📧 Communication

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.