Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/284-04.pdf

ATTACHMENT B PART 3 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 1 of 99 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 2 of 99 Figure 11: Indirect Pay ments for the benefit Women from the Epstein A ccounts Beneficiary/Payee Amount $1,260.00 $1,260.00 $840.00 $840.00 tography $1,290.00 Total $1,290.00 Castle Worldwide Inc. $250.00 Pacific College of Oriental Medicine $21,245.86 Steven D. Kaplan , D MD $5,700.00 $27,195.86 $2,425.85 College $4,135.85 Total $6,561.70 $6,040.00 $450.00 Total $6,490.00 Bloomingdales $532.77 Express $380.87 121 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 3 of 99 Beneficiary/Payee Amount I C Systems $329.00 Target $352.10 $211.04 $1,805.78 $1 0,400.00 lin a1y Center L $42,000.00 $ 52,400.00 $2,000.00 Total $2,000.00 $26,000.00 $26,000.00 my $3,500.00 otal $3,500.00 $2,275.00 Dr. David Price $412 .00 Dr. Ge rald Imber $20,000.00 Dr. Jane Reca nt $2,000.00 Office Based Sm ge1y Care $1,500.00 Total $26,187.00 $2,020.00 122 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 4 of 99 Beneficiary/Payee Amount $2,020.00 $1,408.00 $1,408.00 Grand Total $158,958.34 JPMC Response: Undisputed that this is a summaiy of transactions prepai· ed by U SVI's proffered expe1i Jorge Amador. Disputed that this info1m ation was available to JPMorgan in this fo1m at during the time Epstein was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is n ot provided in the cited source. Disputed as to materiality to the extent this summa1y fails to put Epstein's transactions in the appropriate context. See JPMC Ex . 60 ,i,i 22, 23, 91, 92. Disput ed insofar as USVI contends that this fact suppo1is an inference that JPMorgan paiiicipated in Epstein 's alleged sex-trafficking venture. See CSMF ,i,i 108- 169. 233. JPMorgan also handled $5,600 in legal fees from Epstein's JPMorgan accounts for the benefit of three women . Ex. 56 at 40-41 and Figure 12 (copied below) . Figure 12: Legal Fees Pay ments for Women from the Epstein A ccounts Date Check# Payee Amount Memo line: 1/30/ 2009 2691 V incent A. Fuller, Jr. , Esq. $4,500.00 1/11/2012 3359 M. Arda Beskai·des, Esq. $600.00 8/21/2012 3412 M. Arda Beskai·des, Esq. $500.00 Total $5,600.00 JPMC Response: Undisputed that cited doc ument an d chaii ai·e summai·ies of transactions prepai·ed by USVI's proffered expert Jorge Amador. Disputed that this 123 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 5 of 99 234. infonnation was available to JPMorgan in this fo1mat during the time Epstein was a client f h d. d ! • I Disputed insofar as USVI contends that this fact suppo1is an inference that JPMorgan paii icipated in Epstein's alleged sex-trafficking venture. See CSMF ,i,i 108-169. Smaller Dollar and "Gift" Payments to Girls or Women and $100,000 Payments . Ex. 156 (2012 Jeffrey E. Epstein Gift Tax Return) - - - - - - 124 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 6 of 99 . - - - - - - - - - - - - - - - - 125 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 7 of 99 - - - - - - - - - - - - - - 126 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 8 of 99 • --- - - - JPMC Response: Undisputed that this is a summaiy of transactions prepared by U SVI's proffered expe1i Jorge Amador. Disputed that this info1mation was available to JPMorgan in this fo1mat during the time Epste in was a client of JPMorgan. Disputed as to whether the persons listed were minors when they received the payments as their age is 127 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 9 of 99 235. - not provided in the cited source. Disputed as to materiality to the extent this summa1y fails to put Epste in's transactions in the appropriate context. See JPMC Ex. 60 ,i,i 22, 23, 91, 92. Disputed insofar as USVI contends that this fact suppo1i s an inference that JPMorgan paiiicipated in Epstein's alleged sex-trafficking venture. See CSMF ,i,i 108-169. 128 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 10 of 99 129 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 11 of 99 236. JPMC Response: Undisputed that this is a summaiy of transactions prepared by USVI. Disputed that this info1mation was available to JPMorgan in this fonnat during the time Epstein was a client of JPMorgan. Further disputed as to materiality of these payments based on the am ounts or that the are rovided to attome s and law foms. See JPMC Ex. 60 91 & n .166 Disputed insofar as USVI contends that this fact suppo1 is an inference that JPMorgan paii icipated in Epstein's alleged sex-trafficking venture. See CSMF ,i,i 108-169. 130 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 12 of 99 131 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 13 of 99 237. JPMC Response: Undisputed that this is a summaiy of transactions prepai·ed by USVI. Disput ed that this info1m ation was available to JPMorgan in this fon nat during t h e time Epstein was a client of JPMorgan. Disput ed as to whether the persons listed were minors when they received the payments as their age is not provided in the cited source. Disput ed as to materiality to the extent this summaiy fails to put Epstein's transactions in th e appropriate context. See JPMC Ex . 60 ,i,i 22, 23, 91, 92. Disput ed insofar as USVI contends that this fact suppo1is an inference that JPMorgan paiiicipated in Epstein 's alleged sex-trafficking venture. See CSMF ,i,i 108-169. JPMC Response: Undisputed that this is a summaiy of transactions prepai·ed by USVI. Disput ed that this info1m ation was available to JPMorgan in this fon nat during the time Epstein was a client of JPMorgan. F miher disputed as to materiality of these payments 132 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 14 of 99 from Epstein to a communications and reputation management fnm to any ofUSVI's claims aga inst JPMC. See JPMC Ex.64. Disputed insofar as USVI contends that this fact suppo1 is an inference that JPMorgan paiiicipated in Epstein's alleged sex-trafficking venture. 238. From September 2006 through December 2006, JPMorgan handled $883,750.00 in payments from Epstein's accounts to Alan Dershowitz, Roy Black, Gerald Le/court, and Jack Goldberger (relevant transactions identified and summarized in the chart below) . 239. JPMC Response: Undisputed that this is a summaiy of transactions prepared by USVI. Disputed that this info1mation was available to JPMorgan in this fon nat during the time Epstein was a client of JPMorgan. Further disputed as to materiality or r elevan ce of payments from Epste in to his attom e san d law fnms to USVI's claims in this matter. See JPMC Ex. 60 91 & n.166 Disputed in sofai· as USVI contends that this fact suppo1is an inference that JPMorgan paiiicipated in Epstein's alleged sex-trafficking venture. See CSMF ,i,i 108-169. Date Payee Amount 1/2/2007 AL AN M. DERSHOWITZ $178,000.00 2/7/2007 AL AN M. DERSHOWITZ $78,292.50 4/3/2007 AL AN M. DERSHOWITZ $137,458.00 5/9/2007 AL AN M. DERSHOWITZ $75,000.00 133 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 15 of 99 JPMC Response: Undisputed that this is a summaiy of transactions prepai·ed by USVI. Disputed that this info1mation was available to JPMorgan in this fonnat during the time 134 Case 1:22-cv-10904-JSR Document 284-4 Filed 08/14/23 Page 16 of 99 Epstein was a client of JPMorgan. Fmther disputed as to materiality or relevan ce of payments from Epstein to his attome san d law fnms to USVI's claims in this matter. See JPMC Ex. 60 91 & n.166 Disputed insofar as USVI contends that this fact suppo1t s an inference that JPMorgan pait i