# IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
JANE DOE, individually and on behalf of all others similarly situated,

Plaintiff,


JPMORGAN CHASE BANK, N.A.

Defendant/Third-Party Plaintiff,


JAMES EDWARD STALEY

Third-Party Defendant.

GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS,

Plaintiff,


JPMORGAN CHASE BANK, N.A.

Defendant/Third-Party Plaintiff,


JAMES EDWARD STALEY

Third-Party Defendant.

Case Number: 1:22-cv-10019-JSR

Case Number: 1:22-cv-10904-JSR

# THIRD-PARTY DEFENDANT JAMES STALEY'S LOCAL RULE 56.1 STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF SUMMARY JUDGMENT
# I. PARTIES
- I. James E. "Jes" Staley (Mr. Staley) worked at JPMorgan Chase Bank, N.A. from 1979 to 2013 and held several senior positions in the later part of his tenure.

- 2. JPMorgan Chase Bank, N.A. (JPMorgan) is a national bank whose main office is located in Columbus, Ohio, as designated in its Articles of Association.

# II. STALEY'S TENURE AT JPMORGAN
- 3. Mr. Staley became head ofJPMorgan's Private Bank in 1999. Ex. 1, at 27:24-28:3.
- 4.
- 5. Ex. 2, at 45:18-47:8, 78:21-79:12. Ex. 2, at 45:18-50:14; 248:16-249:1.
- 6. Mr. Staley did not have a relationship with Epstein before meeting with him in or around 2000. Ex. 2, at 45:18-50:14.
- 7. Mr. Staley became CEO JPMorgan's Asset and Wealth Management division in 2001. Ex. 2, at 11.
- 8. Mr. Staley became CEO of JPMorgan's Investment Bank in 2009. Ex. 2, at 11:16-12:6.
- 9. Mr. Staley ended his employment with JPMorgan in January 2013. Ex. 3.
- 10. Epstein introduced Mr. Staley Ex. 2, at 86:19-88:4.
- II. Epstein introduced Mr. Staley Ex. 2, at 86:19-88:13.
- 12. Epstein introduced Mr. Staley Ex. 2, at 86:19-87:6.
- 13. Mr. Staley used his corporate email account to communicate with Epstein. Ex. 2, at 254:4-21, 385:5-12; Ex. 4, at -1998-2019.

## III. RELEVANT POLICIES AND PRACTICES AT JPMORGAN
14. At the relevant times, JPMorgan had policies implementing its Anti-Money Laundering (AML) and Sponsorship Policies known as the Anti-Money Laundering/Know Your Client Policy (KYC). Ex. 5, at -9752; Ex. 6, at -162-163.

15. The policy's principles included that:

16. The client sponsorship policy required generally that

Ex. 6, at -164.

Ex. 6, at -164-165; Ex. 7, at 57:25-58:10.

17. The due diligence outlined in the policy required that


[REDACTED] Ex. 6, at -164-167; Ex. 8, at 61:9-24; Ex. 9,
at-1937; Ex. 10, at 155:20-157:7.

18. [REDACTED]


[REDACTED] Ex. 6, at -0170; Ex. 8, at 79:14-80:2; Ex. 10, at 461:9-16;
Ex. 7, at 54:20-23. [REDACTED]

[REDACTED] Ex. 7, at 54:16-19; Ex. 11, at -570.

19. [REDACTED]

[REDACTED] Ex. 6, at -164; Ex. 12, at -576; Ex. 13, at -159.

20. JPMorgan had additional policies and procedures for clients who were designated “high
risk.” Ex. 11. [REDACTED]

21. [REDACTED]

[REDACTED] Ex. 6, at -170; Ex. 1, at 88:19-89:19.

22. Risk management and compliance also had account monitoring roles at least for high-risk clients. Ex. 11, at -571; Ex. 14, at -938-939. [REDACTED]

Ex. 11, at -571.

23. JPMorgan's policy for identifying and investigating unusual or suspicious activity instructed that [REDACTED]

[REDACTED] Ex. 9, at -134. [REDACTED]


[REDACTED] Ex. 9, at -134.

24. 15, at 25:22-26:4; Ex. 10, at 82:19-83:7; 100:1-102:19. Ex. 9, at -138; Ex. Ex. 15, at 27:5-16; Ex. 10, at 99:13-24. 10, at 485:8-486:24. Ex. 15, at 257:16-258:16; Ex. Ex. 10, at 104:11, 485:8-486:24.

25. Mr. Staley did not have responsibilities to conduct due diligence on any individual private banking clients while he was head of the Private Bank or Asset & Wealth Management, or CEO of the Investment Bank. Ex. 1, at 44:8-47:17.

26. Ex. 7, at 58:13-24.

27. Ex. 7, at 16:17-19:25; Ex. 16, at -617-622.

29.

Ex. 7, at 18:14-19:13; Ex. 17, 747:14-750:9; Ex. 18, at - 722-766; Ex. 19, at -008-011.

Ex. 20, at 180:15-24. Ex. 20, at 326:1-330:23.

# IV. JPMORGAN'S RELATIONSHIP WITH EPSTEIN
30. Ex. 21, at -203; Ex. 22, at 30:24- 31:9, 195:8-18; Ex. 71.

31. 32. Ex. 23. MI x. 24, at 6:17-8:8.

33. MN I.x. 25, at 7:22-25, 56:17-23; Ex. 12, at -577.

Ex. 26, at 11:12-17; Ex. 12, at -577.

35. Ex. 26, at 26:17-18.

36. Ex. 12, at -577. Ex. 12, at -577. 12, at -577. • Ex. 12, at -577. Ex. Ex. 12, at -577.

[REDACTED] Ex. 27, at -977; Ex. 28, at -554-555.

38. [REDACTED]

[REDACTED] Ex. 1, at 157:23-58:13.

39. [REDACTED]

[REDACTED] Ex. 68.

**V. JPMORGAN'S RESPONSE TO DEROGATORY INFORMATION REGARDING EPSTEIN**

40. Epstein was indicted in Florida state court for felony solicitation of prostitution on July 19, 2006. Ex. 30.

41. [REDACTED]

[REDACTED] Ex. 8, at 65:9-66:15; Ex. 31, at -285-288.

42. [REDACTED]

[REDACTED] Ex. 32. [REDACTED]

[REDACTED] Ex. 8, at 65:9-66:10.

43. Mr. Staley did not object to the determination of keeping Epstein solely as a banking client and on a reactive, client service basis. Ex. 8, at 386:5-390:2; Ex. 2, at 123:13-25.

44. Mr. Staley did not object to Epstein's designation as high-risk, nor did he ever ask anyone to change Epstein's high-risk designation. Ex. I, at 146:16-148:17.

46. Ex. 34, at - 787; Ex. 35; Ex. 36; Ex. 37; Ex. 38, at 133:5-17.

47. Ex. 37; Ex. 72, at -30-31.

48. Ex. 39, at - 305-306; Ex. 40, at -738-742; Ex. 41, at -038-041; Ex. 42, at -661-666; Ex. 43, at - 816-17; Ex. 44; Ex. 45, at -272-273; Ex. 46, at -30-31; Ex. 47, at -179-180.

49. Ex. 48, at -305; Ex. 49, at -761-762; Ex. 50, at -519-520; Ex. 51; Ex. 52, at -651-660; Ex. 53.

Ex. 33. Ex. 33.

50. Mr. Staley was unaware of Epstein's practice of withdrawing large amounts of cash. Ex. 2, at 30:12-31:3.

51. Ex. 3; Ex. 54, at -688-691.

52. [REDACTED]

Ex. 3; Ex. 55.

**VI. JPMORGAN INQUIRIES INTO EPSTEIN AND MR. STALEY**

53. In July 2019, Epstein was arrested on a sex-trafficking charge. Ex. 56, at iv.

54. [REDACTED]
[REDACTED] Ex. 57, at
9:2-11:15.

55. [REDACTED]
[REDACTED] Ex. 58; Ex.
4; Ex. 57, at 19:2-11, 38:18-40:1.

56. [REDACTED]
[REDACTED] Ex. 4,
at -2000, -2005.

57. [REDACTED]
[REDACTED] Ex. 61; Ex.
57, at 41:1-44:25.

58. [REDACTED]
[REDACTED] Ex. 57, at 37:18-38:2, 41:3-45:8; Ex. 61, at -702. [REDACTED]

[REDACTED] Ex. 59; Ex. 60; Ex. 29.

59. [REDACTED]

[REDACTED] Ex. 58; Ex. 4; Ex. 57,

at 19:2-11.

60. [REDACTED]


[REDACTED] Ex. 4, at -2005. [REDACTED]

Ex. 4, at -1998, -2000.

61. [REDACTED]

[REDACTED] Ex. 12, at -596; Ex. 62, at -903; Ex. 63,

at -548.

62. [REDACTED]

[REDACTED] Ex. 64, at -221-223; Ex. 57, at 22:21-23:4.

63. [REDACTED]


[REDACTED] Ex. 64,

at 221-223.

64. [REDACTED]

[REDACTED] Ex. 64, at -221-223.

65. [REDACTED]


[REDACTED] Ex. 64, at 221-223.

66. [REDACTED]


[REDACTED] Ex. 57, at 8:21-9:15.

67. [REDACTED]

[REDACTED] Ex. 65, at -725. [REDACTED]

[REDACTED] Ex. 65, at -725

68. [REDACTED]

[REDACTED] Ex. 61.

69. [REDACTED]

[REDACTED] EX. 66, at -580; Ex. 57, at 53:4-54:2.

70. [REDACTED] Ex. 17,

at 750:10-19; Ex. 7, at 20:17-20.

**VII. THE CURRENT LITIGATION**

71. JPMorgan did not sue Mr. Staley before 2023. Ex. 67.

- 72. JPMorgan sued Mr. Staley in 2023, after it was sued by the Government of the U.S. Virgin Islands and the Jane Doe plaintiff. Ex. 67.
- 73. The bank has identified seven instances starting in "late 2009 or early 2010" in which Mr. Staley allegedly "vouch[ed]" for Epstein's character and conduct. Ex. 68.
- 74. The alleged "vouching" lists Mr. Staley telling other bank employees things like "that he knew and trusted Epstein"; that Epstein "had paid his debt to society"; and that Mr. Staley had "a good relationship with him." Ex. 68.
- 75. The bank does not contend that Mr. Staley was aware of Jeffrey Epstein's alleged sex trafficking. Ex. 69.
- 76. Mr. Staley's asserted vouching for Epstein did not violate any policy at the bank. Ex. I, at 112:4-22.
- 77. The bank originally sought rcputational damages, but it has dropped any claim to such damages. Ex. 70, at 8-9.
- 78. JPMorgan seeks "the amount JPMorgan will pay to the [Doe class] to settle this action, in the amount of \$290,000,000.00." Ex. 70, at 9.

Date: August 25, 2023 Respectfully submitted,

By: Is/ Stephen L. Wohlgemuth

Brendan V. Jr. John M. McNichols Zachary K. Eden Schiffmann & CONNOLLY LLP 680 Maine Avenue SW Washington, DC 20024

Tel: (202) 434-5252

Fax: (202) 434-5029

bsullivan@wc.com

St hen L. Wohlgemuth

& CONNOLLY LLP

650 Fifth Avenue, Suite 1500

New York, NY 10019

Tel: (202) 434-5390

Fax: (202) 434-5029

swohlgemuth®wc.com

Counsel for Third-Party Defendant

James Edward Staley