TYB
>>18355781, >>18355789, >>18355927 Ex-JP Morgan Jes Staley [JS]'s Executive’s Jeffrey Epstein Emails Revealed in Lawsuit Against Bank PB
CICO- Criminally Influenced and Corrupt Organizations
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Elements of CICO Claim
a) Association with and Participation in Enterprise
JPMorgan argues that all the Government pleads is that JPMorgan “earned money by
providing ordinary banking services to a client, which is insufficient” to establish a shared common
purpose. Mot. at 17-18. This is incorrect. The Government alleges that JPMorgan, rather than
provide ordinary banking services, processed Epstein’s payments to recruiters and young women
who were trafficked in the Virgin Islands and elsewhere, FAC, ¶ 42, with knowledge that Epstein was procuring women to perform commercial sex acts, id., ¶¶ 54-55, 61 (Staley), had been indicted
for and pled guilty to solicitation of a minor for prostitution and was a criminal felon and registered
sex offender, id. ¶¶ 21-22, 44, and was repeatedly under law enforcement investigations for and
associated with trafficking activity, id., ¶¶ 44-47, while also
, id., ¶¶ 66-69, 74-84. JPMorgan
handled Epstein’s payments even though they had no discernible business or other legitimate
purpose and engaged in a years-long pattern of ignoring obvious red flags and failing to
demonstrate even basic due diligence on Epstein’s accounts—which is particularly out-of-theordinary conduct by JPMorgan for a customer it designated high-risk. Id. ¶¶ 25-26, 66-69, 76-78,
82, 43, 44, 50, 80.c. Further, JPMorgan catapulted Staley’s career based on Staley’s profitable
work with Epstein and directed Staley to manage JPMorgan’s relationship with Epstein in the
pursuit of more profits and referrals of business opportunities. Staley filled his end of the bargain,
establishing a close relationship with Epstein. In 2009 and 2010, after Epstein pled guilty to
conduct that is child sex-trafficking under the TVPA, Staley’s JPMorgan email account—in full
view of JPMorgan—shows multiple emails with Epstein discussing visits to Epstein’s residences,
including in the Virgin Islands; women who they referred to by the names of Disney princesses
that Epstein procured for Staley; discussions of sex with young women; and photos of young women in suggestive poses. Id. ¶¶ 52-62. In 2011, following additional news stories about
Epstein’s human trafficking, JPMorgan’s investigation extraordinarily consisted of asking Staley
to discuss those reports with Epstein. Id. ¶ 47.
This unlawful conduct in furtherance of the trafficking enterprise’s unlawful purpose
constitutes association with and participation in the enterprise by JPMorgan. See, e.g., Handeen
v. Lemaire, 112 F.3d 1339, 1350 (8th Cir. 1997) (law firm’s assistance with sham transactions and false court filings in furtherance of client’s misuse of bankruptcy to shield enterprise assets
constitutes association and participation); Taylor v. Bettis, 976 F. Supp. 2d 721, 735 (E.D.N.C.
2013) (“If a doctor or lawyer provides services that go to the heart of the allegedly fraudulent
scheme, the professional may be liable for providing some direction in the affairs of the
enterprise.”).
The Government also sufficiently pleads participation.
Good read