Epstein Data Wiki

JPMorgan Chase Bank, N.A.

Properties2
tagsentity, bank, private-bank, suspicious-activity-reports, usvi-litigation, class-action
aliasesJPMorgan Chase Bank, JPMorgan Chase, JP Morgan Chase, JPMorgan, JP Morgan, J.P. Morgan, JPMorgan Private Bank, J.P. Morgan Private Bank

23 min read

InstitutionNational banking association; its third-party complaint describes its main office as Columbus, Ohio, as designated in its Articles of Association1
Epstein relationshipJeffrey Epstein was a client of the Private Bank; the Virgin Islands government alleged the bank did business with him from as early as 1998 to 2013 and serviced about fifty-five Epstein-related accounts23
Suspicious activity reportsFiled on Epstein-related accounts in April 2002, December 2002, April 2003, 2008 and 201945678
ExitEpstein-associated accounts recorded in 2013 as “in the process of being exited”; Deutsche Bank’s counsel described a category of its production as the transfer of Epstein’s assets from JP Morgan from 2013 through 2014910
Criminal investigationResponded to grand jury subpoenas from the Southern District of New York issued August–October 2019, under a request for confidential treatment11
Doe v. JPMorgan22-cv-10019 (JSR), S.D.N.Y.; filed November 24, 2022; class certified June 12, 2023; recorded by the court as settled for $290 million1213
USVI v. JPMorgan22-cv-10904 (JSR), S.D.N.Y.; filed December 27, 2022; recorded by the court as settled for $75 million, case closed October 18, 2023113
Stockholder derivative actionNo. 1:23-cv-03903 (JSR), S.D.N.Y.; Verified Stockholder Derivative Complaint filed May 9, 2023 and amended June 30, 2023, naming JPMorgan Chase & Co. as nominal defendant1415
Third-party claimJPMorgan v. James Edward Staley, filed March 8, 2023; dismissed with prejudice under a confidential settlement of October 6, 2023116
Bank’s positionDenied liability and wrongdoing in both actions; said publicly that any association with Epstein “was a mistake and we regret it”1217

JPMorgan Chase Bank, N.A. is a United States national banking association whose Private Bank held accounts for Jeffrey Epstein and for companies and trusts associated with him.311 The Government of the United States Virgin Islands alleged in the Southern District of New York that the bank “knowingly, negligently, and unlawfully provided and pulled the levers through which recruiters and victims were paid and was indispensable to the operation and concealment of the Epstein trafficking enterprise”; JPMorgan denied liability and wrongdoing.212 The bank filed suspicious activity reports with the Financial Crimes Enforcement Network on Epstein-related accounts in 2002, 2003, 2008 and 2019, among them a report filed weeks after his 2008 guilty plea and one in 2019 covering 4,725 wire transactions.5678 A class action brought on behalf of Epstein’s victims was recorded by the court as settled for $290 million and the Virgin Islands action for $75 million, both in 2023.13 JPMorgan brought its own third-party claim against its former executive Jes Staley and dismissed it under a confidential settlement in October 2023.116

The Epstein accounts

A JPMorgan Private Bank Asset Account Portfolio statement for September 1–30, 2002, produced as Government Exhibit 504 in the Maxwell prosecution, is addressed to Jeffrey E. Epstein care of Financial Trust Company in St. Thomas, for the attention of Jeanne Brennan.3 In September 2020 the bank’s counsel produced to the Southern District of New York an index of the accounts on which it held wire data, grouped by the individual associated with each: accounts in the names of JEGE LLC and JEGE Inc., NES LLC, Neptune LLC, Plan D LLC, Hyperion Air, Southern Financial LLC, Southern Trust Company, Inc., the C.O.U.Q. Foundation, Enhanced Education, the Zorro Trust, the Haze Trust and the Butterfly Trust, among others.11 The letter explains that accounts listed under a further heading were associated with Epstein’s overall relationship with the firm although Epstein “did not necessarily have control of or access to those accounts”; Darren K. Indyke’s firm, HBRK Associates Inc. and New York Strategy Group appear under that heading.11

A JPMorgan client file produced under the confidential-treatment request records an account opening in 2007. On April 18 that year Melissa Dalton of the Private Bank’s client services group forwarded an application to a colleague, writing that the bank had received documents to open a new account for Plan D, Inc., that the account “will be linked with JEGE Inc., Hyperion Inc, and Jeffrey Epstein” and that “Rich Kahn is the controller.”18 An officer had answered sixteen minutes earlier that before he could process it he would “need a completed DDR and a CAS assigned. Once done, I can open the account.”18 The following morning Dalton put the outstanding questions back to the client side: a taxpayer identification number with a W-9, the net worth of the entity, its purpose, the sources and expected amounts of inflows and outflows, the sum with which the account would be funded, and “Is this entity 100% owned by Jeffrey Epstein? If so, can you verify it?”; a manuscript note beside the header reads “questions for DDR.”19 On April 27 Dalton told Richard Kahn that the back office “will have the new account set up by the end of today,” and he answered “Thank you” over a signature block for New York Strategy Group LLC at 457 Madison Avenue.20 The same client file also holds the operating agreement of Plan D, LLC, a separate U.S. Virgin Islands limited liability company formed on October 19, 2012 by Epstein as sole member, whose stated purpose is “to engage in any lawful activity, operate any lawful enterprise or to have any other lawful purpose permitted by the law of the territory of the U.S. Virgin Islands.”21

The Virgin Islands government alleged that the bank did business with Epstein from as early as 1998 to 2013 and in that period serviced approximately fifty-five Epstein-related accounts collectively worth hundreds of millions of dollars.2 JPMorgan denied the allegations of the complaint.1

Suspicious activity reporting

A FinCEN transcript compilation in the release contains eight suspicious activity reports on Epstein-related activity filed between 2002 and 2008, four of them by JPMorgan Chase Bank and four by Colonial Bank.22

The earliest JPMorgan filing in the compilation, of April 18, 2002, lists checks cashed against an account at the bank in the name of NES LLC between January and March 2002, most of them for $9,800, and records that the account was funded by wire transfers from an account in Epstein’s name at a bank in North Palm Beach, Florida, and that the account received ten wires totalling $550,000 since January 18, 2002.4 A filing of December 16, 2002 lists a further run of checks cashed against the NES LLC account between September 12 and December 16, 2002, again mostly for $9,800, and records that the account had been credited eleven times between September 12 and December 6, 2002 from an Epstein account at Colonial Bank, the wires totalling $1,925,000.5 A filing of April 15, 2003 lists seventeen more such checks between January and March 2003 and notes that all were payable to cash with the memo “petty cash”.6

Colonial Bank’s own filing of October 31, 2003, in the same compilation, reports that Epstein “BENEFITED FROM 9 CASH WITHDRAWALS TOTALING $69,500.00 OVER A 3-MONTH PERIOD,” five of them for $9,900, and concludes: “IT APPEARS MR. EPSTEIN MAY HAVE BEEN STRUCTURING TO KEEP FROM HAVING CURRENCY TRANSACTION REPORTS TO THE IRS.”23 That report was filed by Colonial Bank, not by JPMorgan.23

JPMorgan filed a further report received on August 18, 2008, seven weeks after Epstein’s guilty plea. It records twenty cash withdrawals of $40,000, totalling $800,000, from a JPMorgan demand deposit account in Epstein’s name between January 2007 and June 2008, all conducted by the holder of a power of attorney on the account, Harry Beller; it states that the customer “CASHED AN UNUSUAL AMOUNT OF $40 000 CHECKS BETWEEN JANUARY 2007 AND JUNE 2008 AND LATER PLEADED GUILTY TO FELONY SOLICITATION OF PROSTITUTION ON JUNE 30 2008,” and that the bank was filing “OUT OF AN ABUNDANCE OF CAUTION.”7

In 2019 JPMorgan Chase Bank NA and J.P. Morgan Securities LLC filed a report covering 4,725 wire transactions totalling $1,081,819,653 between October 1, 2003 and July 22, 2019, involving current, former and non-customers of the bank. The stated grounds were wire activity consistent with negative media involving alleged sex trafficking of minors and allegations that Epstein had misappropriated funds while employed as a money manager, the use of multiple accounts, a high-risk jurisdiction, and Epstein’s status as a politically exposed person “due to his relationships with two US presidents.”8

The New York Times reported in June 2023 that court documents and deposition testimony it had reviewed showed bank employees had filed numerous suspicious activity reports about Epstein’s repeated large cash withdrawals, and that after designating him a “high risk client” in 2006 the bank kept him as a customer.24

The 2011 due diligence report

A JPMorgan Confidential Due Diligence Report on Epstein, stamped JPM-SDNY-00062407 and produced under a request for confidential treatment, carries a section headed “PUBLICATIONS.”25 What stands under that heading is a press-database retrieval printout of an article from The New York Post of March 9, 2011, carrying the retrieval system’s own fields, so that the bank’s report records the article’s section and page, its length of 289 words and its byline.25 The article is headed “SCHOOLGIRL CONFIDENTIAL - TYCOON SEX CALLS” and opens: “Billionaire sex offender Jeffrey Epstein received hundreds of phone calls - some of them from young schoolgirls - to arrange massages for him at his Florida mansion, a sickening new report revealed.”25 It goes on to report handwritten call logs seized by police in an earlier investigation, to quote messages left for Epstein, and to name Ghislaine Maxwell as alleged to have helped recruit young women for him.25

What this document establishes is not the article, which was published and is a matter of public record. It is that the article sat in the bank’s own client due diligence file in 2011, under a heading the report format provides for press coverage. The bank’s relationship with Epstein was terminated in July 2013.9

Jes Staley

Jes Staley was employed by JPMorgan from 1979 to 2013.126 A J.P. Morgan team biography in the bank’s production records that he was named head of the Private Bank in 1999 and assumed responsibility for the Asset Management business late in 2001 in addition to that role; JPMorgan’s own third-party complaint states that he was chief executive of its Asset Management line of business from 2001 to 2009.261 The Virgin Islands’ Second Amended Complaint alleged: “Between 2008 and 2012, Staley exchanged approximately 1,200 emails with Epstein from his JP Morgan email account.” It further alleged that none of those emails was flagged in risk reviews of Epstein’s accounts, that the bank “allowed Staley to remain a decision-maker on Epstein’s accounts,” and that it tasked him with discussing the trafficking allegations with Epstein.2 The government’s earlier opposition brief put the figure as “over 1,000 messages” exchanged “in full view of JPMorgan.”27 JPMorgan did not admit those allegations and denied liability, but pleaded them against Staley in a third-party complaint for indemnity, contribution, breach of fiduciary duty and breach of the faithless servant doctrine.1 No statement from Staley answering these specific allegations is recorded in the documents cited on this page; his own position is recorded at Jes Staley.

An internal Southern District of New York email of December 10, 2019, subject “Epstein/JPM,” records that prosecutors were holding “a brief follow up call this morning at 10 with the FCA, the British regulator who, as discussed, is looking at Jes Staley and his potential relationship with Epstein,” and that they intended to ask the regulator “that they not go overt anytime soon.”28

The 2013 exit

The Virgin Islands complaint alleged that in July 2013, several months after Staley left the bank, a JPMorgan compliance officer terminated the bank’s relationship with Epstein, and that Mary Erdoes testified in her deposition that the bank terminated Epstein as a customer in 2013 after she became aware that the withdrawals were “actual cash.”2 Both are allegations in a pleading; the bank denied the complaint’s allegations.1

A JPMorgan know-your-customer ticket opened on July 13, 2013 on the account of the Max Foundation, which the bank’s 2020 account index groups with Ghislaine Maxwell’s accounts, records the final risk rating as High and gives, under “Summary of Risk Attributes,” the entry: “High risk - Client is associated with the Epstein relationship and is in the process of being exited.”911 The approval history on the same ticket carries the comment “At the request of sr management client is exiting the firm,” with approvals recorded on the ticket between November 8 and December 15, 2013.29

Deutsche Bank’s counsel, describing its eleventh production to the Southern District of New York on November 19, 2019, listed among the categories of documents produced “The transfer of Jeffrey Epstein’s assets from JP Morgan to Deutsche Bank from 2013 through 2014.”10 The New York State Department of Financial Services’ consent order with Deutsche Bank of July 6, 2020 records that in early 2013 Epstein, who had been banking with one of Deutsche Bank’s competitors, “began the process of moving his assets to Deutsche Bank,” and that the relationship came about through a relationship manager who joined Deutsche Bank in November 2012 from that competitor, where he had been a member of the team servicing Epstein’s accounts; the order does not name the competitor bank.30

Criminal investigation and productions

JPMorgan received grand jury subpoenas from the Southern District of New York dated August 11, August 16, September 3 and October 9, 2019.11 Its counsel, WilmerHale, completed the response on September 2, 2020, producing wire data for accounts related to Epstein and to Ghislaine Maxwell collected from at least 2007 to August 2019, together with an index of those accounts.11 The covering letter asked that the letter and the production be accorded confidential treatment under the Freedom of Information Act, marked the material “Confidential Treatment Requested by JPMorgan Chase,” and asserted that public disclosure “could reasonably be expected to cause substantial competitive harm to JPMorgan.”11 In September 2020 prosecutors’ contractors were directed internally to export both the Deutsche Bank and the JPMorgan productions for use in the Maxwell case.31

Litigation

Doe v. JPMorgan Chase Bank, N.A.

The initial complaint in Jane Doe 1 v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10019 (JSR), was filed in the Southern District of New York on November 24, 2022, and an amended complaint on January 13, 2023.12 It alleged violations of 18 U.S.C. §§ 1591(a)(1), (2), 1591(d), 1594(c) and 1595 of the Trafficking Victims Protection Act and of New York state law, contending that the bank had given Epstein and his associates the ability to withdraw cash and use wire services while knowing of his trafficking, and that it had failed in its compliance and regulatory obligations.12 JPMorgan denied the claims and contended that it had a normal banking relationship with a client and that it “did not engage in any conduct that resulted in harm to alleged victims of Epstein’s sex trafficking venture.”12

The bank moved to dismiss on February 7, 2023; the motion was granted in part and denied in part on March 20, 2023.12 The court certified the class on June 12, 2023, the class period running from January 1, 1998 to August 10, 2019.12 The parties mediated on May 30, 2023, executed a term sheet on June 11, 2023 providing for a cash payment of $290 million, and entered a Stipulation of Settlement dated June 22, 2023; a settlement hearing was set before Judge Jed S. Rakoff for November 9, 2023.12 Class counsel, Boies Schiller Flexner and Edwards Henderson Lehrman, told the court in November 2023 that they had dedicated over 15,000 hours to the case.32 Judge Rakoff later recorded that the case “was settled for $290 million.”13

Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A.

The Virgin Islands filed Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904 (JSR), on December 27, 2022, amending on January 10, 2023 and again on April 12, 2023.12 The Attorney General brought the action parens patriae under the Trafficking Victims Protection Act, the Virgin Islands Criminally Influenced and Corrupt Organizations Act and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, after presenting her findings to the bank in September 2022.2 The complaint alleged that internal records showed the bank knew Epstein was a felon and a registered sex offender, that a 2013 entry noted “[p]er bank policy, felons [like Epstein] are considered high risk and require additional approval,” that a 2006 rapid response team had recorded Epstein making cash withdrawals of $40,000 to $80,000 several times a month, and that at least twenty individuals paid through JPMorgan accounts were victims of trafficking.2 JPMorgan moved to dismiss and did not admit the allegations.1

In its statement of undisputed facts the Virgin Islands recorded that counsel for JPMorgan had told the court at the class certification hearing that Epstein’s engagement in “horrendous criminal activity, including sex trafficking” was “not something being contested at all by JPMorgan.”17 The government dismissed its claims with prejudice on September 29, 2023.33 Judge Rakoff recorded that the case “was settled for $75 million” and was closed on October 18, 2023.13

While the case was pending, the Virgin Islands Daily News reported that JPMorgan had filed papers contending that the territorial government was refusing to disclose public records that were not confidential but were embarrassing to officials who had dealt with Epstein.34

Third-party complaint against Staley

On March 8, 2023 JPMorgan filed a third-party complaint against James Edward Staley for indemnity, contribution, breach of fiduciary duty and breach of the faithless servant doctrine, stating that it referenced unproven allegations in the two complaints, did not admit them and denied all liability, but that if it were held responsible it was entitled to recover from Staley.1 It dismissed those claims with prejudice under a confidential settlement agreement entered into with Staley on October 6, 2023.16

The stockholder derivative action

A fourth proceeding arising from the relationship was brought in the same court by a stockholder of JPMorgan Chase & Co. On May 9, 2023 the Operating Engineers Construction Industry and Miscellaneous Pension Fund filed a Verified Stockholder Derivative Complaint in the Southern District of New York, No. 1:23-cv-03903 (JSR), for the benefit of JPMorgan Chase & Co., which is named as nominal defendant, against twenty-five current and former officers and directors, James Dimon first among them and including Mary C. Erdoes and James E. Staley; two of the twenty-five have their surnames blacked out in the produced copy.14 A Verified Amended Stockholder Derivative Complaint filed on June 30, 2023 added the City of Miami General Employees & Sanitation Employees Retirement Trust as a second plaintiff and reduced the individual defendants to nine.15 It pleads three counts, breach of fiduciary duty against the director defendants, breach of fiduciary duty against the officer defendants, and unjust enrichment, and asks the court to declare “that demand on the JPM Board is excused as futile.”35 It also alleges that the company “has tried to lay all blame exclusively on Staley” while asserting no claims against other executives still at the company.36 Those are allegations in a pleading, and the documents cited here record no answer to them and no disposition of the action.

The bank’s response

In statements to the press after the class settlement, JPMorgan said: “We all now understand that Epstein’s behavior was monstrous, and we believe this settlement is in the best interest of all parties, especially the survivors, who suffered unimaginable abuse at the hands of this man,” and “Any association with him was a mistake and we regret it. We would never have continued to do business with him if we believed he was using our bank in any way to help commit heinous crimes.”1724 In the class action the bank denied all claims, allegations and contentions of fault, liability, wrongdoing and damages, and the settlement notice records that the court made no ruling on liability.12 In its third-party complaint the bank itemised its denials: that it perpetrated sex trafficking, participated in an Epstein sex-trafficking venture, knowingly received benefits from any such participation, knew that an Epstein venture trafficked the class representative, aided or abetted or conspired in acts unlawful under the Trafficking Victims Protection Act, or obstructed any investigation into the alleged venture; and, as to the Virgin Islands, that it engaged in racketeering, engaged in unfair competition, or failed to abide by federal banking laws.1 The New York Times reported that the settlement came about two weeks after the bank’s chief executive, Jamie Dimon, sat for a daylong deposition in which “he said he had barely heard of Epstein” before the July 2019 arrest.24 Beyond that general denial and the third-party claim it brought against him, no answer by the bank to the specific allegations about Staley’s correspondence is recorded on this page.

Deutsche Bank; Financial Trust Company; Southern Trust Company; C.O.U.Q. Foundation; Enhanced Education; HBRK Associates; JEGE LLC; Southern District of New York; Jes Staley; Harry Beller; Darren Indyke; Jeanne Brennan Wiebracht; Ghislaine Maxwell; Butterfly Trust.

Footnotes

  1. JPMorgan Chase Bank, N.A.’s Third-Party Complaint against James Edward Staley, USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 70, Mar 8, 2023, ¶¶1–5, 13, 15–16. https://epstein-data.com/EFTA02806526 pp.1–4. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13

  2. Government of the United States Virgin Islands, Second Amended Complaint, 22-cv-10904 (JSR), Doc. 119, Apr 12, 2023, ¶¶1–4, 41–42, 50, 53, 62–63, 92, 96. https://epstein-data.com/EFTA00145666 pp.1–2, 10, 13, 15, 23. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  3. JPMorgan Private Bank, Asset Account Portfolio for Jeffrey Epstein, September 1–30, 2002; Government Exhibit 504, S2 20 Cr. 330 (AJN); JPM-SDNY-00005505. https://epstein-data.com/EFTA00014685 p.1. ↩ ↩2 ↩3

  4. FinCEN SAR-DI transcript, BSA 30000027752905, filed by JP Morgan Chase Bank on April 18, 2002. https://epstein-data.com/EFTA01656376 pp.18–21. ↩ ↩2

  5. FinCEN SAR-DI transcript, BSA 30000027950492, filed by JP Morgan Chase Bank on December 16, 2002. https://epstein-data.com/EFTA01656376 pp.6–9. ↩ ↩2 ↩3

  6. FinCEN SAR-DI transcript, BSA 30000028091513, filed by JP Morgan Chase Bank on April 15, 2003. https://epstein-data.com/EFTA01656376 pp.10–13. ↩ ↩2 ↩3

  7. FinCEN SAR-DI transcript, BSA 30000033212365, filed by JPMorgan Chase Bank NA, received August 18, 2008. https://epstein-data.com/EFTA01656376 pp.26, 29. ↩ ↩2 ↩3

  8. SAR 31000154806804, filed by JP Morgan Chase Bank NA and J.P. Morgan Securities LLC. https://epstein-data.com/EFTA01648787 p.1. ↩ ↩2 ↩3

  9. JPMorgan know-your-customer ticket 105258608, initiated July 13, 2013; JPM-SDNY-00062375. https://epstein-data.com/EFTA01582802 p.1. ↩ ↩2 ↩3

  10. Akin Gump Strauss Hauer & Feld to the U.S. Attorney’s Office for the Southern District of New York, Nov 19, 2019, eleventh Deutsche Bank production. https://epstein-data.com/EFTA00015937 p.1. ↩ ↩2

  11. WilmerHale to the U.S. Attorney’s Office for the Southern District of New York, Sept 2, 2020, and Appendix A. https://epstein-data.com/EFTA00096342 pp.1–2, 4–5. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  12. Notice of Proposed Settlement of Class Action, Jane Doe 1 v. JPMorgan Chase Bank, N.A., 1:22-CV-10019 (JSR). https://epstein-data.com/EFTA00146745 pp.1, 4–5, 11. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  13. Memorandum Order, USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 366, Jun 28, 2024. https://epstein-data.com/EFTA02819006 p.1. ↩ ↩2 ↩3 ↩4 ↩5

  14. Verified Stockholder Derivative Complaint, Operating Engineers Construction Industry and Miscellaneous Pension Fund v. Dimon, No. 1:23-cv-03903-JSR (S.D.N.Y.), Document 1, filed May 9, 2023, caption and p.1. Two surnames in the caption are blacked out at image level and are not supplied here. Read from the page image. https://epstein-data.com/EFTA02822733 p.1. ↩ ↩2

  15. Verified Amended Stockholder Derivative Complaint, same case, Document 17, filed June 30, 2023, caption and p.1. Read from the page image. https://epstein-data.com/EFTA02822837 p.1. ↩ ↩2

  16. JPMorgan Chase Bank, N.A. Stipulation of Dismissal, 22-cv-10904 (JSR), Doc. 345, Oct 6, 2023, and Doc. 347, Oct 16, 2023. https://epstein-data.com/EFTA02818732 p.1; https://epstein-data.com/EFTA02818738 p.1. ↩ ↩2 ↩3

  17. Statement of Material Facts as to Which the Government of the United States Virgin Islands Contends There Is No Genuine Dispute, 22-cv-10904 (JSR), Doc. 221, Jul 24, 2023, ¶¶1–2. https://epstein-data.com/EFTA02809437 pp.1–2. ↩ ↩2 ↩3

  18. Melissa Dalton, JP Morgan Chase Private Bank Client Services, “Fw: Plan D, Inc.,” April 18, 2007, 4:58 pm, enclosing “Plan D - Bank Application.pdf” and quoting the reply of the same day at 4:42 pm; Confidential Treatment Requested by JPMorgan Chase, JPM-SDNY-00063195. Read from the page image. https://epstein-data.com/EFTA01583513 p.1. ↩ ↩2

  19. Melissa Dalton, “Additional information needed for new account for Plan D, Inc.,” April 19, 2007, 10:11 am; JPM-SDNY-00063194. The addressee field is redacted; the manuscript annotation is read from the page image. https://epstein-data.com/EFTA01583512 p.1. ↩

  20. Melissa Dalton to Rich Kahn, “Plan D Inc. - Update,” April 27, 2007, 8:29 am, and his reply of 9:36 am; JPM-SDNY-00063186. Read from the page image. https://epstein-data.com/EFTA01583506 p.1. ↩

  21. “Operating Agreement of Plan D, LLC, A U.S. Virgin Islands Limited Liability Company,” made as of October 19, 2012, sections I.A to I.C; JPM-SDNY-00063140. Read from the page image. This is a different entity from the “Plan D, Inc.” of the 2007 account-opening thread. https://epstein-data.com/EFTA01583466 p.1. ↩

  22. FinCEN SAR-DI transcript compilation. Eight distinct BSA numbers, each with its own filer-information page: 30000028385122 (Colonial Bank, p.3), 30000027950492 (JP Morgan Chase Bank, p.8), 30000028091513 (JP Morgan Chase Bank, p.12), 30000028216574 (Colonial Bank, p.16), 30000027752905 (JP Morgan Chase Bank, p.20), 30000028236307 (Colonial Bank, p.24), 30000033212365 (JPMorgan Chase Bank NA, p.28) and 30000028586838 (Colonial Bank, p.31) — four filed by each institution. https://epstein-data.com/EFTA01656376 pp.3, 8, 12, 16, 20, 24, 28, 31. Other pages of this production, including p.1, are not cited from this page. ↩

  23. FinCEN SAR-DI transcript, BSA 30000028385122, filed by Colonial Bank on October 31, 2003. https://epstein-data.com/EFTA01656376 pp.3–4. ↩ ↩2

  24. Matthew Goldstein, “JPMorgan reaches $290M settlement with Epstein’s victims,” New York Times, reprinted in The Virgin Islands Daily News, June 13, 2023, p.3. https://epstein-data.com/EFTA00129019 ↩ ↩2 ↩3

  25. JPMorgan Chase, “Confidential Due Diligence Report,” PUBLICATIONS section, reprinting Dan Mangan, “SCHOOLGIRL CONFIDENTIAL - TYCOON SEX CALLS,” The New York Post, March 9, 2011, All Editions p.6. Confidential treatment requested by JPMorgan Chase; JPM-SDNY-00062407. https://epstein-data.com/EFTA01582832 p.1. The page is a database retrieval printout rather than the newspaper page, which is why the report carries the article’s word count and section fields. A second printout of the same class, of a different newspaper column, was produced by the same bank and is cited on Andrew Mountbatten-Windsor. ↩ ↩2 ↩3 ↩4

  26. J.P. Morgan, “Team biographies,” JPM-SDNY-00001707. https://epstein-data.com/EFTA01301134 p.26. ↩ ↩2

  27. Government of the United States Virgin Islands’ Memorandum of Law in Opposition to JPMorgan Chase Bank, N.A.’s Motion to Dismiss, 22-cv-10904 (JSR), Doc. 48, Feb 15, 2023. https://epstein-data.com/EFTA02806178 p.9. ↩

  28. Internal Southern District of New York email, “Epstein/JPM,” Dec 10, 2019. https://epstein-data.com/EFTA00022164 ↩

  29. Comment and approval history of ticket 105258608. https://epstein-data.com/EFTA01594156 pp.11–13. ↩

  30. New York State Department of Financial Services, Consent Order under New York Banking Law §§ 39 and 44, Deutsche Bank, July 6, 2020, ¶¶16–18. https://epstein-data.com/EFTA00151495 p.6. ↩

  31. Internal Southern District of New York email chain, “Epstein/Maxwell Upload,” Sept 2020. https://epstein-data.com/EFTA00019851 p.1. ↩

  32. Reply Memorandum of Law in Support of Motion for Final Approval of Class Action Settlement and for Attorneys’ Fees, 22-cv-10019 (JSR), Doc. 256, Nov 2, 2023. https://epstein-data.com/EFTA00145643 pp.1, 15. ↩

  33. Government of the United States Virgin Islands’ Stipulation of Dismissal, 22-cv-10904 (JSR), Doc. 343, Sept 29, 2023. https://epstein-data.com/EFTA02818725 p.1. ↩

  34. Suzanne Carlson, “JPMorgan: V.I. trying to block release of embarrassing Epstein docs,” The Virgin Islands Daily News, June 13, 2023, p.3. https://epstein-data.com/EFTA00129019 ↩

  35. Same amended complaint, Counts I to III at pp.62-65 and the relief requested at p.65. Read from the page images. https://epstein-data.com/EFTA02822837 pp.62-65. ↩

  36. Same amended complaint, paragraph 199, p.62. Read from the page image. https://epstein-data.com/EFTA02822837 p.62. ↩

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