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Court filing

USVI v. JPMorgan response to statement of facts on Epstein's sex trafficking, 2022

JPMorgan's response to US Virgin Islands' disputed statement of facts, contesting claims it knew Epstein ran a sex-trafficking venture.Machine-written summary

ATTACHMENT B PART 2

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On October 25, 2007, [REDACTED] emails Mary [REDACTED], subject: “Re: Jeffrey Epstein new LOC” and states in response to [REDACTED] request to open a new line of credit for Epstein: “we do still have an existing $1MM LC that we issued a few years ago … supporting the Modeling Agency’s loan to Mellon.” Ex. 102 at -962-63.

JPMC Response: Disputed to the extent USVI misstates the document. The quoted language states “we do still have an existing $1MM LC that we issued a few years ago … supporting the Modeling Agency’s loan to Mellon.” USVI Ex. 102 at -962-63. Disputed that the cited document establishes that Mary [REDACTED] was requesting a new line of credit for Epstein. In the cited document, it is clear [REDACTED] is passing along the request from Richard Kahn at Jeffrey Epstein’s office and asking for advice on how to proceed. USVI Ex. 102 at -962-63.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. [REDACTED]

JPMC Response: Undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. In a July 31, 2010 email, Erdoes tells Staley, describing a July 31, 2010 NY Post article: “The feds many not be quite done with (JE). Having just completed 13 months in a fl jail for solicing[sic] prost [sic] from a minor, he now might be under investig [sic] for other possible

crimes, inclduing [sic] whether there’s any evidence of child trafficking. E has settled several lawsuits by teens who say they were lured to his palm beach mansion for massages or sx [sic]. The us AG in fl wouldn’t comment. E’s lawyer, jack goldberger, says he know nothing of any probe, and ‘they are not and should not be any pending criminal investigations. ”’ Ex 104 at -251.

JPMC Response: Undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

    1. The July 31, 2010 NY Post article “Jeffrey Epstein may face child traficking probe” states:

The Feds may not be quite done with Jeffrey Epstein. Having just completed 13 months in a Florida jail for soliciting prostitution from a minor, he now might be under investigation for other possible crimes, including whether there’s any evidence of child trafficking, reports The Daily Beast. Epstein has settled several lawsuits by teens who say they were lured to his Palm Beach mansion for massages or sex. The US attorney general in Florida wouldn’t comment. Epstein’s lawyer, Jack Goldberger, says he knew nothing of any probe and, “There are not and should not be any pending criminal investigations.”

Ex. 90 at -814.

JPMC Response: Disputed to the extent USVI misstates the document, the NY Post article is titled “Epstein Probe”. See USVI Ex. 90 at -814. Otherwise undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107. Further contended that the cited material cannot be presented at trial in admissible form.

    1. The July 29, 2010 Daily Beast article cited in the NY Post article states: “The Justice Department is investigating Autrey Epstein for child trarnking … and has widened the scope of its probe to include a famous modeling agency.” “Federal investigators continue to investiga►e Epstein’s activities, to see whether there is evidence of child trafficking—afar more serious charge

than the two in his non-prosecution agreement, the arrangement between Epstein and the Department of Justice allowing him to plead guilty to lower level state crimes. Trafficking can cony a 20-year sentence.” “The FBI is also investigating Epstein’s friend Jean Luc Brunel, whose MC2 modeling agency appears to have been a source of girls from overseas who ended up on Epstein’s private jets.” Ex. 105 at -902-903.

JPMC Response: Undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107. Further contended that the cited material cannot be presented at trial in admissible form.

  1. JPMorgan admits that in 2010, certain of its employees received, reviewed, or read a Newsier Web Blog, Je:ebel, article (“2010 Newstex article, identifying “MC2” as “the modeling agency owned by Jean Luc Brunel.” Ex. 39 at Resp. 70.

JPMC Response: Undisputed that, in 2010, certain JPMC employees received, reviewed, or read a Newstex Web Blog, Jezebel, article identifying “MC2” as “the modeling agency owned by Jean Luc Brunel.”

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. The 2010 Newsier article states:

  • a. “Jeffrey Epstein, the billionaire financier who the FBI believes molested around 40 underaged girls” Ex. 106 at 596.

  • b. Buying a 14-year old Yugoslavian girl named from her parents in order to keep her as his “sex slave” Id.

  • c. Paying women to bring hint “economically desperate” teenagers to give him massages “that often led to sexual contact” Id.

  • d. Receiving two I 2-year old girls as a “birthday present” Id.

  • e. Flagging Epstein’s relationship with Jean Luc Brunel, owner of MC2 Modeling, and that Epstein, Maxwell, Brunel, Alfredo Rodriguez, and [REDACTED] used the agency to “lure minor children … mostly girls under the age of 17 … to engage in sexual play for money” Id.

  • f. References that the FBI is investigating MC2 and Brunel for “possibly engaging in child sex trafficking” Id.

  • g. Mentions Epstein’s plea of soliciting sex with a minor and settling a dozen civil lawsuits from victims Id.

  • h. “These same civil complaints allege that young girls from South America, Europe, and the former Soviet republics … were recruited for Epstein’s sexual pleasure” Id.

  • i. “Brunel, along with numerous young models, was a frequent passenger on Epstein’s private jet, according to flight manifests” Id.

  • j. “The agency owner also allegedly received $1 million from Epstein in 2005, when he founded MC2 … [but] denied any such payment from the billionaire pervert in 2007, when rumors started swirling” Id.

  • k. “Whether the money was a secret investment in MC2, or a payment for Brunel’s service as a procurer, is unknown” Id.

JPMC Response: Disputed to the extent USVI misstates the cited document. The sentence quoted in ¶ 138(b) states, “buying a 14-year-old Yugoslavian named [REDACTED] from her parents in order to keep [REDACTED] as his ‘sex slave’ [.]” USVI Ex. 106 at -596. The sentence quoted in ¶ 138(e) states, “luring minor children … mostly girls under the age of 17 … to engage in sexual play for money” and the sentence quoted in ¶ 138(k) states, “Whether the money was a secret investment in MC2, or a payment for Brunel’s services as a procurer, is unknown.” See USVI Ex. 106 at -596. Otherwise, undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107. Further contended that the cited material cannot be presented at trial in admissible form.

  1. A DDR regarding Epstein approved by Morris (then banker), Sheridan (then overseeing Morris); and Keating (then CEO U.S. Private Bank) stated: “As of 3/4/2011: Numerous articles detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating in child trafficking and molesting underage girls. Jeffrey Epstein is required to register as a sex offender. Jeffrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding solicitation for an undisclosed amount. MC2 Model Management received .81 million from Epstein in 2005. It is unknown f the money was given as a secret investment or payment for services as a procurer. Jean Luc Brunel, owner of MC2 Model Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children for sexual play for money. In addition, Brunel was a frequent passenger on Epstein’s private jet and often visited Epstein in jail. MC2 Mode! Management was issued a citation by the Florida Business and Professional Regulation for acting as a talent agent without a license. MC2 Model Management LLC has two outstanding federal tax liens totaling 8593,789 (8443, 728 + 8150,061).” Er 31 at -574. Global Security & Investigations, Due Diligence Unit circulated “A Red Dot Memo for Jeffrey Epstein” containing the same information that was circulated to Morris, Dalessio, and = among others, in early March 2011. Et 107 at -499-500.

JPMC Response: Undisputed that Monis, Sheridan, and Keating approved the cited DDR and that the cited DDR contains the quoted text. Undisputed that a Red Dot Memo for Jeffrey Epstein was circulated to Morris, , Dalessio, and M, among others, on March 7, 2011 containing the quoted language from the DDR.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. [Redacted]

[Redacted] Ex. 9 ¶

  1. [Redacted]

[Redacted] Id. ¶ 206.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107. Further contended that the cited material cannot be presented at trial in admissible form.

  1. JPMorgan’s own due diligence process also required that it research and review civil and other lawsuits that may be filed by or against clients. Ex. 32 at 42:20-24.

JPMC Response: Disputed. The cited testimony for this proposition does not support the conclusion the JPMorgan’s due diligence process required that employees research and review civil lawsuits involving its clients. In response to questions about her personal review of civil lawsuits that may be filed by or against a client, [Redacted], a JPMC Private Banker and not a member of JPMC’s compliance function, testified that “[t]hey are included within the due diligence review.” USVI Ex. 32 at 42:20-24. This testimony relates only to [Redacted] understanding regarding the conducting of due diligence and does not reflect an overall policy by JPMC to affirmatively require review of civil lawsuits.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. In 2007, news reports stated Epstein was “bracing for a slew of lawsuits from as many as 40 young women who came to his Palm Beach mansion for massage sessions.” Ex. 63 at -652.

JPMC Response: Undisputed that the cited document, an October 15, 2007 article from the New York Post’s “Page Six” gossip column, contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107. Further contended that the cited material cannot be presented at trial in admissible form.

  1. [Redacted]

[Redacted] Ex. 108 at -685.

USVI Ex. 108 at -685.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. [Redacted]

[Redacted] Ex. 109 at -686.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. The February 7, 2008 New York Post article stated that “the teen -identified only as ‘Jane Doe No. 2’ - says she was lured to Epstein’s Palm Beach mansion and then sexually assaulted in his massage room … He then paid her $200 … ” Ex. 110 at 1. The article further states: ”… Jane Doe No. 1 … says she was 14 when she went to Epstein’s home to give him a massage and wound up getting sexually assaulted by him” and that Epstein is “currently only facing criminal charges related to Jane Doe No. 1.” Id. at 1-2.

JPMC Response: Disputed to the extent that USVI’s citation for the quoted text in its first quotation is only to page 1; the quoted text appears on pages 1 and 2. See USVI Ex. 110 at 1-2. Otherwise undisputed that the cited document contains the quoted language.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107. Further contended that the cited material cannot be presented at trial in admissible form.

  1. On ..hme 30, 2008, Epstein pled guilty to felony solicitation ofprostitution and procurement of a minor to engage in prostitution on June 30, 2008 and was “sentenced to 18 months in jail” and “required to register as a sex offender.” Del JPMorgan Chase Bank, N.A. ‘s Answer Second Am. Comp!. (“Answer) 1 38.

JPMC Response: Disputed to the extent the citation does not support the proposition that Epstein plead guilty on June 30, 2008. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. knew the victim was a 14-year-old girl. Er. 109 at -686; Er. 110 at 1-2.

JPMC Res once:

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

Ex. 2 at -196; Ex 3 at -523.

JPMC Res u once:

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF t¶ 1-107.

  1. In 2011, Langford communicated to Cutler “concern” about retaining Epstein as a client. Cutler testified: “Those concerns are heightened, if you will, by the human trafficking initiative that we’re doing, given that he was convicted of these crimes.” Ex. 99 at 343:12-24.

JPMC Response: Disputed. In the cited testimony, Cutler testified that Langford communicated to him “concern about the reputational issues”. USVI Ex. 99 at 343:19- 21 (emphasis added).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. Er. 55 at -475.

JPNIC Res mnse:

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. The August 5, 2008 AML Operations Human Trafficking Overview states that “nearly two-thirds of the women trafficked for prostitution worldwide come from Eastern Europe” and “former Eastern bloc countries such as Albania, Moldova, Romania, Bulgaria, Russia, Belarus and Ukraine have been identified as major trafficking source countries for women and children.” Ex. 44 at -053.

JPMC Response: Undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. In 2010, additional “news stories … connects Jeffrey Epstein to human trafficking.” Ex. 112 at -262.

JPMC Response: Disputed to the extent USVI characterizes the news stories as “additional”. Undisputed that the cited document contains the quoted text and states that these news stories appeared during 2010.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On November 8, 2010, Dalessio emails Morris and [REDACTED], with a cc to McCleerey, Subject: Excerpt from recent articles. Dalessio writes: “See below new allegations of an investigation related to child trafficking - are you still comfortable with this client who is now a registered sex offender?” Ex. 90 at -814. Dalessio attaches excerpts from four articles:

    1. The Palm Beach Post 8/1/10 “Epstein may be under new sex crime scrutiny from feds”: “Epstein … may be under investigation for other sex crimes, including child trafficking … According to the news website The Daily Beast,

the feds are also checking whether a modeling agency run by a friend of the Wall Street Investor Epstein fed his appetite for underage foreign girls. Epstein was known to fly young women from Eastern Europe to Palm Beach, where they’d massage him, among other services.” Id.

    1. NY Post 7/31/10 “Epstein Probe”: “The Feds may not be quite done with Jeffrey Epstein … [H]e now might be under investigation for other possible crimes, including whether there’s any evidence of child trafficking, reports The Daily Beast. Epstein has settled several lawsuits by teens who say they were lured to his Palm Beach mansion for massages or sex.” Id.
    1. Palm Beach Daily News 7/18/10 “House arrest nears home stretch for Epstein”: “Epstein has settled more than two dozen lawsuits and claims against him by teenagers who say they were lured to his Palm Beach mansion to give him sexually charged massages and/or sex in exchange for money … A secret deal with federal prosecutors revealed Epstein could have been charged with multiple federal counts of sexual exploitation of minors, resulting in much harsher penalties. But the feds deferred to two state charges that got him an 18-month sentence.” Id. at -814-815.
    1. Palm Beach Daily News 9/19/10 article “Woman sues Epstein for $50 M, alleging abuse as teen”: [REDACTED] “alleges repeated sexual abuse by Epstein” and that “she was coerced into prostitution as a minor by Epstein, assisted by his employee [REDACTED] ” [REDACTED] alleges Epstein has transferred and is transferring his assets overseas and elsewhere to conceal them from her and to

prevent ■ from obtaining those assets in any judgment she may receive against him.” Id. at -815.

JPMC Response: Undisputed that Dalessio emailed Morris and = copying McCleerey, on November 8, 2010, and the email contained the quoted language. Disputed to the extent USVI misstates the document with respect to the inclusion of the four article excerpts as attachments; the excerpts are copied into the body of McCleerey’s email. Otherwise, undisputed that the document contains the quoted excerpts of the listed articles.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107. Further contended that the cited material cannot be presented at trial in admissible form.

  1. The JPMC Corporate AML Compliance Human Trafficking Finance: Nature, Scope and Control Project, November 2010, states that one of the results achieved from the program was that JPMorgan “Led effort to draw industry attention to human trafficking as an AML-related issue” and notes multiple industry presentations given by JPMorgan related to human trafficking issues and/or its human trafficking project findings. Et 71 at -975, -977-78. On December 21 2010, Ryan writes to DeLuca : “My fear is will all our touting of good will on the H7’ work, if anyone should ever say yet we bank Epstein, a known child sleaze.” DeLuca responds: “That is what I was thinking when I read this. call you.” Ex. 113 at -018.

JPMC Response: Undisputed that the cited documents contain the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. “HT” in Ryan’s email refers to a project “within investigations related to human trafficking and certain typology work that they were looking to dig through to identify human trafficking.” Ex. 36 at 56:14-57:6.

JPMC Response: Undisputed that Ryan testified that “the FIT work” referred to in the email cited as USVI Ex. 113 was “a project that was going on within investigations

related to human trafficking and certain typology work that they were looking to dig through to identify human trafficking.” USVI Ex. 36 at 56:25-57:6.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On December 22, 2010, DeLuca writes Langford again and states: “This will be raised to the Rapid Response team (Catherine Keating) after the first of the year. McCleerey agrees this customer should go.” Er. 114 at -738.

JPMC Response: Undisputed that DeLuca emailed Langford on December 22, 2010 and the cited email contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. On December 23, 2010, DeLuca writes Langford and states: ”… I sent you an e-mail yesterday on that scum Epstein. That looks good to. I reminded McCleerey that he listened to 2 days of HT at the forum and this account could be problematic in several ways.” Langford responds: “Good. Let me know ifMcCleerey wafles on Epstein. No patience for this.” Ex. 115 at -777.

JPMC Response: Undisputed that DeLuca emailed Langford on December 23, 2010 and the cited email contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On Januaty 4, 2011, Dalessio e-mails Morris, with a cc to and McCleerey, Subject: Rapid Response meeting this Thursday, stating: “See attached draft document for the Rapid Response meeting this Thursday [sicJ We were asked by the firms AML Compliance Director, William Langford, to re-evaluate our sponsorship of Epstein and request re-approval from Steve Cutler if we wanted to retain.” Morris responds: “1 thought we decided this was not necessary.” Dalessio responds: “william langford requested that we responsor this client in light of the new allegations of human trafficking which the firm has been actively assisting law enforcement in uncovering others engaged in this practice.” Ex. 116 at -967.

JPMC Response: Disputed to the extent USVI misstates the cited document. The original email from Dalessio to Morris, copying ” and McCleerey, is sent on January 3, 2011. USVI Ex. 116 at -967. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. On January 5, 2011, Ryan wrote to DeLuca: “BTW, 4 tomorrow is the rapid response meeting on Epstein, the sleazy PB client.” DeLuca responded the next day: “This is the guy who likes young girls, correct? Hope they do not cave!” Et 117 at -062; Er. 36 at 68:11-69:18.

JPMC Response: Disputed to the extent USVI misstates the cited document. DeLuca’s rcbponse to Ryan’s email on January 6, 2011 states, “This is the guy who likes young girls, correct? Hope that they do not cave!!” USVI Ex. 117 at -062. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recldessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. By “sleazy PB client,” Ryan was referring to the allegations against Epstein of sexual misconduct with children. Ex. 36 at 68:11-19.

JPMC Response: Disputed. USVI mischaracterizes Ryan’s testimony in which she stated it was likely, but not definitive, that her use of “sleazy PB” client referred to the allegations against Epstein of sexual misconduct with children. See USVI Ex. 36 at 68:11-15 (Q: When you say, the sleazy PB client, are you referring to the allegations of sexual misconduct with children that you had referred to in a previous email? A: Likely, yes.).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF i¶ 1-107.

  1. On January 7, 2011, Ryan entails DeLuca, copying Middlemiss, writing, “Epstein was released in July from house arrest and the Palm Beach Post carried two articles saying that DOJ nay be investigating for child trafficking via a modeling agency he is part owner in.” Ex. 118 at -066 R; Et 36 at 88:24-90:2.

JPMC Response: Disputed to the extent USVI misstates the cited document. The cited text reads, “Epstein was released in July from house arrest and the Palm Beach Post carried two articles saying DOJ may be investigating for child trafficking via a modeling agency he is part owner in.” USVI Ex. 118 at -066_R. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. Ryan testified: “So, Phil was of the mindset, as was I, that [Epstein] had to go.” Ex. 36 at 70:19-71:3.

JPMC Response: Undisputed that Ms. Ryan testified, “So, Phil was of the mindset, as was I, that [Epstein] had to go.” Disputed to the extent USVI contends that Ryan’s testimony establishes DeLuca’s mindset with respect to Epstein’s status as a client. The cited testimony was provided in response to a question on what Ryan understood an email from DeLuca to mean and is not supported by her personal knowledge of DeLuca’s views about Epstein. See USVI Ex. 36 at 70:19-71:3.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. Langford testified: “We were pushing it. I had asked for this to be redone, to push again, to say it’s time that we exit Epstein.” Er. 119 at 278:17-21.

JPMC Response: Disputed to the extent USVI misstates Langford’s testimony. Langford testified, “We were pushing it. I had ask that this be redone, to push again, to say it’s time that we exit Epstein.” USVI Ex. 119 at 278:17-21. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. Langford testified that by the end of 2010 or early 2011, it was his view that “we should exit Jefrey Epstein as a client ” Et 119 at 58:18-5931.

JPMC Response: Undisputed that Langford testified as such.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. DeLuca testified: “Maryanne [Ryan] was all over this, and like myself and William [Langford], Maryanne wanted to see this client gone, the relationship ternrinated.” Ex. 120 at 204:22-205:1.

JPMC Response: Undisputed that DeLuca testified as such.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. On January 10, 2011, DeLuca mails Nichols, copying Langford, regarding Jeffrey Epstein: “He is alleged to be involved in human trafficking ofyoung girls and law erforcement is allegedly investigating his involvement in this activity… AML Operations went to a PB risk meeting late last week requesting we exit this relationship.” Ex. 70 at -748_12.

JPMC Response: Disputed to the extent USVI misstates the cited document. The cited text reads, “He is alleged to be involved in the human trafficking of young girls and law enforcement is also allegedly investigating his involvement in this activity … AML Operations went to a PB risk meeting late last week requesting that we exit this relationship.” USVI Ex. 70 at -748_R_ Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On March 12, 2013, Ryan entails DeLuca, Subject: High Profile, telling hint: “Here are the ones [accounts] 1 think should be closed where the LOB has disagreed and signed off to keep.

… PB customer Jeffrey Edward Epstein is an American financier and science and education philanthropist, who is a convicted sex ofender.” Ex. 121 at -272.

JPMC Response: Disputed to the extent USVI misstates the cited document. The quoted text is emailed by Ryan to DeLuca on February 19, 2013. See USVI Ex. 121 at - 272. Otherwise, undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. JPMorgan admits that Erdoes was involved in decision snaking with respect to maintaining Epstein as a customer of JPMorgan. Ex. 18 at Resp. 8.

JPMC Response: Undisputed that Erdoes was involved in decision making at certain points with respect to maintaining Epstein as a customer of JPMorgan.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. In 2008, JPMorgan acquired Bear Stearns. ET. 122 at 1; Ex. 123 at 285:8-286:2.

JPMC Response: Undisputed that the cited document states that JPMorgan acquired Bear Steams in 2008. See USVI Ex. 122 at 1.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. JPMorgan knew that Epstein conducted his brokerage business at Bear Stearns. Er. 124 at -175.

JPMC Response: Undisputed that the cited DDR for Jege, Inc. states that “Bear Steams will hold the brokerage relationship with Mr. Epstein.” See USVI Ex. 124 at -175.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Steams knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. Ex. 125 at -076.

JPMC Res nse:

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. After Bear Stearns was acquired by JPMorgan, Arthur Middlemiss assumed a similar role with JPMorgan AML compliance, working with Langford. Ex. 126 at 1; Ex. 120 at 155:21-158:6.

JPMC Response: Undisputed that the cited USVI Ex. 126 states that in June 2008 Mr. Middlemiss transitioned from Managing Director at Bear Stearns to Managing Director at JP [REDACTED] Chase & Co. and that Mr. Langford testified that at some point Arthur Middlemiss “was a direct report” of his. See USVI Ex. 120 at 155:21-22.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. While at Bear Stearns, Middlemiss was the AML Officer responsible for responding to a 2007 subpoena by the federal prosecutors investigating Epstein for federal sex crimes. Ex. 125 at -076.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On January 10, 2011, Ryan e-mails Langford, DeLuca, and Nichols, Subject: Re: Jeffrey Epstein: “Seems JPMC never was served a subpoena, which I find odd since we were his #1 bank and actually Bear got one in 07. Rich is getting me the AUSA correspondence and we will compare their ask of Bear (something about $1000 and $100,000 transactions were of interest to them)[.]” Ex. 127 at -192.

JPMC Response: Undisputed that Ryan emailed Langford, DeLuca, and Nichols on January 10, 2011 and the cited email contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. [Redacted]

[Redacted] Ex. 128 at -247. [Redacted]

[Redacted] Ex. 129 at -248, -251-52; Ex. 125 at -

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. [Redacted]

[Redacted] Ex. 129 at -251. [Redacted]

[Redacted] Id.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. [Redacted]

[Redacted] Ex. 125 at -075. [Redacted]

[Redacted] Id. at -076.

JPMC Response: Undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. In 2007, JPMorgan knew, as part of its investigation of Epstein at that time, that it had made twenty transfers out of Epstein’s accounts in the amount of $100,000 from January 2, 2007 to October 12, 2007. Ex. 63 at -655-60.

JPMC Response: Disputed that this email was part of any JPMC “investigation of Epstein at that time” as unsupported by the cited document. Undisputed that on October 19, 2007 Dalessio emailed Verdon, copying McCleerey, Waters, and Meisner, that includes an attachment of a chart that shows transactions related to Epstein’s accounts from 2007. JPMC disputes, however, that the cited document establishes as a legal conclusion that JPMC knew about the transfers in 2007.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On August 27, 2006, Staley entails Erdoes: “Last night went to the Huggy Bear concert. The age darerence between husbands and wife: [sic] would have fit in well with Jeffrey. What a joke.” Erdoes responds, and what 1 meant to tell you about last night was they [sic] were a few people laughing about Jeffrey. One of the guys ran a unit of Apparently has 8 assistants, one is more beautifid than the other (even though he’s gay). Anyway, lots of comparisons to JE.” Er. 130 at -337.

JPMC Response: Disputed to the extent USVI misstates the quoted document. Erdoes’ response to Staley’s email on August 27, 2006 states “jeffrey,” not “Jeffrey.” See USVI Ex. 130 at -337. Otherwise, undisputed that the cited email contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

Ex. 131 at -627. The article discussed “alleged financier-perv* billionaire Jeffrey Epstein, of whom it is alleged that he retained a procurer of underage girls.” Ex. 132 at 1.

JPMC Res onse:

n ute t t e at artic e containst e quot anguage.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. In May 2008, Erdoes writes to • “This has turned into a cheesy broker fest … totally not cool, the only cool people are here at glenn’s table-same as bat mitzvah!” responds: “Epstein there with miley cyrus?” Ex. 133 at -475.

JPMC Response: Undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. In May 2008. Miley Cyrus was 15 and starring in “Hannah Montana” on the Disney Channel. Er. 134 at 2.

JPMC Response: Undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. On Febnkny 7, 2011, Ryan also said to Langford: ”… wanted to catch up on Epstein as he was featured ripped from the headline story on Law and Order SVU this week.” Er. 135 at - 044; Er. 36 at 145:21-148:2.

JPMC Response: Disputed to the extent USVI misstates USVI Ex. 135. The cited quote reads, “Wanted to catch up on Epstein as he was the featured ripped from the headlines story on Law and Order SW this week.” Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1¶ 1-107.

  1. Ryan testified, “That entire series [Law and Order WU] was based on real life stories, and it’s never difficult to figure out, since 1 am a New Yorker, I knew exactly what this particular episode was on, and so I sent it to William so that he could see. .. . I saw it - happened to see it, made sure I told William that a customer might have been the implied story that was out in the news.” Ex. 36 at 147:4-148:2.

JPMC Response: Undisputed that Ryan testified as such.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. Ryan testified that she wrote to Longford: “1 typed SVU and his name and there is a Gawker story, Law & Order commerates [sic] JE taste for teen hookers.” Ex. 135 at -044; Ex. 36 at 148:21-149:2.

JPMC Response: Disputed to the extent USVI has misstated the Ryan’s testimony. Ryan did not testify that she wrote to Langford “I typed SVU and his name and there is a Gawker story, Law & Order commerates [sic] JE taste for teen hookers.” In the cited portion of Ryan’s testimony, the questioner states, “You write in the second sentence, I typed SVU and his name and there is a Gawker story, Law and Order commerates [sic] JE taste for teen hookers. Do you see that?” and Ms. Ryan responds “Yes”, that she sees that. See USVI Ex. 36 at 148:21-149:2. JPMC does not dispute that USVI Ex. 135 states, “I typed svu and his name and there is a gawker story Law and Order commerates JE taste for teen hookers.” USVI Ex. 135 at -044.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF’¶ 1-107.

  1. The Gawker story states: “Last night, for instance, Dick Law & Order: SVU aired a ‘ripped from the headlines’ episode that seemed to be aimed directly at Epstein. Vie villain was Jordan Hayes,’ a ‘billionaire pervert flying in underage girls for sex’ on his private jet. His parties make the society page, he’s friends with ‘a fonner president,’ and Hayes almost gets away with the statutory rape of a young girl before our heroes uncover scores of underage girls he had sexually abused” Ex. 136 at 1.

JPMC Response: Undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF f 1-107.

  1. The Law & Order episode and the Gawker story made Ryan “more anxious to get Jeffrey Epstein out of the bank.” Er. 36 at 149:5-11. Ryan farther testified “that all of these facts should be escalated to the business to make an informed decision about getting Epstein out of the bank” Id. at 149:17-21. Ryan was of the opinion that Epstein should be out of the bank. Id. at 149:20- 21.

JPMC Response: Disputed to the extent USVI has misstated Ryan’s testimony. With respect to the first sentence, undisputed that Ryan testified that the Gawker story or the Law and Order episode about Epstein made her more anxious to get Epstein out of the bank. For the second sentence, USVI has misstated Ms. Ryan’s testimony. Ryan testified, “I thought that all of these facts had to be escalated to the business to make an informed decision about getting him out of the bank. I was of the opinion that he should be out of the bank.” USVI Ex. 36 at 149:5-21.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. On November 29, 2011, Ryan e-mails DeLuca an article, “FBI Set to Reopen Epstein Case Based on Testimony of ” The ankle states: “The FBI is reportedly preparing to launch a new inquiry into Epstein after one of his under-age erotic masseuses, made a string of disturbing allegations about her role. U.S. detectives are said to be furious that Epstein, 58, escaped with only 13 months in jail for child sex offences [sicJ after he struck a plea bargain with prosecutors. The deal protected him from fitrther prosecution for offences in Florida. But the significance ofl claims that under-age girls were moved abroad for sex is that cite paves the way for the FBI to prosecute him for offences fuel committed outside Florida under the Trafficking Victims Protection Act “Ex. 137 at 689 (emphasis added).

JPMC Response: Undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107. Further contended that the cited material cannot be presented at trial in admissible form.

  1. On June 17, 2013, in a “Lync” chat from DeLuca with Jessica Gomel, who reported to DeLuca, DeLuca repeated the contents of the article, including that “the significance of claims that under-age girls were moved abroad for sex is that she paves the way for the FBI to prosecute him for offences (sic) committed outside Florida under the Trafficking ictims Protection Act.” Ex. 138 at -936 (emphasis added).

JPMC Response: Disputed to the extent the cited document does not support the assertion that Gomel reported to DeLuca or that DeLuca is repeating the contents of an article. Otherwise, undisputed that the cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. In September 2012, David Brigstocke (then CFO of JPMorgan AWM) writes to Erdoes regarding house: “The size of the Union Club. In fact it used to be a club.

Reminded me of JE’s house, except it was more tasteful, and fewer nymphettes. More like the Frick. Art was fabulous. D.” Erdoes responds: “Wow.” Ex 139 at -203 (emphasis added).

JPMC Response: Disputed to the extent USVI misstates the quoted document. Brigstocke’s email states “Union club,” not “Union Club.” See USVI Ex. 139 at -203. Otherwise, undisputed that the cited document contains the quoted text. Undisputed that Brigstocke was the CFO of JPMorgan AWM in September 2012. Disputed as to materiality.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. Staley was the senior person at JPMorgan with a business relationship with Epstein. Et 39 at Resp. 204.

JPMC Response: Undisputed that Staley was the senior person at JPMC with a business relationship with Epstein. See JPMC Ex. 62 at Resp. 204.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF11 1-107.

  1. JPMorgan admits that its employees consulted with Staley regarding Epstein’s account activities. Ex. 39 at Resp. 144.

JPMC Response: Undisputed that JPMC employees consulted with Staley regarding Epstein’s account activities.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. JPMorgan admits that Staley communicated with Epstein through his JPMorgan email account jes.staley@jpmorgan.com. Ex. 39 at Resp. 161, 162.

JPMC Response: Undisputed that Staley, at certain times, communicated with Epstein through his JPMorgan email account jes.staley@jpmorgan.com.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. JPMorgan employees were instructed to only use their email accounts “for business purposes.” Ex. 39 at Resp. 163.

JPMC Response: Disputed that JPMorgan employees were instructed to only use their email accounts for business purposes during the entirety of the relevant time period. Undisputed that in 2009, JPMorgan employees were subject to a Code of Conduct which included the instruction: “electronic mail (e-mail) systems and other electronic communications devices provided by JPMorgan Chase, whether in the workplace or elsewhere, are the property of the firm and should be used for business purposes; however, limited incidental personal use is permitted, consistent with the Code and all other policies of the firm.” See USVI Ex. 39 at Resp. 163, JPMC Ex. 63 at -129.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. JPMorgan admits that Epstein sent Staley photographs of women on Staley’s JPMorgan’s email address. Ex. 39 at Resp. 164.

JPMC Response: Undisputed that Epstein sent Staley photographs of women on Staley’s JPMorgan email address.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. JPMorgan admits that more than 1,200 email messages were sent between Staley and Epstein over Staley’s work account. Ex 39 at Resp. 165.

JPMC Response: Undisputed that more than 1,200 email messages list both jes.staley@jpmorgan.com and jeevacation®gmail.com as either sender, receiver, or carbon copy.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. JPMorgan admits that Staley sent an email from his work account that referenced “Snow ” Ex. 39 at Resp. 166.

JPMC Response: Undisputed that Staley sent an email from his JPMorgan email account that referenced “Snow

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. On July 9, 2010, Staley e-mailed Epstein, “That was fim. Say hi to Snow ” Epstein responded, “what character would you like next “Staley responded, ‘Beauty and the Beast .. ..” Epstein responded “well one side is available.” Ex. 140 at -669.

JPMC Response: Disputed to the extent USVI misstates the cited document. Epstein’s response to Staley’s email states, “well one side is availble.” See USVI Ex. 140 at -669. Otherwise, undisputed that cited document contains quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On August 30, 2009, Epstein entailed Staley, “how long London? Do you need anything there?” Staley responded, “Yep.” Er. 141 at -171.

JPMC Response: Disputed to the extent USVI misstates the quoted document. Epstein’s email states “London,” not “London.” See USVI Ex. 141 at -171. Otherwise, undisputed that cited document contains quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On September 2, 2009, Epstein entailed staying at the berkeley hotel in London tonight.” Ex. 142 at -773. “jes staley is

JPMC Response: Disputed to the extent USVI misstates the quoted document. Epstein’s email states “london,” not “London.” See USVI Ex. Ex. 142 at -773. Otherwise, undisputed that cited document contains quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. On December 20, 2009, Epstein entailed Staley a blank email with only an attachment, which “appears to be a modeling photo”:

Ex. 143 at -791-92; Ex. 144 at -005.

JPMC Response: Undisputed that cited document USVI Ex. 144 contains quoted text. Disputed that the attachment in USVI Ex. 143 “appears to be a modeling photo,” as the email provides no context for the photograph.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On December 5, 2009, Epstein emailed Staley, “you were with larry , [sic] and I had to put up with … ” with the following attachment:

Ex. 145 at -715-16; Ex. 144 at -005. [REDACTED] Ex. 146 at -718.

JPMC Response: Disputed to the extent USVI misstates the quoted document. [REDACTED] [REDACTED] See USVI Ex. 146 at -718. Otherwise, undisputed that cited documents contain quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. On June 16, 2010, Staley wrote to Epstein “is she free tonight?” Epstein replied, “call me.” Staley replied, “I’m with A.” Ex. 144 at -998.

JPMC Response: Undisputed that cited document contains quoted text. See USVI Ex. 144 at -005.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. Staley testified he met at Epstein ‘s townhouse. Ex. 46 at 343:22-346:8.

JPMC Response: Undisputed that Staley testified he met at Epstein’s townhouse. Disputed to the extent the underlying fact requireW illility determination.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. Staley testified he met Lesley Groff at Epstein ‘s townhouse. Ex. 46 at 343:22-346:8.

JPMC Response: Undisputed that Staley testified he met Groff at Epstein’s townhouse. Disputed to the extent the underlying fact requires a credibility determination.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. Staley testified he met at Epstein’s townhouse. Ex. 46 at 343:22-346:8. Stale testified that he met a c iity determination. 1-107. 207. Staley testified

JPMC Response: Disputed that Stal testified he met at E townhouse. ” USVI Ex. 46 at 346:9-12. Dispute tot e extent t e un er ymg act requires

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF f

Er. 46 at 433:9-440:8.

JPMC Res onse: Undi •uted that Stale testified

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. JPMorgan admits that Staley submitted, and JPMorgan reimbursed, the costs associated with expense reports reflecting purported meetings with Epstein. Ex. 39 at Resps. 168, 169.

JPMC Response: Undisputed that Staley submitted, and JPMorgan reimbursed, the costs associated with expenses reports reflecting meetings with, among others, Epstein.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. JPMorgan admits that certain of its employees knew that Staley had visited Epstein while he was incarcerated and still a JPMorgan client. Ex. 39 at Resp. 175.

JPMC Response: Undisputed that certain JPMorgan employees knew that Staley had visited Epstein while he was incarcerated and still a JPMorgan client.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. JPMorgan admits that Staley visited Epstein at Epstein’s New York property while Epstein was a client of JPMorgan. Ex. 39 at Resp. 176.

JPMC Response: Undisputed that Staley visited Epstein at Epstein’s New York property while Epstein was a client of JPMorgan.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF 1-107.

  1. JPMorgan admits that certain ofits employees learned that Staley visited Little Saint James while Epstein was a client of JPMorgan. Ex. 39 at Resp. 177.

JPMC Response: Undisputed that certain of its employees learned that Staley visited Little Saint James while Epstein was a client of JPMorgan.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. JPMorgan admits that it gave Staley a bonus every year between 2001 and 2012. Ex. 39 at Resp. 197.

JPMC Response: Undisputed that Staley received a bonus every year between 2001 and 2012. Disputed as to materiality with respect to USVI’s claims in this litigation.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

  1. JPMorgan admits that Staley’s bonus was related to his performance and performance of the business under his supervision, which may have included the revenue and business that they generated. Ex. 39 at Resp. 198.

JPMC Response: Undisputed that Staley’s bonus was related to his performance and performance of the businesses under his supervision, which may have included the revenue and business that they generated, among a broad range of additional quantitative and qualitative considerations. Disputed as to materiality with respect to USVI’s claims in this litigation.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan knew or recklessly disregarded that Epstein ran a sex-trafficking venture. See CSMF ¶¶ 1-107.

JPMorgan Participated in Epstein’s alleged sex-trafficking venture

JPMC Response: This is a header to which no response is warranted. Disputed insofar as USVI contends that the statements and documents cited below establish as a matter of law that JPMorgan participated in Epstein’s alleged sex-trafficking venture.

  1. On July 6, 2020, the New York State Department of Financial Services entered into a Consent Order with Deutsche Bank imposing a $150 million penalty in connection to Deutsche Bank’s relationship with Jeffrey Epstein. Ex. 147; Ex. 148; Ex. 99 at 457:10-466:2. Regarding the Consent Order, Superintendent Lacewell said: “despite knowing Mr. Epstein’s terrible

criminal history, the Bank inexcusably failed to detect or prevent millions of dollars of suspicious transactions.” Ex. 147; Ex. 148; Ex. 99 at 457:10-466:2. The bank “processed hundreds of transactions totaling millions of dollars” including:

  • payments to individuals who were publicly alleged to have been Mr. Epstein’s coconspirators in sexually abusing young women;
  • settlement payments totaling over 87 million, as well as dozens ofpayments to lmvfirms totaling over 86 million for what appear to have been the legal expenses ofMr. Epstein and his co-conspirators;
  • payments to Russian models, payments for women’s school tuition, hotel and rent expenses, and (consistent with public allegations of prior wrongdoing) payments directly to numerous women with Eastern European surnames; and
  • periodic suspicious cash withdrawals in total, more than 8800,000 over approximately four years.

Ex. 147; Ex. 148; Et 99 at 457:10-466:2.

JPMC Response: Undisputed that on July 6, 2020, the New York State Department of Financial Services entered into a Consent Order with Deutsche Bank imposing a $150 million penalty in connection to Deutsche Bank’s relationship with Jeffrey Epstein. Undisputed that cited documents contain quoted text. Disputed as to materiality of the Deutsche Bank consent order in this matter.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF 108-169. Further contended that the cited material cannot be presented at trial in admissible form.

  1. In 2005, JPMorgan made two separate .825,000 payments from Epstein’s JPMorgan accounts to Tv. 56 at 34, 36 and Figure 9.3 (copied below).

Figure 9.3: Direct Pain eats to

Date200520062007200820092010201120122013Grand Total
1/4/2005$25,000 00
1/5/2005$25,000 00
1/24/2008$3,055 00
3/19/2008$131,000 00
4/16/2009$500 00
4/17/2009$14,000 00
5/13/2009$4,000 00
6/4/2009$6,000 00
6/19/2009$4,000 00
7/30/2009$1,025 00
8/17/2009$4,000 00
8/24/2009$5,000 00
9/16/2009$4,000.00
10/1/2009$13,000.00
11/18/2009$4,000.00
12/4/2009$4,000.00
1/4/2010$4,000.00
2/4/2010$4,000.00
3/4/2010$4,000.00
4/5/2010$4,000.00
4/7/2010$2,604.62
5/4/2010$4,000.00
6/4/2010$4,000.00
8/31/2010$2,104.17
3/10/2011$6,000.00
3/24/2011$300,000.00
8/16/2011$12,252.60
11/16/2011$6,105.75
3/16/2012$3,294.43
10/4/2012$9,800.00
4/8/2013$100,000.00
8/21/2013$15,000.00
Total$50,000.00$0.00$0.00$134,055.00$63,525.00$334,708.79$18,358.35$13,094.43$115,000.00$728,741.57

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. From August 2006 through August 2013, JPMorgan handled $678,741.57 in payments from Epstein’s JPMorgan accounts to [REDACTED] Ex. 56 at 34, 36 and Figure 9.3.

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. In August 2013, JPMorgan handled a payment of $15,000 from Epstein’s JPMorgan account to [REDACTED] Ex. 56 at 34, 36 and Figure 9.3.

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. From August 2006 through January 2013, JPMorgan handled $607,804.30 in payments from Epstein’s JPMorgan accounts to [REDACTED] Ex. 56 at 34-35 and Figure 9.2 (copied below).

Figure 9.2: Direct Payments to [REDACTED]

Date20032004200520062007200820092010201120122013Grand Total
11/3/2003$500.00
3/9/2004$1,166.00
4/8/2004$2,000.00
4/22/2004$1,517.82
4/28/2004$3,000.00
6/1/2004$10,000.00
8/5/2004$5,000.00
10/19/2004$10,000.00
11/22/2004$2,168.29
12/1/2004$1,713.45
1/4/2005$25,000.00
1/19/2005$3,155.56
4/12/2005[REDACTED] 76
4/26/2005$10,000.00
7/19/2005$3,339.96
8/15/2005$480.00
8/25/2005$10,000.00
10/11/2005$5,000.00
10/24/2005$10,000.00
1/4/2006$10,000.00
2/3/2006$11,000.00
3/2/2006$6,786.00
4/10/2006$15,000.00
4/28/2006$7,362.50
7/18/2006$5,000.00
9/6/2006$25,000.00
10/3/2006$1,025.00
12/18/2006$1,724.30
3/19/2007$25,000.00
6/8/2007$50,000.00
9/25/2007$100,000.00
1/24/2008$3,055.00
7/3/2008$2,000.00
9/3/2008$100,000.00
7/8/2009$50,000.00
12/7/2009$10,000.00
1/15/2010$10,000.00
2/17/2010$25,000.00
5/24/2010$20,000.00
7/29/2010$20,000.00
10/6/2010$25,000.00
1/18/2011$10,000.00
2/28/2011$25,000.00
4/1/2011$30,000.00
4/14/2011$25,000.00
6/20/2012$20,000.00
10/10/2012$10,000.00
10/11/2012$10,000.00
1/17/2013$10,000.00
Total$500.00$36,565.56$67,754.28$82,897.80$175,000.00$105,055.00$60,000.00$100,000.00$90,000.00$40,000.00$10,000.00$767,772.64

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. In 2004, 2005, and 2006, JPMorgan handled $36,565.56, $67,754.28, and $82,897.80, respectively, in payments from Epstein’s JPMorgan accounts to [REDACTED] Ex. 56 at 34-35 and Figure 9.2.

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. [REDACTED]

[REDACTED] Ex. 149 [REDACTED]

JPMC Response: Undisputed that cited document is a summary of transactions reflected in USVI Ex. 149. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. From October 1999 through July 2006, JPMorgan handled $25,146,955.30 in payments from Epstein’s JPMorgan accounts to Ghislaine Maxwell. Ex. 56 at 45-46 and Figure 15 (copied below).

Figure 15: Direct Payments to Ghislaine Maxwell

Date1999200220032004200520062009Grand Total
10/19/1999$18,300,000.00$18,3 00,000.00
9/18/2002$5,000,000.00$5,000,000.00
2/27/2003$325,000.00$325,000.00
5/6/2003$250,000.00$250,000.00
6/20/2003$93,037.97$93,037.97
11/4/2004$225,000.00$225,000.00
11/18/2004$34,867.33$34,867.33
4/27/2005$205,000.00$205,000.00
5/20/2005$139,050.00$139,050.00
7/22/2005$200,000.00$200,000.00
7/25/2005$375,000.00$375,000.00
11/28/2006$13,750.00$13,750.00
4/23/2009$100,000.00$100,000.00
Total$18,300,000.00$5,000,000.00$668,037.97$259,867.33$919,050.00$13,750.00$100,000.00$25,260,705.00

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex.60 ¶1122, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF 108-169.

  1. From August 2006 through April 2009, JPMorgan handled $113,750 in payments from Epstein’s JPMorgan accounts to Maxwell. Er. 56 at 45-46 and Figure 15.

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 11 22, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF in 108-169.

  1. In addition, JPMorgan received a $7.4 million wire from Epstein’s Mellon Bank account to Maxwell’s JPMorgan account to purchase a helicopter. On June 15, 2007, JPMorgan received a $7.4 million wire to Maxwell’s JPMorgan account ending in 6312 from Epstein’s Mellon Bank account. Ex. 150 at -025 (June 2007 account statement from Ghislaine Maxwell’s JPMorgan account ending in 86312 showing a $7.4 million wire from Epstein’s Mellon Bank account). On the same day, Maxwell transferred those same finds to Air Ghislaine, Inc. ’s JPMorgan account ending in 4324. Er. 151 at -878 (June 2007 account statement from Air Ghislaine, Inc. ’s

JPMorgan account ending in 4324). Then on June 18, 2007, $7,352,825.00 was transferred to Sikorsky Aircraft as a down payment for the purchase of a [REDACTED] helicopter - Sikorsky S76C. Id. According to the Aviation Database, as of June 27, 2007, the helicopter with tail number N908GM was registered to Air Ghislaine, Inc. Ex. 56, Amador Exhibit G (aircraft registrations).

JPMC Response: Disputed as to date of transfer from Maxwell to Air Ghislaine, Inc.’s JPMorgan account. The date provided in USVI Ex. 151 at -878 is June 18, not June 15. Undisputed that other payments occurred to specified accounts. Undisputed that helicopter with tail number N908GM was registered to Air Ghislaine, Inc. Disputed as to the materiality of this transaction between Maxwell and Epstein to the claims in this litigation.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

Figure 9: Direct Payments to Women from the Epstein Accounts

| ------------ | ---------------------- | | [REDACTED] | $15,000.00 | | [REDACTED] | $5,000.00 | | [REDACTED] | $13,656.00 | | [REDACTED] | $5,000.00 | | [REDACTED] | $7,026.00 | | [REDACTED] | $3,000.00 | | [REDACTED] | $64,599.86 | | [REDACTED] | $5,000.00 | | [REDACTED] | $8,468.00 | | [REDACTED] | $2,400.00 | | [REDACTED] | $400.00 | | [REDACTED] | $500.00 | | [REDACTED] | $4,000.00 | | [REDACTED] | $58,000.00 | | [REDACTED] | $8,000.00 | | [REDACTED] | $30,000.00 | | [REDACTED] | $5,000.00 | | [REDACTED] | $20,000.00 |

| ------------ | ---------------------- | | | $19,000.00 | | | $36,049.30 | | | $22,500.00 | | | $113,500.00 | | | $5,007.13 | | | $1,000.00 | | | $396.44 | | | $500.00 | | | $3,675.00 | | | $12,110.00 | | | $550.00 | | | $200.00 | | | $4,901.00 | | | $3,341.68 | | | $116,399.86 | | | $500.00 | | | $1,550.00 | | | $750.00 | | | $12,500.00 | | | $9,000.00 | | | $211,441.25 | | | $5,000.00 | | | $12,528.67 | | | $728,741.57 | | | $7,750.00 | | | $5,000.00 | | | $80,550.00 | | | $115,000.00 | | | $50,000.00 | | | $8,073.75 | | | $108,500.00 | | | $767,772.64 | | | $1,000.00 | | | $1,495.00 | | | $500.00 | | | $2,700.00 | | | $30,000.00 | | | $15,000.00 | | | $5,000.00 | | | $1,100.00 | | | $79,773.51 | | | $10,000.00 | | | $1,540.00 |

| -------------- | ----------------------- | | | $81,000.00 | | | $30,000.00 | | | $21,739.73 | | | $4,000.00 | | | $1,320.00 | | | $3,000.00 | | | $27,743.00 | | | $23,000.00 | | | $4,200.00 | | | $2,000.00 | | | $10,140.00 | | | $3,500.00 | | | $1,650.00 | | | $8,000.00 | | | $300.00 | | | $5,000.00 | | | $38,031.49 | | | $500.00 | | Total | $3,132,070.88 |

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this fonnat during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF 11 108-169.

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JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source.

Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

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JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

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JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. [Redacted]

JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. JPMorgan sent several of the payments by foreign wire to girls or women—including

in Belarus, Lithuania, and Russia. Ex. 56 at 37-38 and Figure 10 (copied below).

Figure 10: Foreign Wire Transactions from the Epstein Accounts

DateBeneficiary BankLocationAmount a
12/1/2008Alfa BankMoscow, Russia$3,000.00
12/1/2008VTB BankMoscow, Russia$2,000.00
1/8/2009SEB Vilniaus Bankas Lithuania$2,000.00
9/8/2009VTB BankMoscow, Russia$292.00
11/4/2010O
Ra ZAi .
ffeisenbankMoscow, Russia$2,840.00
8/21/2012O
Raiffe ZA isenbankMoscow, Russia$2,000.00
1/14/2013Joint Stok CompanyMinsky, Belarus$10,000.00
10/15/2013Joint Stok CompanyMinsky, Belarus$20,000.00

JPMC Response: Undisputed that this is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 6011 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF II 108-169.

  1. From 2004-2013, JPMorgan handled $211,411.25 in payments to from Epstein’s JPMorgan accounts. Ex. 56, Amador Exhibit F (chart showing breakdown of each direct payment Epstein made to girls or women from his JPMorgan accounts).

JPMC Response: Undisputed that this is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 6011 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF 11 108-169.

  1. JPMorgan also handled $158,958.34 in indirect payments from Epstein’s JPMorgan accounts for the benefit of girls or women. Ex. 56 at 38-40 and Figure 11 (copied below).

ATTACHMENT B PART 3

Figure II: Indirect Payments for the benefit Women from the Epstein Accounts

Beneficiary/Payee 1Amount
Steven D. Kaplan, DMD$1,260.00
Total$1,260.00
Spanish American Institute$840.00
Total$840.00
International Center of Photography$1,290.00
Total$1,290.00
Castle Worldwide Inc.$250.00
Pacific College of Oriental Medicine$21,245.86
Steven D. Kaplan, DMD$5,700.00
Total$27,195.86
Laguardia College$2,425.85
The World’s Community College$4,135.85
Total$6,561.70
New York Film Academy$6,040.00
Steven R. Erle, MD, PC$450.00
TotalS6,490.00
Bloomingdales$532.77
Express$380.87
Beneficiary/PayeeAmount
I C Systems$329.00
Target$352.10
Victoria’s Secret$211.04
Total$1,805.78
Alan Barnett DLP, LLC$10,400.00
The International Culinary Center L$42,000.00
Total$52,400.00
Samuel C. Klagsbnm M.D.$2,000.00
Total$2,000.00
ATP USA, Inc.$26,000.00
Total$26,000.00
New York Film Academy$3,500.00
Total$3,500.00
Alliance Nursing$2,275.00
Dr. David Price$412.00
Dr. Gerald Imber$20,000.00
Dr. Jane Recant$2,000.00
Office Based Surgery Care$1,500.00
Total$26,187.00
Fashion Institute of Technology$2,020.00
Beneficiary/PayeeAmount
Total52,020.00
CC American Language$1,408.00
rand Total$158,958.34

JPMC Response: Undisputed that this is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this infonnation was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. JPMorgan also handled 55,600 in legal fees from Epstein’s JPMorgan accounts for the benefit of three women and Figure 12 (copied below). Er. 56 at 40-41

Figure 12: Legal Fees Payments for If Omer front the Epstein Accounts

DateCheek aPayeeAmountMemo line:
1/30/20092691Vincent A. Fuller, Jr.. Esq.$4,500.00
1/11/20123359M. Arda Beskardes, Esq.$600.00
8/21/20123412M. Arda Beskardes. Esq.$500.00
Total$5,600.00

JPMC Response: Undisputed that cited document and chart are summaries of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this

information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Further disputed as to materiality. See JPMC Ex. 60 ¶ 91 & n.166

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

Smaller Dollar and “Gift” Payments to Girls or Women and $100,000 Payments

[Redacted] Ex. 156 (2012 Jeffrey E.

Epstein Gift Tax Return)

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JPMC Response: Undisputed that this is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is

not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

DateAmountPayee

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JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Further disputed as to materiality of these payments based on the amounts or that they are provided to attorneys and law firms. See JPMC Ex. 60 ¶ 91 & n.166 [Redacted]

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 Tr 22, 23, 91, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶1108-169.

JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Further disputed as to materiality of these payments

from Epstein to a communications and reputation management fum to any of USV1’s claims against JPMC. See JPMC Ex.64.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture.

  1. From September 2006 through December 2006, JPMorgan handled 8883,750.00 in payments from Epstein’s accounts to Alan Dershowitz, Roy Black, Gerald Lefcourt, and Jack Goldberger (relevant transactions identified and summarized in the chart below).

JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Further disputed as to materiality or relevance of payments from Epstein to his attorneys and law firms to USVI’s claims in this matter. See JPMC Ex. 60191 & n.166

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CS/v[1’ 11 108-169.

DatePayeeAmount
1/2/2007ALAN M. DERSHOWITZ$178,000.00
2/7/2007ALAN M. DERSHOWITZ$78,292.50
4/3/2007ALAN M. DERSHOWITZS137,458.00
5/9/2007ALAN M. DERSHOWITZ$75,000.00

JPMC Response: Undisputed that this is a summary of transactions prepared by USV1. Disputed that this information was available to JPMorgan in this format during the time

Epstein was a client of JPMorgan. Further disputed as to materiality or relevance of payments from Epstein to his attorneys and law firms to USVI’s claims in this matter. See JPMC Ex. 60 7 91 & n.166

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ‘ft 108-169.

  1. From 2006 through 2013, JPMorgan handled $50,909,656.04 in payments from Epstein’s JPMorgan accounts to various lasvfinns, including S9,505,547.91 in payments from January 2006 through September 24, 2007; S5,597,358.02 in payments from September 25, 2007 through June 30, 2008; and S35,806,750.11 from July 1, 2008 through December 2013 (relevant transactions identified mid summarised in the chart below).

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JPMC Response: Undisputed that this is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Further disputed as to materiality or relevance of payments from Epstein to his attorneys and law firms to USVI’s claims in this matter. See JPMC Ex. 60 ¶ 91 & n.166 [Redacted]

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. JPMorgan Private Bank’s Client Cash Transaction Guidelines states: “The receipt of large cash deposits and disbursements of cash withdrawals for other than client casual spending needs to be discouraged. It is the primary responsibility of the Banker to obtain explanations on the source of the cash and acceptability of the intended use of the case, and to assess the plausibility of these explanations for large cash transactions.” Ex. 157 at -224.

JPMC Response: Disputed to the extent USVI misstates the cited document. JPMorgan’s Client Cash Transaction Guidelines, last review date November 20, 2012, state “The receipt of large cash deposits and disbursements of cash withdrawals for other than client casual spending needs is discouraged.” See USVI Ex. 157 at -1227. Otherwise, undisputed that cited document contains quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF 11 108-169.

  1. Front September 2003 through November 2013, JPMorgan recorded cash withdrawals from Epstein’s JPMorgan accounts totaling 85,018,472. Ex. 56 at 24-26 and Figure 8 (copied below).

Figure 8: CTRs Relating to Epstein Accounts By Year

YearEpsteinEpsteinIInierionNYSG116 East 65a
#0438#0663#4332#3130St I.LC#4235Total
2003$175,310$175,310
2004$840,000$840,000
2005$901,337$3,000$904,337
2006$935,265$3,000$938,265
2007$520,000$6,000$526,000
2008$460,000$9,000$469,000
2009$100,011$60,000$5.O00$165,011
2010$223,397$30,000$253,397
2011$200,000$60,000$260,000
2012$290,000$290,000
2013$197,152$197,152
Total$4,355,320$90,000S547,152$21,00055.000$5,018,472

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60¶9 22, 88, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶9 108-169.

  1. From 2006 through 2013, JPMorgan recorded $3,098,825 in cash withdrawals from Epstein’s JPMorgan accounts. Ex. 56 at 24-26 and Figure 8.

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60¶9 22, 88, 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶9 108-169.

  1. From 2003 to 2007, JPMorgan recorded $3,383,912 in cash withdrawals from Epstein’s JPMorgan accounts. Er. 56 at 24-26 and Figure 8.

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶122, 88 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF 111 108-169.

  1. From 2005 to 2006, JPMorgan recorded $1,842,602 in cash withdrawals from Epstein’s JPMorgan accounts. Er. 56 at 24-26 and Figure 8.

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI’s proffered expert Jorge Amador. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60¶9 22, 88 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CS/vffill 108-169.

  1. From August 2006 through June 2008, JPMorgan recorded .81,134,000 in cash withdrawals from Epstein’s JPMorgan accounts (relevant transactions identified and summarized in the chart below).
1 ransaction Date Acct#Amount
#0438540,000.00
#0438$60,000.00
#0438$25,000.00
#3130$3.000.00
#3130S3,000.00
8/2/2007 Epstein$40,000.00

| #3130 | $3,000.00 | | Grand Total | $1,134,000.00 |

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 11 22,88,92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF /1 108-169.

  1. From August 2006 through November 2013, JPMorgan recorded $2,485,560.00 in cash withdrawals from Epstein’s JPMorgan accounts (relevant transactions identified and sun:marked in the chart below).

| #0438 | S60,000.00 | | #0438 | S40,000.00 | | #0438 | $25,000.00 | | #0438 | S40,000.00 | | #3130 | $3,000.00 | | #0438 | S40,000.00 | | #3130 | $3,000.00 | | #0438 | S40,000.00 |

| #0438 | S40,000.00 | | #0438 | S40.000.00 | | #3130 | S3,000.00 | | #0438 | S40,000.00 | | #0438 | S40,000.00 | | #0438 | S40,000.00 | | #0438 | $20,000.00 | | #3130 | $3,000.00 | | #0438 | S20,000.00 | | #0438 | S20,000.00 | | #0438 | $20,000.00 | | #0438 | $20,000.00 | | #3130 | S3,000.00 | | #0438 | S20,011.00 | | #0663 | S30,000.00 | | #0438 | S30,000.00 | | #0663 | $30,000.00 |

| #0438 | 530,000.00 | | #0438 | $20,000.00 | | #4235 | S5,000.00 | | #0438 | S20,000.00 | | #0438 | $20,000.00 | | #0438 | S30,000.00 | | #0438 | $30,000.00 | | #0438 | S13,397.00 | | #0438 | S30,000.00 | | #0438 | S40,000.00 | | #0663 | S30,000.00 | | #0438 | S40,000.00 | | #0438 | S40,000.00 | | #4332 | S30,000.00 | | #4332 | S30,000.00 |

| #4332 | S30,000.00 | | #4332 | S30,000.00 | | #4332 | $40,000.00 | | #4332 | $40,000.00 | | #4332 | S40,000.00 | | #4332 | 540,000.00 | | #4332 | $20,000.00 | | #4332 | $97,152.00 | | Grand Total | $2,485,560.00 |

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 II 22, 88 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSNfi 11 108-169.

  1. Front September 2008 through November 2013, JPMorgan recorded 81,308,560 in cash withdrawals from Epstein ‘s JPMorgan accounts (relevant transactions identified and summarized in the chart below).
Transaction DateAcct#Total Cash I
#0438$20,000.00
#0438540,000.00
10/7/2008EpsteinS40,000.00

| Transaction Date Acct# | Total Cash | | #0438 | $20,000.00 | | #0438 | $20,000.00 | | #3130 | $3,000.00 | | #0438 | $20.011.00 | | #0663 | $30,000.00 | | #0438 | $30,000.00 | | #0663 | $30,000.00 | | #0438 | $30,000.00 | | #0438 | $20,000.00 | | #4235 | $5,000.00 | | #0438 | $20,000.00 | | #0438 | $20,000.00 | | #0438 | $30,000.00 | | #0438 | $30,000.00 | | #0438 | $13,397.00 | | #0438 | $30,000.00 | | #0663 | $30,000.00 | | 5/27/2011 Epstein | $40.000.00 |

| Transaction Date Acct# | Total Cash | | #0438 | 540,000.00 | | #4332 | 530,000.00 | | #4332 | 530,000.00 | | #4332 | S30,000.00 | | #4332 | S30,000.00 | | #4332 | S30,000.00 | | #4332 | $40,000.00 | | #4332 | $40,000.00 | | #4332 | $40,000.00 | | #4332 | S40 000.00 | | #4332 | $20,000.00 | | #4332 | 597,152.00 | | Grand Total | $1,308,560.00 |

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 11 22, 88 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. From August 2013 through November 2013, JPMorgan recorded $117,152 in cash withdrawals from Epstein’s JPMorgan accounts (relevant transactions identified and summarized in the chart below).
Transaction DateAcct#Total Cash
8/1/2013Hyperion
#4332$20,000.00
11/1/2013Hyperion
#4332$97,152.00
Grand Total$117,152.00

JPMC Response: Undisputed that cited document is a summary of transactions prepared by USVI. Disputed that this information was available to JPMorgan in this format during the time Epstein was a client of JPMorgan. Disputed as to materiality to the extent this summary fails to put Epstein’s transactions in the appropriate context. See JPMC Ex. 60 ¶¶ 22, 88 92.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

  1. [REDACTED]

[REDACTED] Ex. 158 at -133-134, -

206-210 [REDACTED] Id. at -134. [REDACTED]

[REDACTED] Ex.

159 at -001002, -175-182. [REDACTED]

[REDACTED] Id. at -001.

See SUMF ¶ 22.

[Redacted] See JPMC Ex. 60 ¶¶ 121-23.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan participated in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 108-169.

JPMorgan Benefited from Participation in Epstein’s alleged sex-trafficking venture

JPMC Response: This is a header to which no response is warranted. Disputed insofar as USVI contends that the statements and documents cited below establish as a matter of law that JPMorgan benefited from participation in Epstein’s alleged sex-trafficking venture.

  1. JPMorgan first opened an account for Epstein in 1985. Ex. 39 at Resp. 1.

JPMC Response: Undisputed that Epstein opened an account with one of JPMC’s predecessor entities in 1985.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. JPMorgan admits that it earned fees and revenue from providing banking services to Epstein. Ex. 39 at Resp. 7.

JPMC Response: Undisputed that JPMorgan earned fees and revenue from providing banking services to Epstein.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. One of the factors impacting bonuses for JPMorgan Private Bankers was the revenues that clients brought into the bank. Ex. 160 at 46:11-18; 48:4-49:18.

JPMC Response: Undisputed that Morris testified that revenues were one factor that was taken into account to determine the discretionary bonus a Private Banker would receive.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. In 2003, Epstein brought in over $8.1 million in revenue to the Private Bank. &. 161 at - 088.

JPMC Response: Disputed that the S8.1 million in revenue in 2003 was from Epstein’s accounts at the JPMorgan Private Bank. USVI mischaracterizes the document the S8.1 million includes revenue from other Private Bank clients • rimaril See USVI Ex. 163 at -030.

1 :1’-1 :1

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. Epstein’s $8.1 million in revenue in 2003 was the most investor revenue for JPMorgan Wealth Management. Ex. 161 at -088.

JPMC Response: Disputed that the cited document establishes that Epstein was responsible for “the most investor revenue for JPMorgan Wealth Management” in 2003. The cited document reflects revenues from only a small subset of JPMorgan Private Bank clients, specifically just the Private Bank clients who were categorized as “investors.” Moreover, the revenues related to Epstein include those derived from other clients rinci all . See USVI Ex. 163 at -030.

JPMC Ex. 65 at 123:19-125:12.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. Epstein’s $8.1 million in revenue in 2003 was nearly double the amount of JPMorgan Wealth Management’s second-highest client Ex. 161 at -088.

JPMC Response: Disputed that the cited document establishes that Epstein was responsible for revenues “nearly double the amount of JPMorgan Wealth Management’s second-highest client” in 2003. The cited document reflects revenues from only a small subset of JPMorgan Private Bank clients, specifically just the Private Bank clients who were categorized as “investors.” Moreover, the revenues related to Epstein include those derived from other clients, principally See USVI Ex. 163 at -030.

JPMC Ex. 65 at 123:19-125:12.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. In 2003, “Jeffrey Epstein, through the trading of his accounts and that [sic] of [REDACTED], generates one of the largest annual revenue flows of private clients in the private bank.” Ex. 162 at -098. In 2004, Epstein’s JPMorgan Banker considered the Epstein/Wexner relationship a “crucial relationship to the private bank.” Ex. 163 at -030.

JPMC Response: Undisputed that cited documents contain quoted the text. Disputed to the extent that USVI contends that Epstein was the primary driver of the revenue flows or was the “crucial relationship.” [REDACTED] accounts were the driver of the revenue and the key part of the relationship.

Q: And you believe that [the [REDACTED]] relationship was a, quote, crucial relationship to the private bank; is that fair?

A: Mr. [REDACTED] was a crucial relationship to the private bank, yes.

Q: And Mr. Epstein?

A: Mr. Epstein was the money manager for Mr. [REDACTED], yes. So, therefore, he was part of an important relationship.

JPMC Ex. 66 at 117:20-118:7.

[REDACTED] JPMC Ex. T65 at 123:19-125:12.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Leading up to Epstein’s indictment in 2006, he was one of JPMorgan’s “very big clients.” Ex. 164 at -615.; Ex. 46 at 85:9-86:18.

JPMC Response: Undisputed that cited documents contain the quoted text. Disputed that Epstein was one of JPMorgan’s “very big clients.” [REDACTED]

[REDACTED] JPMC Ex. 65 at 122:2-

123:18

see also JPMC Ex. 65 at 123:19-125:121

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture.

  1. In October 2006, Epstein’s JPMorgan accounts totaled approximately 832 million. Ex. 76 at -953.

JPMC Response: Undisputed that as of October 17, 2006 a Rapid Response Team document states that “[t]he Epstein relationship … consists of banking, asset and credit accounts with balances totaling approximately S32 million.” USVI Ex. 76 at -953.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF /1 170-175.

  1. At the October 2006 Rapid Response Team meeting, layer internal discussion with in Staley, Mary Erdoes, Catherine Keating John Dotaj, and Mary=, it was decided that we will keep Mr. Epstein solely as a banking client and on a ‘reactive, client service basis.” Er. 39 at Resp. 44 (citing JPM-SDNYLIT-00127953 (Ex. 76)).

JPMC Response: Disputed to the extent USVI misstates the quoted document. The document states “[a]fter internal discussions,” not “discussion.” USVI Ex. 76 at -953. Otherwise, undisputed that cited document contains quoted text. JPMorgan lacks knowledge as to whether the referenced internal discussion in fact occurred.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF11 170-175.

  1. Kevin McCleerey testified that these conditions were imposed to “mitigate(’ the risk” presented by Epstein by capping “the number of accounts arid relationships with him.” Et 35 at 119:2-120:1

JPMC Response: Disputed that McCleerey testified that these conditions were imposed to “mitigate[] the risk” presented by Epstein by capping “the number of accounts and relationships with him.” McCleerey testified that “limiting Mr. Epstein to banking and

custody… mitigat[ed] the risk presented by Mr. Epstein” because JPMorgan was “not expanding the relationship based on the reputations/ risk that we knew of at the time in October of 2006.” USVI Ex. 35 at 119: 2-16. McCleerey further testified that “limiting [Epstein] to being a banking-only client” should have “limitaed the risk presented by Mr. Epstein” because “we would cap the number of accounts and relationships with him.” Id. at 119:17-120:1-4.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. In October 2007, JPMorgan continued doing “business as usual with Epstein’s office.” Ex. 102 at -963.

JPMC Response: Disputed that JPMorgan continued doing business as usual with Epstein’s office in October 2007. JPMorgan did not continue doing business as usual with Epstein’s office following his 2006 indictment and instead limited Epstein primarily to banking services. See USVI Ex. 76 at -953. The cited document is an October 25, 2007 email from =, sent after the decision was made to limit Epstein to banking services, that contains the text “[m]y current understanding is that we are business as usual with Epstein’s office” in the context of whether to authorize a new Letter of Credit for Epstein’s office. See USVI Ex. 102 at -963.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. At the time, Mary Erdoes wanted to “move forward based on our earlier decision to continue doing business” with Epstein. Ex. 102 at -962; Ex. 32 at 264:16-265:2; 273:24-274:22.

JPMC Response: Undisputed that the cited document regarding the decision whether to authorize a new Letter of Credit for Epstein in October 2007 contains the quoted text. Disputed that Erdoes “wanted” to move forward with authorizing a new letter of credit for Epstein in October 2007. JPMorgan lacks knowledge as to Erdoes’ state of mind regarding whether or not to authorize a new Letter of Credit for Epstein in October 2007.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. By July 2008, Epstein’s JPMorgan accounts had increased to total approximately $121.5 million. Er. 165 at 944; Er. 32 at 309:8-311:3.

JPMC Response: Undisputed that a July 15, 2008 Rapid Response Meeting document contains quoted text “[t]he Epstein relationship … mainly consists of banking and asset accounts with balances totaling approximately $121.5 million.” USVI Ex. 165 at -944.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF T1 170-175.

  1. On August 28, 2008, Mary entails Marcus Sheridan, subject: “Re: ‘09 plan” and said: “Also, 1 would count Epstein ‘s assets as a probable outflow for ‘08 ($120mm or so?) as I can’t imagine it will stay (pending Dimon review).” Ex. 301 at -706 R.

JPMC Response: Undisputed that cited document contains quoted text. Disputed as to the underlying suggestion that Dimon was involved in any Epstein review. testified that she intended her email to reference Cutler, “and [she] did not mean it to be Jamie Dimon, as he had nothing to do with this.” JPMC Ex. 66 at 341:12-24. Mr. Sheridan, the recipient of the email, also testified

129:8-23. x. 67 at

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. On September 3, 2008, Epstein’s JPMorgan accounts had a PCN Market Value of $156,218,451.45. Ex. 166 at -758; Ex. 39 at Resp. 3.

JPMC Response: Undisputed that cited document identifies a “PCN Market Value” of $156,218,451.45.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. JPMorgan admits that in October 2010 Epstein was one of JPMorgan’s top 20 clients in the Closely Held Business Group. Ex. 39 at Resp. 4.

JPMC Response: Undisputed that Epstein was one of JPMorgan’s top 20 clients in the Closely Held Business Group as of October 2010.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

Ex. 167 at -654.

JPMC Response:

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

Ex. 167 at -654.

JPMC Res nse:

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. . Ex. 167 at -654.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. By 2011, Epstein was JPMorgan Private Bank’s “GIO’s biggest revenue producer.” Ex.

168 at -977.

JPMC Response: Undisputed that cited document contains quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. By JO, 2013, Epstein was still actively trading through the GIO. Ex. 169 at -230.

JPMC Response: Undisputed that cited document, a July 3, 2013 email from Nelson to McCleerey and Duffy states, “The assets [Epstein] keeps at J.P. are his own monerthich he actively trades through our Global Investment Opportunities desk with Paul team.” USVI Ex. 169 at -230.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 9 170-175.

  1. At the time, Epstein’s Banker (Justin Nelson) described Epstein as “one of the most active and sophisticated investors on the GIO desk.” Ex. 169 at -230.

JPMC Response: Undisputed that Epstein’s banker described Epstein as “one of the most active and sophisticated investors on the GIO desk.” USVI Ex. 169 at -230.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. In September 2013, JPMorgan noted the impact of exiting Epstein roughly equated to “$0.5MM YoY revenue decrease in 2013. In 2014 it will be roughly a -$2MM revenue impact ” Ex. 170 at -016. JPMorgan further noted, “He currently has $176MM with us and actually has TCP flows of +$72MM this year.” Id.

JPMC Response: Disputed that JPMorgan “noted the impact” of exiting Epstein equated to “$0.5MM YoY revenue decrease in 2013. In 2014 it will be roughly a -$2MM revenue si .” The quoted text appears in a September 24, 2013 email from Carmen Zee to MEI K. Southmayd, which was sent after the decision was communicated to Epstein in August 2013 that JPMC would be exiting his relationship. See JPMC Ex. 68.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. In or about the year 2000, Douglas “Sandy” Warner, then CEO of JPMorgan, said to Staley (then Head of Private Bank), ”…[Y]ou should meet [sic] Epstein. He’s one of the most connected people I know of in New York” Ex. 46 at 45:18-47:4.

JPMC Response: Undisputed that Staley testified as to the quoted text. Disputed to the extent the underlying fact requires a credibility determination.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. JPMorgan admits Epstein introduced and referred potential clients to JPMorgan Private Bank. Ex. 39 at Resps. 5, 6.

JPMC Response: Undisputed that Epstein introduced and referred clients Robert Lee Burch III, Kathryn Ruemmler, and Ghisliane Maxwell to the JPMorgan Private Bank. See USVI Ex. 39 at Resp. 29; JPMC Ex. 69 at Resp. 3.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. Epstein referred a number of ultra-high net worth clients to JPMorgan over the years. Er. 48 at Resp. 17; Ex. 46 at 86:19-23.

JPMC Response: Undisputed that Epstein referred Robert Lee Burch III, Kathryn Ruemmler, and Ghislaine Maxwell to JPMC. See USVI Ex. 39 at Resp. 29; JPMC Ex. 69 at Resp. 3.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. One of the factors impacting bonuses for JPMorgan Private Bankers was new client acquisition. Ex. 171 at 83:18-84:4.

JPMC Response: Disputed that one of the factors impacting bonuses for JPMorgan Private Bankers was new client acquisition. The cited document does not support the proposition as Nelson testified that new client acquisition was “one of the factors that could be considered for compensation.” USVI Ex. 171 at 83:21-25; 84:1-4.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. One of the objectives that was instilled in JPMorgan Private Bankers was to acquire new clients. Epstein referred Bill Gates as a client to JPMorgan. Ex. 46 at 88:3-4.

JPMC Response: Disputed that “[o]ne of the objectives that was instilled in JPMorgan Private Bankers was to acquire new clients.” The cited testimony does not support this proposition. Disputed to the extent Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17 (“I don’t think [Epstein] referred clients to the bank. I met clients through him, but I don’t think he was making a referral.”).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Epstein referred Sergey Brin as a client to JPMorgan. Ex. 46 at 87:2-4.

JPMC Response: Disputed. Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17) (“I don’t think [Epstein] referred clients to the bank. I met clients through him, but I don’t think he was making a referral.”). See also JPMC Ex 62 at Resp. 18.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. Epstein referred Google LLC as a client to JPMorgan. Ex. 46 at 87:5-6.

JPMC Response: Disputed. Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17 (“I don’t think [Epstein] referred clients to the bank. I met clients through him, but I don’t think he was makin a ferral.” . Di ut that E o le LL a li ntt Mr an

ee JPM Ex. 7I at 5 -1

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. Epstein referred the Sultan of Dubai, Sultan Ahmed bin Sulayem as a client to JPMorgan. Er. 46 at 87:7-8.

JPMC Response: Disputed. Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17 (“I don’t think [Epstein] referred clients to the bank. I met clients through him, but I don’t think he was making a referral.”). See also JPMC Ex. 62 at Resp. 26.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF fi 170-175.

    1. Epstein referred MOH Zuckerman as a client to JPMorgan. Er. 46 at 87:15-16.

JPMC Response: Disputed. Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17 (“I don’t think [Epstein] referred clients to the bank. I met clients through him, but I don’t think he was making a referral.”). See also JPMC Ex. 62 at Resp. 28.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSNIF11 170-175.

    1. Epstein referred the as a client to JPMorgan. Er. 46 at 87:17-18.

JPMC Response: Disputed. Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17) (“I don’t think [Epstein] referred clients to the bank. I met clients through him, but I don’t think he was making a referral.”).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

    1. Epstein referred David Gergen as a client to JPMorgan. Er. 46 at 88:8-9.

JPMC Response: Disputed. Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17 (“I don’t think [Epstein] referred clients to the bank. I met clients through him, but I don’t think he was making a referral.”).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

    1. Epstein referred Boris Nikolic as a client to JPMorgan. Ex. 46 at 88:10-11; Ex. 160 at

17:13-18:4.

JPMC Response: Disputed. Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17) (“I don’t think [Epstein] referred clients to the bank. I met clients through but I don’t think he was making a referral.”). See also JPMC Ex. 72 at -701

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. Boris Nikolic was a medical advisor, who ran a venture fund. Ex. 160 at 17:13-18:4.

JPMC Response: Undisputed that Morris testified during his deposition that, “Boris Nikolic was a medical advisor. He was an entrepreneur, runs a venture fund.” See USVI Ex. 160 at 17:22-25.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. Boris Nikolic was “somehow related to Bill Gates.” Ex. 160 at 17:13-18:4.

JPMC Response: Undisputed that the cited deposition contains the quoted testimony. See USVI Ex. 160 at 18:2-4.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. Epstein referred Larry Summers as a client to JPMorgan. Et 46 at 88:12-13.

JPMC Response: Disputed. Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17 (“I don’t think [Epstein] referred clients to the bank. I met clients through him, but I don’t think he was making a referral.”).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. Epstein referred Pritzker, chairman and CEO of the Pritzker Organization, as a client or for additional activities or funds to JPMorgan. Ex. 172 at Resp. 49; Ex. 46 at 310:19- 311:4.

JPMC Response: Disputed. Staley’s testimony does not support the assertion that Epstein referred any clients to JPMC. See JPMC Ex. 70 at 386:14-17 (“I don’t think [Epstein] referred clients to the bank. I met clients through him, but I don’t think he was making a referral.”). See also USVI Ex. 39 at Resp. 31.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

    1. Epstein facilitated meetings between Staley and Ehud Barak. Ex. 46 at 89:11-16.

JPMC Response: Disputed to the extent the cited testimony does not support the contention that Epstein facilitated meetings between Staley and Barak. Staley testified that he met Barak. USVI Ex. 46 at 89:11-16.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

    1. In January 2008, Epstein facilitated an introduction between JPMorgan executives and Ehud Barak, and Staley directed his assistant to arrange the meeting through Jamie Dimon’s office. Ex. 173 at -152.

JPMC Response: Disputed. JPMorgan Chase did not need Epstein to facilitate a meeting with Barak (or others). As JPMC’s CEO testified: “I don’t think Jeff Epstein ever arranged for me to meet with anybody, to my knowledge. And I knew Ehud Barak. We did not need introductions to anybody.” JPMC Ex. 55 at 253:14. Further disputed to the extent that USVI contends that there was an introduction through Epstein or that he facilitated a meeting between JPMC executives and Mr. Barak. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

    1. Epstein facilitated meetings between Staley and Peter Mandelson. Ex. 46 at 90:20-24.

JPMC Response: Undisputed that Staley testified that Epstein facilitated meetings between Staley and Peter Mandelson. USVI Ex. 46 at 90:20-24. Disputed as to materiality in light of the fact that Epstein did not refer Mandelson to the Private Bank. See JPMC Ex. 62 at Resp. 19.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

    1. Lord Peter Mandelson was a senior member of the British Government. Ex. 144 at -009.

JPMC Response: Undisputed that the cited document states that Lord Peter Mandelson is a “senior member of the British Government.” Disputed as to materiality in light of the fact that Epstein did not refer Mandelson to the Private Bank. See JPMC Ex. 62 at Resp. 19.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. On June 5, 2009, Epstein wrote to Staley, “well , [sic] for all intends [sic] and purposes peter mandelson is now deputy prime minister.” Ex. 174 at -959; Er. 144 at -009; Er. 175 at 6.

JPMC Response: Undisputed that the cited document contains the quoted language. Disputed as to materiality in light of the fact that Epstein did not refer Mandelson to the Private Bank. See JPMC Ex. 62 at Resp. 19.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. On June 17, 2009, Epstein wrote to Staley, “peter will be staying at 71 st over weekend, do you want to organize either you, or you and Jamie” [sic] quietly” [sic] up to you.” Ex. 176 at -005; Ex. 144 at -009; Ex. 175 at 6.

JPMC Response: Undisputed that the cited document contains the quoted language. Disputed as to materiality in light of the fact that Epstein did not refer Mandelson to the Private Bank. See JPMC Ex. 62 at Resp. 19 .

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. In January 2009, Epstein wrote to Staley, “david gergen is coming to see me today.. [sic] we should talk before twelve.” Er. 177 at -763; Er. 144 at -006; Er. 175 at 4.

JPMC Response: Undisputed that the cited document contains the quoted language.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. David Gergen is a former adviser to Presidents Nixon, Reagan, and Clinton. Ex. 144 at -006.

JPMC Response: Undisputed that the cited document states, “David Gergen is the name of a former adviser to Presidents Nixon, Reagan and Clinton through 1994.” USVI Ex. 144 at -006.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. Epstein facilitated meetings between JPMorgan employees and Prince Andrew. El 46 at 96:13-16.

JPMC Response: Undisputed that Staley testified, “[y]es” when asked, “[b]ut Jeffrey Epstein at least facilitated meetings between persons working at the bank and Prince Andrew; is that fair?” USVI Ex. 46 at 96:13-16. Disputed as to materiality in light of the fact that Epstein did not refer Prince Andrew to the Private Bank. See JPMC Ex. 62 at Resp. 23; JPMC Ex. 73 at Resp. 36.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. On April 15, 2010, Epstein wrote to Prince Andrew the of York ‘des staley will be in London on thurs the 22.. [sic] i think you should meet if you are in town.. [sic].” Ex. 178 at -534; Ex. 144 at -011; Ex. 175 at 6.

JPMC Response: Disputed to the extent USVI misstates the quoted document. Epstein’s email to Prince Andrew states “Iondon,” not “London.” See USVI Ex. 178 at - 534. Otherwise, undisputed that the cited document contains the quoted text. Disputed as to materiality in light of the fact that Epstein did not refer Prince Andrew to the Private Bank. See JPMC Ex. 62 at Resp. 23 ; JPMC Ex. 73 at Resp. 36.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. On May 18, 2010, Epstein wrote to Staley, “anadrew [sic] will try to see you on your trip to london.” Ex. 179 at -970; Ex. 144 at -011; Er. 175 at 6.

JPMC Response: Undisputed that the cited document contains the quoted text. Disputed as to materiality in light of the fact that Epstein did not refer Prince Andrew to the Private Bank. See JPMC Ex. 62 at Resp. 23 (JPMC Response to USVI RFA No. 23); JPMC Ex. 73 at Resp. 36.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. On September 2, 2010, Lesley Groff wrote to Epstein, Vas Staley’s office called saying last night Jes met up with Prince Andrew and Tim ” Et 180 at -703; Ex. 144 at -011; Ex. 175 at 7.

JPMC Response: Undisputed that the cited document contains the quoted text. Disputed as to materiality in light of the fact that Epstein did not refer Prince Andrew to the Private Bank. See JPMC Ex. 62 at Resp. 23; JPMC Ex. 73 at Resp. 36.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. Id. Ex. 181 at -071. . Id.

JPMC Res i onse: . See USVI Ex. 181 at - 071. Ot erwise, un pute t t e e contains a quoted text. Disputed as to materiality in light of the fact that Epstein did not refer Prince Andrew to the Private Bank. See JPMC Ex. 62 at Resp. 23 ; JPMC Ex. 73at Resp. 36.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. On December 22, 2010, Prince Andrew wrote to Staley, “Wishing you a very happy Christmas and New Year. Sony to have missed you this week. Hope to catch tql sometime after the New Year. 1 will be at Davos as usual” Et 182 at -808; Ex. 144 at -Oil; Ex. 175 at 7.

JPMC Response: Disputed to the extent USVI misstates the quoted document, which fails to use ellipses between each sentence contained in the quote. See USVI Ex. 182 at - 808. Otherwise, undisputed that the cited document contains the quoted text. Disputed as to materiality in light of the fact that Epstein did not refer Prince Andrew to the Private Bank. See JPMC Ex. 62 at Resp. 23; JPMC Ex. 73 at Resp. 36.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

    1. In November 2013, Prince Andrew hosted Jamie Dimon for dinner and performances at Buckingham Palace. Ex. 183 at -462-63.

JPMC Response: Undisputed that the Financial Times reported that Prince Andrew hosted an event in November 2013 that “had a guestlist that included up to 100 corporate and political heavyweights, ranging from Kofi Annan, the former UN secretary-general, to Indian industrialist Ratan Tata.” See USVI Ex. 183 at -462-63. Disputed to the extent the document does not suggest there was a connection between this event and Jeffrey Epstein. In fact, the document states that David Mayhew, a UK financier and adviser to JPMC at the time, was “[Ic]ey to organising the night.” JPMC Ex. 74). Disputed as to materiality in light of the fact that Epstein did not refer Prince Andrew to the Private Bank. See JPMC Ex. 62 at Resp. 23; JPMC Ex. 73at Resp. 36.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

    1. Epstein facilitated meetings between Staley and Bill Gates. Ex. 46 at 92:20-23.

JPMC Response: Disputed to the extent the underlying fact, which is supported only by Staley’s deposition testimony, requires a credibility determination.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

    1. Epstein introduced his JPMorgan banker (Paul Morris) to Andrew Farkas. Ex. 160 at 15:23-17:12.

JPMC Response: Undisputed that Morris testified that Epstein introduced him to Farkas. Disputed as to materiality in light of the fact that Farkas did not become Morris’s client, USVI Ex. 160 at 16:22-24, and Epstein did not refer Farkas to the Private Bank. See JPMC Ex. 62 at Resp. 13; JPMC Ex. 73 at Rap. 28.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. Andrew Farkas is a major real estate investor who founded Island Capital Group. Ex. 144 at -006.

JPMC Response: Undisputed that the cited document states “Andrew Farkas is a major real estate investor who founded Island Capital Group.” See USVI Ex. 144 at -006. Disputed as to materiality in light of the fact that Farkas did not become Morris’s client, USVI Ex. 160 at 16:22-24, and Epstein did not refer Farkas to the Private Bank. See JPMC Ex. 62 at Resp. 13; JPMC Ex. 73 at Resp. 28.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. Epstein introduced JPMorgan to David Mitchell, a real estate developer. Ex. 160 at 14:20- 15:5.

JPMC Response: Undisputed that Morris testified that Epstein introduced him to Mitchell. USVI Ex. 160 at 14:20-15:2. Disputed as to materiality in light of the fact that Mitchell did not become Morris’s client. USVI Ex. 160 at 15:3-5.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. Epstein referred Robert Lee Burch II, former CEO of Jonathan Engineered Solutions and member of A.W.= advisory board, as a client to JPMorgan. Ex. 184 at -986; Ex. 39 at Resp. 29.

JPMC Response: Undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF¶¶ 170-175.

  1. In 2003, Epstein’s JPMorgan Private Banker noted that Epstein “helped us source several managers, including Glenn and Steve Saltzman.” Ex. 185 at -893.

JPMC Response: Disputed to the extent USVI misstates the cited document. The cited document was not written by Mary and states “Glen and Steve Salzman,” not “Glenn and Steve Saltzman.” See USVI Ex. 185 at -893. Otherwise, undisputed that the cited document contains the quoted text. Disputed that Epstein did in fact refer Saltzman to the Private Bank See JPMC Ex. 62 at Resp. 30; JPMC Ex. 73 at Resp. 48.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

186 at -184 K

e x. at esp. ; . at esp. .

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

Ex. 187 at -559.

JPMC Response: Undisputed that cited document contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF TI 170-175.

Ex. 188 at -001-003; Ex. 189 at -008.

JP:SIC Res )(uric,:

USVI Ex. 188 at -001-003; USVI Ex. 189 at -008. Dispute as to matena ty t o the fact that Epstein did not refer Brin or Page to the Private Bath. See JPMC Ex. 62 at Resps. 17, 18; JPMC Ex. 71 at 53:3-18.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

    1. Sergev Brin became a client ofJPMorgan’s San Francisco Private Bank in 2004. Er. 190 at -710.

JPMC Response: Undisputed that Brin became a client of the Private Bank in 2004. Disputed as to the inference that Epstein referred Brin. See JPMC Ex. 62 at Resp. 18; JPMC Ex. 71 at 53:3-18.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

    1. Staley referred Brin to Robert JPMorgan Banker/Managing Director in San Francisco. Er. 189 at -001; Ex. 190 at -709.

JPMC Response: Undisputed that Brin was referred to by Staley. Disputed as to the inference that Epstein referred Brit See JPMC Ex. 62 at Resp. 18; JPMC Ex. 71 at 53:3-18 .

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

Ex. 191 at -185.

JPMC Res nse:

Ex. 191 at -185.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted]

[Redacted] Ex.

192 at -515.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 192 at -515.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted]

[Redacted] Ex. 193 at -516.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 193 at -516.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted]

[Redacted] Ex. 194 at -517.

USVI Ex. 194 at -517. [REDACTED]

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 195 at -519.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 195 at -519.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. On October 26, 2006, Ann Borowiec emailed Jes Staley, “Catherine spoke to me about the need to have a NY team for Jeffrey Epstein, as the advisor to the Google founders.” Ex. 196 at - 356.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 196 at -356.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

the Times since I knew he was a client. I had it on my desk and gave it to Pooja.” Ex. 197 at -520.

JPMC Response: Disputed to the extent USVI misstates the document. Borowiec’s email states “Which,” not “which.” USVI Ex. 197 at -520. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 198 at -522.

[REDACTED] USVI Ex. 198 at -522.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 199 at -590.

SVI Ex. 199 at -590. [REDACTED]

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted]

[Redacted] Ex. 200 at -423.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 200 at -423.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted]

[Redacted] Ex. 201 at -152.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 201 at -152.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted]

[Redacted] Ex. 202 at -668.

JPMC Response: Undisputed that the cited documents contain the quoted text. USVI Ex. 203 at -670.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

Er. 204 at -671.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

x. 205 at -720.

JPMC Res onse:

USVI Ex. 205 at -720.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. In July 2014, JPMorgan noted “Nhe overall Brin relationship is one of the largest in the Private Bank, of +$4BN” Ex. 190 at -710.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 190 at -710. Disputed as to the inference that Epstein referred Brin. See JPMC Ex. 62 at Resp. 18; JPMC Ex. 71 at 53:3-18.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Brin and the CEO, CFO, and CIO of his family office, Bayshore Global, met with Mary Erdoes, Kelly Coffey, John Duffy and other JPMorgan regional executives. Ex. 190 at -709.

JPMC Response: Undisputed that the cited document states, “Sergey, as well as members of his family office: CEO, CFO and CIO have met with Mary Erdoes, Kelly Coffey, John Duffy and other regional executives.” USVI Ex. 190 at -709. Disputed as to the inference that Epstein referred Brin. See JPMC Ex. 62 at Resp. 18; JPMC Ex. 71 at 53:3-18.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 61 at -033.

JPMC Response: [REDACTED] SVI

Ex. 61 at -033. Disputed as to materiality in light of the fact that Epstein did not refer Sultan Ahmed Bin Sulayem as a client to JPMorgan. See JPMC Ex. 62 at Resp. 26

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 61 at -033.

JPMC Response: [REDACTED] USVI

Ex. 61 at -033. Disputed as to materiality in light of the fact that Epstein did not refer Sultan Ahmed Bin Sulayem as a client to JPMorgan. See JPMC Ex. 62 at Resp. 26.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 206

at -037; Ex. 207 at 1. [REDACTED]

[REDACTED] Ex. 206 at -

037.

JPMC Response: Disputed to the extent USVI omits text from the cited quote. See USVI Ex. 206 at -037. Otherwise, undisputed. Disputed as to materiality in light of the fact that Epstein did not refer Sultan Ahmed Bin Sulayem as a client to JPMorgan. See JPMC Ex. 62 at Resp. 26.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Sultan Ahmed bin Sulayem, was a senior United Arab Emirates official involved in ownership of the Dubai Ports. Ex. 144 at -009.

JPMC Response: Undisputed that the cited document states, “Sultan Ahmed bin Sulayem … is a senior UAE official involved in ownership of the Dubai Ports.” USVI Ex. 144 at -009. Disputed as to materiality in light of the fact that Epstein did not refer Sultan Ahmed Bin Sulayem as a client to JPMorgan. See JPMC Ex. 62 at Resp. 26.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. On December 7, 2009, Epstein wrote to Staley, “if you can have a one on one off the record with sultan , [sic] he will meet you.” Ex. 208 at -724; Ex. 144 at -012; Ex. 175 at 7.

JPMC Response: Undisputed that the cited documents contain the quoted text. USVI Ex. 208 at -724; USVI Ex. 144 at -012; USVI Ex. 175 at 7. Disputed as to materiality in

light of the fact that Epstein did not refer Sultan Ahmed Bin Sulayem as a client to JPMorgan. See JPMC Ex. 62 at Resp. 26.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. On December 8, 2009, Epstein wrote to Staley, “no to china /ports yet.. (sic) sultan will meet you privately to give you guidance… .” Ex. 209 at -897; Er. 144 at -012; Ex. 175 at 7.

JPMC Response: Undisputed that the cited documents contain the quoted text. USVI Ex. 209 at -897; USVI Ex. 144 at -012; USVI Ex 175 at 7. Disputed as to materiality in light of the fact that Epstein did not refer Sultan Ahmed Bin Sulayem as a client to JPMorgan. See JPMC Ex. 62 at Resp. 26.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. On December 8, 2009, Epstein wrote to Sultan bin Sulayem, copying Staley, “sultan , (sic) jes is free thurs” (sic) from 5-10 p.m. where and when” (sic) only the two of please.” Ex. 210 at -727; Ex. 144 at -012; Ex. 175 at 7.

JPMC Response: Undisputed that the cited documents contain the quoted text. USVI Ex. 210 at -727; USVI Ex. 144 at -012; USVI Ex. 175 at 7. Disputed as to materiality in light of the fact that Epstein did not refer Sultan Ahmed Bin Sulayem as a client to JPMorgan. See JPMC Ex. 62 at Resp. 26.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. On December 9, 2009, Epstein wrote to Staley, “sultan is laying the groundwork for you to establish a serious presence.. (sic) jpm reputation in the region is poor.” Ex. 211 at -729; Er. 144 at -012; Ex. 175 at 7.

JPMC Response: Undisputed that the cited documents contain the quoted text. USVI Ex. 144 at -012; USVI Ex. 175 at 7. Disputed as to materiality in light of the fact that Epstein did not refer Sultan Ahmed Bin Sulayem as a client to JPMorgan. See JPMC Ex. 62 at Resp. 26.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Epstein’s client, [REDACTED] Black, was a customer of JPMorgan Private Bank. Ex. 39 at Resp. 192.; Ex. 212 at -010; Ex. 160 at 38:4-41:13.

JPMC Response: Undisputed that [REDACTED] Black was a customer of the Private Bank. Disputed as to materiality in light of the fact that Epstein did not refer [REDACTED] Black as a client to JPMorgan. See USVI Ex. 39 at Resp. 11.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. One of Epstein’s JPMorgan Bankers testified, “[REDACTED] Black had a very significant net worth and he was a CEO of a large investment firm, and I looked at him as a priority prospect.” Ex. 160 at 53:15-54:2.

JPMC Response: Undisputed that Morris testified to the cited information. USVI Ex. 160 at 53:15-54:2. Disputed as to materiality in light of the fact that Epstein did not refer [REDACTED] Black as a client to JPMorgan. See USVI Ex. 39 at Resp. 11.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Epstein occasionally brought opportunities to JPMorgan for them to “deepen” their relationship with [REDACTED] Black. Ex. 171 at 46:9-15.

JPMC Response: Undisputed that Nelson testified to the cited information. USVI Ex. 171 at 46:9-15. Disputed as to materiality in light of the fact that Epstein did not refer [REDACTED] Black as a client to JPMorgan. See USVI Ex. 39 at Resp. 11.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. In July 2012, Epstein sought a loan through JPMorgan on behalf of [REDACTED] Black for an art purchase. Ex. 213 at -569; Ex. 160 at 173:8-21.

JPMC Response: Undisputed that the cited email from Duffy to Erdoes discusses a loan “Jeffrey is pursuing […] on [Redacted] behalf,” USVI Ex. 213 at -569, and that Morris testified that Epstein wanted to bring him on an art loan for [Redacted] Black, USVI Ex. 160 at 173:8-21. Disputed as to materiality in light of the fact that Epstein did not refer [Redacted] Black as a client to JPMorgan. See USVI Ex. 39 at Resp. 11.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted]

[Redacted] Ex. 214 at -112.

USVI Ex. 214 at -112.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted]

[Redacted] Ex. 215 at -892.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 215 at -892. Disputed as to materiality in light of the fact that Epstein did not refer [Redacted] Black as a client to JPMorgan. See USVI Ex. 39 at Resp. 11.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

x. 216 at -912.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 216 at -912. Disputed as to materiality in light of the fact that Epstein did not refer Black as a client to JPMorgan. See USVI Ex. 39 at Resp. 11.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

la-. 217 at -423.

JPMC Res onse: Dis uted to the extent USVI omits text from the cited ote.

USVI Ex. 217 at -42 . erwise, un ut .

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

O. 218 at -646.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 218 at -646.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. On March 23, 2011, Roy Navon wrote Jacob Frenkel and Staley, “Against all odds, we have been granted a meeting with Prime Minister Netanyalm.” Staley forwarded the email from Navon to Epstein and said, “Thanks.” Epstein responded to Staley, “surprisee [sic] surprise.” Ex. 219 at -841; Ex. 144 at -008; Et. 175 at 6.

JPMC Response: Disputed to the extent USVI misstates the cited documents. Epstein’s response to Staley states, “surprisee [sic] suprise [sic].” USVI Ex. 219 at -841. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. On April 10, 2011, Epstein wrote to Staley, “I will be back tomorow. [sic] Karim Wade son of the senegalese president and one of the most important players in africa, will be at the house this week, i think you will enjoy him.” Er. 220 at -260; Ex. 144 at -008; Er. 175 at 6.

JPMC Response: Undisputed that the cited documents contain the quoted text. USVI Ex. 220 at -260; USVI Ex. 144 at -008; USVI Ex. 175 at 6.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. On September 16, 2011, Epstein wrote to Staley, “co founder of facebook , [sic] and founder of spoil& sean , [sic] will be at the house for dinner on sunday —come.” Ex. 221 at -368; Ex. 144 at -009; Ex. 175 at 6.

JPMC Response: Undisputed that the cited documents contain the quoted text. USVI Ex. 221 at -368; USVI Ex. 144 at -009; USVI Ex. 175 at 6.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. Ex. 222 at Re-sp. 5.

USVI Ex. 222 at Resp. 5.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. In August 2013, after JPMorgan informed Epstein of the decision to exit him from the bank, Duffy and Erdoes decided it was okay to continue working with Epstein as long as it was through his client accounts. Ex. 212 at -010; Ex. 171 at 174:19-175:23.

JPMC Response: Disputed. Erdoes and Duffy selectively permitted further engagement where the client directed that JPMC interact with Epstein, but Epstein could not have decision making authority over the accounts. See JPMC Ex. 75. See also JPMC Ex. 61 at 302:19-303:11 (“[W]e can’t stop someone from being affiliated with somebody else. But we wouldn’t be taking direction from [Epstein] … ”); see also JPMC Ex. 76 at 175:2-177:11; JPMC Ex. 77 at 382:23-383:9.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. JPMorgan continued to work with Epstein on accounts f for [REDACTED] Black, CEO of Apollo, a private equity group. Ex. 223 at -344; Ex. 224 at -434-35; Ex. 225 at -511; Ex. 226 at -218-19; Ex. 171 at 45:8-13.

JPMC Response: Disputed to the extent the USVI mischaracterizes JPMorgan as “work[ing] with Epstein on accounts for [REDACTED] Black.” Disputed to the extent the cited documents do not support the assertion that JPMorgan “continued to work with Epstein on accounts for [REDACTED] Black.” In the cited deposition testimony, Nelson is asked, “[w]as there ever a point in time where Jeffrey Epstein was communicating with you on behalf of [REDACTED] Black related to any investment vehicles?” Justin Nelson replies, “I don’t remember.” USVI Ex. 171 at 45:4-8. See also JPMC Response to ¶ 354, supra.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Duffy gave Epstein’s JPMorgan Banker (Nelson) permission to continue a relationship with Epstein as a potential source of referrals. Ex. 171 at 172:2-175:9.

JPMC Response: Undisputed that during his deposition, Justin Nelson responded, “yes” when asked if, after Jeffrey Epstein had been terminated, Nelson got “the permission of John Duffy to continue a relationship with Jeffrey Epstein where he will be a potential source of future referrals?” USVI Ex. 171 at 172:2-175:9. Disputed as to the scope of the relationship implied by USVI’s proposition. See JPMC Response to ¶ 354.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Nelson maintained a relationship with Epstein after he was terminated as a client. Ex. 171 at 43:6-24.

JPMC Response: Undisputed as to the cited deposition testimony. USVI Ex. 171 at 43:6-24.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Nelson met with Epstein 8 to 10 times after Epstein was terminated. Ex. 171 at 177:12-18.

JPMC Response: Undisputed as to the cited deposition testimony. USVI Ex. 171 at 177:12-18.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. JPMorgan admits that Mary [REDACTED] met with Epstein at his Manhattan townhouse two or three times between 2000 and before Epstein’s arrest in 2006. JPMorgan admits that Mary [REDACTED] also met with Epstein at his Manhattan townhouse once in 2011 and once in the summer of 2013. Ex. 227 at Resp. 21.

JPMC Response: Disputed to the extent the USVI misstates the cited document. Response 21 states that Erdoes, not [REDACTED], “met with Epstein twice at his Manhattan townhouse in 2011 and in the Summer of 2013.” USVI Ex. 227 at Resp. 21. Undisputed that the cited document states that Mary [REDACTED] met with Epstein “at his Manhattan townhouse on two or three occasions between 2000 and prior to [Epstein’s] arrest in 2006.” Id.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 228 at -644.

JPMC Response: Undisputed that the cited document contains the quoted text. Disputed as to materiality in light of the fact that Epstein did not refer [REDACTED] Black as a client to JPMorgan. See USVI Ex. 39 at Resp. 11.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 229 at -300.

JPMC Response: Undisputed that cited document contains quoted text. USVI Ex. 229 at -300.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 230 at -592.

JPMC Response: Undisputed that cited document contains quoted text. USVI Ex. 230 at -592.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

Ex. 231 at -975.

JPMC Response: Undisputed that cited document contains quoted text. USVI Ex. 231 at -975.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

[Redacted] Ex. 232 at -177.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

[Redacted] Ex 233 at -618.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 233 at -618.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. JPMorgan admits Epstein was involved in the establishment of a customer relationship with Kathryn Ruemmler. Ex. 234 at Resp. 3.

JPMC Response: Undisputed that the cited document states that “Mr. Epstein had some involvement in the establishment of customer relationships between JPMC’s private bank and Ghislaine Maxwell and Kathryn Ruemmler.” USVI Ex. 234 at Resp. 3.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

IF.x. 235 at -394.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

x.

236 at -392.

JPMC Response: See

USVI Ex. 236 at -392.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. [REDACTED]

[REDACTED] Ex. 237 at 467.

USVI Ex. 237 at -467.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 238 at -063.

USVI Ex. 238 at -063.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Epstein was close friends with Glenn [REDACTED], the billionaire co-founder of Highbridge, and godfather to one of [REDACTED]‘s children. Ex. 239 ¶ 3; Ex. 240 at -164; Ex. 123 at 173:19-74:1.

JPMC Response: Disputed to the extent the USVI inserts the word “close” to describe the relationship. Undisputed that in the cited deposition testimony, Erdoes states, “I understood Mr. Epstein to be — to have had a past relationship with Mr. [REDACTED] wife. And I understood that Mr. Epstein was the godfather of one of the [REDACTED] — the oldest of the [REDACTED] children. That was my understanding.” USVI Ex. 123 at 73:19-74:1.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Epstein advised JPMorgan regarding the acquisition. Ex. 241 at 590; Ex. 242 at -149-50.

JPMC Response: Disputed to the extent the USVI mischaracterizes Epstein’s role regarding the acquisition. On June 16, 2004, von Moltke emails Staley and Brigstocke, copying other JPMC employees. The email summarizes observations from a meeting the

previous day with Highbridge. One of the items under “Next steps” states, ’ e continue to be concerned about the role Jeffrey Epstein is or is not playing. One concern that we have is that Jeffrey has been educating Glenn & Henry about our structure and valuation thoughts behind our backs such that their expectations for yesterday’s were higher. This is clearly not in our interest.” USVI Ex. 242 at -150. This information does not support the proposition that Epstein “advised” JPMC.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. Epstein also advised Highbridge regarding the acquisition. Er 241 at -590; Ex. 242 at - 149-50

JPMC Response: Undisputed that the February 15, 2005 email sent from Shepherd to Staley and Brigstocke, copying M, sets out a “strawman proposal [sic] for the economics of a consulting arrangement at Highbridge for Jeff Epstein.” USVI Ex. 241 at -590. Disputed as to the extent the USVI characterizes this proposal as representative of any final advising arrangement between Highbridge and Epstein or Epstein and JPMC.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. On June 16, 2004, James Von Moltke emailed Jes Staley and David Brigstocke with the subject line, “Thoughts on the 6/15/04 meeting with Highbridge,” stating, “The good news is that we did not leave any money on the table and that, based on the 9-1Ix multiple range we discussed with Dimon et al… They should be encouraged to go ahead with the Dimon and Coulter lunch… . This would be a good part of a follow-up discussion, ideally with you and prior to the Dimon/Coulter meeting. We continue to be concerned about the role Jeffrey Epstein is or is not playing. One concern that we have is that Jeffrey has been educating Glenn & Henry about our structure and valuation thoughts. “Ex. 242 at -149-50.

JPMC Response: Undisputed that the cited document contains the quoted text although the underlying document is formatted as a series of distinct bullet points and not as continuous text, as this paragraph presents it. USVI Ex. 242 at -149-50. Disputed to the extent the cited document is selectively quoted and without appropriate context. For instance, the language that USVI quotes suggests Highbridge “should be encouraged to

go ahead with the Dimon and Coulter lunch” because of the “9-11x multiple range we discussed with Dimon et al.” These statements, however, appear in different, unrelated sections of von Moltke’s email. USVI Ex. 249 at -50 (emphasis added).

Further disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. On January 14, 2004, the New York Times reported that JPMorgan had agreed to acquire Bank One and stated: “The combined company will be headed by William B. [REDACTED], 60, who is currently the chairman and chief executive of J.P. [REDACTED] Chase. James Dimon, 47, the chairman and chief executive of Bank One, will become president and chief operating officer of the combined company. He is to succeed Mr. [REDACTED] as chief executive in 2006, although Mr. [REDACTED] will remain as chairman.” Ex. 243 at 1.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 243 at 1.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175. Further contended that the cited material cannot be presented at trial in admissible form.

  1. [REDACTED]

Ex. 244 at -985, -987, -996, -998.

JPMC Response: [REDACTED] USVI Ex. 244 at -985, -987, -996, -998. [REDACTED]

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

[Redacted] Ex. 245 at -780.

SVI Ex. 245 at -780.

USVI Ex. 245 at 780.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. JPMorgan admits that [Redacted] & Swieca Holdings, Inc. paid Financial Trust Company, Inc. a fee related to JPMorgan’s acquisition of a majority interest in Highbridge Capital Management in 2004. Ex. 39 at Resp. 9.

JPMC Response: Undisputed that [Redacted] & Swieca Holdings, Inc. paid Financial Trust Company, Inc. a fee related to JPMorgan’s acquisition of a majority interest in Highbridge Capital Management in 2004. USVI Ex. 39 at Resp. 9.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex.

246 at -246-47.

[REDACTED] USVI Ex. 246 at -246-47.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. Highbridge managed $7 billion in assets at the time JPMorgan acquired the majority interest. Ex. 247 at 1.

JPMC Response: Undisputed that the cited document, a New York Times article dated September 28, 2004, states that “Highbridge manages $7 billion in assets.” USVI Ex. 247 at 1.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. On June 11, 2009, JPMorgan completed its purchase of Highbridge and touted it as “one of the largest and most significant strategic alliances in the hedge fund industry.” Ex. 248 at 1.

JPMC Response: Disputed as to USVI’s characterization that the cited document “touted” anything. Undisputed that the cited document, dated June 11, 2009, contains the quoted text. USVI Ex. 248 at 1.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. At the October 2006 Rapid Response meeting, the Private Bank imposed a condition on Epstein’s accounts—he could remain a “banking” but not an investment client a 76 at -953.

JPMC Response: Disputed. USVI misstates the conclusion of the meeting and the cited document. The cited document does not support the conclusion that the Private Bank imposed a condition that Epstein could not remain an investment client. The cited Rapid Response Team memorandum states that “it was decided that we will keep Mr. Epstein solely as a banking client and on a `reactive’, client service basis. We will not proactively solicit new investment business from him.” USVI Ex. 76 at -953. JPMC decided that it would not “proactively solicit new investment business” from Epstein, not that Epstein could not be an investment client. Id.; see also JPMC Ex. 71 at 66:17-67:12

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF TI 170-175.

  1. At the time, Epstein’s brokerage business was at Bear Stearns, not JPMorgan. E.T. 124 at - 175; Ex. 249 at -787.

JPMC Response: Undisputed that the cited documents support that Epstein had a brokerage relationship with Bear Steams. USVI Ex. 124 at -175; USVI Ex. 249 at -787.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Beam Steams benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF en 170-175.

  1. JPMorgan considered him “problematic” from an investment standpoint. Er. 250 at -254; Ex. 32 at 97:3-100:1.

JPMC Response: Undisputed that the cited document and testimony support that JPMC considered Epstein “problematic” from an investment standpoint. USVI Ex. 250 at -254; USVI Ex. 32 at 97:30-100: I. Disputed that this fact is at all material to the issues of this case. The cited email shows that JPMC employees are discussing Epstein’s “problematic” behavior in the context of his failure to pay fees and because “every transaction becomes problematic.” USVI Ex. 250 at -254. This discussion has nothing to do with Epstein’s arrest in 2006. testified that the cited email related to “the challenges of covering Jeffrey because he was a difficult investment client” and that the reference to Epstein being “problematic” was in connection with “an investment-related concern.” USVI Ex. 32 at 98:16-23.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted] Ex. 167 at -654. By 2011, Epstein was the Private

Bank’s investment arm’s “biggest revenue producer.” Ex. 168 at -977.

[Redacted] SVI Ex. 76 at -953. Id. [Redacted] See USVI Ex. 167 at -654. [Redacted] See JPMC Ex. 78 at -968; USVI Ex. 168 at -977.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted]

[Redacted] Ex. 251 at -223.

[Redacted] USVI Ex. 251 at -223. d. [Redacted] See

JPMC Response to ¶ 138, supra.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

    1. On March 16, 2008, JPMorgan purchased Bear Stearns. Ex. 122 at 1.

JPMC Response: Undisputed that on March 16, 2008, JPMorgan Chase and Co. purchased Bear Stearns.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ill 170-175.

    1. The purchase kept Bear Stearns, which was heavily in mortgage-backed securities investments, from bankruptcy following the housing market crash that led to the 2008 Great Recession. Ex. 122 at 1.

JPMC Response: Undisputed that the cited document provides the cited information. USVI Ex. 122 at 1. Disputed that the cited document is competent evidence on the impact of the purchase of Bear Stearns or what led to Bear Stearns’ banlcruptcy.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Steams benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

252 at 1-2.

JPMC Res once: USVI Ex. 252 at

See JPMC Ex. 79 at 272:3-: : “An it’s a so consistent at organ retain • e y Epstein as a client to deal with the Bear Steams litigation that Jeffrey Epstein had, correct?” A: “I don’t know that.”); id. at 275:7-22 (explaining reasons JPMC retained Epstein around this time as “Mr. Staley felt very strongly that Mr. Epstein had paid his debt to society, had served his time, and was someone that a lot of other people trusted. I think Mr. Staley didn’t agree with the notion that we shouldn’t have him as a client.”).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Steams benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 71170-175. Further contended that the cited material cannot be presented at trial in admissible form.

  1. In August 2009, Epstein sued Bear Stearns for ‘fraudulently overstaffing] the value of Bear Stearns’ mortgages, mortgage-backed and asset-backed securities and other derivative financial instruments, the adequacy of its liquidity and capital reserves, and the quality of Bear Stearns’ risk management.” Ex. 253 1 /S.

JPMC Response: Undisputed that on August 5, 2009, Epstein’s entity, Financial Trust Company, Inc., filed a complaint against The Bear Stearns Companies Inc. and the complaint contains the quoted language.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175. Further contended that the cited material cannot be presented at trial in admissible form.

  1. On Jiro, 19, 2011, JPMorgan offered Epstein a proposal to settle his High Grade Fund and Bear Stearns claims together for $21 million. Ex. 254 at -561. The following day, Cutler responded “This is not an honorable person in any way. He should not be a client ” Id.

JPMC Response: Disputed. USVI misstates the cited document. The document does not support the contention that “JPMorgan offered Epstein a proposal to settle” his claims for $21 million. Rather, the cited document shows that JPMC responded to Epstein’s proposal to settle his claims for $21 million. See USVI Ex. 254 at -561. On July 19, 2011, James Condren wrote to Staley, Erdoes, Cutler, and Shenker, “I just conveyed to Mr. Epstein our response to his proposal to settle his High Grade Fund and Bear claims together for S21 million.” Id. (emphasis added). Undisputed that on July 20, 2011, Cutler responded to Condren’s email and Cutler’s response contains the quoted text.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture.

  1. On July 21, 2011, Cutler wrote to Erdoes regarding a settlement offer to Epstein, “I would like to put it and HIM behind us. Not a person we should do business with - period.” Er. 255 at - 958R.

JPMC Response: Undisputed that Cutler emailed Erdoes on July 21, 2011 and that email contains the quoted text. USVI Ex. 255 at -958_R. Disputed to the extent USVI contends that this fact supports an inference this litigation had any relevance to JPMC’s retention or exit decisions with respect to Epstein. See JPMC Ex. 79 at 272:3-8 (Q: “And it’s also consistent that JPMorgan retained Jeffrey Epstein as a client to deal with the Bear Steams litigation that Jeffrey Epstein had, correct?” A: “I don’t know that”); id. at 275:7-22 (explaining reasons JPMC retained Epstein around this time as “Mr. Staley felt very strongly that Mr. Epstein had paid his debt to society, had served his time, and was someone that a lot of other people trusted. I think Mr. Staley didn’t agree with the notion that we shouldn’t have him as a client.”).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. On August 4, 2011, JPMorgan met for a fourth Rapid Response Meeting regarding Epstein and concluded that “D41’ to reach out to Jes Staley and advise that we exit while things are a bit settled.” Er. 256 at 31.

JPMC Response: Undisputed that a Rapid Response meeting was held on August 4, 2011 and the cited document contains the quoted text. USVI Ex. 256 at 31.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF TI 170-175.

  1. On April 8, 2011, Nina Shenker entailed Kevin McCleerey with the subject, “Rapid Response.” Shenker wrote, “[IJf you could break down between ddas, brokerage and fund holdings and others [sic] categories. So that we can understand the process for offboarding the account ” Ex. 257 at -025. Kevin McCleerey responded with the attachment, “Rapid Response Team — Jeffrey Espstein [ sic] 3r Mtg — Jan 2011 — March 2011 update-doczip.” Employees were working to collect information to “understand the process for ofiboarding the account.” Id. at -025.

JPMC Response: Disputed. USVI misstates the cited document. Undisputed that on April 8, 2011, Shenker emails McCleerey and the email contains the quoted text. McCleerey does not, however, respond to Shenker with the cited attachment. Rather, McCleerey forwards Shenker’s email to James Dalessio, attaching the file titled “Rapid Response Team - Jeffrey Espstein [sic] 3r Mtg - Jan 2011 - March 2011 update-doc.zip,” and states “Lets [sic] discuss her request.” USVI Ex. 257 at -025.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

  1. In July 2011, when Epstein approved the settlement, Nina Shenker, then GC to the Private Bank, wrote to Erdoes, “Steve [Cutler] at conclusion of JE approval [of Bear Steams settlement], asked when we are offboarding JE. I reminded him that we have the other matter outstanding.” Ex. 258 at -982; Ex. 99 at 268:12-272:24.

JPMC Response: Undisputed that Shenker emailed Erdoes on July 22, 2011 and that email contains the quoted language. USVI Ex. 258 at -982.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF /1 170-175.

  1. Ex. 259 at -106.

  2. Er. 252 at 1-2; Ex. 260 at -610.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 259 at -106.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

JPMC Res nse: See Ex. JPMC Ex. 79 at

274:17-275:5 “I so n t ow t we were not o ar i g Mr. Epstein because of [the Highbridge] litigation or litigation claim.”); id. at 273:1-15 (“We did not, also, offboard him once the Zwim matter was resolved.”); id. at 275:7-22 (explaining reasons JPMC retained Epstein around this time as “Mr. Staley felt very strongly that Mr. Epstein had paid his debt to society, had served his time, and was someone that a lot of other people misted. I think Mr. Staley didn’t agree with the notion that we shouldn’t have him as a client.”).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175. Further contended that the cited material cannot be presented at trial in admissible form.

  1. [REDACTED]

[REDACTED] Ex. 261 at -948_R.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 261 at -948_R.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 262 at -561.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 262 at -561.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Stearns benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 262 at -560.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. “The Talented Mr. Epstein” states: “in his early 20s [Epstein] got a job teaching physics and math at Dalton, the elite Manhattan private school. While there he began tutoring the son of Bear Stearns chairman Ace Greenberg and was friendly with a daughter of Greenberg’s. Soon he went to Bear Stearns, where, under the mentorship of both Greenberg and current Bear Stearns C.E.O. James Cayne, he did well enough to become a limited partner—a rung beneath fill partner.” Ex. 49 at S.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 49 at 6.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan or Bear Steams benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF11 170-175. Further contended that the cited material cannot be presented at trial in admissible form.

  1. In August 2010, Alan “Ace” Greenberg, who was now at JPMorgan, wanted to continue to do business with Epstein so he went to Cutler for an exception to the felon policy. Er. 263 at 910-11.

JPMC Response: Undisputed that the cited email states that “Ace Greenberg wants to do business with [Epstein]” and Todd asks, “Did Ace go to him for an exception to the felon policy,” to which Melissa Getler states, “That’s my understanding.” USVI Ex. 263 at -910-11.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. In his deposition, Jes Staley agreed that Greenberg was “a fairly important person” with “heir at JPMorgan around 2010. Er. 46 at 173:13-24.

JPMC Response: Disputed to the extent USVI mischaracterizes Staley’s testimony. See USVI Ex. 46 at 173:13-24. Undisputed that Staley testified that “Greenberg was important.” Id. at 173:23-24.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF fi 170-175.

  1. Beginning in 2011, Staley and Erdoes had “regular communication with Jetey Epstein relating to certain strategic initiatives and business proposals.” Er. 144 at -012; Ex. 175 at I.

JPMC Response: Undisputed that the cited documents contain the quoted text. USVI Ex. 144 at -012; USVI Ex. 175 at 1.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

Ex. 302 at -555-56; Ex. 303 at -548-49.

USVI x. at -548-49: USVI Ex. 303.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF11 170-175.

  1. JPMorgan admits that Epstein and JPMorgan personnel discussed a potential donor advised find relating to The Bill and Melinda Gates Foundation and Bill Gates. Ex. 39 at Resp.

JPMC Response: Undisputed that Epstein and JPMorgan personnel discussed a potential donor advised fund relating to The Bill and Melinda Gates Foundation and Bill Gates. USVI Ex. 39 at Resp. 14.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 11 170-175.

  1. On February 6, 2011, Epstein wrote to Staley regarding a potential donor advised find for The Bill and Melinda Gates Foundation, “you could tie it initially just to the gates program” [sicJ miinimum [sic] gift. 100 million. it could then be opend [sic] up later. IT will be the largest foundation in the world … . done right its [sic] 100 billion dollars in 2 years Fanning the

investments to a highbridge is no brainer… .1! will be the most sort [sic] after board in the countiy.” Ex. 264 at -591; Ex. 144 at -012; Ex. 175 at 7.

JPMC Response: Undisputed that the cited documents contain the quoted text. USVI Ex. 264 at -591; USVI Ea 144 at -012; USVI Ex. 175 at 7.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF TI 170-175.

  1. hi August 2011, Epstein wrote to Staley and Erdoes regarding noting it will be a “very HIGH profile” opportunity and recommending it require a minimum 5100 million donation. Ex. 265 at -652; Er. 144 at -013; Ex. 175 at 7.

JPMC Response: Undisputed that Epstein emailed Staley and Erdoes on August 10, 2011 and wrote, “This will be very HIGH profile. I propose a minimum of 100 million donation.” USVI Ex. 265 at -654.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF TI 170-175.

  1. Ex. 266 at -924.

  2. lEx. 267 at -666.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 266 at -924.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 267 at -666.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

[REDACTED] Ex. 268 at -028.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 268 at -028.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. JPMorgan admits it had communication with Epstein about a fee for Epstein in connection with a proposed donor advised fund. Ex. 39 at Resp. 15.

JPMC Response: Undisputed that JPMC had communication with Epstein about a fee for Epstein in connection with a proposed donor advised fund. Disputed as to materiality in light of the fact that, as provided in the full cited response, the donor advised fund was never established and JPMC did not pay Epstein any such fee. See USVI Ex. 39 at Resp. 15.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [REDACTED]

Ex. 269 at -931-32.

JPMC Response: [Redacted] USVI Ex. 269 at -931.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. On April 27, 2009, Epstein emailed Staley, ” [Redacted] can meet have dinner lunch a weekend [sic] with any of the following seth Lloyd mit quantum computing.. [sic] [Redacted] gell-man , santa-fe institute quarks ,, [sic] brian [Redacted] Columbia -string theory,, [sic] leonard Susskind ,, [sic] strings theory, [Redacted] Krause,, [sic] origins institute phoenix Arizona.. [sic] lee smolin perimeter institute, loop quantum gravity , [sic] she can see the large adron [sic] collider in switzerland. private tour.” Ex. 270 at -844; Ex. 144 at -004; Ex. 175 at 4.

JPMC Response: Disputed to the extent USVI misstates the document, the quoted text states, ” [Redacted] can meet have dinner lunch a weekend [sic] with any of the following seth lloyd mit quantum computing.. [sic] [Redacted] gell-man , santa- fe institute, quarks ,, [sic] brian [Redacted] columbia -string theory,, [sic] leonard susskind ,, [sic] strings theory, [Redacted] krause,, [sic] origins institute phoenix arizona.. [sic] lee smolin perimeter institute, loop quantum gravity , [sic] she can see the large hadron [sic] collider in switzerland. private tour.” USVI Ex. 270 at -844. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. [Redacted] Ex. 144 at -004.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture.

  1. On September 24, 2010, Staley forwarded an email chain between him, [REDACTED], and Staley’s wife, [REDACTED], regarding a professor at Columbia to Epstein, “can u [sic] get to this professor at Columbia?” Ex. 271 at -121; Ex. 144 at -004; Ex. 175 at 4. On September 25, 2010, Epstein responded, “in a snap.” Id.

JPMC Response: Disputed to the extent USVI misstates the quoted document. Staley’s wife’s [REDACTED] and the quoted email from Staley reads, “Can u get to this professor at Columbia?” USVI Ex. 274 at -121. Otherwise, undisputed.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. On December 12, 2008, Erdoes wrote to Staley regarding Bernie Madoff, ”… glenn and I have been going back and forth all night. This is terrible. Just terrible. [REDACTED] has over 1b. Nicole has another client with 1b. We have HUNDREDS of clients with some. The my/palm beach community will be in shock. Can you call JE to get scoop from down there?” Ex. 272 at -627.

JPMC Response: Undisputed that the cited document contains the quoted text. USVI Ex. 272 at -627.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. On April 7, 2023, in a CNN interview Jamie Dimon, in response to a question about whether “JPMorgan should have acted more quickly after Epstein pleaded guilty to one of these charges in 2008” said “Hindsight is a fabulous gift.” Ex. 273 at 21.

JPMC Response: Undisputed that Dimon provided the quoted response. USVI Ex. 273 at 21.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF ¶¶ 170-175.

  1. In the same CNN interview, Jamie Dimon was asked, Idle U.S. Virgin Islands is] alleging that your bank helped facilitate payments to Epstein’s victims and benefited from human trafficking while ignoring warnings. Do those allegations have merit?” Dimon responded, “[W]e have some of the best lawyers in the world—compliance, out of the DOJ, out of SEC important divisions who review all of these things and make decisions at the tune based on what they know, as best as they know.” Ex. 273 at 20.

JPMC Response: Undisputed that Dimon provided the quoted response. USVI Ex. 273 at 20.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating in Epstein’s alleged sex-trafficking venture. See CSMF 170-175.

JPMorgan Obstructed Enforcement of the TVPA

  1. Shaun O’Neill, former Special Agent with the Federal Bureau of Investigations (“FBI”), states that “the FBI relies on financial institutions as a key partner to .. . obtain the information necessary to answer the questions of who, what, when, where, and why.” Er. 274 at 17. The information in JPMorgan’s possession “warranted a constant stream of information from JPMC to the FBI about Epstein’s .. Human trafficking is an ongoing crime, with harm incurred every day that the crime continues.” Id. at 18. “It shocks the conscience that it was not until Epstein’s death in prison that JPMC suddenly recognized Epstein’s prior banking transactions as Id. at 25. O’Neikfiather states that “When it became public that Jeffrey Epstein had been arrested and that he had used cash to commit his sexual crimes against children, JPMC’s impaired the government’s ability to prosecute the crimes that it was investigating against Epstein.” Id. Further, —“the sheer amount of cash being dispersed,”

“more than $3 million was paid by Epstein to women, many of whom had Eastern European surnames,” and Epstein’s loan to modeling agency MC2—“Epstein would have been federally charged at a much earlier date.” Id. at 18-21 “Had the FBI been notified of this banking activity all being related to Epstein … [Epstein] would not have been able to continue his criminal activity from 2008 onward.” Id. at 20-21.

JPMC Response: Disputed. JPMC does not dispute that the quoted text is included in the report of USVI’s proffered expert Shaun O’Neill. However, JPMC dis utes the underl • conclusions and O’Neill’s misstatement of the record.

ee JPMC Exs. 42. 43. 44. 45. 46. 47. 48.

PMC Ex. 80 at 59:8-60:10. I

See JPMC Ex. 81

1

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan obstructed enforcement of the TVPA. See CSMF ‘f¶ 176-179. Further contended that the cited material cannot be presented at trial in admissible form.

Ex. 275 at -683.

See USVI Ex. 421 at -683 Id. (emphasis added)).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan obstructed enforcement of the TVPA. See CSMF ¶¶ 176-179. Further contended that the cited material cannot be presented at trial in admissible form.

  1. [Redacted]

[Redacted] Ex. 276 at -422.

JPMC Response: Undisputed that the cited document contains the quoted language. USVI Ex. 276 at -422.

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan obstructed enforcement of the TVPA. See CSMF ¶¶ 176-179.

  1. In 2019, Brunel was arrested and charged with rape of minors and sexual harassment and was under investigation for human trafficking. Ex. 277.

JPMC Response: Disputed. Brunel was arrested in December 2020, not 2019. See USVI Ex. 277; JPMC Ex. 82 (“Brunel was arrested at Paris Charles de Gaulle Airport in December 2020 on counts of “rape and sexual assault, rape and sexual assault on a minor under 15, rape and sexual assault on a minor over 15, sexual harassment, criminal associations and human trafficking to the detriment of minor victims for the purposes of sexual exploitation.”)).

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan obstructed enforcement of the TVPA. See CSMF ¶¶ 176-179. Further contended that the cited material cannot be presented at trial in admissible form.

  1. [Redacted]

Ex. 69 at -545.

USVI Ex. 69 at -545-550. [Redacted] See USVI Ex. 69 at -545; JPMC Ex. 83 [Redacted]

Disputed insofar as USVI contends that this fact supports an inference that JPMorgan obstructed enforcement of the TVPA. See CSMF ¶¶ 176-179.

Facts Concerning Epstein’s Registration as a Sex Offender in the Virgin Islands

  1. Shani Pinney, coordinator for the sex offender registry, and former Attorney General Vincent Frazer both testified that they were not responsible for and did not enable Epstein’s crimes. Ex. 278 at 266:17-268:8; Ex. 280 at 12:9-21, 455:24-456:20.

JPMC Response: Undisputed that Pinney and Frazer testified as such. Disputed that such testimony establishes as a legal conclusion that they “were not responsible for and did not enable Epstein’s crimes.” See, e.g., CSMF ¶¶ 261-288, 290-320.

  1. Epstein never failed to register as a sex offender. Ex. 280 at 85:2-87:2; 442:15-17.

JPMC Response: Undisputed that Pinney testified that Epstein never failed to register in the USVI. See USVI Ex. 280 at 442:15-17.

  1. Shani Pinney, coordinator for the sexual offender registry, testified that news reports were not sufficient basis to initiate an investigation because they did not contain the requisite “concrete allegations” of wrongdoing. Ex. 280 at 12:9-21; 415:1-20; 446:5-447:9; 447:16-449:1.

JPMC Response: Undisputed that Pinney testified as such. Disputed as to the underlying fact that news reports were not sufficient basis to initiate an investigation into Epstein. See CSMF ¶¶ 252-255.

  1. Former Attorney General Denise [REDACTED] similarly testified that she couldn’t rely on “news reports,” “rumor” or “innuendo” to initiate an investigation into Epstein. Ex. 282 at 167:3-170:3.

JPMC Response: Undisputed that [REDACTED] testified as such. USVI Ex. 282 at 167:3-170:30. Disputed as to the underlying fact that news reports, rumor, or innuendo could not be used to initiate an investigation into Epstein. See CSMF ¶¶ 252-55, 257-58.

  1. As witnesses testified, absent an actual complaint from a victim or eyewitness evidence brought to the Department of Justice’s attention, the Department could not initiate investigations. Ex. 280 at 415:1-20; 446:5-447:9; 447:16-449:1; Ex. 282 at 167:3-170:3.

JPMC Response: Undisputed that Pinney and [REDACTED] testified as such. Disputed as to the underlying fact that absent an actual complaint from a victim or eyewitness evidence brought to the Department of Justice’s attention, the Department could not initiate investigations. See CSMF ¶¶ 255, 257-58. Further disputed that the USVI lacked actual complaints from a victim or eyewitness. See CSMF ¶¶ 244-48, 251, 315.

  1. Ms. Pinney and Attorney [REDACTED] both confirmed they received no concrete complaints of misconduct by Epstein. Ex. 280 at 206:6-208:17; Ex. 282 at 164:3-167:2.

JPMC Response: Undisputed that Pinney and [REDACTED] testified as such. Disputed insofar as USVI contends that the cited testimony establishes that the USVI lacked sufficient evidence to investigate Epstein or that no information about Epstein’s misconduct ever reached USVI officials. See SUMF ¶¶ 24, 26; CSMF ¶¶ 244-55.

  1. Upon assuming her role as Attorney General, Attorney [REDACTED] inquired of various agencies to confirm whether they had received any complaints regarding Epstein. She found no evidence that any complaints had been received. Ex. 282 at 164:3-167:2.

JPMC Response: Undisputed that [REDACTED] testified that she inquired with the local VIPD and the USVI Department of DOJ as part of a general “inquiry to find out do we have cases? Do we have a record of … anyone complaining about seeing something that looked suspicious on Little St. James or – or with respect to Jeffrey Epstein in particular.” USVI Ex. 282 at 164:16-165:5. Disputed to the extent USVI suggests that [REDACTED] inquired about Epstein with any other agencies. See id. at 165:5-13 (“I didn’t [inquire] with the federal authorities who were also there because they’re – you know, they’re not going to disclose if there’s a pending investigation or anything like that.”); see also CSMF ¶¶ 253, 257.

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