JPMorgan Partial Summary Judgment Memo

JPMORGAN 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 sets out JPMorgan's partial summary-judgment position against the U.S. Virgin Islands. The bank did not use this filing to answer every factual allegation in the case. Instead, it targeted categories of relief and legal theories that it argued were unavailable as a matter of law. JPMorgan argued that the USVI could not recover compensatory damages belonging to victims, punitive damages belonging to victims, or fines and penalties through the TVPA theory asserted by the Government. The bank also argued that any damages would have to be offset to avoid duplicative recovery, given parallel compensation and settlement mechanisms involving Epstein victims. The brief separately attacked the USVI obstruction claim. JPMorgan argued that the Government lacked standing to pursue the obstruction theory and could not prove the required elements. It also raised retroactivity arguments, contending that some TVPA theories could not be applied to conduct before statutory amendments expanded liability. This filing is useful because it shows JPMorgan's legal defense strategy after discovery: narrow the remedies, limit retroactive exposure, and remove the obstruction claim even if other TVPA issues remained disputed. Like the USVI summary-judgment memorandum, it is a party argument, not a judicial finding. The case settled before trial, so these legal positions remain part of the pre-settlement litigation record rather than a final merits ruling. Source: SDNY / CourtListener RECAP Available at: https://storage.courtlistener.com/recap/gov.uscourts.nysd.591653/gov.uscourts.nysd.591653.223.0.pdf