EPSTEIN
page 4 / 1980 . OCR, unverified
other cases. I have attached the Government's amended complaint and the two complaints to which it is
consolidated. See order below. Thanks.
ORDER: Barring any objection from plaintiff Government of the United States Virgin Islands, which must be made by joint
telephone call to Chambers no later than 5:00 PM on January 4, 2023, this case is hereby consolidated for all pretrial
purposes with Doe v. Deutsche Bank, 22- cv-10018 and Doe v. JP Morgan Chase & Co., 22-cv-10019. Further, except for
any motion to dismiss, this case will be governed by the case management plan dated December 5, 2022, previously
entered in those cases. See Doe v. Deutsche Bank, 22-cv-10018, Dkt. 23; Doe v. JP Morgan Chase & Co., 22-cv-10019,
Dkt. 16. Counsel for the Government of the United States Virgin Islands and counsel for JP Morgan Chase Bank, N.A.
should jointly call Chambers, again by no later than 5:00 PM on January 4, 2023, to set a schedule for any motion to
dismiss in this case. SO ORDERED. (Signed by Judge Jed S. Rakoff on 12129/2022) Filed In Associated Cases: 1:22-cv-
10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR (kv) (Entered: 12/30/2022)
Kind regards,
Office of the United States Attorney
Civil Chief
EFTA00161834
--- PAGE 3 ---
5500 Veterans Drive, Suite 260
Ron de Lugo Federal Building
St. Thomas, VI 00802
Attorney-Client Privilege/Attorney Work Product: This communication, along with any attachments, is covered by federal and state
law governing electronic communications and may contain confidential and legally privileged information. If the reader of this
message is not the intended recipient, you are hereby notified that any dissemination, distribution, use, or copying of this message is
strictly prohibited. If you received this message in error, please reply immediately to the sender and delete this message.
EFTA00161835
--- SOURCE: 0015__EFTA00161836.txt ---
METADATA_SOURCE: 0015
METADATA_FILENAME: EFTA00161836.pdf
----------------------------------------
Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 1 of 34
UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF NEW YORK
GOVERNMENT OF THE UNITED
)
STATES VIRGIN ISLANDS
)
PLAINTIFF,
V.
JPMORGAN CHASE BANK, N.A.
DEFENDANT.
)
)
)
)
Case Number: I:22-cv-10904 JSR
ACTION FOR DAMAGES
JURY TRIAL DEMANDED
FIRST AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL
Plaintiff Government of the United States Virgin Islands ("Government") files this
Complaint against JPMorgan Chase Bank, N.A. ("JP Morgan") for violations of Trafficking
Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and
Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and
Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges as
follows:
PARTIES
I.
The Attorney General of the United States Virgin Islands (hereinafter "Virgin
Islands") brings this parens patriae action on behalf of the Plaintiff, Government of the Virgin
Islands, pursuant to 15 U.S.C. § 1595(d) and 3 V.I.C. § 114 and her statutory authority to enforce
the laws of the Virgin Islands and protect public safety.
2.
The Attorney General, pursuant to her authority to represent the Government of the
United States Virgin Islands, also acts on behalf of, and with the lawfully delegated authority of,
the Virgin Islands Department of Licensing and Consumer Affairs under 12 V.I.C. § 327 in regard
to Count Four of the Government's Complaint alleging violations of the Virgin Islands Consumer
EFTA00161836
--- PAGE 2 ---
Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 2 of 34
Fraud and Deceptive Business Practices Act.
3.
This action stems from an enforcement action the Government filed against the
Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey
Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations
Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke et at, Case No. ST-20-
CV-14 (Super. Ct. V.I. Jan. 15, 2020). The Attorney General brings this action, after presenting
her findings to JP Morgan in September 2022, in her ongoing effort to protect public safety and to
hold accountable those who facilitated or participated in, directly or indirectly, the trafficking
enterprise Epstein helmed. The investigation revealed that JP Morgan 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. Financial
institutions can connect—or choke—human trafficking networks, and enforcement actions filed
and injunctive relief obtained by attorneys general are essential to ensure that enterprises like
Epstein's cannot flourish in the future.
4.
Defendant JPMorgan Chase Bank, N.A. is an American multinational investment