{"efta_number": "EFTA02807143", "page_count": 30, "url": "https://epstein-data.com/EFTA02807143", "pdf_url": "https://epstein-data.com/pdf/EFTA02807143.pdf", "pages": [{"efta_number": "EFTA02807143", "page_number": 0, "text_content": "Case 1 22-cv-10904-JSR Document 124 Filed 04/24/23 Page 1 of 30\n\nIN THE UNITED STATES DISTRICT COURT\nFOR THE SOUTHERN DISTRICT OF NEW YORK\nGOVERNMENT OF THE UNITED\nSTATES VIRGIN ISLANDS,\nPlaintiff,\nv.\nJPMORGAN CHASE BANK, N.A.,\nDefendant/Third-Party\nPlaintiff.\n\nCase No. 22-cv-10904 (JSR)\n\nJPMORGAN CHASE BANK, N.A.,\nThird-Party Plaintiff,\nv.\nJAMES EDWARD STALEY,\nThird-Party Defendant.\n\nDEFENDANT JPMORGAN CHASE BANK, N.A.'S\nANSWER TO SECOND AMENDED COMPLAINT\nAND STATEMENT OF AFFIRMATIVE DEFENSES\nDefendant JPMorgan Chase Bank, N.A. (\"JPMC\") hereby files its Answer and Statement\nof Affirmative Defenses to the Second Amended Complaint of Plaintiff Government of the\nUnited States Virgin Islands, Case No. 22-cv-10904 (JSR), ECF No. 119 (the \"SAC\"), as\nfollows:\nTo the extent the headings or jury demand in the SAC require a response, JPMC denies\nthe allegations contained therein.\nTo the extent the first un-numbered paragraph of the SAC requires a response, JPMC\nadmits that Plaintiff purports to bring this action under the specified statutes, but denies that\n1\n\nEFTA02807143\n\n", "char_count": 1082}, {"efta_number": "EFTA02807143", "page_number": 1, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 2 of 30\n\nPlaintiff is entitled to damages or any other relief. JPMC otherwise denies the allegations in that\nparagraph.\nPARTIES\nI.\n\nJPMC admits that the Attorney General of the United States Virgin Islands\n\npurports to bring this action as a parens pairiae action on behalf of the Plaintiff pursuant to the\nstatutes cited. JPMC denies that the Attorney General has the authority to bring this action and\ndenies that the claims brought in this action have any merit.\n2.\n\nBy order dated March 20, 2023, the Court dismissed Count Four and thus no\n\nresponse is required.\n3.\n\nJPMC lacks knowledge or information sufficient to form an opinion as to the truth\n\nof the allegations in the first sentence of paragraph 3, and on that basis denies them. The\nremaining allegations in paragraph 3 are conclusions of law and thus no response is required. To\nthe extent a response is required, JPMC denies the remaining allegations in paragraph 3.\n4.\n\nJPMC is a national bank chartered by the Office of the Comptroller of the\n\nCurrency, with its main office in New York, New York. JPMC denies the remaining allegations\nin paragraph 4.\n5.\n\nDenied.\n\n6.\n\nThe allegations in paragraph 6 purport to state conclusions of law or characterize\n\nthe contents of other allegations in the SAC and thus no response is required. JPMC respectfully\nrefers the Court to those specific allegations. To the extent a response is required, JPMC denies\nthe allegations.\n7.\n\nThe allegations in paragraph 7 are conclusions of law to which no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n\n2\n\nEFTA02807144\n\n", "char_count": 1666}, {"efta_number": "EFTA02807143", "page_number": 2, "text_content": "Case 1 22-cv-10904-JSR Document 124 Filed 04/24/23 Page 3 of 30\n\nJURISDICTION, VENUE, AND RELATED CASE\n8.\n\nJPMC admits that Plaintiff purports to bring this action pursuant to the statutes\n\nand regulations cited. JPMC denies that the claims brought in this action have any merit.\n9.\n\nThe allegations in paragraph 9 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC admits that this Court has subject-matter\njurisdiction over Plaintiff's sole surviving TVPA claim following the Court's March 20, 2023\norder and otherwise denies the allegations in paragraph 9.\n10.\n\nBy order dated March 20, 2023, the Court dismissed Plaintiff's Virgin Islands law\n\nclaims and thus no response is required. To the extent a response is required, JPMC denies the\nallegations in paragraph 10.\nII.\n\nThe allegations in paragraph 11 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC does not contest that the Court has personal\njurisdiction over JPMC as to the sole surviving claim following the Court's March 20, 2023\norder, but JPMC denies the remaining allegations in paragraph 11.\n12.\n\nThe allegations in paragraph 12 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC admits that the Court has accepted this case\nas related to the case cited, but denies the remaining allegations in paragraph 12.\nBACKGROUND\n13.\n\nThe allegations in paragraph 13 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC admits the allegations in paragraph 13.\n14.\n\nThe allegations in paragraph 14 purport to characterize the contents of federal\n\nstatutes and thus no response is required. JPMC respectfully refers the Court to the language of\nthose laws for a complete and accurate recitation of their contents. The allegations in paragraph\n\n3\n\nEFTA02807145\n\n", "char_count": 1917}, {"efta_number": "EFTA02807143", "page_number": 3, "text_content": "Case 1 22-cv-10904-JSR Document 124 Filed 04/24/23 Page 4 of 30\n\n14 are, moreover, conclusions of law to which no response is required. To the extent a response\nis required, JPMC denies the allegations in paragraph 14.\n15.\n\nAdmitted.\n\n16.\n\nThe allegations in paragraph 16 purport to characterize or quote from the contents\n\nof a public document and thus no response is required. To the extent a response is required,\nJPMC respectfully refers the Court to the document for a complete and accurate recitation of its\ncontents.\n17.\n\nThe first, second, and third sentences of paragraph 17 purport to characterize or\n\nquote from the contents of a public document and thus no response is required. JPMC\nrespectfully refers the Court to the document for a complete and accurate recitation of its\ncontents. The allegations in the fourth sentence of paragraph 17 are conclusions of law to which\nno response is required. To the extent a response is required, JPMC denies the allegations in the\nfourth sentence of paragraph 17.\n18.\n\nThe allegations in paragraph 18 purport to characterize or quote from the contents\n\nof a public document and thus no response is required. JPMC respectfully refers the Court to the\ndocument for a complete and accurate recitation of its contents.\n19.\n\nBy order dated March 20, 2023, the Court dismissed Plaintiff's CICO Act claims,\n\nand thus no response is required.\n20.\n\nJPMC lacks knowledge or information sufficient to form a belief as to the truth of\n\nthe allegations in paragraph 20, and on that basis denies them.\n21.\n\nThe allegations in paragraph 21 purport to characterize the contents of public\n\ndocuments. JPMC respectfully refers the Court to those documents for a complete and accurate\nrecitation of their contents. To the extent a response is required, JPMC lacks knowledge or\n\n4\n\nEFTA02807146\n\n", "char_count": 1828}, {"efta_number": "EFTA02807143", "page_number": 4, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 5 of 30\n\ninformation sufficient to form a belief as to the truth of the allegations in paragraph 21, and on\nthat basis denies them.\n22.\n\nJPMC lacks knowledge or information sufficient to form a belief as to the truth of\n\nthe allegations in paragraph 22, and on that basis denies them.\n23.\n\nThe allegations in paragraph 23 purport to characterize the contents of a document\n\nattached to the SAC and thus no response is required. JPMC respectfully refers the Court to that\ndocument for a complete and accurate recitation of its contents. The allegations in the second\nand third sentences of paragraph 23 are, moreover, conclusions of law to which no response is\nrequired. To the extent a response is required, JPMC lacks knowledge or information sufficient\nto form a belief as to the truth of the allegations in paragraph 23, and on that basis denies them.\n24.\n\nThe allegations in paragraph 24 purport to characterize the contents of a document\n\nattached to the SAC and thus no response is required. JPMC respectfully refers the Court to that\ndocument for a complete and accurate recitation of its contents. The allegations in paragraph 24\nare, moreover, conclusions of law to which no response is required. To the extent a response is\nrequired, JPMC lacks knowledge or information sufficient to form a belief as to the truth of the\nallegations in paragraph 24, and on that basis denies them.\n25.\n\nThe allegations in paragraph 25 purport to characterize the contents of a document\n\nattached to the SAC and thus no response is required. JPMC respectfully refers the Court to that\ndocument for a complete and accurate recitation of its contents. To the extent a response is\nrequired, JPMC lacks knowledge or information sufficient to form a belief as to the truth of the\nallegations in paragraph 25, and on that basis denies them.\n26.\n\nThe allegations in paragraph 26 purport to characterize the contents of a document\n\nattached to the SAC and thus\n... [truncated, 2087 chars — for the full page use /api/corpus/document/EFTA02807143/4 or ?id=EFTA02807143&page=4]", "char_count": 2087}, {"efta_number": "EFTA02807143", "page_number": 5, "text_content": "Case 1 22-cv-10904-JSR Document 124 Filed 04/24/23 Page 6 of 30\n\ndocument for a complete and accurate recitation of its contents. To the extent a response is\nrequired, JPMC lacks knowledge or information sufficient to form a belief as to the truth of the\nallegations in paragraph 26, and on that basis denies them.\n27.\n\nThe allegations in paragraph 27 are conclusions of law to which no response is\n\nrequired. To the extent a response is required, JPMC lacks knowledge or information sufficient\nto form a belief as to the truth of the allegations in paragraph 27, and on that basis denies them.\n28.\n\nThe allegations in paragraph 28 are conclusions of law to which no response is\n\nrequired. To the extent a response is required, JPMC lacks knowledge or information sufficient\nto form a belief as to the truth of the allegations in paragraph 28, and on that basis denies them.\n29.\n\nThe allegations in paragraph 29 purport to characterize the contents of a document\n\nattached to the SAC and thus no response is required. JPMC respectfully refers the Court to that\ndocument for a complete and accurate recitation of its contents. To the extent a response is\nrequired, JPMC lacks knowledge or information sufficient to form a belief as to the truth of the\nallegations in paragraph 29, and on that basis denies them.\n30.\n\nThe allegations in paragraph 30 purport to characterize the contents of a document\n\nattached to the SAC and thus no response is required. JPMC respectfully refers the Court to that\ndocument for a complete and accurate recitation of its contents. To the extent a response is\nrequired, JPMC lacks knowledge or information sufficient to form a belief as to the truth of the\nallegations in paragraph 30, and on that basis denies them.\n31.\n\nThe allegations in paragraph 31 purport to characterize the contents of a document\n\nattached to the SAC and thus no response is required. JPMC respectfully refers the Court to that\ndocument for a complete and accurate recitation of its contents. To\n... [truncated, 2044 chars — for the full page use /api/corpus/document/EFTA02807143/5 or ?id=EFTA02807143&page=5]", "char_count": 2044}, {"efta_number": "EFTA02807143", "page_number": 6, "text_content": "Case 1 22-cv-10904-JSR Document 124 Filed 04/24/23 Page 7 of 30\n\nrequired, JPMC lacks knowledge or information sufficient to form a belief as to the truth of the\nallegations in paragraph 31, and on that basis denies them.\n32.\n\nThe allegations in paragraph 32 are conclusions of law to which no response is\n\nrequired. To the extent a response is required, JPMC lacks knowledge of information sufficient\nto form a belief as to the truth of the allegations in paragraph 32, and on that basis denies them.\n33.\n\nThe allegations in paragraph 33 purport to characterize the contents of a document\n\nattached to the SAC and thus no response is required. JPMC respectfully refers the Court to that\ndocument for a complete and accurate recitation of its contents. To the extent a response is\nrequired, JPMC lacks knowledge or information sufficient to form a belief as to the truth of the\nallegations in paragraph 33, and on that basis denies them.\nALLEGATIONS\n34.\n\nDenied.\n\n35.\n\nJPMC lacks knowledge or information sufficient to form a belief as to the truth of\n\nthe allegations in paragraph 35, and on that basis denies them.\n36.\n\nJPMC lacks knowledge or information sufficient to form a belief as to the truth of\n\nthe allegations in paragraph 36, and on that basis denies them.\n37.\n\nJPMC lacks knowledge or information sufficient to form a belief as to the truth of\n\nthe allegations in paragraph 37, and on that basis denies them.\n38.\n\nJPMC admits that Epstein pled guilty to felony solicitation of prostitution and\n\nprocurement of minors to engage in prostitution, that he was sentenced to 18 months in jail, and\nthat he was required to register as a sex offender.\n39.\n\nThe allegations in paragraph 39 purport to characterize the contents of a public\n\ndocument, and thus no response is required. JPMC respectfully refers the Court to that\ndocument for a complete and accurate recitation of its contents. To the extent a response is\n7\n\nEFTA02807149\n\n", "char_count": 1942}, {"efta_number": "EFTA02807143", "page_number": 7, "text_content": "Case 1 22-cv-10904-JSR Document 124 Filed 04/24/23 Page 8 of 30\n\nrequired, JPMC lacks knowledge or information sufficient to form a belief as to the truth of the\nallegations in paragraph 39, and on that basis denies them.\n40.\n\nThe allegations in paragraph 40 purport to characterize or quote from the contents\n\nof public documents, and thus no response is required. JPMC respectfully refers the Court to\nthose documents for a complete and accurate recitation of their contents. To the extent a\nresponse is required, JPMC lacks knowledge or information sufficient to form a belief as to the\ntruth of the allegations in paragraph 40, and on that basis denies them.\n41.\n\nJPMC admits that Epstein maintained accounts at JPMC between 1998 and 2013,\n\nand denies the remaining allegations in paragraph 41.\n42.\n\nThe allegations in paragraph 42 purport to characterize the contents of financial\n\nrecords and thus no response is required. JPMC respectfully refers the Court to those records for\na complete and accurate recitation of their contents. The allegations in the first and second\nsentences of paragraph 42 are, moreover, conclusions of law and thus no response is required.\nTo the extent a response is required, JPMC denies the allegations in paragraph 42.\n43.\n\nDenied.\n\n44.\n\nThe allegations in paragraph 44 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent that a response is required,\nJPMC denies the allegations in paragraph 44.\n45.\n\nThe allegations in paragraph 45 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent that a response is required,\nJPMC denies the allegations in paragraph 45.\n\n8\n\nEFTA02807150\n\n", "char_count": 1920}, {"efta_number": "EFTA02807143", "page_number": 8, "text_content": "Case 1 22-cv-10904-JSR Document 124 Filed 04/24/23 Page 9 of 30\n\n46.\n\nThe allegations in paragraph 46 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent that a response is required,\nJPMC denies the allegations in paragraph 46.\n47.\n\nThe allegations in paragraph 47 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent that a response is required,\nJPMC denies the allegations in paragraph 47.\n48.\n\nThe allegations in paragraph 48 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent that a response is required,\nJPMC denies the allegations in paragraph 48.\n49.\n\nThe allegations in paragraph 49 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent that a response is required,\nJPMC denies the allegations in paragraph 49.\n50.\n\nThe allegations in paragraph 50 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent that a response is required,\nJPMC denies the allegations in paragraph 50.\n51.\n\nThe allegations in paragraph 51 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\n\n9\n\nEFTA02807151\n\n", "char_count": 1839}, {"efta_number": "EFTA02807143", "page_number": 9, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 10 of 30\n\ncomplete and accurate recitation of their contents. To the extent that a response is required,\nJPMC denies the allegations in paragraph 51.\n52.\n\nJPMC admits that James Staley was the CEO of JPMC's Asset Management line\n\nof business from 2001 to 2009 and from 2009 to 2013 was the CEO of JPMC's Investment\nBanking line of business. JPMC lacks knowledge or information sufficient to form a belief as to\nthe truth of the allegation that James Staley \"developed a close relationship with Epstein\" during\nthe time period alleged, and on that basis denies those allegations. JPMC denies the remaining\nallegations in paragraph 52.\n53.\n\nThe allegations in paragraph 53 purport to characterize or summarize documents,\n\nand thus no response is required. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent a response is required, JPMC\nadmits that James Staley exchanged emails with Epstein from Staley's JPMC email and other\nemail accounts between 2008 and 2012. JPMC lacks knowledge or information sufficient to\nform a belief as to the truth of the remaining allegations in paragraph 53, and on that basis denies\nthem.\n54.\n\nThe allegations in the first, second, and third sentences of paragraph 54 purport to\n\ncharacterize or quote from documents and thus require no response. JPMC respectfully refers\nthe Court to those documents for a complete and accurate recitation of their contents. To the\nextent that a response is required, JPMC lacks knowledge or information sufficient to form a\nbelief as to the truth of the allegations in the first, second, and third sentences of paragraph 54,\nand on that basis denies them. JPMC lacks knowledge or information sufficient to form a belief\nas to the truth of the allegations in the fourth sentence of paragraph 54, and on that basis denies\nthem.\n\n10\n\nEFTA02807152\n\n", "char_count": 1941}, {"efta_number": "EFTA02807143", "page_number": 10, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 11 of 30\n\n55.\n\nThe allegations in the first and second sentences of paragraph 55 purport to\n\ncharacterize or quote from documents and thus require no response. JPMC respectfully refers\nthe Court to those documents for a complete and accurate recitation of their contents. To the\nextent a response is required, JPMC lacks knowledge or information sufficient to form a belief as\nto the truth of the allegations in the first and second sentences of paragraph 55, and on that basis\ndenies them. JPMC lacks knowledge or information sufficient to form a belief as to the truth of\nthe allegations in the third sentence of paragraph 55, and on that basis denies them.\n56.\n\nThe allegations in paragraph 56 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent a response is required, JPMC\nlacks knowledge or information sufficient to form a belief as to the truth of the remaining\nallegations in paragraph 56, and on that basis denies them.\n57.\n\nThe allegations in paragraph 57 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents.\n58.\n\nThe allegations in paragraph 58 purport to characterize or quote from documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent a response is required, JPMC\nlacks knowledge or information sufficient to form a belief as to the truth of the allegations in\nparagraph 58, and on that basis denies them.\n59.\n\nThe allegations in paragraph 59 purport to characterize the contents of documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their \n... [truncated, 2029 chars — for the full page use /api/corpus/document/EFTA02807143/10 or ?id=EFTA02807143&page=10]", "char_count": 2029}, {"efta_number": "EFTA02807143", "page_number": 11, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 12 of 30\n\n60.\n\nThe allegations in paragraph 60 purport to characterize the contents of documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent a response is required, JPMC\nlacks knowledge or information sufficient to form a belief as to the truth of the allegations in\nparagraph 60, and on that basis denies them.\n61.\n\nThe allegations in paragraph 61 purport to characterize the contents of documents\n\nand thus require no response. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents.\n62.\n\nJPMC lacks knowledge or information sufficient to form a belief as to the\n\nallegations in the first and third sentences of paragraph 62, and on that basis denies them. JPMC\ndenies the allegations in the second sentence of paragraph 62.\n63.\n\nJPMC admits that in 2013 JPMC communicated to Epstein that JPMC decided to\n\nexit Epstein as a banking client. JPMC denies the remaining allegations in paragraph 63.\n64.\n\nJPMC lacks knowledge or information sufficient to form a belief as to the truth of\n\nthe allegations in paragraph 64, and on that basis denies them.\n65.\n\nThe allegations in paragraph 65 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n66.\n\nJPMC lacks knowledge or information sufficient to respond to the allegations in\n\nthe first and second sentences of paragraph 66, and on that basis denies them. The allegations in\nthe third sentence of paragraph 66 purport to characterize the contents of documents. JPMC\nrespectfully refers the Court to those documents for a complete and accurate recitation of their\ncontents. To the extent a response is required, JPMC lacks knowledge or information sufficient\n\n12\n\nEFTA02807154\n\n", "char_count": 1923}, {"efta_number": "EFTA02807143", "page_number": 12, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 13 of 30\n\nto form a belief as to the truth of the allegations in the third sentence of paragraph 66, and on that\nbasis denies them. JPMC denies the allegations in the fourth sentence of paragraph 66.\n67.\n\nJPMC lacks knowledge or information sufficient to respond to the allegations in\n\nthe first sentence of paragraph 67, and on that basis denies them. The allegations in the second\nand third sentences of paragraph 67 purport to characterize or quote from documents. JPMC\nrespectfully refers the Court to those documents for a complete and accurate recitation of their\ncontents. To the extent a response is required, JPMC lacks knowledge or information sufficient\nto form a belief as to the truth of the allegations in the second and third sentences of paragraph\n67, and on that basis denies them. JPMC denies the allegations in the fourth sentence of\nparagraph 67. The allegations in the fifth sentence of paragraph 67 purport to characterize,\nsummarize, or quote from a document attached to the SAC. JPMC respectfully refers the Court\nto the document for a complete and accurate recitation of its contents. To the extent a response\nis required, JPMC denies the allegations in the fifth sentence of paragraph 67.\n68.\n\nJPMC lacks knowledge or information sufficient to respond to the allegations in\n\nparagraph 68, and on that basis denies them.\n69.\n\nJPMC denies the allegations in the first sentence of paragraph 69. The allegations\n\nin the second sentence of paragraph 69 purport to characterize or quote from documents. JPMC\nrespectfully refers the Court to those documents for a complete and accurate recitation of their\ncontents. To the extent a response is required, JPMC denies the allegations in the second\nsentence of paragraph 69. JPMC denies the allegations in the third sentence of paragraph 69.\n70.\n\nJPMC admits that in 2013 JPMC communicated to Epstein that JPMC decided to\n\nexit Epstein as a banking client. JPMC denies the remai\n... [truncated, 2053 chars — for the full page use /api/corpus/document/EFTA02807143/12 or ?id=EFTA02807143&page=12]", "char_count": 2053}, {"efta_number": "EFTA02807143", "page_number": 13, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 14 of 30\n\n71.\n\nJPMC lacks knowledge or information sufficient to respond to the allegations in\n\nthe first sentence of paragraph 71, and on that basis denies them. The allegations in the second\nsentence of paragraph 71 purport to characterize the contents of other allegations in the SAC and\nthus no response is required. To the extent a response is required, JPMC respectfully refers the\nCourt to those specific allegations.\n72.\n\nJPMC lacks knowledge or information sufficient to respond to the allegations in\n\nthe first sentence of paragraph 72, and on that basis denies them. JPMC denies the allegations in\nthe second sentence of paragraph 72.\n73.\n\nThe allegations in paragraph 73 purport to characterize or quote from documents.\n\nJPMC respectfully refers the Court to those documents for a complete and accurate recitation of\ntheir contents. To the extent a response is required, JPMC denies the allegations in paragraph\n73.\n74.\n\nThe allegations in paragraph 74 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n75.\n\nJPMC denies the allegations in the first sentence of paragraph 75. The allegations\n\nin the second and third sentences of paragraph 75 are conclusions of law, and thus no response is\nrequired. To the extent a response is required, JPMC denies the allegations in the second and\nthird sentences of paragraph 75. The allegations in the fourth sentence of paragraph 75 purport\nto characterize or quote from a document. JPMC respectfully refers the Court to that document\nfor a complete and accurate recitation of its contents. To the extent a response is required, JPMC\ndenies the allegations in the fourth sentence of paragraph 75.\n76.\n\nThe allegations in paragraph 76 purport to characterize, summarize, or quote from\n\ndocuments. JPMC respectfully refers the Court to those documents for a complete and accurate\n\n14\n\nEFTA02807156\n\n", "char_count": 1979}, {"efta_number": "EFTA02807143", "page_number": 14, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 15 of 30\n\nrecitation of their contents. To the extent a response is required, JPMC denies the allegations in\nparagraph 76. The allegations in the last sentence of paragraph 76 also purport to characterize 31\nC.F.R. § 1010.620(bX3). JPMC respectfully refers the Court to the language of that regulation for\na complete and accurate recitation of its contents.\n77.\n\nThe allegations in paragraph 77 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n78.\n\nJPMC admits that in 2013 JPMC communicated to Epstein that JPMC decided to\n\nexit Epstein as a banking client. JPMC admits that, without admitting wrongdoing, it entered\ninto a consent order with the ACC in January 2013. The remaining allegations in paragraph 78\npurport to characterize, summarize, or quote from documents. JPMC respectfully refers the\nCourt to those documents for a complete and accurate recitation of their contents. To the extent\na response is required, JPMC denies the remaining allegations in paragraph 78.\n79.\n\nJPMC admits that in 2013 JPMC communicated to Epstein that JPMC decided to\n\nexit Epstein as a banking client. JPMC lacks knowledge or information sufficient to respond to\nthe remaining allegations in paragraph 79, and on that basis denies them.\n80.\n\nThe allegations in paragraph 80 purport to characterize, summarize, or quote from\n\ndocuments. JPMC respectfully refers the Court to those documents for a complete and accurate\nrecitation of their contents. To the extent a response is required, JPMC lacks knowledge or\ninformation sufficient to respond to the allegations in paragraph 80, and on that basis denies\nthem.\n81.\n\nThe allegations in paragraph 81 purport to characterize, summarize, or quote from\n\ndocuments. JPMC respectfully refers the Court to those documents for a complete and accurate\nrecitation of their contents. To the extent a response is required, JPMC lacks knowled\n... [truncated, 2025 chars — for the full page use /api/corpus/document/EFTA02807143/14 or ?id=EFTA02807143&page=14]", "char_count": 2025}, {"efta_number": "EFTA02807143", "page_number": 15, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 16 of 30\n\ninformation sufficient to respond to the allegations in paragraph 81, and on that basis denies\nthem.\n82.\n\nThe allegations in paragraph 82 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n83.\n\nThe allegations in paragraph 83 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n84.\n\nThe allegations in paragraph 84 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n85.\n\nThe allegations in paragraph 85 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n86.\n\nJPMC denies the allegations in the first, second, and third sentences of paragraph\n\n86. The allegations in the fourth sentence of paragraph 86 are conclusions of law and thus no\nresponse is required. To the extent a response is required, JPMC denies the allegations in the\nfourth sentence of paragraph 86.\n87.\n\nThe allegations in paragraph 87 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n88.\n\nThe allegations in paragraph 88 purport to characterize federal banking\n\nregulations. JPMC respectfully refers the Court to the language of those regulations for a\ncomplete and accurate recitation of their contents.\n89.\n\nThe allegations in paragraph 89 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n90.\n\nDenied.\n\n91.\n\nDenied.\n\n16\n\nEFTA02807158\n\n", "char_count": 1717}, {"efta_number": "EFTA02807143", "page_number": 16, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 17 of 30\n\n92.\n\nThe allegations in paragraph 92 purport to characterize or quote from the contents\n\nof documents, and thus require no response. JPMC respectfully refers the Court to those\ndocuments for a complete and accurate recitation of their contents.\n93.\n\nThe allegations in paragraph 93 purport to characterize or quote from a deposition\n\ntaken in this case, and thus no response is required. JPMC respectfully refers the Court to the\ntranscript of that deposition for a complete and accurate recitation of its contents.\n94.\n\nThe allegations in paragraph 94 purport to characterize or quote from documents,\n\nand thus no response is required. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents.\n95.\n\nThe allegations in paragraph 95 purport to characterize or quote from documents,\n\nand thus no response is required. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent a response is required, JPMC\ndenies the allegations in paragraph 95.\n96.\n\nThe allegations in paragraph 96 purport to characterize or quote from a deposition\n\ntaken in this case, and thus no response is required. JPMC respectfully refers the Court to the\ntranscript of that deposition for a complete and accurate recitation of its contents.\n97.\n\nJPMC denies the allegations in the first and second sentences of paragraph 97.\n\nThe allegations in the third sentence of paragraph 97 purport to characterize the contents of\ndocuments, and thus no response is required. JPMC respectfully refers the Court to those\ndocuments for a complete and accurate recitation of their contents.\n98.\n\nJPMC denies the allegations in the first sentence of paragraph 98. The remaining\n\nallegations in paragraph 98 purport to characterize or quote from documents, and thus no\n\n17\n\nEFTA02807159\n\n", "char_count": 1933}, {"efta_number": "EFTA02807143", "page_number": 17, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 18 of 30\n\nresponse is required. JPMC respectfully refers the Court to those documents for a complete and\naccurate recitation of their contents.\n99.\n\nThe allegations in the first, second, third, fourth, fifth, and sixth sentences of\n\nparagraph 99 purport to characterize or quote from documents, and thus no response is required.\nJPMC respectfully refers the Court to those documents for a complete and accurate recitation of\ntheir contents. JPMC lacks knowledge or information sufficient to respond to the allegations in\nthe seventh sentence of paragraph 99, and on that basis denies them.\n100. The allegations in paragraph 100 purport to characterize or quote from documents,\nand thus no response is required. JPMC respectfully refers the Court to those documents for a\ncomplete and accurate recitation of their contents. To the extent a response is required, JPMC\ndenies the allegations in paragraph 100.\n101.\n\nThe allegations in the first sentence of paragraph 101 purport to characterize or\n\nquote from documents, and thus no response is required. JPMC respectfully refers the Court to\nthose documents for a complete and accurate recitation of their contents. To the extent a\nresponse is required, JPMC denies the allegations in paragraph 101.\nCAUSES OF ACTION\nCOUNT ONE\nParticipating in a Sex-Trafficking Venture\nViolation of Trafficking Victims Protection Act\n18 U.S.C. §§ 1591(aX2), 1595(d) (Parens Patriae)\n102.\n\nJPMC repeats and reasserts each and every response to the allegations asserted in\n\nthe foregoing paragraphs with the same force and effect as if fully set forth herein.\n103.\n\nThe allegations in paragraph 103 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n\n18\n\nEFTA02807160\n\n", "char_count": 1829}, {"efta_number": "EFTA02807143", "page_number": 18, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 19 of 30\n\n104.\n\nThe allegations in paragraph 104 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n105.\n\nThe allegations in paragraph 105 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n106.\n\nThe allegations in paragraph 106 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n107.\n\nThe allegations in paragraph 107 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n108.\n\nThe allegations in paragraph 108 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n109.\n\nThe allegations in paragraph 109 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n110.\n\nThe allegations in paragraph 110 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n111.\n\nThe allegations in paragraph 111 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n112.\n\nThe allegations in paragraph 112 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n113.\n\nThe allegations in paragraph 113 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n114.\n\nThe allegations in paragraph 114 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n\n19\n\nEFTA02807161\n\n", "char_count": 1889}, {"efta_number": "EFTA02807143", "page_number": 19, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 20 of 30\n\n115.\n\nThe allegations in paragraph 115 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n116.\n\nThe allegations in paragraph 116 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n117.\n\nThe allegations in paragraph 117 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n118.\n\nThe allegations in paragraph 118 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n119.\n\nThe allegations in paragraph 119 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\nCOUNT TWO\nCriminal Activity—Participating, Directly or Indirectly, in a Sex-Trafficking Venture\nViolation of Trafficking Victims Protection Act, 18 U.S.C. § 1591(aX2),\nactionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act,\n14 V.I.C. §§ 604(e) and 605(a)\n120.\n\nJPMC repeats and reasserts each and every response to the allegations asserted in\n\nthe foregoing paragraphs with the same force and effect as if fully set forth herein.\n121.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n122.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n123.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n124.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n\n20\n\nEFTA02807162\n\n", "char_count": 1776}, {"efta_number": "EFTA02807143", "page_number": 20, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 21 of 30\n\n125.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n126.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n127.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n128.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n129.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\nCOUNT THREE\nCriminal Activity—Willfully Failing To Comply With Federal Banking Law,\nViolation of Bank Secrecy Act, 31 U.S.C. § 5322(a), as it incorporates\n31 C.F.R. § 1020320(a) and 31 C.F.R. § 1010.620, actionable under Virgin Islands\nCriminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 604(e) and 605(a)\n130.\n\nJPMC repeats and reasserts each and every response to the allegations asserted in\n\nthe foregoing paragraphs with the same force and effect as if fully set forth herein.\n131.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n132.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n133.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n134.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n\n21\n\nEFTA02807163\n\n", "char_count": 1507}, {"efta_number": "EFTA02807143", "page_number": 21, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 22 of 30\n\n135.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n136.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n137.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n138.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n139.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\nCOUNT FOUR\nUnfair Methods of Competition\nViolation of Virgin Islands Consumer Fraud\nand Deceptive Business Practices Act, I2A V.I.C. § 304\n140.\n\nJPMC repeats and reasserts each and every response to the allegations asserted in\n\nthe foregoing paragraphs with the same force and effect as if fully set forth herein.\n141.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n142.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n143.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n144.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n\n22\n\nEFTA02807164\n\n", "char_count": 1326}, {"efta_number": "EFTA02807143", "page_number": 22, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 23 of 30\n\n145.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\n146.\n\nBy order dated March 20, 2023, the Court dismissed this Count and thus no\n\nresponse is required.\nCOUNT FIVE\nObstruction of Enforcement of Trafficking Victims Protection Act\n19 U.S.C. §§ 1591(d),1595(d) (Parens Patriae)\n147.\n\nJPMC repeats and reasserts each and every response to the allegations asserted in\n\nthe foregoing paragraphs with the same force and effect as if fully set forth herein.\n148.\n\nThe allegations in paragraph 148 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n149.\n\nThe allegations in paragraph 149 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n150.\n\nThe allegations in paragraph 150 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n151.\n\nThe allegations in paragraph 151 purport to characterize the contents of public\n\ndocuments, and thus no response is required. JPMC respectfully refers the Court to the contents\nof those documents for a complete and accurate recitation of their contents. To the extent a\nresponse is required, JPMC admits the allegations in the second and third sentences of paragraph\n151. JPMC lacks knowledge or information sufficient to form a belief as to the truth of the first\nand fourth sentences of paragraph 151, and on that basis denies them.\n152.\n\nThe allegations in the first and third sentences of paragraph 152 are conclusions\n\nof law and thus no response is required. To the extent a response is required, JPMC denies the\nallegations in the first and third sentences of paragraph 152. JPMC denies the allegations in the\nsecond sentence of paragraph 152.\n23\n\nEFTA02807165\n\n", "char_count": 1936}, {"efta_number": "EFTA02807143", "page_number": 23, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 24 of 30\n\n153.\n\nThe allegations in paragraph 153 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n154.\n\nThe allegations in paragraph 154 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n155.\n\nThe allegations in paragraph 155 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n156.\n\nThe allegations in paragraph 156 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n157.\n\nThe allegations in paragraph 157 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n158.\n\nThe allegations in paragraph 158 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n159.\n\nThe allegations in paragraph 159 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n160.\n\nThe allegations in the first sentence of paragraph 160 are conclusions of law and\n\nthus no response is required. To the extent a response is required, JPMC denies the allegations\nin the first sentence of paragraph 160. JPMC denies the allegations in the second sentence of\nparagraph 160.\n161.\n\nJPMC denies the allegations in the first, second, third, and fourth sentences of\n\nparagraph 161. The allegations in the fifth sentence of paragraph 161 are conclusions of law and\nthus no response is required. To the extent a response is required, JPMC denies the allegations\nin the fifth sentence of paragraph 161.\n\n24\n\nEFTA02807166\n\n", "char_count": 1848}, {"efta_number": "EFTA02807143", "page_number": 24, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 25 of 30\n\n162.\n\nJPMC denies the allegations in the first and second sentences of paragraph 162.\n\nThe allegations in the third sentence of paragraph 162 are conclusions of law and thus no\nresponse is required. To the extent a response is required, JPMC denies the allegations in the\nthird sentence of paragraph 162.\n163.\n\nThe allegations in paragraph 163 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n164.\n\nThe allegations in paragraph 164 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n165.\n\nJPMC denies the allegations in the first sentence of paragraph 165. The\n\nallegations in the second sentence of paragraph 165 are conclusions of law and thus no response\nis required. To the extent a response is required, JPMC denies the allegations.\n166.\n\nThe allegations in paragraph 166 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n167.\n\nThe allegations in paragraph 167 are conclusions of law and thus no response is\n\nrequired. To the extent a response is required, JPMC denies the allegations.\n168. The allegations in paragraph 168 are conclusions of law and thus no response is\nrequired. To the extent a response is required, JPMC denies the allegations.\nREQUEST FOR RELIEF\nJPMC denies that the relief requested is appropriate or warranted.\nJURY DEMAND\nTo the extent the jury demand requires a response, JPMC denies the allegations contained\ntherein.\nAll allegations in the SAC not specifically admitted or otherwise answered are denied.\n25\n\nEFTA02807167\n\n", "char_count": 1745}, {"efta_number": "EFTA02807143", "page_number": 25, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 26 of 30\n\nDEFENDANT'S STATEMENT OF AFFIRMATIVE DEFENSES\nWithout assuming any burden of proof that it would not otherwise bear, JPMC asserts the\nfollowing defenses. JPMC reserves the right to assert further defenses that may be identified in\nthe course of further investigation, discovery, or litigation of this action.\nFIRST DEFENSE\nPlaintiffs claims arc barred in whole or in part by the applicable statute of limitations.\nSECOND DEFENSE\nJPMC's actions were in full compliance with applicable laws and regulations.\nTHIRD DEFENSE\nPlaintiffs claims are barred by the doctrine of res judicata.\nFOURTH DEFENSE\nPlaintiffs claims are barred by the doctrine of collateral estoppel.\nFIFTH DEFENSE\nPlaintiff's claims are barred by the doctrine of in pari delicto.\nSIXTH DEFENSE\nPlaintiffs claims are barred by the doctrine of unclean hands.\nSEVENTH DEFENSE\nPlaintiff's claims are barred by the doctrine of lathes.\nEIGHTH DEFENSE\nPlaintiffs damages, to the extent Plaintiff suffered any, should be barred or reduced in\naccordance with the doctrines of comparative and contributory negligence or fault.\nNINTH DEFENSE\nPlaintiffs damages, to the extent Plaintiff suffered any, are the result of the conduct of\nthird parties over whom JPMC exercises no control.\n26\n\nEFTA02807168\n\n", "char_count": 1323}, {"efta_number": "EFTA02807143", "page_number": 26, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 27 of 30\n\nTENTH DEFENSE\nPlaintiff's injuries and damages, if any were in fact sustained, were caused in whole or in\npart by the criminal acts of third parties not a party to this litigation.\nELEVENTH DEFENSE\nThe causes of action asserted and any damages claimed are barred in whole or in part\nbecause, to the extent that any agents or employees committed any actionable acts or omissions,\nsuch acts or omissions were committed outside the scope of authority conferred.\nTWELFTH DEFENSE\nThe causes of action asserted and any damages claimed are barred in whole or in part\nbecause any damage, loss, or liability alleged must be reduced, diminished, and/or barred in\nproportion to any wrongful conduct of persons or entities other than JPMC.\nTHIRTEENTH DEFENSE\nWith respect to Plaintiff's claims for punitive damages, JPMC asserts that any\ndetermination and enforceability of an award is limited by the common law ofNew York and the\nDue Process Clause of the Fourteenth Amendment of the United States Constitution, including\nBMW ofN. America v. Gore, 116 U.S. 1589 (1996);\n\nIndustries, Inc. v. Leatherman Tool\n\nGroup, Inc., 532 U.S. 424 (2001); State Farm Mutual Auto Insurance Co. v.\n\n, 538 U.S.\n\n408 (2003), and their progeny.\nFOURTEENTH DEFENSE\nPlaintiff lacks parens patriae standing to pursue its claim(s) under the TVPA.\nFIFTEENTH DEFENSE\nJPMC did not have knowledge, constructive or otherwise, of any venture which directly\nor indirectly violated 28 U.S.C. §§ 1591 or 1595.\n\n27\n\nEFTA02807169\n\n", "char_count": 1552}, {"efta_number": "EFTA02807143", "page_number": 27, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 28 of 30\n\nSIXTEENTH DEFENSE\nJPMC did not have knowledge, constructive or otherwise, that means of force, threats of\nforce, fraud, coercion, or any combination of such means would be used to cause any person to\nengage in a commercial sex act.\nSEVENTEENTH DEFENSE\nJPMC did not have knowledge, constructive or otherwise, that a person under the age of\n18 would be caused to engage in a commercial sex act.\nEIGHTEENTH DEFENSE\nAny knowledge on the part of James Staley (1) of any venture which directly or\nindirectly violated 28 U.S.C. §§ 1591 or 1595; (2) that means of force, threats of force, fraud,\ncoercion, or any combination of such means would be used to cause any person to engage in a\ncommercial sex act; or (3) that a person under the age of 18 would be caused to engage in a\ncommercial sex act, is not imputed to JPMC.\nNINETEENTH DEFENSE\nJPMC did not participate in any venture which directly or indirectly violated 28 U.S.C.\n§§ 1591 or 1595.\nTWENTIETH DEFENSE\nJPMC did not knowingly benefit from any participation in any venture which directly or\nindirectly violated 28 U.S.C. §§ 1591 or 1595.\nTWENTY-FIRST DEFENSE\nJPMC did not obstruct, attempt to obstruct, interfere with, or prevent enforcement of the\nTVPA.\n\n28\n\nEFTA02807170\n\n\n\n[═══ TRANSCRIPT ═══]\nCase 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 30 of 30  New York, NY 10007 (t) (212) 230-8800 (0 (212) 230-8888 boyd.johnson@wilmerhale.com robert.boone@wilmerhale.com hillary.chutter-ames@wilmerhale.com Attorneysfor .IPMorgan Chase Bank N.A.  30  EFTA02807172", "char_count": 1587}, {"efta_number": "EFTA02807143", "page_number": 28, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 29 of 30\n\nTWENTY-SECOND DEFENSE\nJPMC lacked the requisite intent to obstruct, attempt to obstruct, interfere with, or\nprevent enforcement of the TVPA.\nTWENTY-THIRD DEFENSE\nJPMC did not have any knowledge of any enforcement of the TVPA in connection with\nEpstein.\nTWENTY-FOURTH DEFENSE\nTo the extent it is found liable, JPMC reserves the right to seek indemnification from any\nparty and/or non-party so liable as a matter of law or by contractual right. Nothing contained\nherein shall be construed as a waiver of that right.\nTWENTY-FIFTH DEFENSE\nThe causes of action asserted and any damages claimed are barred in whole or in part\nbecause the statute sued upon is unconstitutionally vague and ambiguous.\n\nDated: April 24, 2023\n\nRespectfully submitted,\nWILMER CUTLER PICKERING\nHALE AND DORR LLP\nIs/ Felicia Ellsworth\nFelicia H. Ellsworth\nJohn J. Butts\n60 State Street\nBoston,\n02109\n(t) (617) 526-6000\n(0 (617) 526-5000\nfelicia.ellsworth@wilmerhale.com\njohn.butts@wilmerhale.com\nM.\nRobert L. Boone\nHillary Chutter-Ames\n7 World Trade Center\n250 Greenwich Street\n29\n\nEFTA02807171\n\n", "char_count": 1132}, {"efta_number": "EFTA02807143", "page_number": 29, "text_content": "Case 1:22-cv-10904-JSR Document 124 Filed 04/24/23 Page 30 of 30\n\nNew York, NY 10007\n(t) (212) 230-8800\n(0 (212) 230-8888\nboyd.johnson@wilmerhale.com\nrobert.boone@wilmerhale.com\nhillary.chutter-ames@wilmerhale.com\nAttorneysfor .IPMorgan Chase Bank N.A.\n\n30\n\nEFTA02807172\n\n", "char_count": 272}]}