Case 1:22-cv-10904-JSR Document 246 Filed 07/26/23 Page 1 of 148 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS Plaintiff, v. JPMORGAN CHASE BANK, N.A. Defendant/Third-Party Plaintiff. JPMORGAN CHASE BANK, N.A. Third-Party Plaintiff, v. JAMES EDWARD STALEY Third-Party Defendant. ) ) ) ) ) ) ) ) ) Case Number: I :22-ev- I 0904-J SR ) ) ) ) ) ) ) ) ) ) STATEMENT OF MATERIAL FACTS AS TO WHICH GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS CONTENDS THERE IS NO GENUINE DISPUTE Epstein Engaged in a Sex-Trafficking Venture I. In the May 26, 2023 class certification hearing, counsel for JPMorgan stated, "I think the way the Court could use those grand July findings would be to ascertain something not contested, which is Mr. Epstein was engaged in horrendous criminal activity, including sex trafficking. That's not something being contested at all by JPMorgan." Tr. Class Certification Hr'g at 19:3-7, Doe I v. JPMorgan Chase Bank, N.A., No. 22-cv-I0019 (S.D.N.Y. May 26, 2023); see also id. at 33:10-14 ("Your colleague has just acknowledged, as indeed JPMorgan has repeatedly, that they do not dispute,you do not dispute thatMr. Epstein was engaged in a longtime trafficking venture EFTA02812502