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The USVI And Their Motion In Opposition To JP Morgan's Request For Dismissal (Part 1) · Beyond The Horizon

• 0:00
  Speaker 1: What's up everyone and welcome back to the Epstein Chronicles.
• 0:04
  Speaker 1: In this episode we're going to take a dive right
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  Speaker 1: back into the court documents and we're going to start
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  Speaker 1: taking a look at the government of the United States
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  Speaker 1: Virgin Islands and their memorandum of law in opposition to
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  Speaker 1: JPMorgan Chase and their motion to dismiss. Introduction. For two
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  Speaker 1: decades defendant JPMorgan Chase Bank North America facilitated and sustained
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  Speaker 1: Jeffrey Epstein's sex trafficking and by handling and redacted his
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  Speaker 1: payments to young women and girls who were his victims
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  Speaker 1: and recruiters. Sex trafficking was the principal business of Epstein's
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  Speaker 1: accounts held by J.P. Morgan, and J.P. Morgan profited handsomely
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  Speaker 1: from the hundreds of millions of dollars in assets in
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  Speaker 1: those accounts, in addition to Epstein's connections and referrals of
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  Speaker 1: ultra-wealthy and powerful clients. Far from the so-called ordinary banking
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  Speaker 1: services J.P. Morgan claims it provided to Epstein, JPMorgan broke
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  Speaker 1: every rule to facilitate Epstein's sex trafficking and feed off
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  Speaker 1: his wealth and his connections. In 2008, after Epstein pled
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  Speaker 1: guilty to felony charges for procuring a child for prostitution,
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  Speaker 1: conduct that is child sex trafficking under the TVPA, the
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  Speaker 1: expectation was that JPMorgan would cut ties with, or at
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  Speaker 1: a minimum, closely monitor the convicted felon and registered sex offender.
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  Speaker 1: It did neither. Instead, and decided at the highest level,
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  Speaker 1: pending Diamond Review, J.P. Morgan continued to facilitate and sustain
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  Speaker 1: Epstein sex trafficking by making the payments and covering up
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  Speaker 1: the trafficking, including for many years after it no longer
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  Speaker 1: held Epstein's accounts, which predictably enabled ongoing and future trafficking
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  Speaker 1: by Epstein. J.P. Morgan, through its head of private bank,
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  Speaker 1: assigned to manage Epstein and Epstein's accounts, made multiple visits
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  Speaker 1: to Epstein's Virgin Islands residence where women and girls were
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  Speaker 1: sex trafficked. only when there was nothing left to be
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  Speaker 1: gained upon Epstein's arrest and death in federal prison in 2019, redacted.
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  Speaker 1: The government of the United States, Virgin Islands, brings this
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  Speaker 1: action as parents patriae seeking relief for J.P. Morgan's participation
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  Speaker 1: in Epstein's sex trafficking that took place in and was
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  Speaker 1: directed from the Virgin Islands. Throughout the decades when J.P.
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  Speaker 1: Morgan handled the redacted Epstein payments to victims and recruiters,
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  Speaker 1: Epstein lived in the Virgin Islands, on his secluded private island,
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  Speaker 1: Little St. James. The government asserts claims for J.P. Morgan's
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  Speaker 1: violations of the Trafficking Victims Protection Act, 18 U.S. Code
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  Speaker 1: Section 1580-1597, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, SECO,
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  Speaker 1: Virgin Island Code 14, Section 600-614, and the Consumer Fraud
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  Speaker 1: and Deceptive Business Practices Act, CFDBPA. JPMorgan tries to shift
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  Speaker 1: the blame for its participation onto the government, contending that
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  Speaker 1: the government had access to the same information on Epstein
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  Speaker 1: that JPMorgan did. This belies both facts, ignoring the allegations
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  Speaker 1: detailing Epstein's redacted. The TVPA establishes liability for those who
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  Speaker 1: participate in human trafficking, and JPMorgan's efforts at misdirection do
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  Speaker 1: not alter its legal responsibility for its own conduct and
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  Speaker 1: the profound consequences for the dozens of women whose trafficking
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  Speaker 1: was uniquely visible in to and made possible by his bank.
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  Speaker 1: Unlike the government, J.P. Morgan had real-time knowledge of millions
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  Speaker 1: of dollars of payments Epstein was making to young women
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  Speaker 1: who were his victims and recruiters, which had no conceivable
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  Speaker 1: relationship to Epstein's stated business interests. J.P. Morgan had real-time
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  Speaker 1: knowledge that Epstein was using accounts of his charitable organizations
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  Speaker 1: to make payments to young women, which had no conceivable
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  Speaker 1: relationship to his charities' stated purposes. JPMorgan's Global Corporate Security
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  Speaker 1: Division Risk Management Division and AML Compliance Director over the
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  Speaker 1: course of years repeatedly identified evidence of Epstein's child sex
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  Speaker 1: trafficking and human trafficking. JPMorgan identified, redacted, JPMorgan identified, had
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  Speaker 1: more of an up-close-and-personal view of Epstein's sex trafficking through
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  Speaker 1: his senior executive J.P. Morgan, assigned to manage Epstein and
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  Speaker 1: Epstein's accounts, who, in his role, built a close relationship
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  Speaker 1: with Epstein, visited Epstein's properties in the Virgin Islands and elsewhere,
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  Speaker 1: exchanged hundreds of messages with Epstein from his J.P. Morgan
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  Speaker 1: email account in full view of J.P. Morgan, including some
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  Speaker 1: with photos of young women, discussed Epstein's provision of services
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  Speaker 1: to him, during his travel on dates that closely corresponded
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  Speaker 1: with Epstein's payments to the same young women from his J.P.
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  Speaker 1: Morgan accounts, and discussed young women or girls procured by
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  Speaker 1: Epstein using the names of Disney princesses, Snow White, and
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  Speaker 1: Beauty and the Beast. J.P. Morgan's failed attempt to divert
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  Speaker 1: attention from its participation in Epstein's sex trafficking is understandable,
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  Speaker 1: as its attempted defenses to the government's TVPA, SECO, and
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  Speaker 1: CFDBPA claims have no merit. Factual Background Between 1998 and 2013, J.P.
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  Speaker 1: Morgan serviced approximately 55 Epstein-related accounts valued in the hundreds
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  Speaker 1: of millions of dollars. During this time, J.P. Morgan handled
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  Speaker 1: payments by Epstein to at least 20 young women or
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  Speaker 1: girls whom he trafficked and subjected to sexual assault in
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  Speaker 1: the Virgin Islands and elsewhere. The payments had no conceivable
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  Speaker 1: relationship to Epstein's stated business interests. Epstein also withdrew hundreds
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  Speaker 1: of thousands of dollars in cash over that time from J.P.
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  Speaker 1: Morgan accounts especially significant as Epstein was known to pay
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  Speaker 1: for massages, sexual encounters, with young girls in cash. During
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  Speaker 1: this time, J.P. Morgan also processed payments by Epstein totaling
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  Speaker 1: almost $ 1. 5 million to known recruiters of victims of Epstein's
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  Speaker 1: sex trafficking enterprise, including the MC2 modeling agency. Among the
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  Speaker 1: recipients of these payments were numerous women with Eastern European surnames,
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  Speaker 1: who were publicly and internally identified as Epstein recruiters and
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  Speaker 1: or victims, including $ 600, 000 to Jane Doe One, a woman
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  Speaker 1: who J.P. Morgan's own due diligence reports stated Epstein purchased
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  Speaker 1: at the age of 14. Throughout its relationship with Epstein, J.P.
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  Speaker 1: Morgan's internal investigation teams identified evidence that he was engaged
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  Speaker 1: in criminal sex trafficking. In 2006, J.P. Morgan's Global Corporate
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  Speaker 1: Security Division reported that Epstein was indicted in Florida for
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  Speaker 1: felony solicitation of minors for prostitution. In 2008, Epstein pled
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  Speaker 1: guilty in Florida to solicitation or procurement of a minor
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  Speaker 1: for prostitution and became a registered sex offender. J.P. Morgan's
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  Speaker 1: continued relationship with Epstein after his criminal plea was reviewed
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  Speaker 1: and approved at the highest levels of the bank. In
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  Speaker 1: August 2008, internal email states, I would count Epstein's assets
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  Speaker 1: as a probable outflow for 2008, $ 120 million or so,
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  Speaker 1: so I can't imagine it will stay pending Diamond's review.
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  Speaker 1: Yet the assets did stay. Next part, redacted. In 2010, J.P.
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  Speaker 1: Morgan's Risk Management Division discussed new allegations of an investigation
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  Speaker 1: of Epstein involving child sex trafficking. Throughout 2010 and 2011, J.P.
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  Speaker 1: Morgan's Compliance and Security Divisions reported evidence of Epstein's engagement
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  Speaker 1: in sex trafficking, including his settlement of a dozen civil
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  Speaker 1: lawsuits and his payment of $ 1 million to the MC2
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  Speaker 1: modeling agency engaged with Epstein in child sex trafficking, luring
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  Speaker 1: girls on the pretext of providing modeling opportunities and careers. J.P. Morgan,
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  Speaker 1: through senior executive Jeff Staley, engaged in multiple visits to
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  Speaker 1: Epstein's residence on Little St. James, where the sex trafficking
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  Speaker 1: took place as part of its management of its business
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  Speaker 1: relationship with Epstein. At the time of these visits, Staley
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  Speaker 1: was serving in the role of J.P. Morgan's head of
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  Speaker 1: private bank, which was dedicated to extremely wealthy clients like Epstein. J.P.
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  Speaker 1: Morgan assigned Staley to manage Epstein and his accounts for
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  Speaker 1: his wealth, connections, and referrals to other ultra-wealthy and powerful clients. Thus,
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  Speaker 1: Staley's job was to maintain a close relationship with Epstein
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  Speaker 1: so that his money, connections, and referrals would continue to
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  Speaker 1: flow to JP Morgan. Between 2008 and 2012, Staley exchanged
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  Speaker 1: over 1,000 messages with Epstein from his JP Morgan email
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  Speaker 1: account in full view of JP Morgan, including emails about
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  Speaker 1: his visit to Little St. James. A December 2008 email
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  Speaker 1: shows Staley planning to visit Epstein in early January of 2009,
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  Speaker 1: Around the time of Staley's scheduled visit, Epstein wired $ 2, 000
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  Speaker 1: from his JP Morgan account to a woman with an
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  Speaker 1: Eastern European surname. In late August 2009, Staley emailed that
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  Speaker 1: he was visiting London. Epstein asked if he needed anything.
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  Speaker 1: Staley replied, yep. Soon after, JP Morgan wired $ 3, 000 from
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  Speaker 1: an Epstein account to the same Eastern European woman, and
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  Speaker 1: then in July of 2010, Staley emailed Epstein saying that
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  Speaker 1: was fun. Say hi to Snow White. to which Epstein responded,
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  Speaker 1: what character would you like next? And Staley said, Beauty
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  Speaker 1: and the Beast. Epstein was also emailed Staley photos of
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  Speaker 1: young women in seductive poses. Following the internal reports of
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  Speaker 1: additional law enforcement investigations into Epstein's sex trafficking in 2010
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  Speaker 1: and 11, J.P. Morgan's response was to send Staley in
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  Speaker 1: 2011 to obtain Epstein's denial on which the bank hung
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  Speaker 1: its hat. J.P. Morgan was at all times required by
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  Speaker 1: the federal law to perform due diligence on its customers
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  Speaker 1: and file SARS with the Treasury Department's Financial Crimes Enforcement Network.
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  Speaker 1: While Epstein was a customer, redacted, or performed even basic
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  Speaker 1: due diligence on Epstein, even though he was high-risk. During
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  Speaker 1: this time, J.P. Morgan benefited from Epstein's wealth and connections.
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  Speaker 1: Epstein helped and promised to help Staley recruit ultra-wealthy clients
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  Speaker 1: to J.P. Morgan. Epstein introduced Staley to the owner of
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  Speaker 1: Highbridge Capital Management, LLC, one of the country's largest hedge funds. J.P.
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  Speaker 1: Morgan subsequently acquired Highbridge, which catapulted Staley's career with and
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  Speaker 1: beyond J.P. Morgan. In 2011, Epstein helped Staley to pitch
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  Speaker 1: the creation of a donor-advised fund, which would be an
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  Speaker 1: exclusive club, with a minimum $ 100 million donation. Epstein continued
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  Speaker 1: trafficking and sexually abusing young women and female children until
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  Speaker 1: his arrest in 2019. It was only after Epstein's death
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  Speaker 1: in federal detention in August 2019, redacted, that JP Morgan
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  Speaker 1: acknowledged that redacted and JP Morgan's illegal conduct, which continued
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  Speaker 1: until 2019, caused repeated and continuous harm to the Virgin
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  Speaker 1: Islands and its residents. All right, we're going to wrap
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  Speaker 1: up right here. And in the next episode, we're going
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  Speaker 1: to pick up with the argument. All of the information
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  Speaker 1: that goes with this episode can be found in the
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  Speaker 1: description box.