USVI Partial Summary Judgment Memo

GOVERNMENT'S MEMORANDUM IN SUPPORT OF PARTIAL SUMMARY JUDGMENT Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. S.D.N.Y. No. 1:22-cv-10904 Filed: July 24, 2023 This memorandum presents the U.S. Virgin Islands' summary-judgment argument against JPMorgan. The Government argued that the record showed Epstein operated a sex-trafficking venture, that JPMorgan knew or recklessly disregarded that venture, and that the bank participated in and benefited from it through financial services. The filing organizes the Government's case around the Trafficking Victims Protection Act. It argues that JPMorgan had information about Epstein's criminal conduct by 2006, including diligence materials, reporting about Ghislaine Maxwell, cash-withdrawal patterns, civil settlements, and Epstein's later Florida conviction. The memorandum also points to alleged knowledge held by bank employees and to Epstein's relationship with senior banker James Staley. The USVI further argued that JPMorgan participated by maintaining accounts, moving money, extending services to related entities, and preserving the bank relationship despite escalating compliance concerns. The brief also challenged JPMorgan's effort to shift blame to territorial officials, contending that defenses based on the Government's own sex-offender monitoring or travel-waiver decisions could not defeat public enforcement claims. As a party brief, the document is advocacy rather than a court finding. Its archival value is that it collects the Government's strongest public narrative of the bank-compliance evidence, the asserted trafficking indicators, and the remedies the USVI sought before the case settled. Source: SDNY / CourtListener RECAP Available at: https://storage.courtlistener.com/recap/gov.uscourts.nysd.591653/gov.uscourts.nysd.591653.220.0.pdf