unit, in addition to completing any transaction documents required by local procedures, +the Banker must notify appropriate personnel at the location where the transaction will occur. +The notification should include information regarding the individual who is expected to conduct +the transaction and the manner in which he or she will be properly identified. +I. Process +All recorded information and approvals for a cash transaction must be recorded in accordance +with local procedures. +Documentation, including any form used, must be submitted along with the appropriate written +approvals to the teller or processing department who is responsible for assuring appropriate +approvals have been obtained. If it is not feasible to obtain written approval prior to the time of +the transaction, verbal approval may be obtained, in accordance with local procedures. Written +approved must be submitted as soon as possible thereafter. +The relevant area Risk Management & Control or Compliance officer will monitor cash +transactions to identify potential structuring occurrences in accordance with the local AML +monitoring process. In addition, quarterly Cash Transaction Reports will be generated by AML +Operations, which will then be used by Risk Management & Control to identify those customers +posing higher risk due to significant cash activity. The assessment of risk will be facilitated by +completion of an appropriate cash questionnaire. +III. Exceptions +Requests for exceptions to the Client Cash Transaction Guidelines must be approved in writing +by the Area Head or designee. +2 + +JPM-SDNYLIT-00130225 + + +Case 1:22-cV-10904-JSR Document 241-27 Filed 07/25/23 Page 4 of 4 +IV. Related Policies +This procedure must be used in conjunction with the Private Bank Identification And +Investigation Of Unusual Or Suspicious Activity; Non-Compliance With Sponsorship +Criteria; Escalation And Reporting Procedure, which delineates the process to be followed +in the event suspicions client account activity is recognized. +V. Questions +Any questions concerning this procedure should be directed to the relevant Risk Management & +Control or Compliance officer. +3 + +JPM-SDNYLIT-00130226 diff --git a/vision-fixhub/court-05/731855758b0d1cbfbc1c1478bfb59c8c843e9aaa8cd55a9df9352d76b0573126.receipt.json b/vision-fixhub/court-05/731855758b0d1cbfbc1c1478bfb59c8c843e9aaa8cd55a9df9352d76b0573126.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3cd84d6c09a1857c0e701e5287e77a93cc21d56a --- /dev/null +++ b/vision-fixhub/court-05/731855758b0d1cbfbc1c1478bfb59c8c843e9aaa8cd55a9df9352d76b0573126.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -105, + "dataset": "marble-joined", + "doc_id": "731855758b0d1cbfbc1c1478bfb59c8c843e9aaa8cd55a9df9352d76b0573126", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "11ec9065ffaf063c1ec7cfc226ddd2904038fe4b47da538bf10fb9141cbbc431", + "output_sha256": "f56974764b1efb76ca84979f33e345905a3d1ab5a49c1e51faff2daed04674ce", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7324740fd2db33382828c534fed123dbcd6671d076d9870513e971bd410c36a5.md b/vision-fixhub/court-05/7324740fd2db33382828c534fed123dbcd6671d076d9870513e971bd410c36a5.md new file mode 100644 index 0000000000000000000000000000000000000000..837adf3c41fb2e24d8e4a21755b47eeea1cf142a --- /dev/null +++ b/vision-fixhub/court-05/7324740fd2db33382828c534fed123dbcd6671d076d9870513e971bd410c36a5.md @@ -0,0 +1,42 @@ +Case 1:22-cV-10904-JSR Document 285-62 Filed 08/15/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 285-62 Filed 08/15/23 Page 2 of 2 +From: +ann.borowiec@jpmorgan.com [ann.borowiec@jpmorgan.com] +Sent: +1/12/2007 12:50:21 AM +To: +barry.s.berger@jpmorgan.com +CC: +robert.c.blanch@jpmorgan.com; patricia.lunka@jpmorgan.com +Subject: +Re: Jeffrey E. referrals! +Attachments: graycol.gif +Is this the do guy? I did speak to jes and he specifically told me to keep the epstein referrals...and he mentioned +the one in dc....knew about it. Ann +Sent from my BlackBerry Wireless Handheld +Barry S Berger +From: Barry S Berger +Sent: 01/11/2007 10:20 AM +To: Ann Borowiec +Co: Robert Blanch; Patricia Lunka +Subject: Jeffrey E. referrals! +just got call from one of Jeff's referrals, Nick Ribis; his background material is on your chair (he is principal in +Colony Capital, S6billion private equity fund, specializing in ownership of casinos (Resorts Int'l,etc.)). Spoke +with him for about 15 minutes earlier this AM and he then asked me to meet him for lunch next week (the 17th) +to discuss his estate planning (especially since his lawyer at +Block has "confused him"); mentioned he had +need of our investment capabilities as well, but when I suggested I would bring group to meeting to discuss +investing/banking as well (Bob and Pat), he suggested for first meeting 1 come alone and we do it at his office +(61th Street) over sandwiches. He also thought unnecessary to invite Jeffrey, but I will call Jeff and let him +know Nick called me and he and I set up lunch. Lisa is puttingNick Ribis into Sicbel. +Barry S. Berger +Wealth Advisor +JPMorgan Private Bank +345 Park Avenue, 8th Floor +New York, NY 10154 +Tel. 212-464-2661 +Fax 212-464-1903 +Email: barry.s.berger@jpmorgan.com diff --git a/vision-fixhub/court-05/7324740fd2db33382828c534fed123dbcd6671d076d9870513e971bd410c36a5.receipt.json b/vision-fixhub/court-05/7324740fd2db33382828c534fed123dbcd6671d076d9870513e971bd410c36a5.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9c1345abfdb8e9f0191566e5a4b0158cc129f6a8 --- /dev/null +++ b/vision-fixhub/court-05/7324740fd2db33382828c534fed123dbcd6671d076d9870513e971bd410c36a5.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -35, + "dataset": "marble-joined", + "doc_id": "7324740fd2db33382828c534fed123dbcd6671d076d9870513e971bd410c36a5", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "dfea125369ba18741eb7204232135f6dec60e765bb283285ef61677a3526bfe1", + "output_sha256": "3f92c957c1ef3cb0a404983fd294d7e317c6a824b92a526d4ef359a1937791a6", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7397af49b58b5fb75b2337b232af5370eb421f31d70a98e1dac4480d1d1ba0e9.md b/vision-fixhub/court-05/7397af49b58b5fb75b2337b232af5370eb421f31d70a98e1dac4480d1d1ba0e9.md new file mode 100644 index 0000000000000000000000000000000000000000..c1b42242946df2f270807798f795fbfd2d089eb8 --- /dev/null +++ b/vision-fixhub/court-05/7397af49b58b5fb75b2337b232af5370eb421f31d70a98e1dac4480d1d1ba0e9.md @@ -0,0 +1,59 @@ +Case 1:22-cv-10904-JSR Document 326-109 Filed 09/08/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 326-109 Filed 09/08/23 Page 2 of 3 +Sunday, November 27 2016 09:46 PM +Date: +Subject: Re: +From: +To: +jeffrey E. : +Spoke with him. He said not yet, but thanks. +On Nov 27, 2016, at 12:40 PM, jeffrey E. wrote: +great +On Sun, Nov 27, 2016 at 12:39 PM +Will do. He's on a plane to London right now but l'Il reach him after. +Hope all is well. +On Nov 27, 2016, at 11:43 AM, jeffrey E. wrote: +could you ask +if he would like to considered for treasury +-- + +mr: Stalug +DATE: 6-11-23 +C. Campbell, ROR CHH CSPI#13821 +wrote: +please note +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +JEE +Unauthorized use, disclosure or copying of this +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved +please note +The information contained in this communication is +confidential, may be attorney-client privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +JEE +Unauthorized use, disclosure or copying of this + +Estate_004300 + + +Case 1:22-cv-10904-JSR Document 326-109 Filed 09/08/23 Page 3 of 3 +communication or any part thereof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation(@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. copyright -all rights reserved + +Estate_004301 diff --git a/vision-fixhub/court-05/7397af49b58b5fb75b2337b232af5370eb421f31d70a98e1dac4480d1d1ba0e9.receipt.json b/vision-fixhub/court-05/7397af49b58b5fb75b2337b232af5370eb421f31d70a98e1dac4480d1d1ba0e9.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f1fa0a2ce9a8a556e2b614c84a68490311ee651b --- /dev/null +++ b/vision-fixhub/court-05/7397af49b58b5fb75b2337b232af5370eb421f31d70a98e1dac4480d1d1ba0e9.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -82, + "dataset": "marble-joined", + "doc_id": "7397af49b58b5fb75b2337b232af5370eb421f31d70a98e1dac4480d1d1ba0e9", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "5eb779415d288fdae7ee53f3a3f3ece20771c5b6b7c2839bcd1c9879a992aa7c", + "output_sha256": "2afcf083d401df65a80bca494ef164b59ad81881f501a0f399f58e5ec3c5aa2b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/73cba7c8a21d4a35d0c10073969607d3a95d3115acd15538e5a0b74ee275119c.md b/vision-fixhub/court-05/73cba7c8a21d4a35d0c10073969607d3a95d3115acd15538e5a0b74ee275119c.md new file mode 100644 index 0000000000000000000000000000000000000000..061b3227d42211eca6ebac1229b0146adf6fa4ac --- /dev/null +++ b/vision-fixhub/court-05/73cba7c8a21d4a35d0c10073969607d3a95d3115acd15538e5a0b74ee275119c.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 244-4 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/73cba7c8a21d4a35d0c10073969607d3a95d3115acd15538e5a0b74ee275119c.receipt.json b/vision-fixhub/court-05/73cba7c8a21d4a35d0c10073969607d3a95d3115acd15538e5a0b74ee275119c.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..cf44988889b5b54fc5a76eb4deb66acf2b41ccba --- /dev/null +++ b/vision-fixhub/court-05/73cba7c8a21d4a35d0c10073969607d3a95d3115acd15538e5a0b74ee275119c.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "73cba7c8a21d4a35d0c10073969607d3a95d3115acd15538e5a0b74ee275119c", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "e93a70ab1eb200c92eb3b899ab22c3fe1d0c198005fff045b0efac21f5b806cf", + "output_sha256": "196b10fb93293c8d210fbc92908f9035507aecf42f95c463d41cd23fac9bb8de", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/740a6dc674c6c24428a4b4e5b651d97eda7d8cb491724aca43364d1c72c21a0f.md b/vision-fixhub/court-05/740a6dc674c6c24428a4b4e5b651d97eda7d8cb491724aca43364d1c72c21a0f.md new file mode 100644 index 0000000000000000000000000000000000000000..a5d019c5238dc5e540a0070b0aac454d0ca5ba4d --- /dev/null +++ b/vision-fixhub/court-05/740a6dc674c6c24428a4b4e5b651d97eda7d8cb491724aca43364d1c72c21a0f.md @@ -0,0 +1,306 @@ +Case 1:22-cV-10904-JSR Document 270-12 Filed 08/07/23 Page 1 of 6 + + + +Case 1:22-cV-10904-JSR Document 270-12 Filed 08/07/23 Page 2 of 6 +1 +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiff, +No. 22-cv-10904-JSR +JPMORGAN BANK, N.A., +Defendant. +JPMORGAN CHASE BANK, N.A., +Third-Party Plaintiff +v. +JAMES EDWARD STALEY, +Third-Party Defendant. +THE ORAL DEPOSITION OF ALBERT BRYAN, JR. was +taken on the 6th day of June, 2023, at the Law Offices +of Joel Holt, 2132 Company Street, Christiansted, St. +Croix, U.S. Virgin Islands, between the hours of 8:42 +a.m. and 3:47 p.m. pursuant to Notice and Federal Rules +of Civil Procedure. +Reported by: +DESIREE D. O +Registered Merit Reporter +Reporting Services +St. +P.O. Box 307501 +. Virgin Islands +(340) 777-6466 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cV-10904-JSR Document 270-12 Filed 08/07/23 Page 3 of 6 +ALBERT BRYAN, JR. -- DIRECT +10 +Okay. So there were two topics that came +up in the meeting then, the environmental topic and +his reporting as a sex offender, you mean? +A. +Right. +What did he say about that? +A. He just wanted to have more leniency in +terms of being able to leave the island on a moment's +notice. As most of our wealthy residents here, they +have jets and boats. British Virgin Islands, there's +a lot of things close by. So I guess from time to +time when he wanted to leave he could not. +All right. +What did you state to him about +that topic? +A. +Well, I didn't know what the rules were. +So I just told him I would inquire about it, and when +I inquired, it was not available for him to do it. +e. +All right. What did you understand at that +time about why Mr. Epstein was required to register as +a sex offender? +A. +I mean, more than just understanding that +all sex offenders are required to list their +residence, nothing else. +What, if anything, did you know about what +he had done that led him to being a registered sex +offender? + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cV-10904-JSR Document 270-12 Filed 08/07/23 Page 4 of 6 +ALBERT BRYAN, JR. -- DIRECT +A. +At the time, I figured he -- well, I knew +he was arrested in Florida and he had pled to a +charge. At the time I didn't know that the charge +was having to do with prostitution and young women. +e. +So at this time, is to be all the way into +2019, you didn't know anything more than it had +something to with prostitution and young women? +A. +e. +A. +That's correct. +All right. Anything else that you can +remember about this second meeting with Mr. Epstein? +Other than he -- I mean, the most +significant thing about the meeting was he came in a +helicopter. +That stood out in your mind? +A. +Yeah. +To Erika Kellerhals' office? +Yes. +Was there like a helipad nearby? How does +11 +A. +e. +that work? +A. +Well, the hospital. Schneider Regional +has a helipad and it's across the street essentially. +Got it. How did you know he had come by +helicopter? +A. +You could see the helicopter. I mean, it +is literally right in front of the office, so. + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cV-10904-JSR Document 270-12 Filed 08/07/23 Page 5 of 6 +ALBERT BRYAN, JR. -- DIRECT +we could take a break now. +Q. (By Mr. Neiman:) You want a break or you +want to take a look at the document? +A. +No, I'm good. +(Deposition Exhibit No. 36 was +marked for identification.) +Let's me show you a document marked as +Exhibit 36. Exhibit 36 is an article from the Virgin +Islands Daily News. Do you see that? +A. +Yes. +And is that a newspaper that you read? +A. +No. +e. +A. +You don't read it? +Yes, I do. +You do. You have to. Kind of doing your +job, right? +A. +I have to. That's a better word of it, I +have to. +238 +Maybe not your choice but you got to. +A. +Yeah. +You can see this is an article from +July 12th of 2019 headline "Local authorities not +currently investigating Epstein." You see that? +A. +Yes. +e. +All right. And do you think you would have + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +Case 1:22-cV-10904-JSR Document 270-12 Filed 08/07/23 Page 6 of 6 +ALBERT BRYAN, JR. -- DIRECT +seen this article at the time it came out? +A. +NO. +e. Why not? +A. I mean, I'm not particularly, you know -- +I wasn't following the Epstein thing, to be quite +honest. +239 +You see in the second page of the article, +it reads, "While at least one individual has said in a +civil lawsuit in New York that she was sexually abused +at Epstein's home on Little St. James." +A. +Yes. +That would be a topic of interest to you, +wouldn't it? +A. +(Witness reading article.) Yes. +You don't remember learning that in July of +2019? +A. +No, I don't. I remember the attorney +general making a public statement that said, None of +these victims were from the Virgin Islands. That's +what I remember. At that point, I turned my +attention elsewhere. +MR. ACKERMAN: Still want to take +a break? +THE WITNESS: You were saying +after the document. diff --git a/vision-fixhub/court-05/740a6dc674c6c24428a4b4e5b651d97eda7d8cb491724aca43364d1c72c21a0f.receipt.json b/vision-fixhub/court-05/740a6dc674c6c24428a4b4e5b651d97eda7d8cb491724aca43364d1c72c21a0f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..520e17570e41a64f84fe737ff9117e1c4d07ccbe --- /dev/null +++ b/vision-fixhub/court-05/740a6dc674c6c24428a4b4e5b651d97eda7d8cb491724aca43364d1c72c21a0f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -82, + "dataset": "marble-joined", + "doc_id": "740a6dc674c6c24428a4b4e5b651d97eda7d8cb491724aca43364d1c72c21a0f", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "86cad42e1a5c63c4d6cca01b7035958fd3e2877cef4dab508fd4dad95265e2fa", + "output_sha256": "de0b17e72fb7ab7ab71fb5b9771c05578466cb2f336748d79c19a001dd4a7539", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/740a99774af54a400a5723cd5be834a98b04e06c26d90fee43cdd524120d8194.md b/vision-fixhub/court-05/740a99774af54a400a5723cd5be834a98b04e06c26d90fee43cdd524120d8194.md new file mode 100644 index 0000000000000000000000000000000000000000..01868e9c07e2e9605c93b9bcaf924677f64dd590 --- /dev/null +++ b/vision-fixhub/court-05/740a99774af54a400a5723cd5be834a98b04e06c26d90fee43cdd524120d8194.md @@ -0,0 +1,32 @@ +Case 1:20-cr-00330-PAE +Document 738 +Filed 07/22/22 Page 1 of 1 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AM +USA / Plaintiffs) +v. +GHISLAINE MAXWELL +Defendants) +Case No. 20CR330 +) +NOTICE OF FILING OF OFFICIAL TRANSCRIPT +SENTENCE +Notice is hereby given that an official transcript of a +_ held on +6/28/2022 +has been filed by the court reporter/transcriber in the above-captioned matter. +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting +the transcript is a judge or a member of the public or media. +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court +ny NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must als‹ +›e served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronicall +available to the public without redaction after ninety (90) calendar days. +This process may only be used to redact the following personal data identifiers: Social Security +numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure +5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information +may proceed by motion. +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. +IS ALENA +Court Reporter/Transcriber +Date diff --git a/vision-fixhub/court-05/740a99774af54a400a5723cd5be834a98b04e06c26d90fee43cdd524120d8194.receipt.json b/vision-fixhub/court-05/740a99774af54a400a5723cd5be834a98b04e06c26d90fee43cdd524120d8194.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b7eaaa47d5490b7543c82334e24ed3a495848845 --- /dev/null +++ b/vision-fixhub/court-05/740a99774af54a400a5723cd5be834a98b04e06c26d90fee43cdd524120d8194.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -14, + "dataset": "marble-joined", + "doc_id": "740a99774af54a400a5723cd5be834a98b04e06c26d90fee43cdd524120d8194", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "9f8b397b29529b6f57edfba52e2ad22450abc5e37bc15ea4cc7b851855b1dfac", + "output_sha256": "0cafd145fc581b46ab1d37a27575b741db574792226bd2653cac735dae858845", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/744a10d245b631b7b689e393b071f27710092e24d678a68a2b5e2a0de235c766.md b/vision-fixhub/court-05/744a10d245b631b7b689e393b071f27710092e24d678a68a2b5e2a0de235c766.md new file mode 100644 index 0000000000000000000000000000000000000000..b453dc4505532bce064f0b798071f5fc21688724 --- /dev/null +++ b/vision-fixhub/court-05/744a10d245b631b7b689e393b071f27710092e24d678a68a2b5e2a0de235c766.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 242-17 Filed 07/25/23 + +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/744a10d245b631b7b689e393b071f27710092e24d678a68a2b5e2a0de235c766.receipt.json b/vision-fixhub/court-05/744a10d245b631b7b689e393b071f27710092e24d678a68a2b5e2a0de235c766.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..04b3d54f9518254d767eea0995ab7f3ef4e03c7f --- /dev/null +++ b/vision-fixhub/court-05/744a10d245b631b7b689e393b071f27710092e24d678a68a2b5e2a0de235c766.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -34, + "dataset": "marble-joined", + "doc_id": "744a10d245b631b7b689e393b071f27710092e24d678a68a2b5e2a0de235c766", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "40a7c658f41df3e851285aea4e0bcd8da3b380bcc2858744b1d2319cfdd98b32", + "output_sha256": "7455bc05f62ae1b98c89aa7a95aba0d3cf8c6b4a325dad956b25474588d0dcb4", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7485c7922c54949976bbca177830801b27035806af8f2223855aaba60b8f4f3b.md b/vision-fixhub/court-05/7485c7922c54949976bbca177830801b27035806af8f2223855aaba60b8f4f3b.md new file mode 100644 index 0000000000000000000000000000000000000000..eca1bec91410c53687197f69d111bc0edef0e8e4 --- /dev/null +++ b/vision-fixhub/court-05/7485c7922c54949976bbca177830801b27035806af8f2223855aaba60b8f4f3b.md @@ -0,0 +1,31 @@ +Case 1:20-cr-00330-PAE +Document 787-3 Filed 07/21/25 + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES OF AMERICA, +1:20-CR-00330-PAE +vS. +GHISLAINE MAXWELL. +PROPOSED ORDER FOR ADMISSION PRO HAC VICE +The motion of David Oscar Markus, for admission to practice Pro Hac Vice in +the above captioned action is granted. +Applicant has declared that he is a member in good standing of the bar of the +state of Florida; and that his contact information is as follows: +David Oscar Markus +MARKUS/ +PLLC +40 NW 3RD STREET, PH1 +MIAMI, FL 33128 +Telephone: (305) 379-6667 +Fax: (305) 379-6668 +dmarkus@markuslaw.com +Applicant having requested admission Pro Hac Vice to appear for all purposes +as counsel for Ghislaine Maxwell in the above entitled action; +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice +in the above captioned case in the United States District Court for the Southern +District of New York. All attorneys appearing before this Court are subject to the +Local Rules of this Court, including the Rules governing discipline of attorneys. +Dated: +PAULA. ENGELMAYER +UNITED STATES DISTRICT JUDGE diff --git a/vision-fixhub/court-05/7485c7922c54949976bbca177830801b27035806af8f2223855aaba60b8f4f3b.receipt.json b/vision-fixhub/court-05/7485c7922c54949976bbca177830801b27035806af8f2223855aaba60b8f4f3b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..99abf45eb7d5f868077f29303554c18590b80cc8 --- /dev/null +++ b/vision-fixhub/court-05/7485c7922c54949976bbca177830801b27035806af8f2223855aaba60b8f4f3b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "7485c7922c54949976bbca177830801b27035806af8f2223855aaba60b8f4f3b", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "314be4f330581e96693f0ea82f13f50082c26da967468ad9c147ac21254fa9a7", + "output_sha256": "d0799e68b3558574a0e06ba48804863ecdba86c0d1ba5c712dd4d1250186f2cb", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/748b5f786431c61f694435c323cb2b492a72a5d9247efc6c4cb32ceb743a3f38.md b/vision-fixhub/court-05/748b5f786431c61f694435c323cb2b492a72a5d9247efc6c4cb32ceb743a3f38.md new file mode 100644 index 0000000000000000000000000000000000000000..e9f3051c6d1679c0b36bdb1bb4b65cd01e4268a2 --- /dev/null +++ b/vision-fixhub/court-05/748b5f786431c61f694435c323cb2b492a72a5d9247efc6c4cb32ceb743a3f38.md @@ -0,0 +1,45 @@ +Case 1:22-cv-10904-JSR Document 8-1 Filed 01/04/23 Page 1 of 2 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904 JSR +AFFIDAVIT OF +LINDA L +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +I, Linda fl, declare and state the following: +1. +I have never been convicted of a felony; +2. +I have never been censured, suspended, disbarred or denied admission or +readmission by any court; and +3. +there are no disciplinary proceedings presently against me. +I make this Affidavit in support of my Motion for Admission Pro Hac Vice to appear as +counsel for Plaintiff, Government of the United States Virgin Islands, in the above-captioned +action. +I hereby declare under penalty of perjury that the foregoing statements are true and correct. +4 +Dated: January +_ 2023 +Motley Rice LLC +401 9* Street NW, Suite 630 +Washington, DC 20004 +(202) 386-9626 phone / (202) 386-9622 fax +Isinger@motleyrice.com + + +Case 1:22-cv-10904-JSR Document 8-1 Filed 01/04/23 Page 2 of 2 +DISTRICT OF COLUMBIA l +SWORN to and subscribed before me this † +dup +NOTARY PUBLIC +My Commission Expires: 10/ 14 2027 +_ day of January 2023. +10-14-27 +DISTRICT +Of +2 diff --git a/vision-fixhub/court-05/748b5f786431c61f694435c323cb2b492a72a5d9247efc6c4cb32ceb743a3f38.receipt.json b/vision-fixhub/court-05/748b5f786431c61f694435c323cb2b492a72a5d9247efc6c4cb32ceb743a3f38.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0edbdaaa8a66217b91930d02471ae3d969644fb8 --- /dev/null +++ b/vision-fixhub/court-05/748b5f786431c61f694435c323cb2b492a72a5d9247efc6c4cb32ceb743a3f38.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "748b5f786431c61f694435c323cb2b492a72a5d9247efc6c4cb32ceb743a3f38", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "361c83af9e131e0290d47645e84f2b0270f85024ce5752e378cf7f6a7c96de94", + "output_sha256": "41ec303e58b2ee47e8edb2f7e605de8c0028260e26ac11b2d0071d143c574ad5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/74c8d0ddba9cd6fa86f7d70937f6f4c8fe775fa3ff78fc089f61a559c24b7ef3.md b/vision-fixhub/court-05/74c8d0ddba9cd6fa86f7d70937f6f4c8fe775fa3ff78fc089f61a559c24b7ef3.md new file mode 100644 index 0000000000000000000000000000000000000000..982d52abb89ab724bdba5f378580779ec6627c48 --- /dev/null +++ b/vision-fixhub/court-05/74c8d0ddba9cd6fa86f7d70937f6f4c8fe775fa3ff78fc089f61a559c24b7ef3.md @@ -0,0 +1,336 @@ +Case 1:20-cr-00330-PAE +Document 696 +(form modified within District on Sept. 30, 2019) +Filed 06/29/22 Page 1 of 8 +Sheet 1 +UNITED STATES DISTRICT COURT +Southern District of New York +UNITED STATES OF AMERICA +V. +GHISLAINE MAXWELL +JUDGMENT IN A CRIMINAL CASE +Case Number: S2 20 CR 330 (AJN) +USM Number: 02879-509 +BOBBI C. STERNHEIM +Defendant's Attorney +THE DEFENDANT: +•pleaded guilty to counts) +• pleaded nolo contendere to counts) +which was accepted by the court. +M was found guilty on counts) +after a plea of not guilty. +1, 3, 4, 5, 6 (judgment not entered on 1 & 5 as multiplicitous, Dkt. No. 657) +The defendant is adjudicated guilty of these offenses: +Title & Section +18 USC 371.F +Nature of Offense +CONSPIRACY TO TRANSPORT MINORS WITH +INTENT TO ENGAGE IN CRIMINAL SEXUAL +ACTIVITY +Offense Ended +7/30/2004 +Count +3 +The defendant is sentenced as provided in pages 2 through +of this judgment. The sentence is imposed pursuant to +the Sentencing Reform Act of 1984. +Z The defendant has been found not guilty on count(s) +2 +• Count(s) 7, 8 and underlying indictments • is are dismissed on the motion of the United States. +Date of Imposition of Judgment +6/29/2022 +Alie O. Notor +USDC SONY +DOCUMENT +ELECTRONICALLY FILED +DOC#: +DATE FILED: 6/29/2022 +Signature of Judge +ALISON J. NATHAN, US Circuit Judge sitting by designation +Name and Title of Judge +6/29/2022 +Date + + +Sheet IA +Filed 06/29/22 Page 2 of 8 +Judgment Page +2 +DEFENDANT: GHISLAINE MAXWELL +CASE NUMBER: S2 20 CR 330 (AJN) +ADDITIONAL COUNTS OF CONVICTION +Title & Section +18 USC 2423.F +18 USC 1591.F +Nature of Offense +TRANSPORTATION OF A MINOR WITH INTENT TO +ENGAGE IN CRIMINAL SEXUAL ACTIVITY +SEX TRAFFICKING OF AN INDIVIDUAL UNDER THE +Offense Ended +12/31/1997 +7/30/2004 +AGE OF EIGHTEEN +of +Count +4 +6 + + +AO 245B (Rev. 09/19) Judgment in Criminal Case +Sheet 2 +- Imprisonment +DEFENDANT: GHISLAINE MAXWELL +CASE NUMBER: S2 20 CR 330 (AJN) +Filed 06/29/22 Page 3 of 8 +Judgment — Page +3 +of +8 +IMPRISONMENT +The defendant is hereby committed to the custody of the Federal Bureau of Prisons to be imprisoned for a +The Defendant is sentenced to a term of 240 Months. +Count 3 a sentence of 60 Months. Count 4 a sentence of 120 Months. Count 6 a sentence of 240 Months. All Counts to +run concurrently. +Defendant was notified of her right to Appeal. +• The court makes the following recommendations to the Bureau of Prisons: +Defendant to be considered for designation to FCI Danbury. +Defendant to be considered for enrollment in FIT program. +• The defendant is remanded to the custody of the United States Marshal. +• The defendant shall surrender to the United States Marshal for this district: +at +a.m. +• p.m. +on +as notified by the United States Marshal. +• The defendant shall surrender for service of sentence at the institution designated by the Bureau of Prisons: +• before 2 p.m. on +• +as notified by the United States Marshal. +• +as notified by the Probation or Pretrial Services Office. +RETURN +I have executed this judgment as follows: +Defendant delivered on +at +to +, with a certified copy of this judgment. +UNITED STATES MARSHAL +By +DEPUTY UNITED STATES MARSHAL + + +Sheet 3. +— Supervised Release +DEFENDANT: GHISLAINE MAXWELL +CASE NUMBER: S2 20 CR 330 (AJN) +Filed 06/29/22 Page 4 of 8 +Judgment-Page +4 +of +8 +SUPERVISED RELEASE +Upon release from imprisonment, you will be on supervised release for a term of: +3 Years on Counts 3 and 4. 5 Years on Count 6 to run concurrently. +MANDATORY CONDITIONS +1. +2. +3. +You must not commit another federal, state or local crime./ +You must not unlawfully possess a controlled substance. +You must refrain from any unlawful use of a controlled substance. You must submit to one drug test within 15 days of release from +imprisonment and at least two periodic drug tests thereafter, as determined by the court. +• The above drug testing condition is suspended, based on the court's determination that you pose a low risk of future +substance abuse. (check if applicable) +4. You must make restitution in accordance with 18 U.S.C. §S 3663 and 3663A or any other statute authorizing a sentence of +restitution. (check if applicable) +5. E You must cooperate in the collection of DNA as directed by the probation officer, (check if applicable) +6. +M You must comply with the requirements of the Sex Offender Registration and Notification Act (34 U.S.C. § 20901, et seq.) as +directed by the probation officer, the Bureau of Prisons, or any state sex offender registration agency in the location where you +reside, work, are a student, or were convicted of a qualifying offense. (check if applicable) +7. • You must participate in an approved program for domestic violence. (check if applicable) +You must comply with the standard conditions that have been adopted by this court as well as with any other conditions on the attached + + +Filed 06/29/22 Page 5 of 8 +Judgment in a Criminal Casc +Sheet 3А +Supervised Release +JudgmentPage +5 +of +8 +DEFENDANT: GHISLAINE MAXWELL +CASE NUMBER: S2 20 CR 330 (AJN) +STANDARD CONDITIONS OF SUPERVISION +As part of your supervised release, you must comply with the following standard conditions of supervision. These conditions are imposed +because they establish the basic expectations for your behavior while on supervision and identify the minimum tools needed by probation +officers to keep informed, report to the court about, and bring about improvements in your conduct and condition. +1. You must report to the probation office in the federal judicial district where you are authorized to reside within 72 hours of your +release from imprisonment, unless the probation officer instructs you to report to a different probation office or within a different time +2. After initially reporting to the probation office, you will receive instructions from the court or the probation officer about how and +when you must report to the probation officer, and you must report to the probation officer as instructed +3. You must not knowingly leave the federal judicial district where you are authorized to reside without first getting permission from the +court or the probation officer. +4. +5. +You must answer truthfully the questions asked by your probation officer. +You must live at a place approved by the probation officer. If you plan to change where you live or anything about your living +arrangements (such as the people you live with), you must notify the probation officer at least 10 days before the change. If notifying +6. +hours of becoming aware of a change or expected change. +You must allow the probation officer to visit you at any time at your home or elsewhere, and you must permit the probation officer to +take any items prohibited by the conditions of your supervision that he or she observes in plain view. +You must work full time (at least 30 hours per week) at a lawful type of employment, unless the probation officer excuses you from +doing so. If you do not have full-time employment you must try to find full-time employment, unless the probation officer excuses +aware of a change or expected change. +8. You must not communicate or interact with someone you know is engaged in criminal activity. If you know someone has been +convicted of a felony, you must not knowingly communicate or interact with that person without first getting the permission of the +probation officer. +9. +If you are arrested or questioned by a law enforcement officer, you must notify the probation officer within 72 hours. +10. You must not own, possess, or have access to a firearm, ammunition, destructive device, or dangerous weapon (i.e., anything that was +designed, or was modified for, the specific purpose of causing bodily injury or death to another person such as nunchakus or tasers). +11. You must not act or make any agreement with a law enforcement agency to act as a confidential human source or informant without +first getting the permission of the court. +12. You must follow the instructions of the probation officer related to the conditions of supervision. +U.S. Probation Office Use Only +A U.S. probation officer has instructed me on the conditions specified by the court and has provided me with a written copy of this +judgment containing these conditions. For further information regarding these conditions, see Overview of Probation and Supervised +Release Conditions, available at: www.uscourts.gov. +Defendant's Signature +Date + + +Filed 06/29/22 Page 6 of 8 +Sheet 3D +- Supervised Release +JudgmentPage +6 +of +8 +DEFENDANT: GHISLAINE MAXWELL +CASE NUMBER: S2 20 CR 330 (AJN) +SPECIAL CONDITIONS OF SUPERVISION +You shall submit your person, and any property, residence, vehicle, papers, computer, other electronic communication, +data storage devices, cloud storage or media, and effects to a search by any United States Probation Officer, and if +needed, with the assistance of any law enforcement. The search is to be conducted when there is reasonable suspicion +concerning violation of a condition of supervision or unlawful conduct by the person being supervised. Failure to submit to +a search may be grounds for revocation of release. You shall warn any other occupants that the premises may be subject +to searches pursuant to this condition. Any search shall be conducted at a reasonable time and in a reasonable manner. +You shall undergo a sex-offense-specific evaluation and participate in an outpatient sex offender treatment and/or +outpatient mental health treatment program approved by the U.S. Probation Office. You shall abide by all rules, +requirements, and conditions of the sex offender treatment programs), including submission to polygraph testing and +refraining from accessing websites, chatrooms, instant messaging, or social networking sites to the extent that the sex +offender treatment and/or mental health treatment program determines that such access would be detrimental to your +ongoing treatment. You will not view, access, possess, and/or download any pornography involving adults unless +approved by the sex-offender specific treatment provider. You must waive your right of confidentiality in any records for +mental health assessment and treatment imposed as a consequence of this judgment to allow the U.S. Probation Office to +review the course of treatment and progress with the treatment provider. You must contribute to the cost of services +rendered based on your ability to pay and the availability of third-party payments. The Court authorizes the release of +available psychological and psychiatric evaluations and reports, including the presentence investigation report, to the sex +offender treatment provider and/or mental health treatment provider. +You must not have contact with the victims) in this case. This includes any physical, visual, written, or telephonic contact +with such persons. Additionally, you must not directly cause or encourage anyone else to have such contact with the victim +(s). +You must not have deliberate contact with any child under 18 years of age, unless approved by the U.S. Probation Office. +You must not loiter within 100 feet of places regularly frequented by children under the age of 18, such as schoolyards, +playgrounds, and arcades. You must not view and/or access any web profile of users under the age of 18. This includes, +but is not limited to, social networking websites, community portals, chat rooms or other online environment +(audio/visual/messaging), etc. which allows for real time interaction with other users, without prior approval from your +probation officer. +You must provide the probation officer with access to any requested financial information. +You must not incur new credit charges or open additional lines of credit without the approval of the probation officer unless +you are in compliance with the installment payment schedule. +If you are sentenced to any period of supervision, it is recommended that you be supervised by the district of residence. + + +Case 1:20-cr-00330-PAE Document 696 Filed 06/29/22 Page 7 of 8 +Sheet 5 — Criminal Monetary Penalties +Judgment - Page +DEFENDANT: GHISLAINE MAXWELL +CASE NUMBER: S2 20 CR 330 (AJN) +CRIMINAL MONETARY PENALTIES +The defendant must pay the total criminal monetary penalties under the schedule of payments on Sheet 6. +TOTALS +Assessment +S +300.00 +Restitution +Fine +$ 750,000.00 +AVAA Assessment* +S +of +8 +JVTA Assessment** +• The determination of restitution is deferred until +entered after such determination. +. An Amended Judgment in a Criminal Case (AO 245C) will be +• The defendant must make restitution (including community restitution) to the following payees in the amount listed below. +In priorin dancer or pera patial payment each payee shall receiver, arrant ly so one are real release ne +before the United States is paid +Name of Payee +Total Loss*** +Restitution Ordered +Priority or Percentage +TOTALS +0.00 +0.00 +• Restitution amount ordered pursuant to plea agreement S +• The defendant must pay interest on restitution and a fine of more than $2,500, unless the restitution or fine is paid in full before the +fifteenth day after the date of the judgment, pursuant to 18 U.S.C. § 3612(f). All of the payment options on Sheet 6 may be subject +to penalties for delinquency and default, pursuant to 18 U.S.C. § 3612(g). +• The court determined that the defendant does not have the ability to pay interest and it is ordered that: +• the interest requirement is waived for the • fine O restitution. +• the interest requirement for the • fine • restitution is modified as follows: + + +Case 1:20-cr-00330-PAE +Document 696 +Sheet 6- +- Schedule of Payments +DEFENDANT: GHISLAINE MAXWELL +CASE NUMBER: S2 20 CR 330 (AJN) +Filed 06/29/22 Page 8 of 8 +Judgment - Page +8 +of +8 +SCHEDULE OF PAYMENTS +Having assessed the defendant's ability to pay, payment of the total criminal monetary penalties is due as follows: +A Ø Lump sum payment of'$ 300.00 +due immediately, balance due +not later than +in accordance with DC. OD. DEor OFbelow: or +B • Payment to begin immediately (may be combined with +•C, +OD, or OF below); or +C • Payment in equal +(e.g.. weekly, monthly, quarterly) installments of S +over a period of +(e.g.. months or years), to commence +(eg, 30 or 60 days) after the date of this judgment; or +D • Payment in equal +(e.g., months or years), to commence +(e.g., weekly, monthly, quarterly) installments of S +over a period of +(e.g., 30 or 60 days) after release from imprisonment to a +term of supervision; or +(e.g., 30 or 60 days) after release from +* I Payrien duit the cout of su servie payient pill base on an issessment of the defendant abi d to pat a that te roor +FADE Special instructions regarding the payment of criminal monetary penalties: +the period of imprisonment. All criminal monetary +The defendant shall receive credit for all payments previously made toward any criminal monetary penalties imposed. +• Joint and Several +Case Number +Defendant and Co-Defendant Names +(including defendant number) +Total Amount +oint and Severa +amoun +Coreondipe Payce, +• The defendant shall pay the cost of prosecution. +• The defendant shall pay the following court costs): +• The defendant shall forfeit the defendant's interest in the following property to the United States: +prosecution and court costs. \ No newline at end of file diff --git a/vision-fixhub/court-05/74c8d0ddba9cd6fa86f7d70937f6f4c8fe775fa3ff78fc089f61a559c24b7ef3.receipt.json b/vision-fixhub/court-05/74c8d0ddba9cd6fa86f7d70937f6f4c8fe775fa3ff78fc089f61a559c24b7ef3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..4383fc7edc4c5c7cc184b8cf168c5fe2b39a5bee --- /dev/null +++ b/vision-fixhub/court-05/74c8d0ddba9cd6fa86f7d70937f6f4c8fe775fa3ff78fc089f61a559c24b7ef3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -592, + "dataset": "marble-joined", + "doc_id": "74c8d0ddba9cd6fa86f7d70937f6f4c8fe775fa3ff78fc089f61a559c24b7ef3", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "7b52b0e6dabded2345dd406f751556488da1fcd84c727600d8e943c4dc575174", + "output_sha256": "a588e1e33d8a657a1e5d279991d7d34936c4e88fd4e2fd095aad975fd0abf747", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/74ea52f46e90e45013cfb033fff4388ff6b69584a86cc1c17ede321f14a4c1ad.md b/vision-fixhub/court-05/74ea52f46e90e45013cfb033fff4388ff6b69584a86cc1c17ede321f14a4c1ad.md new file mode 100644 index 0000000000000000000000000000000000000000..01ffb3fb4d88a98a514dec01a6ac77308698a89d --- /dev/null +++ b/vision-fixhub/court-05/74ea52f46e90e45013cfb033fff4388ff6b69584a86cc1c17ede321f14a4c1ad.md @@ -0,0 +1,149 @@ +Case 1:22-cV-10904-JSR Document 268-17 Filed 08/07/23 Page 1 of 5 + + + +Case 1:22-cV-10904-JSR Document 268-17 Filed 08/07/23 Page 2 of 5 +14 V.I.C. $ 1721B +Statutes current through Act 8722 of the 2023 session of the 35th Legislature, including all code changes through +June 22, 2023 +Virgin Islands Code Annotated > TITLE FOURTEEN Crimes (Chs. 1 - 124) > Chapter 86. Sexual +Offender Registration and Community Protection (§§ 1721 — 1733) +§ 1721B. Tiered offenses + +1 +(a) Tier 1 Offenses. +(1) A "Tier 1" offense includes any sex offense for which a person has been convicted, or an attempt or +conspiracy to commit such an offense, that is not a "Tier 2" or "Tier 3" offense. +(2) A "Tier 1" offense also includes any offense for which a person has been convicted by any +jurisdiction, local government, or qualifying foreign country pursuant to section 1721A(c) that involves: +(i) the false imprisonment of a minor, +(ii) video voyeurism of a minor, or +(iii) possession or receipt of child pornography. +(3) Any sex offense covered by this act where punishment was limited to one year in jail shall be +considered a "Tier 1" sex offense. Local Offenses covered in this Statute include, but may not be +limited to: +(i) 14 V.I.C. § 1709, unless enhanced with 14 V.I.C. § 70Z (Use of intimidation by reason of the +actual or perceived race, religion, color, place of birth, sex or ethnicity or handicap of another +individual or group of individuals when engaging in unlawful sexual contact); +(ii) 14 V.I.C. § 121(use of invitation or device to prevail upon an adult to visit a place for the +purpose of prostitution of a minor); +(iii) 14 V./.C. § 1622(2), (3) & (4) (Prohibition on solicitation and use of minors in prostitution); +(iv) 14 V.I.C. § 1623(Knowingly leasing property to be used for prostitution of minors); or +(v) 14 V.I.C. § 1624(Keeping house of prostitution of minors). +(4) Conviction for any of the following federal offenses shall be considered a conviction for a "Tier 1" +offense: +(i) 18 U.S.C. § 1801 (video voyeurism of a minor), +(ii) 18 U.S.C. § 2252 (receipt or possession of child pornography), +(iii) 18 U.S.C. § 2252A (receipt or possession of child pornography), +(iv) 18 U.S.C. § 2252B (misleading domain names on the internet), +(v) 18 U.S.C. § 2252C (misleading words or digital images on the internet), +(vi) 18 U.S.C. § 2422(a) (coercion to engage in prostitution), +(vii) 18 U.S.C. § 2423(b) (travel with the intent to engage in illicit conduct), +(vili) +18 U.S.C. § 2423(c) (engaging in illicit conduct in foreign places), + + +Case 1:22-CV-10904-JSR Document 268-17 Filed 08/07/23 Page 3 of Page 2 of 4 +14 V.I.C. § 1721B +(ix) 18 U.S.C. § 2423(d) (arranging inducing, procuring or facilitating the travel in interstate +commerce of an adult for the purpose of engaging in illicit conduct for financial gain), +(x) 18 U.S.C. § 2424 (failure to file factual statement about an alien individual), or +(xi) 18 U.S.C. § 2425 (transmitting information about a minor to further criminal sexual conduct). +(5) Any military offense specified by the Secretary of Defense under section 115(a)(8)(C)(i) of Public +Law 105-119 (codified at 10 U.S.C. § 951 note) that is similar to those offenses outlined in section +1721B(a)(3) and (4) shall be considered a "Tier 1" offense. +(b) Tier 2 Offenses. +(1) Unless otherwise covered by section 1721B(c), any sex offense that is not the first sex offense for +which a person has been convicted and that is punishable by more than one year in jail is considered a +"Tier 2" offense. +(2) A "Tier 2" offense includes any sex offense against a minor for which a person has been convicted, +or an attempt or conspiracy to commit such an offense that involves: +(i) the use of minors in prostitution, including solicitations, +(ii) enticing a minor to engage in criminal sexual activity, +(iii) sexual contact with a minor 13 years of age or older, whether directly or indirectly through the +clothing, that involves the intimate parts of the body, +(iv) the use of a minor in a sexual performance, +(v) the production or distribution of child pornography, or +(vi) a non-forcible Sexual Act with a minor 16 or 17 years old. +(3) Local Offenses covered under Tier 2 include, but may not be limited to: +(i) 14 V.I.C. § 134(a)(3)(Trafficking of persons for illegal sexual activity based upon convictions +under 14 V.I.C. §§ 1622, 1623, 1624 & 1625, +(ii) 14 V.I.C. § 1024(b) (Distribution of child pornography), +(iii) 14 V.I.C. § 1025(Distribution of obscene matter to a minor when the obscene matter depicts a +minor engaging in sexual conduct and is distributed for the purpose of enticing the minor into +engaging in sexual conduct), +(iv) 14 V.I.C. § 1700a(Aggravated rape in the 2nd degree when the minor is under eighteen but +thirteen years or older) +(v) 14 V.I.C. § 1702(Rape in the Second Degree when minor is under 16 but over 13 years of age) +(vi) 14 V.I.C. § 121(use of invitation or device to prevail upon a minor to visit a place for the +purpose of prostitution) +(vii) 14 V.I.C. § 1027(Employment of minor to perform prohibited acts), or +(vill) 14 V.I.C. § 489(Computer pornography). +(4) Conviction for any of the following federal offenses shall be considered a conviction for a "Tier 2" +offense: +(i) 18 U.S.C. § 1591 (sex trafficking by force, fraud, or coercion), +(ii) 18 U.S.C. § 2244 (abusive sexual contact, where the victim is 13 years of age or older), +(iii) 18 U.S.C. § 2251 (sexual exploitation of children), +(iv) 18 U.S.C. § 2251A (selling or buying of children), +(v) 18 U.S.C. § 2252 (material involving the sexual exploitation of a minor), + + +Case 1:22-CV-10904-JSR Document 268-17 Filed 08/07/23 Page 4 of Page 3 of 4 +14 V.I.C. S 1721B +(vi) 18 U.S.C. § 2252A (production or distribution of material containing child pornography), +(vil) 18 U.S.C. § 2260 (production of sexually explicit depictions of a minor for import into the +United States), +(viii) 18 U.S.C. § 2421 (transportation of a minor for illegal sexual activity), +(ix) 18 U.S.C. § 2422(b) coercing a minor to engage in prostitution), +(x) 18 U.S.C. § 2423(a) (transporting a minor to engage in illicit conduct), or +(xi) 18 U.S.C. § 2423(d) (arranging, inducing procuring or facilitating the travel in interstate +commerce of a minor for the purpose of engaging in illicit conduct for financial gain). +(5) Any military offense specified by the Secretary of Defense under section 115(a)(8)(C)(i) of Public +Law 105-119 (codified at 10 U.S.C. § 951 note) that is similar to those offenses outlined in subsections +1721B(b)(1), (2), (3) or (4) above shall be considered a "Tier 2" offense. +(c) Tier 3 Offenses. +(1) Any sex offense that is punishable by more than one year in jail where the offender has at least one +prior conviction or an attempt or conspiracy to commit such an offense for a Tier 2 sex offense, or has +previously become a Tier 2 sex offender, is a "Tier 3" offense. +(2) A "Tier 3" offense includes any sex offense for which a person has been convicted, or an attempt or +conspiracy to commit such an offense, that involves: +(i) non-parental kidnapping of a minor, +(ii) a sexual act with another by force or threat, +(iii) a sexual act with another who has been rendered unconscious or involuntarily drugged, or who +is otherwise incapable of appraising the nature of the conduct or declining to participate, or +(iv) sexual contact with a minor 12 years of age or younger, including offenses that cover sexual +touching of or contact with the intimate parts of the body, either directly or through the clothing. +(3) Local Offenses covered under Tier 3 for which a person has been convicted, or has been convicted +of an attempt or conspiracy to commit such an offense, include, but may not be limited to: +(i) 14 V.I.C. § 1051(non-parental kidnapping of a minor), +(ii) 14 V.I.C. § 1052(b)(kidnapping of persons for purpose of rape), +(iii) 14 V.I.C. § 1700(Aggravated rape), +(iv) 14 V.I.C. § 1701(Rape in the first degree), +(v) 14 V.I.C. § 1700a(Aggravated rape in the second degree when force is used), +(vi) 14 V.I.C. § 1708(Unlawful sexual contact in the first degree), +(vil) 14 V.I.C. § 1709when a person is also convicted of 14 V.I.C. § 70Z (Unlawful sexual contact in +the second degree when motivated by the victim's race, religion, color, place of birth, sex, ethnicity +or handicap), +(vili) 14 V.I.C. § 506(Aggravated child abuse when it involves the use of a minor for the purpose of +exploitation or to engage in sexual conduct), +(ix) 14 V.I.C. § 1625( Prohibition on pandering when the pandering involves the use of minors in +sexual acts), or +(x) 14 V.I.C. § 505(child abuse of a minor involving sexual exploitation or sexual acts). +(4) Conviction for any of the following federal offenses shall be considered conviction for a "Tier 3" +offense: + + +Case 1:22-CV-10904-JSR Document 268-17 Filed 08/07/23 Page 5 of Page 4 of 4 +14 V.I.C. § 1721B +(i) 18 U.S.C. § 2241 (aggravated sexual abuse), +(ii) 18 U.S.C. § 2242 (sexual abuse), +(iii) Where the victim is 12 years of age or younger, 18 U.S.C. § 2244 (abusive sexual contact); or +(iv) 18 U.S.C. § 2243 (sexual abuse of a minor or +(5) Any military offense specified by the Secretary of Defense under section 115(a)(8)(C)(i) of Public +Law 105-119 (codified at 10 U.S.C. § 951 note) that is similar to those offenses outlined in subsections +1721B(c)(1), (2), (3) or (4) above shall be considered a "Tier 3" offense. +History +—Added July 18, 2012, No. 7372, § 3, Sess. L. 2012, p. 125-131. +Virgin Islands Code Annotated +Copyright © 2023 Office of the Code Revisor, Legislature of the Virgin Islands All rights reserved. +End of Document diff --git a/vision-fixhub/court-05/74ea52f46e90e45013cfb033fff4388ff6b69584a86cc1c17ede321f14a4c1ad.receipt.json b/vision-fixhub/court-05/74ea52f46e90e45013cfb033fff4388ff6b69584a86cc1c17ede321f14a4c1ad.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..353245421586af11f772ffb31cf2d70146f4a860 --- /dev/null +++ b/vision-fixhub/court-05/74ea52f46e90e45013cfb033fff4388ff6b69584a86cc1c17ede321f14a4c1ad.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -78, + "dataset": "marble-joined", + "doc_id": "74ea52f46e90e45013cfb033fff4388ff6b69584a86cc1c17ede321f14a4c1ad", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "a725bdca10ccbdaed069411eeec4c2aad8f51a77854fe6c68b1c6c61577ff5fc", + "output_sha256": "5a62405bd12197de13f07f520b078ac68fb3f7b2c78c591225630f00d3f5d274", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/750cc68c1785be3f33ae61fbdb4cffff90f38232bcd8c923a3ae340ebaf1e4ad.md b/vision-fixhub/court-05/750cc68c1785be3f33ae61fbdb4cffff90f38232bcd8c923a3ae340ebaf1e4ad.md new file mode 100644 index 0000000000000000000000000000000000000000..a4ed25be4a81ca6f85a995f3eaffc81aa0f5f367 --- /dev/null +++ b/vision-fixhub/court-05/750cc68c1785be3f33ae61fbdb4cffff90f38232bcd8c923a3ae340ebaf1e4ad.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 226-9 Filed 07/24/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/750cc68c1785be3f33ae61fbdb4cffff90f38232bcd8c923a3ae340ebaf1e4ad.receipt.json b/vision-fixhub/court-05/750cc68c1785be3f33ae61fbdb4cffff90f38232bcd8c923a3ae340ebaf1e4ad.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..911cf4094f269b21071f272940581694b70a6ed0 --- /dev/null +++ b/vision-fixhub/court-05/750cc68c1785be3f33ae61fbdb4cffff90f38232bcd8c923a3ae340ebaf1e4ad.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "750cc68c1785be3f33ae61fbdb4cffff90f38232bcd8c923a3ae340ebaf1e4ad", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "bb06a3e377438ec971e66ad9025879125650934a99425b51185985911223f866", + "output_sha256": "feb7c4a9d54208a4aa9dd8c92e1bc484f131f14f8e4bf1c08cc14b27cc50c15d", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/752de520a5fe5bf329f32b748c5fe5d76f7e1898fbd5644be740784f62c03658.md b/vision-fixhub/court-05/752de520a5fe5bf329f32b748c5fe5d76f7e1898fbd5644be740784f62c03658.md new file mode 100644 index 0000000000000000000000000000000000000000..6ded384c32e27b44a01c31411f043575890e8294 --- /dev/null +++ b/vision-fixhub/court-05/752de520a5fe5bf329f32b748c5fe5d76f7e1898fbd5644be740784f62c03658.md @@ -0,0 +1,1024 @@ +Case 1:22-cv-10904-JSR Document 174-6 Filed 06/12/23 Page 1 of 20 + + + +Case 1:22-cv 399/NER Operant 174§giga 062{308999 a pf 20 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +1 +2 +3 +4 +5 +6 +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party +Plaintiff. +: Case Number: +: 1:22-cv- +: 10904-JSR +: +7 +8 +9 +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +: +JAMES EDWARD STALEY +Third-Party Dozendant. +10 +11 +12 +- +MAY 24, +2023 +HIGHLY CONFIDENTIAL +- +13 +Videotaped deposition of +14 +15 +STEPHEN CUTLER, taken pursuant to notice, +was held at the law offices of Boies +16 +17 +Schiller Flexner ILP, 55 Hudson Yards, +New York, New York, commencing at +18 +9:40 a.m., on the above date, before +19 +Amanda Dee Maslynsky- +• a Certified +20 +Realtime Reporter and Notary Public in +21 +and for the State of New York. +22 +23 +- +- +GOLKOW LITIGATION SERVICES, INC. +877.370.3377 ph| 917.591.5672 fax +deps@golkow.com +24 +Page 1 + + +Case 1:22-cv-390NSR @perrent 1741§gFigd 066723d&ag9 ả pf 20 +APPEARANCES : +1 +2 +3 +4 +5 +6 +MOTLEY RICE LLC +BY: MIMI Y. LIU, ESQUIRE +BY: LINDA +1, ESQUIRE +BY: BRENDAN C. AUSTIN, ESQUIRE +401 9th Street NW +Suite 630 +Washington,_DC 20004 +(202) 232-5504 +mliu@motleyrice.com +lsinger@motleyrice.com +baustinemotleyrice.com +Representing the Plaintiff, +U.S. Virgin Islands +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +WILMER CUTLER PICKERING HALE AND +DORR LLP +BY: +| BOUCHOUx, ESQUIRE +7 World Trade Center +250 Greenwich Street +New York, New York 10007 +(212) 230-8800 +Representing the Defendant, +JPMorgan Chase Bank N.A. +POMPANO LAW +BY: 1 +I D. OATES, ESQUIRE +1701 East Atlantic Boulevard +Suite 4 +Pompano Beach, Florida 33060 +(954) 942-6500 +Representing the Defendant, +JPMorgan Chase Bank N.A. +Page 2 +EFTÁ02807989 + +Case 1:22-cv-39900NSR Aperrent 1741§gFigd 066723d8ag9 4 pf 20 +APPEARANCES: +(Continued) +2 +3 +4 +5 +6 +MASSEY & GAIL LLP +BY: LEONARD A. GAIL, ESQUIRE +50 East Washington Street +Suite 400 +Chicago, +Illinois 60602 +(312) 283-1590 +1gail@masseygail.com +Representing the Defendant, +JPMorgan Chase Bank N.A. +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +MILBANK LLP +BY: SCOTT A. EDELMAN, ESQUIRE +BY: ANDREW LICHTENBERG, ESQUIRE +BY: ILIANA ONGUN, ESQUIRE +55 Hudson Yards +New York, New York 10001 +(212) 530-5000 +Longnen. Iban.comnk.com +Representing the Witness +VIA ZOOM: +BY : +1930 Broadway +Suite 12B +New York, New York 10023 +(833) 780-0834 +info@epllc.com; +Representing the Plaintiff, +Jane Doe +Page 3 +EFTÁO2807990 + +Case 1:22-cv-39900NSR Aperrent 1741fghigd 066723a8ag9 a of 20 +1 +APPEARANCES: +(Continued) +2 VIA ZOOM: +4 +5 +6 +_ & CONNOLLY LLP +BY: EDEN SCHIFFMANN, ESQUIRE +BY: KATHERINE A. TREF, EsQUIRE +›80 Maine Avenue Sh +Washington, DC 20024 +(202) 434-5000 +eschiffmann@wc.com +ktreizewc.com +Representing Third-Party Defendant, +James Edward Staley +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +MASSEY & GAIL LLP +BY: SHIVA KOORAGAYALA, ESQUIRE +50 East Washington Street +Suite 400 +chicago, +Illinois 60602 +(312) 283-1590 +skooragayala@masseygail.com +Representing the Defendant, +JPMorgan Chase Bank N.A. +ALSO PRESENT: +Danny Ortega, Videographer +- +- +- +Page 4 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +Case 1:22-cv-390NSR @perrent 174rfgFilgd 066R2Ba8agg 8 of 20 +the stenographic record. The +court reporter today is Amanda +and will now swear in the +witness. +--- +STEPHEN CUTLER, after having +been duly sworn, was examined and +testified as follows: +- - +- +EXAMINATION +--- +BY MS. LIU: +A. +e. +Good morning. +Good morning. +Could you please +state your +name? +A. +Stephen M. Cutler. +l. +And, Mr. Cutler, you +currently live in Scarsdale, New York? +A. +Yes. +Do you have any intention of +moving before November of 2023? +A. +NO. +Do you plan to testify at +Page 12 + + +Case 1:22-cv-390NSR @errent 1741§gFigd 0667R3d8ag9 a pf 20 +1 +2 +embarked upon was the only reason, +or even a primary reason, to exit +3 +Mr. Epstein. +4 BY MS. LIU: +5 +You had already decided +6 there were other reasons? +7 +A. +Yeah. +I don't think I was +8 +oblivious to the issue that William +9 +raised. But I -- in my own mind, I don't +10 +remember it as being the core of the -- +11 +of the issue that drove my conclusion. +12 +Do you recall William +13 Langford saying to you, AML +14 +investigations does not want -- believe +15 +we should retain Jeffrey Epstein as a +16 +client, in early 2011? +17 +A. +I don't remember him +18 +referring to AML investigations in +19 particular. I think what he communicated +20 to me was concern about the reputational +21 +issues. Those concerns are heightened, +22 +if you will, by the human trafficking +23 +initiative that we're doing, given that +24 +he was convicted of these crimes. +Page 343 + + +1 +ongoing human trafficking through Jeffrey +2 Epstein? +3 +A. +Here is what I was +4 interested in: +If Mr. Epstein was +5 continuing to engage in unlawful +6 +activity, we didn't want him as a client. +7 +We understood that he had +8 +engaged in unlawful activity in the past. +9 +10 +That, itself, raised issues. But we were +continuing to serve as his bank and +11 maintain his accounts. +12 +If he was involved in -- +13 +in -- if he continued to be involved in +14 +criminal activity, we did not want to +15 +maintain those accounts. +16 +e. +And what did you do to +17 +determine whether or not Jeffrey Epstein +18 +was continuing to be involved in criminal +19 activity, namely human trafficking? +20 +A. +Right. I -- again, I would +21 +not have personally been involved in +22 that. But we had a compliance department +23 and an anti-money laundering function +24 +with well-regarded people. And I trusted +Page 363 + + +Case 1:22-cv 39/NER Operant 1746giga ∞62₽308999 a pr 20 +1 them to have done the work that they +2 needed to do in light of Mr. Epstein's +3 status as +a -- as a convicted felon and +4 as a high-risk client, to do everything +5 that they could to protect the bank. +6 +e. +And they all did their job, +right, Mr. Cutler? Your lawyers and +compliance personnel told you nobody +wanted to keep Mr. Epstein as a client, +correct? +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +MR. GAIL: Objection. +MR. EDELMAN: Objection. +That's - again, you have two +questions, and it's really just a +speech. +So ask a question. +BY MS. LIU: +19 +20 +21 +22 +23 +24 +under you, correct? +A. +function. +AML operations - that's +That's within the AML +e. +- went to private bank, +risk meeting late last week requesting +that we exit this relationship, correct? +That's what we saw on the +Page 364 + + +2 +3 +4 +5 +6 +document, right? +MR. EDELMAN: Objection. +MR. GAIL: Objection. +MR. EDELMAN: You're +reading - are you reading from a +document? Are you asking him to +remember what he said word for +word? Come on. +BY MS. LIU: +l. +8 +9 +10 +Anne Verdon -- +11 +MR. EDELMAN: Let's use the +12 +time. +13 BY MS. LIU: +14 +l. +Anne Verdon, the general +15 +16 +counsel for the private bank, was not in +favor of having retained Jeffrey Epstein +17 +as a client? +18 +A. +Nor was I. +19 +Right. The lawyers and +20 +compliance and -- who reported up to you +21 +and yourself looked at Jeffrey Epstein +22 +and your evaluation was he should not be +23 +a client at the bank, correct? +24 +A. +Yes. +Page 365 + + +1 22v +1 +goings on with respect to Jeffrey +2 Epstein's exit? +3 +A. +I'm assuming this relates to +4 Mr. Epstein. It doesn't say that, but +I'm assuming that's the case. +6 +If it's the case, then it +7 +appears that Mary Erdoes was -- had +8 +included me on the list of people to whom +9 +10 +she kept apprised of the exiting process. +I'm going to hand you two +11 +12 +documents together. This is Exhibit-7 +from the Mary +deposition. +13 +14 +And, actually, I'll hold the +other one and ask you about this one +15 +first. +16 +So I will represent to you, +17 +18 +Mr. Cutler, this is not a document that +JPMorgan produced to us in this case. +19 This is a document that we put together +20 based on information provided to us in +21 this litigation from JPMorgan and we have +22 entitled it, Cash Withdrawals/Direct +23 +Payments to Women and Girls from Epstein +24 +JPMC Accounts 2003 to 2013. +Page 442 + + +1 +Do you see that? +2 +A. +I do. +3 +e. +Okay. So you can see, for +4 +example, that - on the first page, +5 +you'll see that there are numerous, +6 +starting with cash, it's in alphabetical +order, there are numerous cash +withdrawals. +8 +9 +Do you see the whole first +10 +page after +, you see +11 cash, cash, cash, cash, all the way to +12 the bottom. +13 +Do you see that? +14 +15 +16 +17 +18 +A. +Yes. +e. +Okay. You also see the +names of women and girls who we believe +had payments made to them out of an +account that was either Jeffrey Epstein's +account or an account related to Jeffrey +Epstein. +A. +20 +21 +22 +23 +24 +Okay. +So you'll see, for example, +just to give an example, the first entry +is Jeffrey Epstein, it lists an account +Page 443 + + +1 +number, date 7/16/2003, year 2003, amount +2 $1,000, payee, and it's a woman's name, +3 +4 +Do you see that? +5 +A. +I do. +6 +Now, I'm not asking you to +7 +8 +confirm the accuracy of this document, +obviously you cannot. I'm just asking +9 +you to assume that the payments listed on +10 +here, for purposes of my question, are +11 +compiled from information gathered in +12 this litigation. +13 +14 +15 +16 +A. +e. +A. +e. +Okay. +Do you understand that? +Yes. +Okay. +So from this +17 +spreadsheet, which was the entirety of +18 +the cash withdrawals and direct payments +19 to women and girls that we could glean +20 +from evidence provided in this case, I +21 +have isolated all of the cash withdrawals +22 +or direct payments to women and girls +23 +24 +that were made in 2013, including +payments that were made after the filing +Page 444 + + +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +Case 1 +1 +of that August suspicious activity +2 +report. +3 +And I'm going to show that +4 to you. It's Exhibit-37. +5 +- - +6 +(Whereupon, Exhibit +Cutler-37, No +, Epstein's +payments to Women and Cash (2013), +was marked for identification.) +-- - +MR. EDELMAN: So there was +no question as to that last +exhibit? +MS. LIU: Right. I'm just +asking him if he understands what +I'm asking him to assume. +BY MS. LIU: +Okay. So, Mr. Cutler, do +you see the first entry, account name +Jeffrey Epstein, date, 1/14/2013, year +2013, amount $10,000, payee, +? +A. +Do you see that? +I do. +Page 445 + + +1 +e. +You would agree that the +2 name +would appropriately +3 be referred to as an Eastern European +4 name? +5 +MR. GAIL: Objection. +6 +MR. EDELMAN: Objection. +7 +THE WITNESS: I don't know. +8 +BY MS. LIU: +9 +What about +10 +11 +12 +would you consider that to be +an Eastern European name? +A. +I don't -- it could be +13 Russian. It could be Eastern European. +14 I don't know. +15 +l. +Okay. So it could be +16 Russian or it could be Eastern European. +17 +And then we have seen +18 +19 +A. +20 +e. +'s name, right, the next one? +Right. +Have you heard of the name +21 +22 +23 +A. +e. +That doesn't sound familiar. +You see a lot of +24 +• you see that? +Page 446 + + +1 +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +1 22v +A. +e. +I do. +All right. +A. +e. +Okay. +August of 2013. All right. +So let's look at August and +beyond. +A. +Okay. +August Ist, 2013, a payment +is made of $20,000 in cash from Jeffrey +Epstein's account at JPMorgan. +August 21st, 2013, after the +13 exit conversation with Jeffrey Epstein, +we see a payment of $15,000 to +• +Do you see that? +A. +I do. +MR. GAIL: Object to the +first part of the question. It +wasn't a question. +BY MS. LIU: +l. +August 23rd, 2013, we see a +payment handled by JPMorgan from Jeffrey +Epstein's account to +in +Page 447 + + +2 +3 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +Case 1 +the amount of $1, 670. +Do you see that? +A. +I do. +August 26th, 2013, $2,000 +from Jeffrey Epstein's JPMorgan account +to +A. +Do you see that? +I do. +August 30th, 2013, $520 from +Jeffrey Epstein's JPMorgan account to +Do you see that? +A. +I do. +We'll keep going. +September 20, 2013 - +MR. +EDELMAN: Are you +filibustering? +BY MS. LIU: +- $15,000 - +MR. EDELMAN: Is there a +question that has some relevance? +Why are you wasting our time? +MS. LIU: You can object to +form. +Page 448 + + +Case 1:22-cv-1998b&R earment 174 9 giley 0617/23 aBagei t81of 20 +1 +2 +MR. EDELMAN: I object to +form and to the fact that you +are -- +4 +MS. LIU: Thank you. You +5 +can stop talking. +6 +MR. EDELMAN: -- totally +7 +wasting time. +8 +BY MS. LIU: +9 +l. +Mr. Cutler, do you see there +10 is an entry, 9/24/2013 — 9/3/2013, a +11 payment of $15,000 from Jeffrey Epstein's +12 +account to +? +13 +Do you see that? +14 +15 +A. +e. +I do. +9/24/2013, $586.25 to +16 +17 +Do you see that? +18 +A. +I do. +19 +9/27/2013, $2,000, again to +20 +1. +21 +Do you see that? +22 +A. +I do. +23 +10/3/2013, $7,143.81, again +24 +to +Page 449 + + +Case 1 22v 899& gme 1749 |99 0&8?23089110{20 +1 +2 +3 +4 +Do you see that? +A. +I do. +MR. GAIL: Can we stipulate +everything on here is on here? +BY MS. LIU: +e. +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +We go on to the next page. +10/8/2013, months after the +exit conversation, +$440 to +A. +Do you see that? +I do. +10/10/2013, Jeffrey Epstein, +$1,495 to +A. +Epstein to +Do you see that? +I do. +10/15/2013, from Jeffrey +$20,000. +A. +e. +Do you see that? +I do. +10/15/2013, Jeffrey Epstein, +$900 to +A. +e. +Do you see that? +I do. +To the extent all of these +Page 450 + + +1 transactions accurately reflect payments +2 of cash made by Jeffrey Epstein to women +3 and girls, or withdrawals he made in +4 cash, you would agree with me that all of +5 the ones we just read occurred after +6 +7 +and also after the decision had been made +8 +to exit Jeffrey Epstein, correct? +9 +MR. GAIL: Objection. +10 +11 +THE WITNESS: I actually +don't know when the checks were +12 +13 +14 +written and when they cleared, et +cetera, et cetera. +But if you represent to me +15 +that these checks were written +16 +17 +after the accounts were closed, I +accept the representation. +18 BY MS. LIU: +19 +Thank you. You can put that +20 document away. +21 +22 +23 +MR. GAIL: Can we get a time +check? Go off the record. +MR. LICHTENBERG: We have +24 +one. +Page 451 \ No newline at end of file diff --git a/vision-fixhub/court-05/752de520a5fe5bf329f32b748c5fe5d76f7e1898fbd5644be740784f62c03658.receipt.json b/vision-fixhub/court-05/752de520a5fe5bf329f32b748c5fe5d76f7e1898fbd5644be740784f62c03658.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ecf6b923d21bca4cc23329752b07891e066bce0e --- /dev/null +++ b/vision-fixhub/court-05/752de520a5fe5bf329f32b748c5fe5d76f7e1898fbd5644be740784f62c03658.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -739, + "dataset": "marble-joined", + "doc_id": "752de520a5fe5bf329f32b748c5fe5d76f7e1898fbd5644be740784f62c03658", + "engine": "marble-apple-vision", + "event_count": 20, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "f62ef31278da89b85af965cc1f937b4edc21e8eb85866fbf50c237eeec73569f", + "output_sha256": "dda3b4b49f19c33d98d35995b750a50a7780e8321cdf154a12e3fc59b518f4d2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/753d0149073bb83b70557772e7dba21678f83d406b5d478141c81930702f52e0.md b/vision-fixhub/court-05/753d0149073bb83b70557772e7dba21678f83d406b5d478141c81930702f52e0.md new file mode 100644 index 0000000000000000000000000000000000000000..312dd3b166dc9277d69275e89d99ceb0499a3bb1 --- /dev/null +++ b/vision-fixhub/court-05/753d0149073bb83b70557772e7dba21678f83d406b5d478141c81930702f52e0.md @@ -0,0 +1,236 @@ +Case 1:20-cr-00330-PAE Document 704 | +Filed 07/12/22 Page 1 of 8 +U.S. Department of Justice +United States Attorney +Southern District of New York +The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007 +December 14, 2021 +The Honorable Alison J. Nathan +United States District Court +Southern District of New York +United States Courthouse +40 Foley Square +New York, New York 10007 +Re: +United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) +Dear Judge Nathan: +The Government respectfully submits this letter in opposition to the defendant's request to +permit three witnesses to testify using pseudonyms or first names. The defendant's unprecedented +request seeks relief for an issue that arises in a large number of cases, and that relief is not necessary +to protect the defendant's constitutional rights. Accordingly, the Government opposes the motion. +I. +Applicable Law +It is "firmly established" that "the press and general public have a constitutional right of +access to criminal trials." Globe Newspaper Co. v. Superior Court for Norfolk County, 457 U.S. +596, 603 (1982); see United States v. Alcantara, 396 F. 3d 189, 194-95 (2d Cir. 2005) (describing +the "qualified First Amendment right to attend trials"). +It is well settled that the names of certain categories of trial witnesses can be withheld from +1 + + +Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 2 of 8 +the public, even though the witness testifies in open court. But those categories are limited and +narrowly circumscribed. For instance, victims in sex abuse cases regularly testify using +pseudonyms. (See Gov't Omnibus Mots. in Limine at 7-8, Dkt. No. 380 (collecting cases)). In +those cases, victims often testify "in explicit detail," and revealing victim identities "could chill +the willingness of other alleged victims of sex crimes to come forward." See Order at 2, +No. 17 Cr. 281 (ERK) (E.D.N.Y. Dec. 18, 2017), Dkt. No. 34; see also Globe Newspaper Co., 457 +U.S. at 607 (agreeing that "safeguarding the physical and psychological well-being of a minor" is +a "compelling" interest); 18 U.S.C. § 3771(a)(1), (a)(8) (providing crime victims a right to be +"reasonably protected from the accused" and to be "treated with fairness and with respect for the +victim's dignity and privacy"). Courts also permit undercover law enforcement officers to testify +using pseudonyms when testifying about facts related to their work, typically when doing so also +poses safety concerns See, e.g., United States v. Urena, 8 F. Supp. 3d 568, 572-73 (S.D.N.Y. +2014) (permitting an undercover officer to testify using an alias "to protect UC-188's personal +safety and the viability of his current and future undercover investigation"); see also United States +v. Schulte, 436 F. Supp. 3d 698, 706-07 (S.D.N.Y. 2020) ("Permitting certain witnesses to testify +using a pseudonym and certain witnesses to testify by first name only protects the safety and +efficacy of the CIA officers."). +Il. +Factual Background +Consistent with well-worn precedent for sex abuse cases, the Government sought and +received authorization from the Court for to two Minor Victims, Jane and Kate, to testify under +pseudonyms, and for two others, Carolyn and Melissa, to be referenced using only their first +names. The Government also sought and received authorization from the Court to refer to other +2 + + +Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 3 of 8 +witnesses using pseudonyms or first names, and to redact or seal certain exhibits, as a further +measure to protect the identities of the four Minor Victims. The Government did not argue that +those witnesses merited pseudonyms on their own, but rather that they needed derivative +anonymity to protect the Minor Victims. +Numerous other witnesses testified at trial for the Government under their true name, +including those closely associated with the defendant and Epstein, such as Larry Visoski, Juan +Alessi, David Rodgers, and +And the Government did not seek anonymity for a +number of other witnesses the Government ultimately did not call at trial.' +The defendant now seeks anonymity protection for three lay witnesses, none of whom are +offered to testify as victims of sexual abuse: +, and +III. Discussion +The defendant's motion should be denied for two reasons. First, it seeks anonymity for +categories of witnesses that courts generally have not previously permitted to testify with their +identities protected. Second, the defendant's request does not implicate her right to a fair trial or +to present a defense. +First, none of the defense witnesses satisfy any of the established categories of witnesses +who courts have permitted to testify under pseudonyms. The defendant does not even suggest that +fits into any such category. (Def. Letter at 8-9). Indeed, the defense concedes +' The Government also offered a large number of exhibits under seal or in redacted form. Those +requests largely, if not entirely, concerned (1) witnesses whom the Court permitted to testify using +pseudonyms or under their first names; (2) personal identifying information, such as addresses; (3) +information related to third parties, that is, individuals who are not testifying at trial or at issue in +the case; or (4) exhibits where information for testifying witnesses was co-mingled with private +information so extensively that redactions were impractical. +3 + + +Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 4 of 8 +that "[t]here is no allegation that +is a victim of any improper or illegal conduct by Mr. +Epstein or Ms. Maxwell" and offers no suggestion that +would face any particularized harm +should she testify under her true name. (Def. Letter at 8). She is no different from the several +Government witnesses who were closely associated with Maxwell and Epstein who have already +testified under their true names. There is accordingly no legal basis for +to testify under a +pseudonym. +For +the defendant claims that she is the same +who, on crossexamination, Jane recalled participating in sexualized massages with her and Epstein after Jane +reached the age of consent and moved to New York.' On this theory, which the Government +disputes, the defendant claims +is a victim-witness entitled to the same solicitude as the +victims who testified in the Government's case-in-chief. (Def. Letter at 7-8). The defendant's +position is misplaced. First, the defendant has not established that +is the same +that +Jane referenced in her testimony. Indeed, the Government anticipates filing a separate motion to +preclude +testimony in part because there is an insufficient basis to find that +testimony would in fact contradict Jane's. +Second, and relatedly, it appears based on the defendant's Rule 26.2 disclosures that +will testify that she was not a victim of Epstein and the defendant. (Presumably, if she were, the +defendant would not be calling +) Unlike the Government's victim-witnesses, then, +testimony will contain no explicit details about sexual abuse, her dignity and privacy are not at += The Government disputes this characterization of Jane's testimony: Jane testified on crossexamination that a " +participated in those massages, not that +did so. +Defense counsel chose not to ask for a last name or otherwise attempt to identify to which +" she was referring. +4 + + +Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 5 of 8 +stake in the manner of other victims, and testifying under her true name will not chill the decision +of other victims to come forward. The defendant can hardly invoke the Crime Victims' Rights +Act to say +is a victim for purposes of her pseudonym motion, just so +can take the +stand and say she is not a victim. +With respect to +, the defendant argues this witness is entitled to privacy +protection as +(Def. Letter at 3). The +defendant has not produced any Rule 26.2 disclosures regarding +so the Government has +very limited information regarding her identity and no information about her expected testimony. +But it does not appear from the defendant's letter that her testimony will concern anything +sensitive. Nor does it appear that +It is not clear then why +revelation of +"true name could impact her security and professional responsibilities" +(Def. Letter at 4). The Government's case agents, whose identities are no +secret at this trial, +The defendant also argues that +employment will be "compromised by the revealing +of her testimony in this case." (Def. Letter at 4-5). But the cases the defendant cites do not stand +for the broad proposition tha +(Def. Letter at 5). Those cases involve undercover officers or CIA officers, for whom public +association with law enforcement at all would render them unable to do their job and pose safety +concerns. See, e.g., United States v. Alimehmeti, 284 F. Supp. 3d 477, 490-91 (S.D.N.Y. 2018) +("This Court has approved pseudonymous testimony by a UC as a means of protecting a UC's +safety and ability to continue to work as such, as have other courts." (citations omitted)). Here, +5 + + +Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 6 of 8 +the alleged harm to +comes not through the mere fact of testifying as a +, but through alleged public opprobrium. +Accordingly, the defendant's argument has no connection to whether +are compromised; it is just an example of the generalized argument that testifying may +pose reputational risk for +pseudonym.4 +3 There is thus no basis in law to permit +to testify under a +Second, to the extent the defendant's argument is rooted in more general concerns about +harassment, intimidation, or risks to employment, those concerns arise in different forms for a +large number of witnesses in this and any number of other cases. In this case, Government +witnesses testified about their association with the defendant and Epstein in their true names, +regardless of any feelings they may have had about their testimony. Those witnesses face the same +generalized risks of harassment and negative implications of association with this case in the public +eye as any defense witnesses. More broadly, this is hardly the first high-profile trial in this District, +or this country, yet the defendant has identified no analogous circumstance in which the +generalized concerns identified by the defendant justified the kind of anonymity order the +defendant seeks. And in any number of other cases, witnesses are reluctant to testify publicly in +3 The defendant argues that +is similarly situated to the witnesses who testified as Matt and +Shawn. (Def. Letter at 7). +That comparison is unfounded. Matt and Shawn's identities were +protected for an entirely different reason: failure to do so would identify Jane and Carolyn, +respectively. The defendant has not argued that identifying +would reveal the identity of +some other protected witness. +4 Based on the limited information available to the Government so far, +profession appears +to be irrelevant. Accordingly, insofar as the defendant could show some employment consequence +for +there would be no need for +profession to be identified in open court. +6 + + +Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 7 of 8 +front of their friends, families, and communities. For instance, Government cooperators and +confidential sources routinely express reluctance to testify and have their cooperation with the +Government made public. Yet, absent a safety concern, they do so. +Third, denying the defendant's motion does not implicate the defendant's constitutional +rights to a fair trial or to present a defense. Although the defendant states that she has encountered +resistance from potential witnesses who are afraid of "unfavorable publicity should their names be +publicly associated with Mr. Epstein," (Def. Letter at 3), the defendant retains the right to +compulsory process. If +or +will not testify willingly unless the +Court anonymizes their identities, the defendant can compel them to testify. See Fed. R. Crim. P. +17(a). If +will not testify willingly, the defendant can seek a letter rogatory. See 18 +U.S.C. § 1781(a)(2). Once the witnesses take the stand, they must testify truthfully on penalty of +perjury. See 18 U.S.C. § 1621. The defendant is right that she cannot compel witnesses to be +interviewed away from the presence of the jury— but she has no constitutional right to do so. And +the Government has the same powers and limitations. Put simply, the defendant's constitutional +rights are not infringed if this Court follows the same rule as every other court in every other trial, +high profile or not. +IV. +Conclusion +For the reasons set forth above, the Court should deny the defendant's motion. +7 + + +Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 8 of 8 +Respectfully submitted, +DAMIAN +United States Attorney +By:. +S/ +Maurene Comey +Alison Moe +Lara Pomerantz +Andrew Rohrbach +Assistant United States Attorneys +Southern District of New York +Ce: Defense Counsel (by e-mail) +8 diff --git a/vision-fixhub/court-05/753d0149073bb83b70557772e7dba21678f83d406b5d478141c81930702f52e0.receipt.json b/vision-fixhub/court-05/753d0149073bb83b70557772e7dba21678f83d406b5d478141c81930702f52e0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..abd3420723f19c50a5e947d1db147c9f64248f70 --- /dev/null +++ b/vision-fixhub/court-05/753d0149073bb83b70557772e7dba21678f83d406b5d478141c81930702f52e0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -100, + "dataset": "marble-joined", + "doc_id": "753d0149073bb83b70557772e7dba21678f83d406b5d478141c81930702f52e0", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "31c10a2ed2b9b3290ff53af5c35ef782504447a2a22678a250af8ed005e776c8", + "output_sha256": "db2f9ab000f4a1ec151e2ff339f854fb855d167ee53023eb8ff688200e14af4e", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/755969bb5fc11c32e289d4263d5e0bd18a66ef6272af4e92e1718a6b0cf0b49f.md b/vision-fixhub/court-05/755969bb5fc11c32e289d4263d5e0bd18a66ef6272af4e92e1718a6b0cf0b49f.md new file mode 100644 index 0000000000000000000000000000000000000000..4ae712e8f2eb15622860174bc5c70b8e0cff0693 --- /dev/null +++ b/vision-fixhub/court-05/755969bb5fc11c32e289d4263d5e0bd18a66ef6272af4e92e1718a6b0cf0b49f.md @@ -0,0 +1,36 @@ +Case 1:22-0-10904 J5R Document 23 Filed QDOEZA Page 1 of 1 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904 JSR +ORDER FOR ADMISSION +PRO HAC VICE +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +The motion of Carol +for admission to practice Pro Hac Vice in the abovecaptioned action is granted. +Applicant has declared that she is a member in good standing of the bars of the state of +New York and the United States Virgin Islands; and that her contact information is as follows: +Name: +Firm Name: +Carol | +Virgin Islands Department of Justice, Office of the Attorney General +34-38 Kronprindsens Gade +City/State/Zip: St. +, U.S. Virgin Islands 00802 +Telephone/Fax: (340) 774-5666 ext. 10101 +Email: +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for +Plaintiff, Government of the United States Virgin Islands, in the above-entitled action; +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the +above-captioned case in the United States District Court for the Southern District of New York. +All attorneys appearing before this Court are subject to the Local Rules of this Court, including +the Rules governing discipline of attorneys. +New York, NY +January 6 +_ 2023 +jed s. Rakof +ED S. RAKOFF. U.S.D. diff --git a/vision-fixhub/court-05/755969bb5fc11c32e289d4263d5e0bd18a66ef6272af4e92e1718a6b0cf0b49f.receipt.json b/vision-fixhub/court-05/755969bb5fc11c32e289d4263d5e0bd18a66ef6272af4e92e1718a6b0cf0b49f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f54af40c2cc9ff7cdf3514705bf7f8781a806427 --- /dev/null +++ b/vision-fixhub/court-05/755969bb5fc11c32e289d4263d5e0bd18a66ef6272af4e92e1718a6b0cf0b49f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -14, + "dataset": "marble-joined", + "doc_id": "755969bb5fc11c32e289d4263d5e0bd18a66ef6272af4e92e1718a6b0cf0b49f", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "b484a5fe4485e56c8f3ffbe470c53392687e8bd59783dc9123bcbc436600b1fd", + "output_sha256": "557721f1754587713995f11159e8cc887d2cbdde14a958a7622ac1a66264b1e7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/758d0109823d9ab9e7fed29b9fafa1bebb4b0dddb2d4f3da0d4c5df6ad2b47f7.md b/vision-fixhub/court-05/758d0109823d9ab9e7fed29b9fafa1bebb4b0dddb2d4f3da0d4c5df6ad2b47f7.md new file mode 100644 index 0000000000000000000000000000000000000000..65467ce4c711365f879a6378d6256e7c28bfe0c3 --- /dev/null +++ b/vision-fixhub/court-05/758d0109823d9ab9e7fed29b9fafa1bebb4b0dddb2d4f3da0d4c5df6ad2b47f7.md @@ -0,0 +1,86 @@ +Case 1:20-cr-00330-PAE Document 724 +Filed 07/12/22 Page 1 of 3 +HADDON +Haddon, +and +, P.C +Jeffrey S. Pagliuca +150 East 10th Avenue +Denver, Colorado 80203 +PH 303.831.7364 +FX 303.832.2628 +www.hmflaw.com +jpagliuca@hmflaw.com +December 16, 2021 +VIA Email +The Honorable Alison J. Nathan +United States District Court +Southern District of New York +40 Foley Square +New York, NY 10007 +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +Dear Judge Nathan, +I write in response to this Court's order. +As to the first question, federal law is clear. "No longer, when a lawyer asks a witness +whether he made a certain statement, written or not, is the lawyer required (as he was at common +law, see Note of Advisory Committee to Fed .R. Evid. 613(a)) to show the statement or disclose +its contents to the witness, though he must upon request show it to opposing counsel." United +States v. Marks, 816 F.2d 1207, 1210 (7th Cir. 1986) (Posner, J.). +As to the second question a statement provable by extrinsic evidence even though the +witness affirms that the 3500 material contains the inconsistent statement and also expresses +disagreement with the substance. By disagreeing with the substance, the witness has logically +and necessarily denied making the statement (or failed to remember making the statement). +Thus, under Rule 613, the statement is inconsistent because it has "under any rational theory it +might lead to any relevant conclusion different from any other relevant conclusion resulting from +anything the witness said." United States v. Barile, 286 F.3d 749, 755 (4th Cir. 2002) + + +Case 1:20-cr-00330-PAE Document 724 Filed 07/12/22 Page 2 of 3 +The Honorable Alison J. Nathan +December 15, 2021 +Page 2 +(Weinstein's Federal Evidence § 613.04[1] (2d ed. 2001)). To be sure, every time Jane denied +making a statement but agreed the 3500 material reflected the statement, she denied its substance +to the jury; the prior statement is therefore provable by extrinsic evidence because Jane's trial +testimony—I did not make the prior statement, or I don't remember making the prior statement, +the FBI agent made a typo—would lead to a relevant conclusion different from any other +relevant conclusion resulting from anything the witness said. See id. And referring Jane to the +3500 material, which was not admitted into evidence, is not sufficient to protect Ms. Maxwell's +right under Rule 613 to prove the statement by extrinsic evidence. +Extrinsic evidence is disallowed only when the witness admits making the prior +inconsistent statement. United States v. +578 F.2d 1332, 1340 (10th Cir. 1978) ("The +principle is that where it is sought to impeach a witness by showing a prior inconsistent +statement and the witness admits the prior inconsistent statement, the witness is thereby +impeached and further testimony is not necessary."). Where the witness admits the 3500 material +contains the statement, but denies making the statement or remembering making the statement, +the witness has not "admitted the statement" within the meaning of Rule 613. Cf. id. +Due to the press of time, Ms. Maxwell's counsel was not able to indicate each disputed +prior inconsistent statement that was read into the record by the deadline of 10:15 p.m. + + +Case 1:20-cr-00330-PAE Document 724 | +Filed 07/12/22 Page 3 of 3 +The Honorable Alison J. Nathan +December 15, 2021 +Page 3 +Jeffrey S. Pagliuca +Laura A. Menninger +HADDON, +150 East 10th Avenue +Denver, CO 80203 +Phone: 303-831-7364 +& +Christian R. Everdell +& GRESSER LLP +800 Third Avenue +New York, NY 10022 +Phone: 212-957-7600 +Bobbi C. Sternheim +Law Offices of Bobbi C. Sternheim +225 Broadway, Suite 715 +New York, NY 10007 +Phone: 212-243-1100 +Attorneys for Ghislaine Maxwell +IP.C. +cc: Counsel of record (via email) diff --git a/vision-fixhub/court-05/758d0109823d9ab9e7fed29b9fafa1bebb4b0dddb2d4f3da0d4c5df6ad2b47f7.receipt.json b/vision-fixhub/court-05/758d0109823d9ab9e7fed29b9fafa1bebb4b0dddb2d4f3da0d4c5df6ad2b47f7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1bc31c1f70702d88f1ec0b7f86306df8f19a7326 --- /dev/null +++ b/vision-fixhub/court-05/758d0109823d9ab9e7fed29b9fafa1bebb4b0dddb2d4f3da0d4c5df6ad2b47f7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marble-joined", + "doc_id": "758d0109823d9ab9e7fed29b9fafa1bebb4b0dddb2d4f3da0d4c5df6ad2b47f7", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "5648e60b76a44cdbcc8a2ae81489f26cf7718f0aef69b76d46540887b9032434", + "output_sha256": "349894a3489d11198ca1bdb1fcda6fa812975553c164815542c8dad61a373e45", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7595a4a616c93fe61c358098283ebe6f23a768eae0af1e0dda43839ced7faade.md b/vision-fixhub/court-05/7595a4a616c93fe61c358098283ebe6f23a768eae0af1e0dda43839ced7faade.md new file mode 100644 index 0000000000000000000000000000000000000000..0dd144711bb0eb271ab003f692021c066de7f783 --- /dev/null +++ b/vision-fixhub/court-05/7595a4a616c93fe61c358098283ebe6f23a768eae0af1e0dda43839ced7faade.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 326-108 Filed 09/08/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/7595a4a616c93fe61c358098283ebe6f23a768eae0af1e0dda43839ced7faade.receipt.json b/vision-fixhub/court-05/7595a4a616c93fe61c358098283ebe6f23a768eae0af1e0dda43839ced7faade.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a8e4045b1837120cc62ea16298cf8278d806b6e8 --- /dev/null +++ b/vision-fixhub/court-05/7595a4a616c93fe61c358098283ebe6f23a768eae0af1e0dda43839ced7faade.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "7595a4a616c93fe61c358098283ebe6f23a768eae0af1e0dda43839ced7faade", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "0e5abce96f2ed6b6016660407991574e1da286fdb0d93c9eefe097e9c9f8b688", + "output_sha256": "7542f969ec042eb28cbb716b7ce526ddf4fdfe2bbdd070935980720045a8d272", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/75aa0f2411da978a57848bd79003b4869cbadab7e091781f5dc89382d15adab4.md b/vision-fixhub/court-05/75aa0f2411da978a57848bd79003b4869cbadab7e091781f5dc89382d15adab4.md new file mode 100644 index 0000000000000000000000000000000000000000..4ec588ad30cdc81aef0fc4476dbf2cfd798b3999 --- /dev/null +++ b/vision-fixhub/court-05/75aa0f2411da978a57848bd79003b4869cbadab7e091781f5dc89382d15adab4.md @@ -0,0 +1,28 @@ +Case 1:22-cV-10904-JSR Document 326-92 Filed 09/08/23 Page 1 of 2 + + + +Case 1:22-cV-10904-JSR Document 326-92 Filed 09/08/23 Page 2 of 2 +Date: Friday. October 23 2009 11:05 AM +From: Jeffrey Epstein +To: +photos ??. tell the eye +place that these glasses have to be re done,, izon tells me that the glasses as they +are progressives -have to sit high on the nose as close to the eye as possible,, the person who fit these did not +know that. Jes staley and wife are going to be at the ranch next weekend,, please coordinate== they get to stay +in blue room +********************************************* +The information contained in this communication is +confidential, may be attorney-chent privileged, may +constitute inside information, and is intended only for +the use of the addressee. It is the property of +Jeffrey Epstein +Unauthorized use, disclosure or copying of this +communication or any part thercof is strictly prohibited +and may be unlawful. If you have received this +communication in error, please notify us immediately by +return e-mail or by e-mail to jeevacation@gmail.com, and +destroy this communication and all copies thereof, +including all attachments. + +ESTATE_JPM001758 diff --git a/vision-fixhub/court-05/75aa0f2411da978a57848bd79003b4869cbadab7e091781f5dc89382d15adab4.receipt.json b/vision-fixhub/court-05/75aa0f2411da978a57848bd79003b4869cbadab7e091781f5dc89382d15adab4.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a4e0da259f6dc35bd20144931e9d6ab46a0c206e --- /dev/null +++ b/vision-fixhub/court-05/75aa0f2411da978a57848bd79003b4869cbadab7e091781f5dc89382d15adab4.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -46, + "dataset": "marble-joined", + "doc_id": "75aa0f2411da978a57848bd79003b4869cbadab7e091781f5dc89382d15adab4", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "aecf427eb9af9100b24b7ee29f418d1fa6f855bb77289809ce1e487c4720f99f", + "output_sha256": "e97b2f52c248a146eb76d0c74be605d9969171ecf7471d019bab5f46bba6d61c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/75aa165b24e8e5b0596dd85e4cca277943d2b0f99e57012d7ecf469ed60d1046.md b/vision-fixhub/court-05/75aa165b24e8e5b0596dd85e4cca277943d2b0f99e57012d7ecf469ed60d1046.md new file mode 100644 index 0000000000000000000000000000000000000000..7f8b252aca7b2d13127347a058587444680183df --- /dev/null +++ b/vision-fixhub/court-05/75aa165b24e8e5b0596dd85e4cca277943d2b0f99e57012d7ecf469ed60d1046.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 341-3 Filed 09/20/23 Page 1 of 1 + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/75aa165b24e8e5b0596dd85e4cca277943d2b0f99e57012d7ecf469ed60d1046.receipt.json b/vision-fixhub/court-05/75aa165b24e8e5b0596dd85e4cca277943d2b0f99e57012d7ecf469ed60d1046.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a6492fa5ea35608b59afe9998f4916dd40c117d2 --- /dev/null +++ b/vision-fixhub/court-05/75aa165b24e8e5b0596dd85e4cca277943d2b0f99e57012d7ecf469ed60d1046.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "75aa165b24e8e5b0596dd85e4cca277943d2b0f99e57012d7ecf469ed60d1046", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "8f58d4984d69b73e82fb4b4cc4ea25afcf1ee8d553b40562414481b443496eda", + "output_sha256": "73f74227acc12375770bb8cc8f35525d05463f7ff567ed68e90ec09f554847f2", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/75eec7bb3c942e423af0fceb45ec07a039fa3afeb956598768e3203883535f20.md b/vision-fixhub/court-05/75eec7bb3c942e423af0fceb45ec07a039fa3afeb956598768e3203883535f20.md new file mode 100644 index 0000000000000000000000000000000000000000..07ddcf99d9aa301224db42dbb5c30460da14a3e2 --- /dev/null +++ b/vision-fixhub/court-05/75eec7bb3c942e423af0fceb45ec07a039fa3afeb956598768e3203883535f20.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 244-1 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/75eec7bb3c942e423af0fceb45ec07a039fa3afeb956598768e3203883535f20.receipt.json b/vision-fixhub/court-05/75eec7bb3c942e423af0fceb45ec07a039fa3afeb956598768e3203883535f20.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2120da1c6168afdb2a4a105d9644b718323543ca --- /dev/null +++ b/vision-fixhub/court-05/75eec7bb3c942e423af0fceb45ec07a039fa3afeb956598768e3203883535f20.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -23, + "dataset": "marble-joined", + "doc_id": "75eec7bb3c942e423af0fceb45ec07a039fa3afeb956598768e3203883535f20", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "b29034afb6ac7b5fb5b4154978b59ff84b3253df2a0ca5edfcde570d95c65207", + "output_sha256": "243e8beed129e95f5ef51b4e8e0695b5b48032c4b6c008bd35201ddfd22f32d0", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7601a7b0531de4e110b153d3e38b4e45baf728634436708f1b4b9258f196197a.md b/vision-fixhub/court-05/7601a7b0531de4e110b153d3e38b4e45baf728634436708f1b4b9258f196197a.md new file mode 100644 index 0000000000000000000000000000000000000000..4254745d9096db3a988eb2ccf23cee4ab863dabf --- /dev/null +++ b/vision-fixhub/court-05/7601a7b0531de4e110b153d3e38b4e45baf728634436708f1b4b9258f196197a.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 238-36 Filed 07/25/23 +_Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/7601a7b0531de4e110b153d3e38b4e45baf728634436708f1b4b9258f196197a.receipt.json b/vision-fixhub/court-05/7601a7b0531de4e110b153d3e38b4e45baf728634436708f1b4b9258f196197a.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1a91a30de9a37d9bd23d954e78457e1b7636b082 --- /dev/null +++ b/vision-fixhub/court-05/7601a7b0531de4e110b153d3e38b4e45baf728634436708f1b4b9258f196197a.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "7601a7b0531de4e110b153d3e38b4e45baf728634436708f1b4b9258f196197a", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "c8f01c1d0ece503150efb9b30da6518451de26c4a8c413b6f89c5ee7d91172fa", + "output_sha256": "0568042c905311d3dfc415a5468f2c80d299c27c1566c3c4c4f65540c6a77181", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/766fee6659131093accf0403e0551b76da6113645c9df7eddff63f137890b90b.md b/vision-fixhub/court-05/766fee6659131093accf0403e0551b76da6113645c9df7eddff63f137890b90b.md new file mode 100644 index 0000000000000000000000000000000000000000..e13aaef32ac643141f2c191139ae30475a388e80 --- /dev/null +++ b/vision-fixhub/court-05/766fee6659131093accf0403e0551b76da6113645c9df7eddff63f137890b90b.md @@ -0,0 +1,54 @@ +Case 1:22-cV-10904-JSR Document 326-41 Filed 09/08/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 326-41 Filed 09/08/23 Page 2 of 3 +From: +Sent: +To: +Subject: +Mary E Erdoes [mary.erdoes@jpmorgan.com] +2/26/2010 5:08:27 PM +Phil Dilorio [phil.diiorio@jpmorgan.com] +Re: Jeffrey Epstein +If jes wants it, we do it +From: Phil Dilorio +To: Mary E Erdoes +Sent: Fri Feb 26 11:40:30 2010 +Subject: Fw: Jeffrey Epstein +Do u have a view? +From: Lisa E. Waters +To: Phil Dilorio +Sent: Fri Feb 26 11:32:54 2010 +Subject: Fw: Jeffrey Epstein +Mary +and catherine keating are calling me in a few minutes. +From: Mary C +To: Lisa E. Waters +Sent: Fri Feb 26 11:20:10 2010 +Subject: FW: Jeffrey Epstein +Lisa - I am going to need an answer asap. Can you call me when you have a chance? Did you speak to les? +Mary +From: Rosa M da Silva +Sent: Friday, February 26, 2010 10:58 AM +To: Mary C +Subject: FW: Jeffrey Epstein +Hi Mary: Do you have any news us? Thanks, Rosa + +Erdoes -22 +3/15/23 +From: Lesley Groff [mailto:lgroff@dkipllc.com] +Sent: Friday, February 26, 2010 10:47 AM +To: Rosa M da Silva +Subject: Jeffrey Epstein +Hi Rosa. Enjoying the lovely snow! Darren asked that I follow up again on the docs Jeffrey is requesting... not to be a +pain!) I'm sure the weather is not helping in the expediting of things! +Just let me know where we are... +Thanks, Lesley + +JPM-SDNYLIT-00099897 + + +Case 1:22-cv-10904-JSR Document 326-41 Filed 09/08/23 Page 3 of 3 + +JPM-SDNYLIT-00099898 diff --git a/vision-fixhub/court-05/766fee6659131093accf0403e0551b76da6113645c9df7eddff63f137890b90b.receipt.json b/vision-fixhub/court-05/766fee6659131093accf0403e0551b76da6113645c9df7eddff63f137890b90b.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f0341d4d9ce3c9c13118bc8ab6ab9997be25edfd --- /dev/null +++ b/vision-fixhub/court-05/766fee6659131093accf0403e0551b76da6113645c9df7eddff63f137890b90b.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -77, + "dataset": "marble-joined", + "doc_id": "766fee6659131093accf0403e0551b76da6113645c9df7eddff63f137890b90b", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "3f680594e40199098d828cd490420496b993112f9f9badb5673fd23b73a065b5", + "output_sha256": "b4b950151d9c011e20c2e370202c7d64c1b938b57f75e2a3348150c3a91cf497", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/76813a6348b26719e2288b5c8aaf19748a61acbedd9a490f4c19c2bbeec919fa.md b/vision-fixhub/court-05/76813a6348b26719e2288b5c8aaf19748a61acbedd9a490f4c19c2bbeec919fa.md new file mode 100644 index 0000000000000000000000000000000000000000..e7b5212da462084418a870d426cc404e8bbf28ce --- /dev/null +++ b/vision-fixhub/court-05/76813a6348b26719e2288b5c8aaf19748a61acbedd9a490f4c19c2bbeec919fa.md @@ -0,0 +1,30 @@ +Case 1:22-cv-10904-JSR Document 41 Filed 02/03/23 Page 1 of 1 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED STATES +VIRGIN ISLANDS, +Plaintiffs, +Case No. 22-ev-10904-JSR +MOTION FOR ADMISSION +PRO HAC VICE +JPMORGAN CHASE BANK, N.A., +Defendant. +Pursuant to Rule 1.3(c) of the Local Rules of the United States District Courts for the +Southern and Eastern Districts of New York, 1, Leonard A. Gail, hereby move this Court for an +Order for admission to practice Pro Hac Vice to appear as counsel for Defendant JPMorgan Chase +Bank, N.A. in the above-captioned action. +I am in good standing with the bar of Illinois and there are no disciplinary proceedings +against me in any state or federal court. I have never been convicted of a felony. I have never +been censured, suspended, disbarred or denied admission or readmission by any court. I have +attached the affidavit pursuant to Local Rule 1.3. +Dated: February 3, 2023 +Respectfully submitted, +/s/ Leonard A. Gail +Leonard A. Gail +MASSEY & GAIL LLP +50 East Washington Street, Suite 400 +Chicago, IL 60602 +Tel.: (312) 283-1590 +lgail@masseygail.com +Attorney for Defendant JPMorgan +Chase Bank, N.A. diff --git a/vision-fixhub/court-05/76813a6348b26719e2288b5c8aaf19748a61acbedd9a490f4c19c2bbeec919fa.receipt.json b/vision-fixhub/court-05/76813a6348b26719e2288b5c8aaf19748a61acbedd9a490f4c19c2bbeec919fa.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9ed9ecb59ce332114baa267336c68d889cbb8f56 --- /dev/null +++ b/vision-fixhub/court-05/76813a6348b26719e2288b5c8aaf19748a61acbedd9a490f4c19c2bbeec919fa.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "76813a6348b26719e2288b5c8aaf19748a61acbedd9a490f4c19c2bbeec919fa", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "55fea15aec1385cea61704de6a34b92474820e4be54807f5afdbdf8c14a7103c", + "output_sha256": "d887d6784e0daa9ec0fe3db65ea2a044acaa87de7497bf307c2ddb5c179d4fb8", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/769619cad85df7cadb7ef2b139d4ce60e9f1708319c2ea166afa8e2ea6190895.md b/vision-fixhub/court-05/769619cad85df7cadb7ef2b139d4ce60e9f1708319c2ea166afa8e2ea6190895.md new file mode 100644 index 0000000000000000000000000000000000000000..5a3361d240e5c0b0906d0cf6289fb75a860e4a30 --- /dev/null +++ b/vision-fixhub/court-05/769619cad85df7cadb7ef2b139d4ce60e9f1708319c2ea166afa8e2ea6190895.md @@ -0,0 +1,449 @@ +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 1 of 15 +IN THE UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +JANE DOE, individually and on behalf of +all others similarly situated, +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +Case Number: 1:22-cv-10019-JSR +Case Number: 1:22-cv-10904-JSR +JAMES EDWARD STALEY +Third-Party Defendant. +THIRD-PARTY DEFENDANT JAMES STALEY'S +REPLY MEMORANDUM IN SUPPORT OF MOTION TO DISMISS + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 2 of 15 +TABLE OF CONTENTS +1. The Indemnification and Contribution Claims Are Legally Deficient +A. JPMorgan's Shotgun Pleading Warrants Dismissal of Counts I and I| +B. The TVPA Does Not Permit Indemnification or Contribution Claims +1 +1 +1 +C. The Indemnification Claim Has Additional Defects +...4 +i. Mr. Staley's Contractual Indemnity Bars this Claim +. 4 +ii. The Complaints Against the Bank Do Not Seek To Hold It Vicariously +Liable for Mr. Staley's Actions +5 +ili. The Alleged Misconduct Was Outside the Scope of Mr. Staley's Employment.... 5 +D. +JPMorgan's Contribution Claim Fails +6 +II. The Court Should Dismiss the Remaining Employment Claims Under Rule 14 +.. 6 +III. The Employment Claims (Count III and IV) Are Stale and Deficiently Pleaded +. 7 +A. +The Opposition Cannot Resurrect the Time-Barred Claims.. +B. The Employment Claims Do Not Satisfy Rule 9(b) +..7 +. 9 +C. The Breach of Fiduciary Duty Claim is Deficient +D. +The Faithless Servant Claim is Defective +CONCLUSION +..9 +10 +10 +ii + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 3 of 15 +TABLE OF AUTHORITIES +CASES +A.B. v. Marriott International, Inc., 2020 WL 3642485 (E.D. Pa. July 6, 2020) +Corley v. Country Squire Apartments, Inc., 80 N.Y.S.2d 900 (2d Dep't 2006).. +Ditullio v. Boehm, 2010 WL 11534265 (D. Alaska Feb. 23, 2010) +Donahue v. Pendleton Woolen Mills, Inc., 633 F. Supp. 1423 (S.D.N.Y. 1986) +Droney v. Vivint Solar, 2020 WL 3425301 (D.N.J. June 23, 2020). +Ebel v. G/O Media, Inc., 2021 WL 2037867 (S.D.N.Y. May 21, 2021) +Epiphany Cmty. Nursery Sch. v. Levey, 171 A.D.3d 1 (Ist Dep't 2019). +Fownes Bros. v. JPMorgan Chase & Co., 92 A.D.3d 582 (2012) +Greenspun v. Lindley, 36 N.Y.2d 473 (N.Y. 1975) +Herman v. RSR Sec. Servs., 172 F.3d 132 (2d Cir. 1999)... +In re Allianz Glob. Invs. U.S. LLC Alpha Series Litig., +2021 WL 4481215 (S.D.N.Y. Sept. 30, 2021)... +In re Bernard L. Madoff Inv. Sec. LLC., 721 F.3d 54 (2d Cir. 2013).. +_v. Odenat, 9 F. Supp. 3d 342 (S.D.N.Y. 2014) +KBL Corp. v. Arnouts, 646 F. Supp. 2d 335 (S.D.N.Y. 2009). +McCarthy v. Turner Constr., Inc., 953 N.E.2d 794 (N.Y. 2011). +Stanley v. Skowron, 989 F. Supp. 2d 356 (S.D.N.Y. 2013) +N.Y. State Electric & Gas Corp. v. FirstEnergy Corp., +2007 WL 1434901 (N.D.N.Y. May 11, 2007) +Picard v. HSBC Bank PLC, 454 B.R. 25 (S.D.N.Y. 2011) +Rogers v. Grimaldi, 875 F.2d 994 (2d Cir. 1989). +v. Bolton, 904 F.2d 819 (2d Cir. 1990). +v. FSG PrivatAir, Inc., 2004 WL 1837366 (S.D.N.Y. Aug. 17, 2004). +Serv. Sign Erectors Co. v. Allied Outdoor Advert., Inc., 573 N.Y.S.2d 513 (Ist Dep't 1991). +iii +3 +6 +..3 +.9 +5 +10 +. 8 +10 +. 7 +2,4 +.. 7 +2,3 +.2 +..2 +...5 +10 +..3 +..2 +..7 +..9 +10 +. 4 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 4 of 15 +Stewart Title Ins. Co. v. N.Y. Title Rsch. Corp., 117 N.Y.S.3d 175 (Ist Dep't 2019). +Texas Indus. v. Radcliff Mats., 451 U.S. 630 (1981). +Too, Inc. v. Kohl's Dep't Stores, 213 F.R.D. 138 (S.D.N.Y. 2003) +Tyco Int'l, Ltd. v. Kozlowski, 756 F. Supp. 2d 553 (S.D.N.Y. 2010) +United States v. Tutstone, 525 F. App'x 298 (6th Cir. 2013) +United States v. Walls, 784 F.3d 543 (9th Cir. 2015) +v. Affinion Grp., 889 F.3d 116 (2d Cir. 2018) +STATUTES +.. 5 +.. 3 +..2 +.. 7 +.. 4 +. 4 +9 +N.Y. C.P.L.R. § 1401 +.. 2 +RULES +Federal Rule of Civil Procedure 8 +Federal Rule of Civil Procedure 9(b).. +Federal Rule of Civil Procedure 10(b). +Federal Rule of Civil Procedure 14 +.. 1 +6,9 +... 1 +. 6, 7 +iv + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 5 of 15 +JPMorgan's Opposition confirms the many flaws in its Third-Party Complaints +("Complaints" or "TPCs"), which require dismissal of this case. The brief ignores governing case +law and fails to respond to many of Mr. Staley's arguments. Indeed, most of the brief is a study +in distraction. To avoid binding case law that forecloses its claims for contribution and +indemnification under the TVPA, the bank cites inapposite authority on conflict preemption; to +paper over its failure to properly plead indemnification for the remaining claims, it offers a strawman argument on Mr. Staley's indemnification rights; to dodge the untimeliness of its Employment +Claims, it invents an illusory choice-of-law conundrum—and that's just to name a few. At bottom, +the Opposition follows the same playbook that animated the bank's third-party practice from the +start: when in trouble, pull in something (or someone) new to change the conversation, no matter +the legal defects. Each claim is defective and should be dismissed with prejudice. +I. The Indemnification and Contribution Claims Are Legally Deficient. +A. JPMorgan's Shotgun Pleading Warrants Dismissal of Counts I and II. +The TPCs improperly lump together plaintiffs' claims under both federal and state law into +one omnibus claim for contribution (Count I) and another for indemnification (Count II). +JPMorgan never disputes that these claims flunk Rules 8 and 10(b), instead asserting that the +"hyper technical" (i.e., correct) argument does not establish prejudice to Mr. Staley. Id. Not so. +Although, for the reasons explained in his Motion and below, the indemnification and contribution +claims should be dismissed, the lumping together of separate federal and state claims into the same +counts shields each claim from separate consideration (and the separate law that applies to each) +at the motion to dismiss stage as is required (and appropriate). The federal rules do not allow +claims with such clear pleading errors to proceed. +B. The TVPA Does Not Permit Indemnification or Contribution Claims. +JPMorgan does not seriously dispute that the TVPA provides no federal causes of action +1 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 6 of 15 +for indemnification or contribution. Instead, the bank argues that it can pursue such claims under +C.P.L.R. § 1401. But the Second Circuit has repeatedly held that "federal courts recognize a right +to contribution under state law only in cases in which state law supplies the appropriate rule of +decision." Herman v. RSR Sec. Servs., 172 F.3d 132, 144 (2d Cir. 1999) (cleaned up); see In re +Bernard L. Madoff Inv. Sec. LLC., 721 F.3d 54, 65 (2d Cir. 2013) ("[I]t is settled in this Circuit +that there is no claim for contribution unless the operative federal statute provides one." (affirming +dismissal of claim under § 1401)). Courts in this circuit have thus overwhelmingly held that +"[w]hether contribution is available in connection with a federal statutory scheme is a question +governed solely by federal law," and a party "cannot use New York State common law [or C.P.L.R. +§ 1401] as an end-around to make a claim ... that it could not make under the federal statutory +scheme." KBL Corp. v. Arnouts, 646 F. Supp. 2d 335, 341 (S.D.N.Y. 2009) (collecting cases); see +Picard v. HSBC Bank PLC, 454 B.R. 25, 37-38 (S.D.N.Y. 2011) (Rakoff, J.) (dismissing § 1401 +contribution claim for federal statutory liability). +JPMorgan (at 7) cites several cases in an attempt to argue that state contribution statutes +do apply "when the source of the underlying liability is a federal statute." But these cases are +unavailing. +In +v. Odenat, the court actually dismissed a contribution claim under the +federal Copyright Act, allowing only a contribution claim to proceed for the state-law claim +vindicating the plaintiff's "right of publicity." 9 F. Supp. 3d 342, 366 (S.D.N.Y. 2014). In Too, +Inc. v. Kohl's Dep't Stores, 213 F.R.D. 138 (S.D.N.Y. 2003), as other courts have noted, the parties +there did not even contest "that state law could not be used to support a claim for contribution in +connection with a [federal] copyright action," KBL, 646 F. Supp. at 341 (emphasis added). +Moreover, Too has received unfavorable treatment in this district, as it is "contrary to the numerous +well-reasoned decisions" coming out the other way. Id. The bank also cites N.Y. State Electric & +2 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 7 of 15 +Gas Corp. v. FirstEnergy Corp., 2007 WL 1434901, at *6-7 (N.D.N.Y. May 11, 2007). But there +the court rejected the New York law contribution claim seeking to reapportion federal liability, +ruling that CERCLA preempted state law. Id. at *11. While the court posited that state +contribution law could, theoretically, apply to federal liability in the absence of preemption, id. at +*7, that dicta cannot survive the Second Circuit's later holding that the "source of a right of +contribution under state law must be an obligation imposed by state law." Madoff, 721 F.3d at 65. +The same is true of A.B. v. Marriott International, Inc., 2020 WL 3642485 (E.D. Pa. July +6, 2020), an out-of-circuit case that permitted impleader for state-law contribution claims under +the TVPA. To start, the case addressed only whether the proposed third-party complaint satisfied +Rule 14(a)'s lenient standard that the nonparty "may be liable." Id. at *5. Even more significantly, +the parties did not brief whether state-law contribution claims can reapportion federal liability, and +the court's ruling contravenes the only case to have addressed the issue under the TVPA. Ditullio +v. Boehm, 2010 WL 11534265, at *2 (D. Alaska Feb. 23, 2010). In any event, JPMorgan's reading +of this case is foreclosed by the binding Second Circuit authority discussed above. +JPMorgan (at 8-11) tries to turn decades of Supreme Court precedent on its head by +recasting the question here as one of traditional conflict preemption. That neglects the binding +Second Circuit case law and the Supreme Court's directive that contribution and indemnification +for federally created liability arise only "through the affirmative creation of a right of action by +Congress, either expressly or by clear implication" or "through the power of federal courts to +fashion a federal common law of contribution." Texas Indus. v. Radcliff Mats., 451 U.S. 630, 638 +(1981). The Court has carefully protected Congress's prerogative, and implied indemnity and +contribution are highly disfavored. But under JPMorgan's view, Congress's decision is beside the +point-any general state-law contribution statute engrafts a right onto the federal scheme unless +3 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 8 of 15 +Congress specifically preempts it. That cannot be correct, and it would make the Supreme Court's +implied-contribution case law nonsensical. The Supreme Court and Second Circuit have been +clear: when Congress chooses not to create contribution or indemnification, none exists. +Moreover, as Mr. Staley explained, Mot. 9-11, JPMorgan's proposed state-law indemnity +and contribution rights would directly undercut the TVPA's goal to protect victims. The TVPA +provides a comprehensive civil and criminal scheme with various remedies.' Such "express +provision[s] for private enforcement in certain carefully defined circumstances ... strongly +counsels against judicially engrafting additional remedies." Herman, 172 F.3d at 144. So even +under the bank's analysis, indemnification and contribution are inappropriate here? +C. The Indemnification Claim Has Additional Defects. +i. Mr. Staley's Contractual Indemnity Bars this Claim. +JPMorgan never disputes that it agreed to indemnify Mr. Staley without any reciprocal +indemnity for itself. The bank instead argues that Mr. Staley acted in bad faith and therefore could +not receive indemnification under Delaware law. Opp'n 11-13. That misses the point. Mr. Staley +is not seeking (at least right now) indemnification. Rather, the presence of this one-way +indemnification provision shows that "indemnification [was] clearly contemplated and expressly +addressed by" the parties. Serv. Sign Erectors Co. v. Allied Outdoor Advert., Inc., 573 N.Y.S.2d +513, 514 (Ist Dep't 1991). Since the parties did not contract for Mr. Staley to indemnify the bank, +any common-law indemnification benefitting the bank is "extinguished" as a matter of law. Id. +' United States v. Walls, 784 F.3d 543, 548 (9th Cir. 2015) ("The TVPA is part of a comprehensive +regulatory scheme ...."); United States v. Tutstone, 525 F. App'x 298, 302 (6th Cir. 2013) (same). +2 The bank concedes Congress's silence but asserts that implying rights is required to prevent +saddling "passive intermediaries" with liability in lieu of frontline traffickers. Opp'n 9. But +traffickers are not immunized by the lack of indemnity and contribution; they can still be sued +directly by victims. That Congress prioritized empowering victims to choose whom to sue, rather +than letting alleged perpetrators control litigation is not surprising given the law's goals. Mot. 10. +4 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 9 of 15 +ii. The Complaints Against the Bank Do Not Seek To Hold It Vicariously Liable +for Mr. Staley's Actions. +JPMorgan does not dispute that under New York law a "party cannot obtain common-law +indemnification unless it has been held to be vicariously liable without proof of any negligence .. +. on its own part." McCarthy v. Turner Constr., Inc., 953 N.E.2d 794, 801 (N.Y. 2011) (emphases +added). Here, the bank concedes that the plaintiffs seek to hold it directly liable at least in part for +its own misconduct, not for Mr. Staley's. Opp'n 13. This forecloses any indemnification claim. +Indeed, the plaintiffs' claims could not be pleaded on a theory of vicarious liability. As outlined +in the Motion (at 13-14), and conceded in the Opposition (at 14), Mr. Staley had no decisionmaking +authority over Epstein's accounts, no knowledge of specific transactions, and no hand in ensuring +BSA compliance relating to the same.? That vicarious liability is missing is particularly apparent +for the plaintiffs' claims for obstruction and negligent banking, which stem from the bank's failure +to follow federal banking regulations. Without vicarious liability, indemnification cannot succeed. +See Stewart Title Ins. Co. v. N.Y. Title Rsch. Corp., 117 N.Y.S.3d 175, 177 (Ist Dep't 2019) +(dismissing indemnification at pleading stage). The bank fails to cite a single case to the contrary. +ili. The Alleged Misconduct Was Outside the Scope of Mr. Staley's Employment. +As Mr. Staley's opening brief showed, indemnification is available only (1) for acts falling +within the scope of employment and (2) where plaintiff's "injury was due solely to the [agent's] +negligent performance or nonperformance of an act solely within [his] province." Corley v. +Country Squire Apartments, Inc., 820 N.Y.S.2d 900 (2d Dep't 2006). On the first element, +JPMorgan never disputes that the claim applies only to injuries caused by an agent acting within +his agency. Opp'n 14-15. Rather than plead that Mr. Staley's actions were within the scope of +" At most, the plaintiffs merely allege that Mr. Staley's knowledge of Epstein's misconduct can be +imputed to the bank. See, e.g., Doe FAC 11 228-29. But the imputation of knowledge is distinct +from vicarious liability. Droney v. Vivint Solar, 2020 WL 3425301, at *6 (D.N.J. June 23, 2020). +5 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 10 of 15 +employment-or just say nothing the bank chose to plead that he acted outside that scope. TPC +942. So the indemnification claim fails. The bank argues that dismissal is premature because +there is a factual dispute over whether Mr. Staley acted within the scope of employment, Opp'n +14, but it cannot cite allegations in the plaintiffs' complaints (allegations it disclaimed repeatedly) +to try to fix what is plainly missing from its own complaints. And the claim still fails the second +element: the bank does not and cannot allege that the injuries were "solely" caused by Mr. Staley +or arose from actions that fell solely within his responsibilities at the bank. +D. JPMorgan's Contribution Claim Fails. +JPMorgan concedes that it did not allege that Mr. Staley owed a duty to Doe or the USVI. +Opp'n 15. As to a duty to the bank, JPMorgan has failed to adequately plead that such a duty was +breached, Mot. 21-23, especially under Rule 9(b)'s pleading standard. +The contribution claim also fails the same-injury requirement. First, the Complaints simply +do not allege the specific harm that Mr. Staley inflicted on the plaintiffs, much less say that it is +the "same" as the one the bank allegedly caused. The claim is defective without that. Second, +faced with this clear pleading failure, JPMorgan asserts that both Mr. Staley and the bank in some +way allegedly helped caused "Epstein's continued retention as a JPMC client." Opp'n 16. But +that is not the injury that the plaintiffs complain of; they allege that JPMorgan provided the +"financial lifeblood" for Epstein's enterprise— which is of course not something that any single +bank employee could provide. JPMorgan's stray comment about being able to pursue "different +grounds" of liability than the plaintiffs is beside the point; what matters is that under no theory +could Mr. Staley, as an individual, have provided the "financial lifeblood" to Epstein's enterprise. +Il. +The Court Should Dismiss the Remaining Employment Claims Under Rule 14. +JPMorgan insists that if this Court dismisses Counts I and II, then it can still retain +supplemental jurisdiction over the Employment Claims. Opp'n 16-18. Mr. Staley never argued + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 11 of 15 +otherwise. He instead asserted that the Court should reject the Employment Claims under Rule 14 +if only they remain. The bank entirely failed to address the argument. +III. The Employment Claims (Count III and IV) Are Stale and Deficiently Pleaded. +A. The Opposition Cannot Resurrect the Time-Barred Claims. +JPMorgan sat on its Employment Claims against Mr. Staley, who left the bank over a +decade ago. The bank declares that Delaware law governs the claims and provides the statute of +limitations. Opp'n 18. This assertion is bizarre given that Count III explicitly pleads the claim +"[u]nder New York law." TPC 9| 57. It is also wrong. This Court applies New York's choice of +law principles, Rogers v. Grimaldi, 875 F.2d 994, 1002 (2d Cir. 1989), and under the interestanalysis test, for breach of fiduciary duty "the law of the jurisdiction where the tort occurred will +generally apply because that jurisdiction has the greatest interest in regulating behavior within its +borders." In re Allianz Glob. Invs. U.S. LLC Alpha Series Litig., 2021 WL 4481215, at *10 +(S.D.N.Y. Sept. 30, 2021). Mr. Staley worked in New York, the bank's worldwide headquarters +is in New York, and the TPCs' allegations concern alleged misconduct in New York.4 +Regardless, choice of law is a sideshow: the Employment Claims fail under either a twoor three-year limitations period. JPMorgan nowhere denies that its only hope to preserve these +dated claims is the discovery rule, under which it must "plead and establish that the alleged fraud +could not have been discovered prior to the" limitations period. Mot. 19. JPMorgan argues that it +"did not discover" any misconduct until it was sued. Opp'n 19. But that misses the point. The +standard does not require the bank to have discovered all the factual allegations, including those +underlying the plaintiffs' claims, before the clock started on its Employment Claims. It merely +* Unlike some other states, New York rejects any automatic application of the so-called interna +affairs choice-of-law rule, that looks merely to the state of incorporation. Tyco Int'l, Ltd. v +Kozlowski, 756 F. Supp. 2d 553, 560-61 (S.D.N.Y. 2010). Regardless, JPMorgan is not +incorporated in Delaware; it is a "national bank" with its main office in Ohio. TPC 9|4. +7 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 12 of 15 +needed to know enough to be on notice to investigate Mr. Staley's possible disloyalty-that is, +that he might have lied about "Epstein's character and conduct." TPC 9| 61. And JPMorgan, in +touting the "public scrutiny" from news reports in 2018 and Epstein's 2019 arrest that "exposed +shocking details about" Epstein's trafficking enterprise, Doe Dkt. 46 at 1-2, has conceded it was +on notice of a potential need to investigate well over three years ago. +In the face of this barrier, JPMorgan's chief response is to punt—claiming that the statute +of limitations presents a factual issue. Opp'n 19-20. But to create a factual dispute, JPMorgan +had to plead relevant contested facts. It has not and cannot do so. Even JPMorgan's favored +authority notes that once a defendant makes a prima facie case of inquiry notice——as Mr. Staley +has done the "burden then shifts to the plaintiff to establish that even if it had exercised +reasonable diligence, it could not have discovered the basis for its claims before that date." +Epiphany Cmty. Nursery Sch. v. Levey, 171 A.D.3d 1, 7 (Ist Dep't 2019) (affirming dismissal of +fraud claim because plaintiff "could have discovered" allegations). Neither the Complaints nor +the Opposition explains why JPMorgan could not have discovered Mr. Staley's alleged disloyalty +with reasonable diligence. Indeed, in addition to the abundant press on Epstein and Mr. Staley, +the bank possessed decades' worth of Mr. Staley's records and emails with Epstein.° +JPMorgan also tosses in a bid for equitable tolling. Opp'n 20. But to qualify, a plaintiff +must "plead and prove (1) the wrongful concealment by the defendant of its actions, (2) the failure +5 The result would be no different under Delaware law. JPMorgan did not plead how Mr. Staley's +alleged misconduct was "inherently unknowable," Opp'n 18, especially given that Doe and the +USVI uncovered it, even without all Mr. Staley's emails and records, which JPMorgan possesses. +• JPMorgan questions how it could've thought to investigate Mr. Staley when Barclay's was telling +reporters that it still had "full confidence" in him, despite the UK authorities' public investigation. +Opp'n 20, n.6. But in its Answer in this case, the bank concedes that it knew that Mr. Staley's +conduct was still in question; indeed, it "admits" that in 2019 it produced to the UK authorities +more than 1,200 emails between Staley and Epstein. Answer 9| 233, 22-cv-10019, ECF No. 83. +8 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 13 of 15 +by the plaintiff to discover the operative facts underlying the action within the limitations period, +and (3) the plaintiff's due diligence to discover the facts." Donahue v. Pendleton Woolen Mills, +Inc., 633 F. Supp. 1423, 1443 (S.D.N.Y. 1986). JPMorgan pleaded literally zero about any due +diligence undertaken. Courts also "require particularity in pleading fraudulent concealment." Id. +The bank's conclusory statements come nowhere close, as discussed below. +B. The Employment Claims Do Not Satisfy Rule 9(b). +JPMorgan does not contest that the Employment Claims' factual allegations must satisfy +Rule 9(b). Opp'n 21. Courts must "rigorously enforce" this standard, which "safeguards" parties" +"reputation and goodwill from improvident charges of wrongdoing." +v. Bolton, 904 F.2d +819, 823 (2d Cir. 1990). The TPCs, however, never identify any date or event or even a single +person Mr. Staley supposedly fooled, and thus lack the mandatory "who, what, when, where and +how of" the alleged fraud. +v. Affinion Grp., 889 F.3d 116, 124-25 (2d Cir. 2018). The +Opposition barely offers any fix. It notes that Mr. Staley (like every employee) allegedly signed +a Code of Conduct-here again, without any dates or allegations that anyone at the bank relied on +this and then points outside the TPCs to the plaintiffs' pleadings (which, notably, the bank never +expressly incorporated and often disclaimed). But the conduct underlying the Employment Claims +is Mr. Staley's alleged deception of the bank's employees in their managing of Epstein's accounts. +TPC 11 59-62, 70-77. And the TPCs plainly lack particularized pleading on the alleged deception. +C. The Breach of Fiduciary Duty Claim is Deficient. +The breach claim requires pleading (1) that Mr. Staley actually had a duty to share the +information he supposedly concealed, and (2) that the bank suffered damages directly caused by +his alleged acts or omissions. That the Opposition points to scattered allegations from the +plaintiffs' complaints underscores what is missing from JPMorgan's complaints: any allegations +that sharing personal details about Epstein fell within Mr. Staley's job purview. "A fiduciary +9 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 14 of 15 +obligation... is limited to matters relevant to affairs entrusted." +v. FSG PrivatAir, Inc., 2004 +WL 1837366, at *7 (S.D.N.Y. Aug. 17, 2004). The Complaints, however, plead that Mr. Staley's +"alleged knowledge, participation, and observations were not in connection with the performance +of his duties for" JPMorgan. TPC 9| 42. Nor does the Opposition shore up the deficient damages +allegations. A breach claim requires non-conclusory factual allegations explaining how the breach +was a direct and proximate cause of a nonspeculative injury. See Fownes Bros. v. JPMorgan +Chase & Co., 92 A.D.3d 582, 583 (2012). JPMorgan claims damages for its litigation costs and +reputational harm incurred over a decade after Mr. Staley left the bank. Mr. Staley's alleged +actions, even if true, could not be the direct and proximate cause of those harms. +D. The Faithless Servant Claim is Defective. +The Opposition merely repeats inflammatory (and baseless) accusations of sexual +misconduct by Mr. Staley and then casually labels them "disloyal" activities because Mr. Staley +purportedly served "his own interest" by not reporting himself and Epstein to the bank. Opp'n at +23-24. But JPMorgan's capacious reading of this cause of action departs from the case law. It +would sweep in literally any activity that benefitted an employee to his employer's detriment. +Faithless servant claims are "limited [to] circumstances" that put a company and its employee at +financial odds. Ebel v. G/O Media, Inc., 2021 WL 2037867, at *7 (S.D.N. Y. May 21, 2021). The +Opposition tries to fight the standard, but it unsurprisingly cites no cases supporting its reading. +Compare id. at *6 (rejecting suit for employee retaining "confidential and privileged documents" +and trying to trigger favorable +package) with +Stanley v. Skowron, 989 F. Supp. +2d 356, 362 (S.D.N.Y. 2013) (permitting suit over "insider trading" off employer's information). +Hiding alleged malfeasance is not akin to competing with the bank to its financial detriment. +CONCLUSION +The Complaints should be dismissed with prejudice. +10 + + +Case 1:22-cv-10904-JSR Document 146 Filed 05/15/23 Page 15 of 15 +Date: May 15, 2023 +Respectfully submitted, +By: /s/ Brendan V. Jr. +Brendan V.. +1. Jr. +Zachary K. +Stephen L. Wohlgemuth +& CONNOLLY LLP +680 Maine Avenue SW +Washington, DC 20024 +Tel: (202) 434-5252 +Fax: (202) 434-5029 +zwarren(@wc.com +Counsel for Third-Party Defendant +James Edward Staley +11 diff --git a/vision-fixhub/court-05/769619cad85df7cadb7ef2b139d4ce60e9f1708319c2ea166afa8e2ea6190895.receipt.json b/vision-fixhub/court-05/769619cad85df7cadb7ef2b139d4ce60e9f1708319c2ea166afa8e2ea6190895.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b506ed1204087b42b5dc034f04fc1689218e1bc2 --- /dev/null +++ b/vision-fixhub/court-05/769619cad85df7cadb7ef2b139d4ce60e9f1708319c2ea166afa8e2ea6190895.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -186, + "dataset": "marble-joined", + "doc_id": "769619cad85df7cadb7ef2b139d4ce60e9f1708319c2ea166afa8e2ea6190895", + "engine": "marble-apple-vision", + "event_count": 18, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "b661cce065492ead6afee6995fec666a1a33200677d6c7f87b91b9c007f04114", + "output_sha256": "5a86ebcc8b103f8e2388f54ad41ae606f30d73b14f43ce6402f419d0809f85a5", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/769e0cfc64404f0dd8efe1d3afef9ee4694298b5b0747c2b4b6799100c8a9179.md b/vision-fixhub/court-05/769e0cfc64404f0dd8efe1d3afef9ee4694298b5b0747c2b4b6799100c8a9179.md new file mode 100644 index 0000000000000000000000000000000000000000..738791516b7c0e6731f23d70af42147b19120c93 --- /dev/null +++ b/vision-fixhub/court-05/769e0cfc64404f0dd8efe1d3afef9ee4694298b5b0747c2b4b6799100c8a9179.md @@ -0,0 +1,3 @@ +Case 1:22-cv-10904-JSR Document 237-2 Filed 07/25/23 Page 1 of 1 +FILED UNDER SEAL + diff --git a/vision-fixhub/court-05/769e0cfc64404f0dd8efe1d3afef9ee4694298b5b0747c2b4b6799100c8a9179.receipt.json b/vision-fixhub/court-05/769e0cfc64404f0dd8efe1d3afef9ee4694298b5b0747c2b4b6799100c8a9179.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d861155aa0d94e54674a01f47f563ba0811eef30 --- /dev/null +++ b/vision-fixhub/court-05/769e0cfc64404f0dd8efe1d3afef9ee4694298b5b0747c2b4b6799100c8a9179.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -21, + "dataset": "marble-joined", + "doc_id": "769e0cfc64404f0dd8efe1d3afef9ee4694298b5b0747c2b4b6799100c8a9179", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "2a57e6b2380b187ed37abb92ba0d0b2c7a4785da4c89583991838b3d0cc6dc67", + "output_sha256": "d97224cda26be55cfcd977dd87b3fd89f2998ce19a5a6e20f03fbf0a9ce54804", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/76cfa11551e07e139fd121542e6ba9fd43ad32035a55e46eee82689161b630a0.md b/vision-fixhub/court-05/76cfa11551e07e139fd121542e6ba9fd43ad32035a55e46eee82689161b630a0.md new file mode 100644 index 0000000000000000000000000000000000000000..2e33e804674f8064cf78f9e58c46f7f175b746c6 --- /dev/null +++ b/vision-fixhub/court-05/76cfa11551e07e139fd121542e6ba9fd43ad32035a55e46eee82689161b630a0.md @@ -0,0 +1,180 @@ +Case 1:22-cv-10904-JSR Document 100 Filed 03/27/23 Page 1 of 5 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +Plaintiff, +Case Number: 1:22-cv-10904-JSR +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +JAMES EDWARD STALEY +Third-Party Defendant. +STIPULATED MOTION FOR APPROVAL OF PROTOCOL FOR REVIEW OF +VIDEOMATERIALS AND PHOTOGRAPHS FOR THE PRESENCE OF POTENTIAL +CHILD SEX ABUSE MATERIALS AND FOR DISCLOSURE OF THOSE MATERIALS +Plaintiffs Jane Doe 1 and the Government of the United States Virgin Islands +("Government"), by their respective counsel, move pursuant to Federal Rules of Civil Procedure +26(c), and the authority of the Court to administer proceedings before it, for approval of an agreedupon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to +review videorecorded materials and photographs in the possession, custody, or control of the +Epstein Estate (the "Epstein Media") in response to subpoenas previously issued by Jane Doe 1 +and, to the extent responsive to those subpoenas, disclose relevant portions of the Epstein Media + + +Case 1:22-cv-10904-JSR Document 100 Filed 03/27/23 Page 2 of 5 +(the "Responsive Media") to Jane Doe I's counsel and to other parties in the litigations pending +before the Court involving claims related to Jeffrey Epstein. +Factual Background +The Court is aware of the general nature of this case from earlier proceedings. For purposes +of this Motion, it is relevant to note that Jane Doe 1 has alleged that she was the victim of coerced +commercial sex trafficking by Jeffrey Epstein and his co-conspirators. Jane Doe 1 has issued a +subpoena to the Epstein Estate, seeking certain videorecorded materials and photographs within +the Epstein Media, and the Estate has agreed to produce Responsive Media in the Estate's +possession to the extent that the production is not inconsistent with federal or state law, and to the +extent that the videos or photographs were not downloaded or otherwise obtained at the time +through publicly-available sources.' +On March 14, 2023, counsel for the Epstein Estate notified counsel for Jane Doe 1 that it +had located materials within the Epstein Media that may be responsive to her subpoenas. The +Estate also advised counsel for the Government and Jane Doe 1 of its concern that some of the +Epstein Media might contain child sex abuse imagery (CSAM). The knowing accessing, +possession, or distribution of CSAM is forbidden by federal law. See 18 U.S.C. $§ 2252, 2252A. +The Estate has expressed concern that its counsel's review of the Epstein Media could subject +counsel to criminal investigation or charges or civil claims in light of the possibility that the review +" Videos or photographs that were not obtained at the time through publicly-available sources is +meant to include Responsive Media that may consist of movies or You Tube videos, for example, +but does not extend to Responsive Media relating to Epstein activities or properties that may have +been publicly disclosed at any time. +" In this motion, the parties use the term "child sex abuse imagery" or CSAM as a synonym for the +inappropriate term, "child pornography." See United States v. Larson, No. 5:19-CR-50165-RAL, +2023 WL 196171, at *1 (D.S.D. Jan. 17, 2023) ("Pornography connotes a certain aspect of consent +that is impossible when the images or videos depict children."). + + +Case 1:22-cv-10904-JSR Document 100 Filed 03/27/23 Page 3 of 5 +of the Epstein Media could involve accessing CSAM. The Epstein Estate has advised that it does +not have any specific knowledge that any of the Epstein Media does, in fact, contain CSAM, but +wishes to put in place an appropriate procedure in case its counsel encounters such material. +Proposed Review Protocol +Against that backdrop, counsel for the Government and Jane Doe 1 and the Epstein Estate +have conferred and have agreed that the Government and Jane Doe 1 would move the Court for +the entry of an order approving the following protocol for the Epstein Estate's review of the Epstein +Media for potential production to parties in the litigations pending before the Court: +The Epstein Estate shall review the Epstein Media to determine its responsiveness +to the subpoenas that have been issued by Jane Doe 1 and other parties to the related litigations. +2. +If, during the course of that review, the Epstein Estate sees a particular recording +that appears to contain possible CSAM, it shall promptly stop further review of that recording and +notify the Federal Bureau of Investigation ("FBI") or such other agency or entity as the FBI may +direct of the recording's existence. No CSAM shall be copied or transmitted to another party, +except as directed by the FBI or other government agency. +3. +If no CSAM is observed during the review, the Responsive Media will be provided +to counsel for Jane Doe 1 and the Government in response to the relevant subpoena. To the extent +Responsive Media is identified prior to the identification of possible CSAM, such materials also +will be produced to counsel. Counsel for Jane Doe 1 and any other recipient of Responsive Media +may then use this material for the prosecution or defense of the above-captioned case and make +such further disclosures as are required by civil discovery rules (e.g., appropriate disclosures to +opposing counsel). +The attached proposed Order reflecting this protocol is intended to: + + +Case 1:22-cv-10904-JSR Document 100 Filed 03/27/23 Page 4 of 5 +Provide the Epstein Estate with an approved protocol for reviewing the Epstein +Media for purposes of this litigation only without fear of criminal or civil liability; +2. +Provide Jane Doe 1 with Responsive Media that may be relevant to her case; +3. +Protect against disclosure or dissemination of CSAM; and +4. +Follow the directive of 18 U.S.C. 3509(m) against reproduction of CSAM. +Conclusion +This Motion has been agreed to by the parties. +Date: March 27, 2023 +Respectfully submitted, +Is/ Linda +Linda +(pro hac vice) +Mimi Liu (pro hac vice) +David I. Ackerman +Paige Boggs (pro hac vice) +MOTLEY RICE LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Fax: (202) 232-5513 +Isinger@motleyrice.com +mliu@motleyrice.com +dackerman@motleyrice.com +pboggs@motleyrice.com +/s/ +POTTINGER LLP +425 N. Andrews Ave., Suite 2 +Fort Lauderdale, FL 33301 +Tel: (954) 524-2820 +Fax: (954) 524-2822 +brad@epllc.com +Brittany N. +POTTINGER LLP +1501 Broadway, Floor 12 +New York, NY +Tel: (954) 524-2820 +Fax: (954) 524-2822 +brittany@epllc.com +Carol +(pro hac vice) +Acting Attorney General of the +United States Virgin Islands +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +St. +, U.S. Virgin Islands 00802 +Tel: (340) 774-5666 ext. 10101 +Counsel for Plaintiff Government +of the United States Virgin Islands +David Boies +Andrew Villacastir +BOIES SCHILLER FLEXNER LLF +55 Hudson Yards +New York, NY +Tel: (212) 446-2300 +Fax: (212) 446-2350 +dboies@bsfllp.com +avillacastin@bsfllp.com + + +Case 1:22-cv-10904-JSR Document 100 Filed 03/27/23 Page 5 of 5 +Sigrid McCawley (pro hac vice) +BOIES SCHILLER FLEXNER LLP +401 E. Las Olas Blvd., Suite 1200 +Fort Lauderdale, FL 33316 +Tel: (954) 356-0011 +Fax: (954) 356-0022 +smccawley@bsfllp.com +Counsel for Plaintiff Jane Doe 1 +STIPULATED AND AGREED TO BY: +Is/John Butts +John Butts +Felicia H. Ellsworth +WILMER CUTLER PICKERING +HALE AND DORR LLP +60 State Street +Boston, +02109 +Tel: (617) 526-6687 +Fax: (617) 526-5000 +john.butts@wilmerhale.com +felicia.ellsworth@wilmerhale.com +Counsel for Defendant +JPMorgan Chase Bank, N.A. +Is/ Zachary K. +Zachary K. +(pro hac vice pending) +& CONNOLLY LLP +680 Maine Avenue SW +Washington, DC 20024 +Tel: (202) 434-5252 +Fax: (202) 434-5029 +zwarren@wc.com +Counsel for Third-Party Defendant +James Edward Staley diff --git a/vision-fixhub/court-05/76cfa11551e07e139fd121542e6ba9fd43ad32035a55e46eee82689161b630a0.receipt.json b/vision-fixhub/court-05/76cfa11551e07e139fd121542e6ba9fd43ad32035a55e46eee82689161b630a0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..783b0f93677353a15887e0bc74ac90f7a6aec0e6 --- /dev/null +++ b/vision-fixhub/court-05/76cfa11551e07e139fd121542e6ba9fd43ad32035a55e46eee82689161b630a0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -62, + "dataset": "marble-joined", + "doc_id": 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Page 1 of 1 + +Filed Under Seal diff --git a/vision-fixhub/court-05/76f189e2207bf5582c8971b98236f2a0aeb1dc765285e1ca7ab9e3ccaf61d8ff.receipt.json b/vision-fixhub/court-05/76f189e2207bf5582c8971b98236f2a0aeb1dc765285e1ca7ab9e3ccaf61d8ff.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c17a04c08faf1e2a8c5e421b04147875d21ad4d0 --- /dev/null +++ b/vision-fixhub/court-05/76f189e2207bf5582c8971b98236f2a0aeb1dc765285e1ca7ab9e3ccaf61d8ff.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -22, + "dataset": "marble-joined", + "doc_id": "76f189e2207bf5582c8971b98236f2a0aeb1dc765285e1ca7ab9e3ccaf61d8ff", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "a0d4493a68a0019a9c8f75f8d6b5c3227aea88583cf6ea5454b3b9331647a8b6", + "output_sha256": "83c8f6a568ed174f3773aa3169e810f4e8972a6901075e20f06e591114be4463", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/7737515e8d6e26d25a7ba8db419b3acda88351729dbd514c7280514954592690.md b/vision-fixhub/court-05/7737515e8d6e26d25a7ba8db419b3acda88351729dbd514c7280514954592690.md new file mode 100644 index 0000000000000000000000000000000000000000..c114b00b835dd4f4bdb251209000a3ae69bce865 --- /dev/null +++ b/vision-fixhub/court-05/7737515e8d6e26d25a7ba8db419b3acda88351729dbd514c7280514954592690.md @@ -0,0 +1,4 @@ +Case 1:22-cv-10904-JSR Document 158-93 Filed 05/23/23 + + +FILED UNDER SEAL diff --git a/vision-fixhub/court-05/7737515e8d6e26d25a7ba8db419b3acda88351729dbd514c7280514954592690.receipt.json b/vision-fixhub/court-05/7737515e8d6e26d25a7ba8db419b3acda88351729dbd514c7280514954592690.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e0ced8da9f1892c8abbcc602131485bd46c5d7bc --- /dev/null +++ b/vision-fixhub/court-05/7737515e8d6e26d25a7ba8db419b3acda88351729dbd514c7280514954592690.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "7737515e8d6e26d25a7ba8db419b3acda88351729dbd514c7280514954592690", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "e64ff9f606594b885c2bd6ff5438a34c9d45aa83143780252b96fbbf0c0730ac", + "output_sha256": "c596d0919cd2d32aeb075ab9ed36e9a371bdca9e1a1d2a7c948565fb46544ede", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/77cbb12b8f80e3f420917eb7848823518552ba953d02e0f58bc087abeb23a765.md b/vision-fixhub/court-05/77cbb12b8f80e3f420917eb7848823518552ba953d02e0f58bc087abeb23a765.md new file mode 100644 index 0000000000000000000000000000000000000000..c3b3cd169e7ad7b469088f825c74d17f09d4f322 --- /dev/null +++ b/vision-fixhub/court-05/77cbb12b8f80e3f420917eb7848823518552ba953d02e0f58bc087abeb23a765.md @@ -0,0 +1,65 @@ +Case 1:22-cv-10904-JSR Document 94 Filed 03/23/23 Page 1 of 2 +IN THE UNITED STATES DISTRICT COURT +FOR THE SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS, +Plaintiff, +Case No. 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A., +Defendant. +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' +MOTION FOR LEAVE TO WITHDRAW SARA D. AGUIÑIGA +AS COUNSEL OF RECORD +Plaintiff, Government of the United States Virgin Islands, by and through undersigned +counsel, respectfully submits this Motion for Leave to Withdraw Sara D. Aguiñiga as Counsel of +Record. In support, Plaintiff states as follows: +On January 27, 2023, the Court entered an Order [Docket #35] granting admission +pro hac vice to Sara D. Aguiñiga as counsel for Plaintiff in the above-captioned litigation. +Plaintiff now moves for leave to withdraw Ms. Aguiñiga's appearance in this action +because Ms. Aguiñiga is no longer associated with the law firm of Motley Rice LLC and therefore +no longer represents Plaintiff in this litigation. +3. +Withdrawal is sought with notice to and consent from Plaintiff. Plaintiff remains +represented in this action by legal counsel from Motley Rice LLC, including but not limited to +undersigned counsel. +3. +Granting this motion will not cause any undue delay in these proceedings or +prejudice any party. + + +Case 1:22-cv-10904-JSR Document 94 Filed 03/23/23 Page 2 of 2 +WHEREFORE, the Plaintiff, Government of the United States Virgin Islands, by counsel, +respectfully requests that the Court grant this motion and enter an Order permitting the withdrawal +of Sara D. Aguiñiga as counsel of record and removing her from the list of attorneys receiving +electronic notices of filings and proceedings in this action. +Dated: March 23, 2023 +CAROL +_ ESQ. +ACTING ATTORNEY GENERAL +/s/ Linda +Linda +(pro hac vice) +Mimi Liu (pro hac vice) +David I. Ackerman +Paige Boggs (pro hac vice) +MOTLEY RICE LLC +401 9th Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Fax: (202) 232-5513 +Isinger@motleyrice.com +mliu@motleyrice.com +dackerman@motleyrice.com +pboggs@motleyrice.com +Carol +(pro hac vice) +Acting Attorney General of the +United States Virgin Islands +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +St. +1. U.S. Virgin Islands 00802 +Tel: (340) 774-5666 ext. 10101 +Attorneys for Plaintiff Government of the +United States Virgin Islands diff --git a/vision-fixhub/court-05/77cbb12b8f80e3f420917eb7848823518552ba953d02e0f58bc087abeb23a765.receipt.json b/vision-fixhub/court-05/77cbb12b8f80e3f420917eb7848823518552ba953d02e0f58bc087abeb23a765.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..521cfaa80ee271b8e124b68d8e34eec6fb5dd2c4 --- /dev/null +++ b/vision-fixhub/court-05/77cbb12b8f80e3f420917eb7848823518552ba953d02e0f58bc087abeb23a765.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "77cbb12b8f80e3f420917eb7848823518552ba953d02e0f58bc087abeb23a765", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "fedb2ad54366e31dff7b4d75e35b2d79d8d27c68d18a322d26e51da7f701078f", + "output_sha256": "9cc0933de4c5380b3eca7c1fe06a4d5379b17d715dcfb53955c10b11c16a0384", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/77d58ac38fcdfb03d2b3c77236062ab8717422fa3d4eea5e7ed9f67944f21269.md b/vision-fixhub/court-05/77d58ac38fcdfb03d2b3c77236062ab8717422fa3d4eea5e7ed9f67944f21269.md new file mode 100644 index 0000000000000000000000000000000000000000..7b9c7ca5183a3db2c1b5bcd10d56a21ffe9911dc --- /dev/null +++ b/vision-fixhub/court-05/77d58ac38fcdfb03d2b3c77236062ab8717422fa3d4eea5e7ed9f67944f21269.md @@ -0,0 +1,62 @@ +Case 1:22-cV-10904-JSR Document 267-49 Filed 08/07/23 Page 1 of 3 + + + +Case 1:22-cv-10904-JSR Document 267-49 Filed 08/07/23 Page 2 of 3 +From: +Sent: +To: +Subject: +Lesley Groff L +@gmail.com] +7/12/20183:32:46 PM +Jeffrey Epstein [jeevacation@gmail.com] +Re: Bloomberg Invite for Plaskett for Congress fundraiser +Importance: High +Sure thanks Lesley +The short answer is that because there will be a primary and a general clection for the congressional race our +campaign can receive $5,400 from each individual contributor. The FEC states that a candidate may receive +$2,700 for each race - and because there will be a primary and a general election a contributor may write one +check for $5,400 and designate on the note line $2.7k for primary; $2.7k for general. +On Jul 12, 2018, at 1057 AM, jeffrey E. wrote: +get maximum ampounts allowed +On Thu, Jul 12, 2018 at 10:57 AM, Lesley Groff < +@gmail.com> wrote: +Begin forwarded message: +From: Stacey Plaskett < +@gmail.com> +Subject: Bloomberg Invite for Plaskett for Congress fundraiser +Date: July 12, 2018 at 10:55:05 AM EDT +To: +@gmail.com, Erika Kellerhals ‹ +Cc: +@kellfer.com> +@detailsconsultingllc.com +Good morning Lesley, +If you would share this invitation with Jeffiey I'd be much appreciative. I would be grateful for his support and +the support of those that he may direct to assist me. +I'll be in New York City the Thursday of the event through the weekend. +Again thanks +Stacey +Begin forwarded message: +From: Yolonda Addison < +Date: July 11, 2018 at 3:15:09 PM EDT +To: LeRoy Daughter +Cc: Jerome +Subject: Bloomberg Invite +@ detailsconsultingllc.com> +@gil.com>, Stacey Plaskett < +@gmail.com +@gmail.com> + +ESTATE_JPMO12219 + + +Case 1:22-cV-10904-JSR Document 267-49 Filed 08/07/23 Page 3 of 3 +Here it is! Please let me know if you would like me to send it to anyone :) +Yolonda Addison +Managing Director +Details Consoéting, LC +fice +www.detailsconsultine/le.com +-- diff --git a/vision-fixhub/court-05/77d58ac38fcdfb03d2b3c77236062ab8717422fa3d4eea5e7ed9f67944f21269.receipt.json b/vision-fixhub/court-05/77d58ac38fcdfb03d2b3c77236062ab8717422fa3d4eea5e7ed9f67944f21269.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f7f83f0e1925df75b1d99cb998a39c718dcd74e0 --- /dev/null +++ b/vision-fixhub/court-05/77d58ac38fcdfb03d2b3c77236062ab8717422fa3d4eea5e7ed9f67944f21269.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -686, + "dataset": "marble-joined", + "doc_id": "77d58ac38fcdfb03d2b3c77236062ab8717422fa3d4eea5e7ed9f67944f21269", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "7100343cc9d6b513a0fcc468a577603ba119c3ff8ff2a4f859845b8adaf14d5e", + "output_sha256": "c9f7c79edef62de0bfebaa7b0f39d0c0e78b9f2b9468108b25e114f34ff9e521", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/77dd190e83caa1711d6bcbae31eb12985bab9c9f1f7d0325d2b39492dc4eb208.md b/vision-fixhub/court-05/77dd190e83caa1711d6bcbae31eb12985bab9c9f1f7d0325d2b39492dc4eb208.md new file mode 100644 index 0000000000000000000000000000000000000000..8c631f15338618db4783b3b1f374e30433c804e0 --- /dev/null +++ b/vision-fixhub/court-05/77dd190e83caa1711d6bcbae31eb12985bab9c9f1f7d0325d2b39492dc4eb208.md @@ -0,0 +1,74 @@ +Case 1:22-cv-10904-JSR Document 84 Filed 03/09/23 Page 1 of 2 +AO 441 (Rev. 07/10) Summons on Third-Party Complaint +UNITED STATES DISTRICT COURT +for the +Southern District of New York +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS +Plaintiff +V. +JPMORGAN CHASE BANK, N.A. +Defendant, Third-party plaintiff +V. +JAMES EDWARD STALEY +Third-party defendant +Civil Action No. 22-cv-10904-JSR +SUMMONS ON A THIRD-PARTY COMPLAINT +To: (Third-party defendant's name and address) +James Edward Staley +930 Park Avenue, Unit 6N/6S +New York, NY 10028 +A lawsuit has been filed against defendant JPMorgan Chase Bank, N.A., who as third-party plaintiff is making +this claim against you to pay part or all of what the defendant may owe to the plaintiff Goverment of the United States Virgin Islands +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you +are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. +P. 12 (a)(2) or (3) — you must serve on the plaintiff and on the defendant an answer to the attached complaint or a +motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the defendant or +defendant's attorney, whose name and address are: +Winer Culei Pickerng Hale and Don LLH +onlon, 0210s +111 19S7) 526-6000 +It must also be served on the plaintiff or plaintiff's attorney, whose name and address are: +40/1 geh Steel NVN, Sul 6590 +202) 732-5504 +If you fail to respond, judgment by default will be entered against you for the relief demanded in the third-party +complaint. You also must file the answer or motion with the court and serve it on any other parties. +A copy of the plaintiff's complaint is also attached. You may - but are not required to - respond to it. +Date: +3/9/2023 +CLERK OF COURT +Is/ J. +Signature of Clerk or Deputy Clerk + + +Case 1:22-cv-10904-JSR Document 84 Filed 03/09/23 Page 2 of 2 +AO 441 (Rev. 07/10) Summons on Third-Party Complaint (Page 2) +Civil Action No. 22-cv-10904-JSR +PROOF OF SERVICE +(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l)) +This summons for (name of individual and title, if any) +was received by me on (date) +• I personally served the summons on the individual at (place) +on (date) +; or +] I left the summons at the individual's residence or usual place of abode with (name) +, a person of suitable age and discretion who resides there, +on (date) +, and mailed a copy to the individual's last known address; or +• I served the summons on (name of individual) +designated by law to accept service of process on behalf of (name of organization) +on (date) +; or +, who is +• I returned the summons unexecuted because +• Other (specify): +; or +My fees are S +for travel and S +I declare under penalty of perjury that this information is true. +for services, for a total of S +0.00 +Date: +Server's signature +Printed name and title +Server's address +Additional information regarding attempted service, etc: diff --git a/vision-fixhub/court-05/77dd190e83caa1711d6bcbae31eb12985bab9c9f1f7d0325d2b39492dc4eb208.receipt.json b/vision-fixhub/court-05/77dd190e83caa1711d6bcbae31eb12985bab9c9f1f7d0325d2b39492dc4eb208.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2ccd3d9c133bcc9da8ca05078accc3852283ff2a --- /dev/null +++ b/vision-fixhub/court-05/77dd190e83caa1711d6bcbae31eb12985bab9c9f1f7d0325d2b39492dc4eb208.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -24, + "dataset": "marble-joined", + "doc_id": "77dd190e83caa1711d6bcbae31eb12985bab9c9f1f7d0325d2b39492dc4eb208", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "46f1eedd03520963a96a87c6eb9b9b2a41373467b4b25ce2f888def9f90cbfd1", + "output_sha256": "05efb0c50403428017857c8c28373ffa03bf01bfa6a407e56cf46a5c1739e517", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/77ee89ef35aa71dab746172dab630f1f6aab79d06ee2ee81c5a6cae772c2bc5c.md b/vision-fixhub/court-05/77ee89ef35aa71dab746172dab630f1f6aab79d06ee2ee81c5a6cae772c2bc5c.md new file mode 100644 index 0000000000000000000000000000000000000000..41f4267645204fffa7c8d91e6db74fa64faf1475 --- /dev/null +++ b/vision-fixhub/court-05/77ee89ef35aa71dab746172dab630f1f6aab79d06ee2ee81c5a6cae772c2bc5c.md @@ -0,0 +1,26 @@ +Case 1:22-cV-10904-JSR Document 326-74 Filed 09/08/23 Page 1 of 2 + + + +From: +To: +Sent: +Subject: +Case 1:22-cv-10904-JSR Document 326-74 Filed 09/08/23 Page 2 of 2 +Jeffrey Epstein