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Epstein's sex offender registration in the U.S. Virgin Islands

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tagstopic, virgin-islands, sex-offender-registration, jpmorgan

19 min read

Registering authorityTerritorial Sex Offender Registry, Virgin Islands Department of Justice (“VIDOJ”)12
Governing lawVirgin Islands Sexual Offender Registration and Community Protection Act, 14 V.I.C. § 1721 et seq.3
Year of registration2010, on the territorial Government’s pleading and on JPMorgan Chase’s account of discovery in its own case45
Classification pleadedTier 1 under Virgin Islands law, on the 2008 Florida conviction for procuring a minor for prostitution4
Obligations pleadedAnnual registration with VIDOJ, advance notice of travel to and from the territory, random address verification4
Travel-notification termsReset by the Acting Attorney General on March 14, 2019; still under review by her successor when Epstein was arrested in July63
In litigationJPMorgan Chase pleaded the territory’s own conduct as an affirmative defence in Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904 (JSR); the Government moved to strike78

Jeffrey Epstein registered as a sex offender in the U.S. Virgin Islands, where he kept his permanent residence, and the territorial Department of Justice supervised that registration until his death. This page reports what the released court filings record about that registration and that supervision, and about the dispute in the territory’s later suit against JPMorgan Chase over whether the territory’s own handling of him could be pleaded against it.

It does not cover the Virgin Islands Government’s action against Epstein’s estate, its settlement or the sale of the two islands, which are on Little St. James; the corporate and tax-benefit history, which is on Southern Trust Company and LSJE, LLC; the course of the bank litigation, which is on JPMorgan Chase; Cecile de Jongh’s roles in Epstein’s Virgin Islands companies, which are on Cecile de Jongh; or Denise George’s own tenure as Attorney General, including its end, which this page does not otherwise address.

Registration

The Government of the Virgin Islands pleaded, in the complaint against Epstein’s estate signed by Attorney General Denise N. George and dated January 15, 2020, that “Epstein registered as a sex offender in the Virgin Islands in 2010” and was “a Tier 1 offender under Virgin Islands law based upon his Florida conviction of procuring a minor for prostitution.”4 As a Tier 1 offender, it pleaded, he “was required to register annually with the Virgin Islands Department of Justice (‘VIDOJ’) and give advance notice of his travel to and from the Virgin Islands”, and “was also subject to random address verification by VIDOJ.”4 Those are the Government’s allegations; the action was against Epstein’s estate and no answer from him to them exists.

JPMorgan Chase gave the same year from its own discovery in the later case, stating that “In 2009, upon his release from prison for procuring a minor for prostitution, Epstein sought to arrange for supervision of his parole to be transferred from Florida to USVI. He registered with the USVI as a sex offender in 2010 and maintained his primary residence there.”5

The 2012 waiver

Attorney General Vincent F. Frazer answered Epstein’s then Virgin Islands counsel, Maria Tankenson Hodge, on July 25, 2012. Her letter of July 16, 2012, made on Epstein’s behalf, was “accepted as a request pursuant to the new provisions of Act No. 7372, for the Attorney General to waive the 21 day prior notice requirement to the Department of Justice for Mr. Epstein, when travelling out of the Virgin Islands,” and Frazer wrote that “based upon your representation and that of Attorney Darren Indyke, we will grant the waiver of the (21) twenty one day notice requirement” on condition that notice be given at least 72 hours before travel, in person, by signed facsimile, or by e-mail with an electronic signature.9 Hodge asked Frazer on July 30, 2012 to relax that further; Frazer agreed on August 14, 2012, signing a letter that let Epstein give 24 hours’ notice instead of 72 and softened the condition that he disclose the address of his lodging within the United States.10 No response from Frazer to either letter is recorded in the documents cited here.

The DNA notification, 2014

An undated letter on the Attorney General’s letterhead, signed by Shani A. Pinney as Territorial Sex Offender Registry Program Manager, gave Epstein “formal notification that the Virgin Islands Department of Justice will be collecting a DNA sample from you to be entered into the Federal Bureau of Investigations Combined DNA Index System ‘CODIS.’”1 It cited Section 1726(b)(3) of the territorial act and Section 114(b)(6) of the federal Sex Offender Registration and Notification Act, whose requirements it says “have been incorporated in the Virgin Islands Sexual Offender Registration and Community Protection Act”, and scheduled him to appear in person on Wednesday, October 1, 2014 at ten in the morning.1 Its closing paragraph is the registry’s own contemporaneous assessment: “Thus far, you have cooperated with the Registry Staff at the Department of Justice by registering as a sex offender and by keeping your registration current.”1

Travel notices, 2018

Epstein and his attorney Darren Indyke sent the registry written notice of his movements. On October 10, 2018 Pinney forwarded a run of those notices to the United States Marshals Service.11 The first is an Indyke letter of September 30, 2018 headed “Mr. Jeffrey Epstein - Travel Notice”, advising “of a further modification to Mr. Epstein’s travel plans”: the Paris trip was cancelled, Epstein would travel that day from New York to Palm Beach, and would return to “his permanent residence in the U.S Virgin Islands” on October 13 and “email you upon his return.”11 The recipient at the Marshals Service and both of the attorney’s telephone lines are blacked out in the image.

The conditions imposed in March 2019

On March 14, 2019 the Acting Attorney General, Carol Thomas-Jacobs, wrote to Epstein at his Red Hook address to replace the arrangements he had been working under. The letter says the Department “understands that your business activities require you to make frequent trips outside of the Territory to the United States destinations and international destinations”, and that “While provisions were granted in the past, upon our careful review and consideration these are the conditions to which you must now comply”.6 It then imposes four: notice of any travel outside the territory in person at the Department while he was in the territory; notice by email only if he was already outside the jurisdiction; appearance in person “at least twenty one calendar days prior to any intended travel outside of the United States”; and, for any reduction in that period, information in support of the request “for approval at the discretion of USVIDOJ”.6 It lists what he had to supply in person, including destination, dates, places of arrival and departure, itinerary details, an address or telephone contact and the purpose of travel, and states that the requirements are “pursuant to Chapter 86, Section 1724 (b) of the Virgin Islands Code and H.R.515 - International Megan’s Law.”6 Its second sheet, signed by Thomas-Jacobs as Acting Attorney General, tells him that “the previous provisions for your travel notifications are no longer accepted by USVIDOJ and you must comply immediately with the conditions noted above.”6 The copy in the released files is an evidence photograph of the letter and its envelope.

Counsel’s objection, April 2019

Epstein’s Virgin Islands counsel, Erika A. Kellerhals, answered on April 30, 2019 in a letter to Denise N. George. It argues that the federal registration guidelines and the territorial statute both allow flexibility for a frequent traveller, that Section 1724(b)(4) “provides for a mandatory exception to the twenty-one (21) day in person notice otherwise required for international travel”, and that the in-person requirement for travel between the territory and the mainland “appears to exceed the requirements of Virgin Islands law” because Section 1724(c) “specifically does not require in person notification.”12 It states that Epstein’s temporary lodgings in Florida, New York and New Mexico had been on file “since Mr. Epstein initially registered in the USVI in 2009”, and asks that in future the Department send him an email copy of every notification it was required to make to jurisdictions outside the territory under Section 1726(d), so that he could confirm his notices had been received and forwarded.12 The letter is signed.12

The occasion for that request is set out in an appendix to the same letter, which is counsel’s account and not a finding. It states that Epstein gave email notice on February 16, 2019 of a day trip to the Dominican Republic on February 19; that “Despite Mr. Epstein’s timely and proper notice to the Department of Justice of his travel to the Dominican Republic, the Dominican Republic did not receive advance notice of Mr. Epstein’s travel”; that he was on arrival “detained for several hours and ultimately denied entry”; and that six days after the notice was sent the registry manager replied that she had been out of the office, that “I have not received your travel details”, and that “In the future, report in person to DOJ to register and there will be Investigators that can assist in my absence.”12

Counsel’s letter puts the initial registration in 2009. The Government’s own complaint pleads 2010, and JPMorgan Chase’s brief separates the two, placing the attempt to transfer parole supervision in 2009 and the registration in 2010.4512 The documents cited here are three accounts by three parties and this page does not reconcile them.

The June 2019 review

Denise George, then Attorney General Nominee, answered counsel on June 2, 2019 that she would need further information before deciding.3 Her letter sets out the Department’s function under “the Sexual Offender Registration and Community Protection laws codified at 14 V.I.C. § 1721, et seq.”, whose primary purpose she described as “to protect the safety of communities from the dangers posed by sexual offenders like Mr. Epstein, through ensuring that such criminal sex offenders are registered and that their whereabouts are accounted for and verified at all times within the United States, its territories and abroad.”3

On the point at issue she wrote that “While my predecessors have apparently had differing interpretations of Title 14, Section 1724(b)(4) of the Virgin Islands Code, it is my understanding that the 21-day in-person notification for international travel can only be waived upon a showing of ‘reasonable and reliable proof satisfactory to the Department of Justice’ that your client frequently travels internationally for business or some other legitimate purpose.”3 She added: “In this particular case, I have not been presented with any documentation of such proof, nor does the VIDOJ have any record of such documentation ever having been submitted to the VIDOJ.”3 She asked counsel to produce the documentation originally submitted to a former Attorney General that had validated the waiver, together with supporting documentation from 2012 onward, and directed that “Until this review is completed, the Department is requiring that the current terms of Mr. Epstein’s travel—both internationally and nationally—be strictly adhered to.”3

Counsel replied on June 17, 2019 that neither the Virgin Islands Code nor the SORNA guidelines define “reasonable and reliable proof”, asked what would satisfy it, and asked whether the Department wanted every travel notification sent to the registry since 2012 compiled or would retrieve them itself.13 George answered the same day: “There is no specific information that I am seeking at this time. Please submit reasonable and reliable proof as required by statute. If the travel notifications are helpful in your submission of the required proof, you may submit.”13 Counsel asked on June 20 to meet with her the following week.13 Epstein was arrested in New York on July 6, 2019.

George later gave the Federal Bureau of Investigation her own account of how the review ended. In an interview on October 2, 2023, which she had herself requested in order to file a complaint, she said Governor Albert Bryan had texted her that “you need to make a decision on the Epstein matter”, and that “GEORGE did not grant EPSTEIN the waiver. The same day she informed KELLERHALS via a letter and BRYAN via an email.” Bryan, she said, “responded with ‘Thank you for your work on this’.”14 That is George’s own account, given more than four years after the events it describes; it dates counsel’s meeting request to July, where the contemporaneous chain above dates it to June, and it is not a departmental determination of the kind the June letters record.14

The affidavit of diligent search, July 2019

On July 15, 2019, at the request of the United States Marshals Service, Pinney searched the registry’s database and its pending files and swore an Affidavit of Diligent Search. It records that “there were records indicating that JEFFREY EPSTEIN is registered in the U.S. Virgin Islands as a sexual offender and is required to provide in person notification of any travel outside of the U.S. Virgin Islands”, and then lists what the registry had been told in 2019: notice on March 9 of travel to Paris from March 19 to March 29; notice on March 30 that he had instead returned to the United States on April 2; notice on April 11 of travel to Paris from April 4 to April 30; notice on April 23 of a day trip to Marrakech on April 25; notice on April 26 that he had instead returned on April 29; notice on June 13 of travel to Paris from June 14 to June 20; notice on July 2 of a day trip to Nice on July 6, cancelled by a further notice on July 3; and notice the same day that he had instead returned to the United States on July 6.2 Paragraph 11 reads in full: “Our records do not reflect that JEFFREY EPSTEIN returned to the U.S. on June 20, 2019.”2 That is a statement about the registry’s records and not about his movements. The affidavit is signed and was sworn before a notary public on the fifteenth day of July; the year is left blank on the jurat and the document is headed July 15, 2019.2

The affirmative defences in the suit against JPMorgan Chase

The Virgin Islands sued JPMorgan Chase Bank, N.A. in the Southern District of New York in December 2022 under the Trafficking Victims Protection Act and territorial law. The course of that case is on JPMorgan Chase. What belongs here is the fight over the territory’s own conduct.

The Government’s motion records that the bank answered on April 24, 2023 with twenty-five affirmative defences, among them that the Government’s claims were barred by in pari delicto, unclean hands and laches, and that its damages “should be barred or reduced in accordance with the doctrines of comparative and contributory negligence or fault.”7 On May 8, 2023 the Government moved to strike those four, arguing that “this Court and others long have held that equitable defenses—including in pari delicto, unclean hands, and laches—do not apply against government plaintiffs suing to vindicate public rights”, and that it asserted its claims “as sovereign acting in its law enforcement capacity.”7

JPMorgan opposed on May 23, 2023. Its brief opens: “Plaintiff Government of the United States Virgin Islands (‘USVI’) is complicit in the crimes of Jeffrey Epstein.”5 Under a heading asserting that Epstein “exerted influence over USVI sex offender legislation and received lax monitoring”, it states that “Even as to the regulations USVI did enforce, it did so incompetently”, and that “Further, while the USVI did conduct site visits of Epstein’s residence, those inspections were cursory at best.”8 It concludes that section: “In sum, in exchange for Epstein’s cash and gifts, USVI made life easy for him. The government mitigated any burdens from his sex offender status. And it made sure that no one asked too many questions about his transport and keeping of young girls on his island.”15 Those are a defendant’s assertions in civil litigation and were not tested at a hearing. The examples and the record citations that follow each of them are blacked out in the filing, so what a reader of that copy has is the assertion and not the evidence offered for it.

The Government replied on May 30, 2023. On the registration point specifically it wrote that “Although JPMorgan seeks to predicate its defense on the fact that prior Attorneys General modified Mr. Epstein’s notification requirements as a registered sex offender, it fails to advise the Court that Virgin Islands law authorizes the Attorney General to modify those requirements ‘at his discretion.’ See 14 V.I.C. § 1724(b)(4).”16 It argued that what the bank described, including the notification requirements, the award of economic development benefits, a university’s scheduling of a language course and “alleged airport security failures”, was “exactly the kind of alleged government negligence or neglect in the performance of discretionary duties that is not a basis for a defense to government enforcement of public statutory rights”, and that the argument “amounts to little more than an attempt to second-guess the Government’s administration of its laws.”16

The Government dismissed its claims against the bank with prejudice on September 29, 2023.17 The settlement that preceded that dismissal, and the court’s own record of it, are on JPMorgan Chase.

What the documents cited here do not establish

No ruling on the motion to strike is among the documents cited here, and searches of the released files for one returned nothing: the phrases “motion to strike” with “denied” and with “granted”, “equitable defenses” with “stricken”, “in pari delicto” with the judge’s name, and “opinion and order” with the case number. What those searches return in this case are the parties’ own briefs, which are cited above.

A search of the released files under “Thomas-Jacobs” returns twenty-one pages; the third is Denise George’s October 2023 interview with the FBI, discussed above. Searches under “travel notification” with Epstein’s name and under “Sex Offender Registry” with “Virgin Islands” return, among many results, the correspondence set out above. Searches under “Pinney”, under “VIDOJ” and under “address verification” with Epstein’s name each return far more pages than could be read for this page; among the “address verification” results is a Florida Department of Law Enforcement certification of Epstein’s registration records in that state, a different jurisdiction, not otherwise used here. A search under “site visit” with Epstein’s name returns many pages, of which the ones read for this page are construction and landscaping messages about work on the island and no inspection record. Among the pages read for this page, whether the documentation George asked for in June 2019 was ever produced, and what any inspection of the residence found, are not recorded.

JPMorgan Chase; Cecile de Jongh; Darren Indyke; Little St. James; Great St. James; LSJE, LLC; Nautilus, Inc.; Southern Trust Company.

Footnotes

  1. Virgin Islands Department of Justice, Office of the Attorney General, letter to Jeffrey Epstein signed by Shani A. Pinney, Territorial Sex Offender Registry Program Manager, notifying him of DNA collection and setting an appointment for October 1, 2014. The letter carries no date of its own. https://epstein-data.com/EFTA00869275 p.1. ↩ ↩2 ↩3 ↩4

  2. Shani A. Pinney, Affidavit of Diligent Search, Virgin Islands Department of Justice, Office of the Attorney General, July 15, 2019, ¶¶ 1–14 and jurat; USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 194-27, June 20, 2023. https://epstein-data.com/EFTA02809037 pp.195–196. No other page of this exhibit is cited here. ↩ ↩2 ↩3 ↩4

  3. Denise George, Attorney General Nominee, Virgin Islands Department of Justice, to Epstein’s Virgin Islands counsel, June 2, 2019, at 2–3, quoted in a later message in the same chain; USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 194-24, June 20, 2023. https://epstein-data.com/EFTA02808954 pp.57–58. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  4. Government of the Virgin Islands v. Estate of Jeffrey E. Epstein, Complaint, Superior Court of the Virgin Islands, ¶¶ 4–6 and signature page, filed as an exhibit in Doe v. Indyke, No. 1:19-cv-08673-KPF-DCF (S.D.N.Y.), Doc. 45-1, January 15, 2020. Signed by Denise N. George, Attorney General; the clerk’s received stamp appears on the following sheet. https://epstein-data.com/EFTA02751057 pp.2, 48–49. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  5. JPMorgan Chase Bank, N.A.’s Opposition to USVI’s Motion to Strike Affirmative Defenses, USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 157, May 23, 2023, at 1. https://epstein-data.com/EFTA02807570 p.5. ↩ ↩2 ↩3 ↩4

  6. Carol Thomas-Jacobs, Acting Attorney General, United States Virgin Islands Department of Justice, to Jeffrey Epstein, March 14, 2019, pp. 1-2. The released copy is a photograph of the letter and its envelope; both sheets are legible and the second carries her signature. https://epstein-data.com/EFTA01340980 p.1. ↩ ↩2 ↩3 ↩4 ↩5

  7. Government of the United States Virgin Islands’ Memorandum of Law in Support of its Motion to Strike Certain of JPMorgan’s Affirmative Defenses, USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 139, May 8, 2023, at 2. https://epstein-data.com/EFTA02807321 p.6. ↩ ↩2 ↩3

  8. Same brief, at 8 and 11. https://epstein-data.com/EFTA02807570 pp.12, 15. ↩ ↩2

  9. Vincent F. Frazer, Attorney General, United States Virgin Islands Department of Justice, to Maria Tankenson Hodge, Hodge & Francois, July 25, 2012, signed; filed in USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 194-24, June 20, 2023. https://epstein-data.com/EFTA02808954 pp.39-40. ↩

  10. Same, Vincent F. Frazer to Maria Tankenson Hodge, August 14, 2012, signed. https://epstein-data.com/EFTA02808954 pp.46-47. ↩

  11. Shani A. Pinney to the United States Marshals Service, October 10, 2018, forwarding travel notices; enclosing Darren K. Indyke to Pinney, September 30, 2018, “Mr. Jeffrey Epstein - Travel Notice”. Filed in USVI v. JPMorgan, 22-cv-10904 (JSR). https://epstein-data.com/EFTA01305746 p.1. No other page of this compilation is cited here. ↩ ↩2

  12. Erika A. Kellerhals to Denise N. George, Esq., April 30, 2019, at 4-5 and Appendix 1, signed; filed in USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 194-24, June 20, 2023. https://epstein-data.com/EFTA02808954 pp.5-7. ↩ ↩2 ↩3 ↩4 ↩5

  13. Same chain: counsel to George, June 17, 2019; George to counsel, June 17, 2019; counsel to George, June 20, 2019. https://epstein-data.com/EFTA02808954 pp.56–57. ↩ ↩2 ↩3

  14. FBI FD-302, interview of Denise George, former Attorney General of the U.S. Virgin Islands, conducted October 2, 2023, entered October 6, 2023, File No. 272L-SJ-3775806. https://epstein-data.com/EFTA00129035 p.1. ↩ ↩2

  15. Same brief, at 14. https://epstein-data.com/EFTA02807570 p.18. ↩

  16. Government of the United States Virgin Islands’ Reply in Support of its Motion to Strike, USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 168, May 30, 2023, at 7. https://epstein-data.com/EFTA02807856 p.11. ↩ ↩2

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

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