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’ MOTION FOR PARTIAL SUMMARY JUDGMENT¶
For the reasons set forth in the accompanying memorandum of law and supporting documents, which are incorporated as if fully set forth herein, the Government of the United States Virgin Islands (“Government”) moves for Partial Summary Judgment. The Government is entitled to judgment as a matter of law for JPMorgan’s participation in Epstein’s sex-trafficking venture and obstruction of enforcement of the law in violation of the Trafficking Victims Protection Act (“TVPA”), 18 U.S.C. §§ 1591(a)(2) and (d). The Government is also entitled to judgment as a matter of law in regard to JPMorgan’s equitable and fault-shifting affirmative defenses (Defenses 5-8).¶
Accordingly, the Government requests entry of judgment in its favor on Counts I and V of its Second Amended Complaint and requests declaratory relief, injunctive relief, and civil penalties as set forth herein. The Government defers its request for disgorgement, compensatory and punitive damages, and other appropriate relief for JPMorgan’s TVPA violations until trial. The Government also requests entry of judgment as to JPMorgan’s affirmative defenses 5-8.¶
Dated: July 24, 2023 ARIEL ESQ. ATTORNEY GENERAL¶
/s/ 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 lsinger@motleyrice.com dackerman@motleyrice.com pboggs@ motleyrice.com¶
Attorneys for Plaintiff Government of the United States Virgin Islands¶