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Court filing · April 3, 2023

USVI motion for leave to amend complaint to add obstruction count against JPMorgan, 2023

The US Virgin Islands government moves for leave to amend its complaint against JPMorgan Chase to add a sex-trafficking obstruction count, in the case also naming a public figure.Machine-written summary

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. )

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 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 ESQ. ACTING ATTORNEY GENERAL

Isl 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

lsinger@motleyrice.com

mliu CO 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. , U.S. Virgin Islands 00802

Tel: (340) 774-5666 ext. 10101

Attorneys for Plaintiff Government of the United States Virgin Islands

USVI motion for leave to amend complaint to add obstruction count against JPMorgan, 2023

Court filings

The US Virgin Islands government moves for leave to amend its complaint against JPMorgan Chase to add a sex-trafficking obstruction count, in the case also naming a public figure.

Court Records: U.S. Virgin Islands v. JPMorgan Chase (S.D.N.Y. 1:22-cv-10904) · April 3, 2023

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. ) 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 I…