Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/238-49.pdf
usvi-v-jpmorgan Court Filing 985.1 KB • Feb 12, 2026
EXHIBIT 74
Case 1:22-cv-10904-JSR Document 238-49 Filed 07/25/23 Page 1 of 5
Case 1:22-cv-10904-JSR Document 238-49 Filed 07/25/23 Page 2 of 5
From:
To:
CC:
Sent:
Subject:
Attachments:
Hi
Paul-
Bonnie
K Perry
<bonnie.k
.perry@jpmorgan
.com>
Paul
V Morris
<paul.v.morris@jpmorgan
.com>
Mary
C Casey
<mary
.c.casey@jpmorgan
.com>;James
Dalessio
<James.Dalessio@jpmorgan
.com>
6/9/2010
10
:16:07
PM
Jeffrey
Epstein
Epstein
Article
- dtd.
6-9-2010.pdf;
Epstein
Article
dtd.
5-27
-2010
.pdf
,
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-,
..'.
have
_ regressed_the_
DDR
__ back
to
you
.for _additional
_ informati
_on
.
.
L.
....
......
..
_____
_
___
_
Redacted
_ -
_Privileg
_
ed
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···
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J
i
Redacted
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-'
DDR
Name:
Jeffrey
Epstein
,,,
DDR
Link
->
Notes://PPUSMC017/85256F64005749BC/6BCDEBE8A049C44485256E6F0063C802
/SEE4238F2F8C2E1485256D2400745A6D
Please
update
the
Transaction
Profile/Expected
account
activity
- specifically,
please
note
monthly
cash
withdrawal
activity,
ranging
$30k
to
$50k
and
the
purpose
of
these
cash
withdrawals
.
Please
update
the
summary
to
include
the
client's
current
personal
circumstances
, business
activities,
etc.
I have
attached
a couple
of
articles
to
assist.
Further,
please
update
the
"Financial
Trust
Company
Inc
." DOR
- last
update
2003
.
This
entity
holds
the
bulk
of
the
wealth
held
for
Mr.
Epstein
within
the
relationship.
DDR
Name:
Financial
Trust
Company,
Inc.,,,
DDR
link
->
Notes
://PPUSMC017
/85256F64005749BC/58A38C458E8182CD8525727C0067562D
/26A36B1774A08A5485256D240076F422
Since
this
is a BVI
entity
, please
ensure
that
you
obtain
evidence
of
tax
declaration
(e .g
.,
a statement
from
the
lawyer
I
accountant and
5 yrs
of
tax
statements).
3 entities
within
the
relationship
do
not
currently
have
DD
Rs
. Please
create
DDRs
for
the
following
entities
:
116
East
65th
St
LLC
NES,
LLC
Zorro
Trust
If you
have
any
questions,
please
feel
free
to
contact
either
me
or
Jim
Dalessio
.
Thanks,
Bonnie
Bonnie
K
Perry,
VP,
CAMS
I
Pri
Ya
te Bauk
Risk
l\Igmt
&
Co
ntrol
7
12
;\
fain
, 4th
Fl ,
Hou
sto
n ,
TX
7700
2 (Di:
2-N
04S
)
Te
l:
7
13
.2 16
-.513
6
Fax:
'7
13
.216
-79
70
Confidential
EXHIBIT
3C
WIT:
~~
DATE:
=~
C.
Campbell
,
ROR
CRR
CSR
#
13921
JPM
-SDNYLIT-00008237
Case 1:22-cv-10904-JSR Document 238-49 Filed 07/25/23 Page 3 of 5
Local
ATTORNEYS
SETTLE
FEE
DISPUTE WITH
BILLIONAIRE
LAW
FIRM
HAD
SOUGHT
MONEY
FOR
LEGAL
BILLS
FROM
SEX
OFFENDER
By
Jane
Musgrave
The
Palm
Beach
Post
314words
9 June
2010
South
Florida
Sun-Sentinel
FLSS
Palm
Beach
3B
English
Copyright
2010,
South
Florida
Sun-Sentinel.
All
Rights
Reserved.
A $2
million
dispute
between
billionaire
sex
offender
Jeffrey
Epstein
and
attorneys
who
represented
15
women
who
claimed
the
Palm
Beach
resident
sexually
abused
them
is
apparently
over.
In
court
papers
filed
late
Monday,
attorneys
representing
Miami
law
firm
Podhurst
Orseck
said
a settlement
had
been
reached
with
Epstein.
Terms
of
the
agreement
weren't
spelled
out.
Podhurst
Orseck
filed
suit
against
Epstein
last
month,
claiming
his
refusal
to
pay
its
legal
bill
constituted
a
violation
of
an
agreement
the
money
manager
signed
to
escape
federal
charges.
As
part
of
the
2007
plea
deal,
Epstein
agreed
to
pay
attorneys
to
negotiate settlements
on
behalf
of
the
33
women
who
told
federal
prosecutors
he
had
paid
them
for sexually
charged
massages
at
his
Palm
Beach
mansion
when
some
were
as
young
as
14.
Twelve
of
the
women
sought
the
help
of
Podhurst
partner
Robert
Josefsberg,
who
was
appointed
to
negotiate
settlements.
He
also
represented
three
women
in
civil
lawsuits that
were
also
settled
for
undisclosed
amounts.
About
a dozen
other
women
hired
other
attorneys
to
represent
them.
Most
of
those
lawsuits
are
still
pending.
Epstein,
57,
argued
that
Podhurst
inflated
its
costs.
He
said
he
had
already
paid
the
firm
roughly
$500,000
and
didn't
believe
he
owed
another
$2
million.
He
offered
to
put
$2
million
in
a court
registry
until
the
dispute
was
resolved.
Epstein
pleaded
guilty
to
two
sex-related
charges
and
was
released
from
the
Palm
Beach
County
jail
in
July
after
serving
13
months
of
an
18-month
jail
sentence.
In
return,
federal
prosecutors
agreed
not
to
pursue
him
for
crimes
that
could
have
sent
him
to
prison
for
decades.
Billionaire
sex
offender
Jeffrey
Epstein
had
argued
law
finn
inflated
its
costs.
Photo(s)
DocumentFLSS000020100609e6690003z
Page
1
of
1
2010
Factiva,
Inc.
All
rights
reserved.
Confidential
JPM-SDNYLIT-00008238
Case 1:22-cv-10904-JSR Document 238-49 Filed 07/25/23 Page 4 of 5
A SECTION
JUDGE ORDERS N.Y. PAPER\ TO GIVE UP EPSTEIN TAPE
By MICHELE DARGAN Daily News Staff Writer
529 words
27 May 2010
Palm Beach Daily News
PBDN
DN1
1A
English
Copyright 2010 The Palm Beach Daily News. All Rights Reserved.
Palm Beach Post File Photo by Uma Sanghvi\
Jeffrey Epstein, shown in this 2008 file photo, spoke to 'New
York Daily\ News' reporter George Rush on tape. Since Epstein has asserted his Fifth\ Amendment privilege
in depositions, the taped conversation is the only way\ the jury can hear Epstein in his own words, attorneys
for client Jane Doe\ say.
The
New York Daily News must turn over a tape-recorded interview between reporter George Rush and sex
offender
Jeffrey Epstein because the information cannot be obtained anywhere else and outweighs
reporter's privilege, a federal judge has ruled.
Attorneys Brad Edwards and Paul Cassell have been fighting to obtain the tape
in representing their client
Jane Doe, a minor at the time
of Epstein's abuse. Since Epstein has asserted his Fifth Amendment privilege
in depositions, the taped conversation is the only way the jury can hear Epstein in his own words, the
attorneys say.
After listening to the 22-minute recording and reading the transcript, Manhattan U.S. District Judge Lawrence
McKenna agreed
in his six-page ruling.
Of particular relevance, McKenna noted "a statement included in the first full paragraph attributed to Mr.
Epstein
at page 15 of the transcript ... the court finds that the materials at issue 'are not reasonably
obtainable from other available source' ... since the record
is quite clear that Mr. Epstein has regularly been
asserting, and will continue
to assert, his Fifth Amendment privilege to relevant questions. The fact that the
recording is
in Mr. Epstein's own voice is also significant from a trial perspective."
Portions
of the recording can be used related to liability and damages, the ruling says.
But whether the attorneys
will have the tape in time for the start of their July 17 trial is still in question.
The judge's order says the recording and transcript will be held
in chambers or under seal until any appeal is
decided or the time to file a notice of appeal has expired.
'We're happy that the court agreed with our argument that this important evidence supporting Jane Doe's
case can be presented to the jury," Cassell said by phone Tuesday.
Laura Handman, attorney
for the New York Daily News, said they are appealing the decision.
Epstein, 57, pleaded guilty last year to soliciting a minor for pros
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