030.pdf
491 KB
Extraction Summary
19
People
9
Organizations
3
Locations
6
Events
4
Relationships
6
Quotes
Document Information
Type:
Legal memorandum (plaintiffs’ memorandum of law in opposition to defendants’ motions to dismiss)
File Size:
491 KB
Summary
This document is a Plaintiff's Memorandum of Law opposing a motion to dismiss a derivative lawsuit against JPMorgan Chase's board regarding their oversight of Jeffrey Epstein. It alleges that the Board, including CEO Jamie Dimon, ignored red flags about Epstein's sex trafficking and financial crimes (such as massive cash withdrawals) to retain him as a client, failed to implement required BSA/AML monitoring systems, and violated a Deferred Prosecution Agreement related to Madoff. The plaintiffs argue that demand on the board is excused because a majority of directors face liability or lack independence.
People (19)
| Name | Role | Context |
|---|---|---|
| Jamie Dimon | CEO of JPMorgan Chase & Co. |
Accused of turning a blind eye to Epstein's crimes; allegations suggest he knew of violations but took no action; con...
|
| James E. Staley | Former JPM Executive (Second-in-command) |
Had close ties to Epstein; accused of sexual assault of an Epstein victim; discussed Epstein with Dimon in 2006 and 2...
|
| Jeffrey Epstein | JPM Client / Convicted Felon |
Used JPM accounts to facilitate sex trafficking; registered sex offender; client from 1998 to 2013.
|
| Ghislaine Maxwell | Epstein Associate |
Applied to open a new account in August 2011 for a 'personal recruitment consulting business', flagged as High Risk.
|
| Stephen Cutler | JPM General Counsel |
Sounded the alarm about Epstein; stated Epstein was 'not an honorable person' and should not be a client.
|
| Mary Erdoes | CEO of JPM’s Asset and Wealth Management |
Recipient of emails regarding Epstein's suitability as a client; knew in 2006 regarding abuse allegations.
|
| Burke | Board Member |
Accused of failing to implement BSA/AML reporting systems.
|
| Crown | Board Member |
Deceased (2023); Accused of failing to implement BSA/AML reporting systems; family controls General Dynamics.
|
| Flynn | Board Member |
Accused of failing to implement BSA/AML reporting systems.
|
| Bammann | Board Member / Former JPM Executive |
Accused of lacking independence from Dimon due to past professional success owed to him.
|
| Combs | Board Member |
Accused of failing to comply with DPA and Consent Orders.
|
| Neal | Board Member |
Accused of failing to comply with DPA and Consent Orders.
|
| Novakovic | Board Member / CEO of General Dynamics |
Accused of lacking independence from Crown family due to her role at General Dynamics.
|
| Kessler | Board Member (2004-2007) |
Accused of breach of fiduciary duty.
|
| Nelson | JPM Managing Director |
Met frequently with Epstein in New York and Santa Fe until 2017.
|
| Barrett | JPM Managing Director |
Met frequently with Epstein in New York and Santa Fe until 2017.
|
| Benjamin Netanyahu | Meeting Participant |
Epstein helped schedule a meeting for Dimon with him between 2009-2011.
|
| Bill Gates | Meeting Participant |
Epstein helped schedule a meeting for Dimon with him between 2009-2011.
|
| Prince Andrew | Meeting Participant |
Epstein helped schedule a meeting for Dimon with him between 2009-2011.
|
Organizations (9)
Timeline (6 events)
2006
Epstein arrested for soliciting a minor; Staley spoke with Dimon about maintaining him as a client.
Unknown
2008
Epstein pleads guilty; Staley spoke with Dimon about maintaining him as a client.
Unknown
2009-2011
Epstein helped schedule meetings for Dimon with high profile individuals.
Unknown
Locations (3)
| Location | Context |
|---|---|
Relationships (4)
Epstein helped schedule meetings for Dimon with Netanyahu, Gates, and Prince Andrew.
Staley tasked to 'get to know' Epstein; Staley discussed Epstein with Dimon multiple times; Staley accused of sexual assault of Epstein victim.
Bammann owes significant portion of professional success to Dimon; worked under him at Bank One and JPM.
Novakovic is CEO of General Dynamics, where Crown family has substantial influence.
Key Quotes (6)
"Epstein is not an honorable person in any way. He should not be a client."Source
030.pdf
Quote #1
"I would like to put it and him behind us. Not a person we should do business with, period."Source
030.pdf
Quote #2
"pending [Jamie] Dimon review"Source
030.pdf
Quote #3
"get to know him"Source
030.pdf
Quote #4
"What does she mean by personal recruitment?? Are you sure this will have nothing to do with Jeffrey?"Source
030.pdf
Quote #5
"An officer who receives credible information indicating that the corporation is violating the law cannot turn a blind eye and dismiss the issue as ‘not in my area.’"Source
030.pdf
Quote #6
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