EFTA00162265 C6ses4:222-2cv100904SBR Document86-6 Filed 01/13/23 Page 15 of 343 62. None of the emails between Epstein and Staley were flagged in connection with risk reviews of Epstein’s accounts. Moreover, JP Morgan allowed Staley to remain a decisionmaker on Epstein’s accounts. JP Morgan even tasked Staley to discuss the human trafficking allegations with Epstein. 63. In July 2013—several months after Staley left JP Morgan to join another financial institution—JP Morgan’s Compliance Officer terminated JP Morgan's relationship with Epstein. 64. At the time of Epstein’s death in 2019, Staley was the Chief Executive Officer of Barclays; however, Staley stepped down from that position in November 2021 after British 15 EFTA00162266 C6ses4:222-2cv100904SBR DDocument86-6 Filedi 01/13/23 Page 16 off 343 financial regulators concluded an investigation into Staley’s characterization of his relationship with Epstein. ## IV. JP Morgan Ignored Obvious Red Flags Relating to Epstein’s Accounts 65. Despite JP Morgan’s claims that it would closely monitor Epstein’s accounts, JP Morgan ignored numerous red flags related to Epstein’s accounts and failed to comply with federal banking regulations. 66. Between 2003 and 2013, Epstein and/or his associates used Epstein’s accounts to make numerous payments to individual women and related companies. Among the recipients of these payments were numerous women with Eastern European surnames who were publicly and internally identified as Epstein recruiters and/or victims. For example, Epstein paid more than $600,0000 to Jane Doe 1, a woman who—according to news reports contained in JP Morgan’s due diligence reports—Epstein purchased at the age of 14. Like other women who received payments from Epstein, Jane Doe 1 listed Epstein’s apartments on 66th Street in New York City as her address, which should have been a red flag to JP Morgan. 67. Epstein and/or his associates also made significant cash withdrawals and 95 foreign remittances with no known payee. For example, Hyperion Air, Inc.—the Epstein-controlled company that owned Epstein’s private jet—issued over $547,000 in checks payable to cash purportedly for “fuel expenses when traveling to foreign countries.” Additionally, between January 2012 and June 2013, Hyperion converted more than $120,000 into foreign currency. Many of these cash withdrawals either exceeded the $10,000 reporting threshold or were seemingly structured to avoid triggering the reporting requirement. This is particularly significant since it is well known that Epstein paid his victims in cash. SAC ¶ 100. 68. In addition, Epstein and/or his representatives appeared to be misusing JP Morgan 16 EFTA00162267 C6ss4:22-2vc1-00904SBRDdocument86-6 Filedi 01/13/23 Page 18 of 343 accounts for Epstein’s purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization’s charitable purpose. For example, Epstein and/or his representative used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims, and over $20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and , a firm owned by Epstein’s reportedly prior girlfriend. 69. Each of these red flags was serious; together, they suggest a pattern of potentially illegal conduct that should have prompted action by JP Morgan. ## V. Epstein Brought Additional High Net Worth Clients to JP Morgan 71. In addition to his own holdings with JP Morgan, Epstein helped, or promised to help, Staley recruit ultrawealthy clients to JP Morgan. A few examples are laid out below. 72. In 2004, Epstein introduced Staley to Glenn Dubin, the owner of Highbridge Capital Management—one of the country’s largest hedge funds. This laid the groundwork for JP 17 EFTA00162268 C6ses4:222vc100904SBRDDocument86-6 Filedi 01/10/23 Page 18 of 343 Morgan's acquisition of Highbridge—a move that helped catapult Staley’s career. 73. In 2011, Epstein and Staley had extensive discussions regarding the creation of a “very HIGH profile” donor advised fund (“DAF”), which is an investment account established to support charitable organizations, headed by the . Epstein pitched the DAF as an “exclusive club” with a minimum $100 million donation where JP Morgan would act as the fiduciary. 18 EFTA00162269 C6ses4:222:vc1-0099-4SBRD Document86-6 Filedi 01/10/23 Page 29 of 343 77. JP Morgan also seemingly did no due diligence on the nature of the various business entities for which it held accounts for Epstein, which appear to have no legitimate business purpose and, upon information and belief, were part of Epstein’s criminal enterprise in the Virgin Islands. 78. In January 2013—the year JP Morgan terminated Epstein’s accounts—the Office of the Comptroller of the Currency (“OCC”) entered into a consent order with JP Morgan regarding deficiencies in the bank’s overall program for BSA/AML compliance. The OCC found—consistent with the Government's findings here—that JP Morgan failed to develop adequate due diligence on customers and failed to comply with federal banking regulations. In fact, the OCC noted that JP Morgan “failed to identify significant volumes of suspicious activity”. $^{4}$ 79. After JP Morgan terminated Epstein's accounts, Epstein moved his accounts to 4 NYSDFS Consent Order at 2-4 (Jan. 14, 2013), https://www.occ.treas.gov/news-issuances/news-releases/2013/nr-occ-2013-8a.pdf. 19 EFTA00162270 C6ses4:222-2cv100904SBR Document86-6 Filedi 01/13/23 Page 21 off 343 Deutsche Bank from 2013 to 2018. 80. The New York State Department of Financial Services (“NYSDFS”) investigated Deutsche Bank for failures to monitor Epstein’s accounts. On July 6, 2020, the NYSDFS and Deutsche Bank entered into a Consent Order with a $150 million penalty, which stated, in relevant parts: a. “The Bank’s fundamental failure was that, although the Bank properly classified Mr. Epstein as high-risk, the Bank failed to scrutinize the activity in the accounts for the kinds of activity that were obviously implicated by Mr. Epstein’s past. The Bank was well aware not only that Mr. Epstein had pled guilty and served prison time for engaging in sex with a minor but also that there were public allegations that his conduct was facilitated by several named co-conspirators. Despite this knowledge, the Bank did little or nothing to inquire into or block numerous payments to named co-conspirators, and to or on behalf of numerous young women, or to inquire how Mr. Epstein was using, on average, more than $200,000 per year in cash.” b. “Whether or to what extent those payments or that cash was used by Mr. Epstein to cover up old crimes, to facilitate new ones, or for some other purpose are questions that must be left to the criminal authorities, but the fact that they were suspicious should have been obvious to Bank personnel at various levels. The Bank’s failure to recognize this risk constitutes a major compliance failure.” c. "These errors are unacceptable in the context of a major international bank 20 EFTA00162271 C6ses4:222-2cv100904SBR Document86-6 Filedi 01/13/23 Page 22 of 343 and inexcusable in the context of the heightened scrutiny that should have occurred in the monitoring of a high-risk customer.” 81. The NYSDFS also found fault with Deutsche Bank’s failure to obtain answers regarding Epstein’s use of his accounts to pay women with Eastern European surnames: “In a May 2018 email, a compliance officer submitted an inquiry . . . about payments to the accounts of women with Eastern European surnames at a Russian bank, and asking for an explanation of the purpose of the wire transactions and Epstein’s relationship with the counterparties.”5 82. JP Morgan’s failures to appropriately monitor Epstein’s accounts and comply with federal banking regulations are even more egregious than Deutsche Bank’s failures because JP Morgan failed to demonstrate even basic due diligence and continued its relationship with Epstein for over a decade, despite the glaring indications of criminal activity. ## VII. JP Morgan Fraudulently Concealed Its Continuing Violations 85. JP Morgan's continuous illegal conduct has caused repeated and continuous injury. 86. JP Morgan knew—including at the highest level of the bank—that Epstein was an extremely high-risk client. Between 2005 and 2013, there were myriad reports that Epstein sexually abused women and girls. In 2008, Epstein pled guilty to sexual offenses and registered as $$ ^{5} Id. \text{ at } 15. $$ 21 EFTA00162272 C6ses4:222:vc100904SBRDDocumenter86-6 Filedi 01/10/23 Page 23 of 343 a sex offender. Despite JP Morgan’s acknowledgement that it needed to closely monitor Epstein, JP Morgan ignored numerous red flags and failed to comply with federal banking regulations until years later after JP Morgan was no longer benefiting from Epstein’s business. 87. JP Morgan also engaged in a course of conduct aimed at fraudulently concealing its illegal conduct, including by failing to timely comply with federal banking regulations in order to profit from Epstein’s wealth and connections. 88. A key purpose of federal banking regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye to unusual cash transactions and wires and failed to carry out or follow up on basic due diligence and to timely comply with federal banking regulations, as required by the law. 90. Over more than a decade, JP Morgan clearly knew it was not complying with federal regulations in regard to Epstein-related accounts as evidenced by its too-little too-late efforts after Epstein was arrested on federal sex trafficking charges and shortly after his death, when JP Morgan belatedly complied with federal law. 91. The continued illegal conduct by JP Morgan has caused repeated and continuous injury. JP Morgan’s illegal conduct was not completed nor were all damages incurred until the wrongdoing ceased in August 2019 when JP Morgan began belatedly complying with federal banking regulations in regard to Epstein-related accounts. 22 EFTA00162273 C6ses4:222-2-cv1-0090-4JSBR Document 36-6 Filedi 01/13/23 Page 23 of 343 ## CAUSES OF ACTION ## COUNT ONE Participating in a Sex-Trafficking Venture Violation of Trafficking Victims Protection Act 18 U.S.C. §§ 1591(a)(2), 1595(d) (Parens Patriae) 92. The Government restates and realleges paragraphs 1 to 91 of this Complaint as if fully set forth herein. 93. The Government brings this Count as parens patriae on behalf of the residents and visitors of the United States Virgin Islands and pursuant to the Attorney General’s express statutory authority. 94. JP Morgan knowingly and intentionally participated in Epstein’s sex-trafficking venture that was in and affecting interstate and foreign commerce, together and with others, in violation of 18 U.S.C. § 1591(a)(2) by facilitating payments to women and girls, channeling funds to Epstein to fund the operation, and concealing Epstein’s criminal conduct by failing to comply with federal banking law. 95. JP Morgan knowingly and intentionally benefitted financially from and received value for its participation in the sex-trafficking venture in which Epstein and his co-conspirators, with JP Morgan’s knowledge or reckless disregard of the fact, would use means of force, threats of force, fraud, coercion, and a combination of such means to sexually abuse young women and underage girls, including by causing them to engage in commercial sex acts, in the Virgin Islands and elsewhere. 96. Among the financial benefits that JP Morgan received for participating in and facilitating Epstein’s sex-trafficking venture was the deposit of funds that Epstein—a Virgin Islands resident—and Epstein-controlled entities located in the Virgin Islands made to JP Morgan. JP Morgan profited from the use of these deposits. Epstein and Epstein-controlled entities located 23 EFTA00162274 C6ses4:222-2cv100904SBR Document 36-6 Filedi 01/13/23 Page 25 of 343 in the Virgin Islands deposited these funds in exchange for JP Morgan’s facilitation of and participation in Epstein's sex-trafficking venture. 97. Also, among the financial benefits that JP Morgan received for participating in and facilitating Epstein’s sex-trafficking venture were referrals of business opportunities from Epstein and his co-conspirators. JP Morgan profited from, or expected to profit from, these referred business opportunities. Epstein referred business entities and business opportunities to JP Morgan in exchange for its facilitation of and participation in Epstein’s sex-trafficking venture. 98. JP Morgan financially profited from the deposits made by Epstein and Epstein-controlled entities located in the Virgin Islands and from the business opportunities referred to JP Morgan by Epstein and his co-conspirators in exchange for its known facilitation of and implicit participation in Epstein’s sex trafficking venture. 99. JP Morgan knew and recklessly disregarded and concealed the fact that it was Epstein’s pattern and practice to use the channels and instrumentalities of interstate and foreign commerce to recruit, entice, harbor, transport, provide, obtain, and maintain young women and underage girls for purposes of causing them to engage in commercial sex acts in violation of 18 U.S.C. § 1591(a)(1). 100. JP Morgan and its employees had actual knowledge that they were facilitating Epstein’s sexual abuse and sex-trafficking conspiracy to recruit, entice, harbor, transport, provide, obtain, and maintain young women and underage girls to engage in commercial sex acts through the means of force, threats of force, fraud, abuse of process, and coercion. 101. Despite this knowledge, JP Morgan intentionally paid for, concealed, facilitated, and participated in Epstein’s and his co-conspirators’ violations of 18 U.S.C. § 1591(a), which JP Morgan knew and was in reckless disregard of the fact that Epstein and his co-conspirators would 24 EFTA00162275 C6ses4:222:vc100904SBRDDocument86-6 Filedi 01/10/23 Page 26 of 343 use its bank accounts and financial transactions to coerce, defraud, and force young women and underage girls to engage in commercial sex acts. 102. JP Morgan, through its employees and agents and their role in facilitating the financial aspect of Epstein’s enterprise, actively facilitated or participated in the sex-trafficking conspiracy in which Epstein and his co-conspirators led young women and underage girls in the Virgin Islands and elsewhere to believe that they would be rewarded if they cooperated with Epstein and his co-conspirators and acquiesced to their demands. 103. JP Morgan committed this affirmative conduct knowing or in reckless disregard of the fact that Epstein would use cash transactions and financial support provided by JP Morgan as a means to defraud, force, and coerce commercial sex acts from young women and underage girls. 104. In addition to having actual knowledge that it was participating in and facilitating the Epstein sex-trafficking venture, JP Morgan also knew that it was participating in and facilitating a venture that was engaged in coercive sex trafficking in violation of 18 U.S.C. § 1591(a)(1). 105. In exchange for facilitating and covering up Epstein’s commercial sex trafficking, JP Morgan's employees received financial benefits and career advancement from JP Morgan. 106. Facilitating and covering up Epstein’s sex trafficking venture was a means for JP Morgan employees to obtain economic success and promotion within JP Morgan. 107. JP Morgan’s knowing and intentional conduct has caused serious harm to the Virgin Islands and its residents, including without limitation financial harm, by facilitating the commission of sexual abuse against young women and underage girls, including their engagement in commercial sex acts, in the Virgin Islands. 25 EFTA00162276 C6ses4:222-2-cv1-0090-4JSBR Document 36-6 Filedi 01/13/23 Page 26 off 343 108. JP Morgan’s tortious conduct in violating the TVPA was outrageous and intentional because it was in deliberate furtherance of a widespread and dangerous criminal sex-trafficking venture operated in and from the Virgin Islands. JP Morgan’s tortious conduct also evidenced a high degree of moral turpitude and demonstrated such wanton disregard for the safety of young women and underage girls in the Virgin Islands and elsewhere as to imply a deliberate indifference to its legal obligations. 109. By virtue of these knowing and intentional violations of 18 U.S.C. § 1591(a)(2), JP Morgan is liable to the Government for all appropriate relief under 18 U.S.C. § 1595(d), including damages suffered by the Government and/or Epstein’s victims, punitive damages, restitution, appropriate injunctive relief, fines, reasonable attorneys’ fees, and all such other relief as the Court deems appropriate. COUNT TWO ## Criminal Activity—Participating, Directly or Indirectly, in a Sex-Trafficking Venture Violation of Trafficking Victims Protection Act, 18 U.S.C. § 1591(a)(2), actionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 604(e) and 605(a) 110. The Government restates and realleges paragraphs 1 to 109 of this Complaint as if funny set forth herein. 111. The Virgin Islands Legislature enacted the CICO Act with the purpose to “curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies.” 14 V.I.C. § 601. 112. At all times material herein, JP Morgan was a “person” identified in 14 V.I.C. § 604(1). 26 EFTA00162277 C6ses4:222vc100904SBRDDocumenter86-6 Filedi 01/10/23 Page 28 of 343 113. At all times material herein, Epstein and his co-conspirators were engaged in an illicit sex-trafficking “enterprise” as defined in 14 V.I.C. § 604(h). 114. At all times material herein, JP Morgan supported and/or was associated with the Epstein sex-trafficking enterprise by providing banking and payment-processing services to Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or incorporated in the Virgin Islands. 115. In providing banking and payment-processing services to Epstein and Epstein-controlled entities in return for profits realized both from Epstein’s and Epstein-controlled entities’ accounts and from receiving referrals by Epstein of other high-value banking clients, JP Morgan knowingly, intentionally, and willfully benefitted financially and by receiving things of value from its participation, directly or indirectly, in Epstein’s sex-trafficking venture and enterprise, in violation of 18 U.S.C. § 1591(a)(2). 116. JP Morgan’s knowing, intentional, and willful receipt of financial benefits and things of value from its facilitation and participation in Epstein’s sex-trafficking venture and enterprise through the financial infrastructure it provided and concealed constitutes a felony under 18 U.S.C. § 1591(b) and “criminal activity” as defined in 14 V.I.C. § 604(e). 117. By knowingly, intentionally, and willfully receiving financial benefits and things of value from its participation, directly or indirectly, via financing in Epstein’s sex-trafficking venture and enterprise, JP Morgan enabled Epstein to have ready and reliable access to and use of resources with which to recruit, entice, harbor, transport, provide, obtain, and maintain young women and underage girls for purposes of causing them to engage in commercial sex acts in the Virgin Islands and elsewhere. JP Morgan thereby unlawfully conducted and/or participated in, 27 EFTA00162278 C6ses4:222-2cv100904JSBR Document 36-6 Filedi 01/13/23 Page 28 of 343 directly or indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal activity in violation of 14 V.I.C. § 605(a). 118. JP Morgan’s illegal activity has caused serious harm to the Virgin Islands and its residents, including without limitation financial harm, by facilitating the commission of sexual abuse against young women and underage girls, including their facilitation and participation, directly or indirectly, in commercial sex acts, in the Virgin Islands. 119. By virtue of this pattern of illegal activity in furtherance of the Epstein sextrafficking enterprise, JP Morgan is liable to the Government for all appropriate civil remedies under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein’s victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive relief, attorneys’ fees and costs, and all such other relief as the Court deems appropriate. COUNT THREE Criminal Activity—Willfully Failing To Comply With Federal Banking Law, Violation of Bank Secrecy Act, 31 U.S.C. § 5322(a), as it incorporates actionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 604(e) and 605(a) 120. The Government restates and realleges paragraphs 1 to 119 of this Complaint as if fully set forth herein. 121. The Virgin Islands Legislature enacted the CICO Act with the purpose to “curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies.” 14 V.I.C. § 601. 122. At all times material herein, JP Morgan was a “person” as defined in 14 V.I.C. § 604(1). 28 EFTA00162279 C6ses4:22-2vc1-00994SBRDdocumenter36-6.Filedi 01/10/23.Page 29 off 343 123. At all times material herein, Epstein and his co-conspirators were engaged in an illicit sex-trafficking “enterprise” as defined in 14 V.I.C. § 604(h). 124. At all times material herein, JP Morgan was employed by and/or associated with the Epstein sex-trafficking enterprise by providing banking and payment-processing services to Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or incorporated in the Virgin Islands. 125. In providing banking and payment-processing services to Epstein and Epstein-controlled entities, JP Morgan knowingly, intentionally, and willfully failed to comply with federal banking regulations in violation of 31 U.S.C. § 5322(a), Epstein and Epstein-controlled entities received payments of large dollar amounts for no apparent business or other lawful purpose and made repeated cash payments, sometimes in amounts and patterns designed to evade federal reporting requirements, to young women and/or underage girls who were sexually abused and coerced into engaging in commercial sexual acts in the Virgin Islands and elsewhere. 126. JP Morgan’s knowing, intentional, and willful failure to comply with federal banking regulations constitutes a felony under 31 U.S.C. § 5322(a) and “criminal activity” as defined in 14 V.I.C. § 604(e). 29 EFTA00162280 C6ses4:222vc100904SBRDDocument86-6 Filedi 01/10/23 Page 30 of 343 127. By knowingly, intentionally, and willfully failing to comply with federal banking regulations, JP Morgan enabled Epstein to have ready and reliable access to and use of resources with which to recruit, entice, harbor, transport, provide, obtain, and maintain young women and underage girls for purposes of causing them to engage in commercial sex acts in the Virgin Islands and elsewhere. JP Morgan thereby unlawfully conducted and/or participated in, directly or indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal activity in violation of 14 V.I.C. § 605(a). 128. JP Morgan’s illegal activity has caused serious harm to the Virgin Islands and its residents, including without limitation financial harm, by facilitating the commission of sexual abuse against young women and underage girls, including their engagement in commercial sex acts, in the Virgin Islands. 129. By virtue of this pattern of illegal activity in furtherance of the Epstein sex-trafficking enterprise, JP Morgan is liable to the Government for all appropriate civil remedies under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein’s victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive relief, attorneys’ fees and costs, and all such other relief as the Court deems appropriate. ## COUNT FOUR Unfair Methods of Competition Violation of Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. § 304 130. The Government restates and realleges paragraphs 1 to 129 of this Complaint as if fully set forth herein. 131. Section 304 of Title 12A of the Virgin Islands Code provides that “[i]t is unlawful for any person to engage in unfair methods of competition . . . in the conduct of any trade or commerce.” 30 EFTA00162281 C6ses4:222-2-cv1-0090-4JSBR Document 36-6 Filedi 01/13/23 Page 32 of 343 132. JP Morgan is a “person” as defined in 12A V.I.C. § 303(h). 133. JP Morgan’s provision of banking services and payment processing for Epstein and Epstein-controlled entities constitutes “[t]rade or commerce” as defined in 12 V.I.C. § 303(k). 134. In return for knowingly and intentionally participating in, directly or indirectly, facilitating, and concealing by failing to comply with federal banking regulations regarding Epstein-related accounts, JP Morgan both profited from the use of the funds in their accounts and received referrals of other high-value business opportunities from Epstein and his co-conspirators. 135. By receiving referrals of high-value business opportunities from Epstein and his co-conspirators in return for participating in, directly or indirectly, facilitating, and concealing by failing to comply with federal banking regulations regarding Epstein-related accounts, JP Morgan unlawfully and unjustly enriched itself at the expense of other banks that complied with their legal obligations. This conduct constitutes an unfair method of competition in violation of 12A V.I.C. § 304. 136. By virtue of its knowing, intentional, and repeated acts constituting unfair competition, JP Morgan is liable to the Government for all appropriate civil remedies under 12A V.I.C. §§ 328 and 332, including damages, civil penalties awarded on a per-violation basis pursuant to 12A V.I.C. § 328(b), appropriate injunctive relief, attorneys’ fees and costs, and all such other relief as the Court deems appropriate. ## REQUEST FOR RELIEF The Government respectfully requests that the Court enter judgment in its favor, and against JP Morgan, as follows: 31 EFTA00162282 C6ses4:222vc100904SBRDDocumenter86-6 Filedi 01/10/23 Page 32 of 323 A. That the Court award the Government compensatory, consequential, general, and nominal damages, as suffered by the Government and/or Epstein’s victims, and punitive damages, all against JP Morgan in amounts to be awarded at trial; B. That the Court award the Government punitive and exemplary damages against JP Morgan in an amount to be determined at trial; C. That the Court order JP Morgan to pay appropriate fines to the Government pursuant to 18 U.S.C. § 1591(b) in amounts to be determined at trial; D. That the Court order JP Morgan to provide restitution of all ill-gotten gains to the Government pursuant to 18 U.S.C. § 1593 and 14 V.I.C. § 607(a)(6) and pursuant to 14 V.I.C. § 608(c)(4) to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of the CICO Act, in amounts to be determined at trial; E. That the Court award the Government treble damages against JP Morgan pursuant to 14 V.I.C. § 607(c) in an amount to be determined at trial; F. That the Court order JP Morgan to pay appropriate civil penalties to the Government pursuant to 14 V.I.C. § 607(e) and 12A V.I.C. § 328(b) and pursuant to 14 V.I.C. § 608(c)(4) to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of the CICO Act, in amounts to be determined at trial; G. That the Court enter an injunction pursuant to 14 V.I.C. § 607(a)(2) and 12A V.I.C. § 328(a)(2) to prevent further illegal conduct and any concealment of illegal conduct; 32 EFTA00162283 C6ses4:222-2-cv1-0090-4JSBR Document 36-6 Filedi 01/13/23 Page 33 of 343 H. That the Court order JP Morgan to provide disgorgement of all ill-gotten gains to the Government pursuant to 14 V.I.C. § 607(a)(6) and pursuant to 14 V.I.C. § 608(c)(4) to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of the CICO Act, in amounts to be determined at trial; I. That the Court award the Government attorneys’ fees and costs pursuant to 18 U.S.C. § 1595, 14 V.I.C. § 607(c), and 12A V.I.C. § 332 in amounts to be determined after trial; and J. That the Court award the Government and order JP Morgan to provide all such other relief as the Court deems appropriate. ## JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL /s/David I.Ackerman # DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 dackerman@motleyrice.com ## CAROL THOMAS-JACOBS (NYS Bar #2941300) Admitted Pro Hac Vice Acting Attorney General of the United States Virgin Islands Virgin Islands Department of Justice 34-38 Kronprindsens Gade St. Thomas, U.S. Virgin Islands 00802 Tel.: (340) 774-5666 ext. 10101 carol.jacobs@doj.vi.gov 33 EFTA00162284 C6ses4:222-2cv100904SBR Document 36-6 Filed 01/10/23 Page 35 of 343 **LINDA SINGER** (NYS Bar #2473403) Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 lsinger@motleyrice.com PAIGE BOGGS Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 386-9629 pboggs@motleyrice.com 34