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Stephen Cutler

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030.pdf

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.

Legal memorandum (plaintiffs’ memorandum of law in opposition to defendants’ motions to dismiss)
2025-12-26
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Epstein

From: Stephen Cutler
To: Jes

Stated Epstein 'is not an honorable person in any way. He should not be a client.'

Email
2011-01-01
Communication Source

Epstein

From: Stephen Cutler
To: Mary Erdoes

'I would like to put it and him behind us. Not a person we should do business with, period.'

Email
2011-01-01
Communication Source

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