Raymond
PersonRelationship Network
Event Timeline
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| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | Court case | The court case United States v. Raymond, where grooming testimony from expert Ken Lanning was exc... | N/A | View |
| 2021-04-23 | N/A | Plea Hearing | SDNY Court | View |
| 2019-07-08 | N/A | Acknowledgment of success regarding the 'Epstein case' (likely referring to his arrest which occu... | Unknown | View |
040.pdf
This document is a court order from the Southern District of New York dated November 7, 2023, granting attorney John McNichols of Williams & Connolly LLP admission *pro hac vice* to represent defendant James Edward Staley. The case involves the Operating Engineers Construction Industry and Miscellaneous Pension Fund against JPMorgan Chase & Co. and several individual defendants, including James Dimon and James Staley.
019.pdf
This document is a Motion for Admission Pro Hac Vice filed on June 30, 2023, in the US District Court for the Southern District of New York. Attorney John McNichols of Williams & Connolly LLP seeks permission to represent defendant James Edward Staley in the case 'Operating Engineers Construction Industry and Miscellaneous Pension Fund v. James Dimon et al.', which names numerous JPMorgan Chase executives and board members as defendants.
019-05.pdf
A proposed court order filed on June 30, 2023, in the Southern District of New York, granting attorney John McNichols of Williams & Connolly LLP admission *pro hac vice* to represent defendant James Edward Staley. The underlying case involves a lawsuit by the Operating Engineers Construction Industry and Miscellaneous Pension Fund against JPMorgan Chase executives, including Jamie Dimon and Mary Erdoes.
019-01.pdf
This document is an affidavit filed on June 30, 2023, by John McNichols, a partner at Williams & Connolly LLP, supporting his motion to appear pro hac vice in the case of Operating Engineers Construction Industry and Miscellaneous Pension Fund v. James Dimon, et al. The case involves JPMorgan Chase & Co. as a nominal defendant and lists numerous individual defendants including James Dimon and James E. Staley. McNichols attests to his good standing with the bars of Maryland, Virginia, and D.C., and lack of criminal or disciplinary history.
016.pdf
This document is a Civil Case Management Plan filed on June 27, 2023, in the Southern District of New York for the case 'Operating Engineers Construction Industry... v. James Dimon, et al.' (Case 1:23-cv-03903-JSR). It outlines the scheduling order for the lawsuit brought by shareholders against JPMorgan's board of directors and executives (including Jes Staley) regarding the bank's relationship with Jeffrey Epstein. The plan sets deadlines for motions to dismiss (July 2023), discovery completion (November 2023), and summary judgment motions (late 2023/early 2024), with a trial readiness date set for January 19, 2024. Handwritten notes by Judge Rakoff modify several specific deadlines.
015.pdf
This document is a Notice of Appearance filed on June 22, 2023, in the U.S. District Court for the Southern District of New York (Case No. 23-cv-03903-JSR). Attorney Jacobus J. Schutte from Paul, Weiss, Rifkind, Wharton & Garrison LLP enters his appearance as counsel for a specific group of eighteen defendants, including Linda B. Bammann and James A. Bell, in a lawsuit involving JPMorgan Chase & Co. and its executives/board members (including James Dimon and James E. Staley). The plaintiff is the Operating Engineers Construction Industry and Miscellaneous Pension Fund.
014.pdf
This document is a Notice of Appearance filed on June 22, 2023, in the United States District Court for the Southern District of New York (Case No. 23-cv-03903-JSR). Attorney Jessica S. Carey of Paul, Weiss, Rifkind, Wharton & Garrison LLP is entering her appearance as counsel of record for a large group of individual defendants—primarily board members and executives—in a lawsuit brought by the Operating Engineers Construction Industry and Miscellaneous Pension Fund against JPMorgan Chase & Co. (nominal defendant) and its leadership.
013.pdf
This document is a Notice of Appearance filed on June 22, 2023, in the US District Court for the Southern District of New York (Case No. 23-cv-03903-JSR). Attorney Audra J. Soloway of Paul, Weiss, Rifkind, Wharton & Garrison LLP formally enters her appearance as counsel for a specific group of defendants, including Linda B. Bammann, James A. Bell, and others, in a lawsuit filed by the Operating Engineers Construction Industry and Miscellaneous Pension Fund against JPMorgan Chase & Co. directors and officers. The case appears to be a shareholder derivative suit involving JPMC leadership, including James Dimon and James E. Staley.
008.pdf
A court order from the Southern District of New York in the case of Operating Engineers Construction Industry v. James Dimon, et al. (Case 1:23-cv-03903-JSR). Judge Jed S. Rakoff granted the motion for attorney Michael J. Barry of Grant & Eisenhofer P.A. to appear *pro hac vice* as counsel for the plaintiff. The lawsuit names numerous JPMorgan executives, including James Dimon and James E. Staley, as defendants.
007.pdf
Order from the U.S. District Court for the Southern District of New York, dated June 9, 2023, granting Christine M. Mackintosh of Grant & Eisenhofer P.A. admission pro hac vice to represent the plaintiff, Operating Engineers Construction Industry and Miscellaneous Pension Fund. The lawsuit names JPMorgan Chase & Co. as a nominal defendant and numerous individual defendants, including James Dimon and James E. Staley.
006.pdf
This document is a Motion for Admission Pro Hac Vice filed on June 6, 2023, in the Southern District of New York. Attorney Michael J. Barry of Grant & Eisenhofer P.A. seeks permission to represent the plaintiff, Operating Engineers Construction Industry and Miscellaneous Pension Fund, in a lawsuit against JPMorgan Chase & Co. and various individual defendants, including James Dimon and James E. Staley.
006-01.pdf
This document is a legal declaration filed on June 6, 2023, by attorney Michael J. Barry of Grant & Eisenhofer P.A. He is applying for admission pro hac vice (to practice in this specific case) in the Southern District of New York. The case (1:23-cv-03903) involves the Operating Engineers Construction Industry and Miscellaneous Pension Fund as plaintiff against numerous JPMorgan Chase & Co. executives and board members, including James Dimon and James 'Jes' Staley, likely regarding a shareholder derivative suit related to the bank's ties to Jeffrey Epstein.
005.pdf
This document is a Motion for Admission Pro Hac Vice filed on June 6, 2023, in the Southern District of New York. Attorney Christine M. Mackintosh of Grant & Eisenhofer P.A. seeks permission to represent the plaintiff, Operating Engineers Construction Industry and Miscellaneous Pension Fund, in a lawsuit against JPMorgan Chase & Co. and its executives/board members (including James Dimon and James E. Staley). The motion confirms Mackintosh's good standing with the bars of Pennsylvania and Delaware.
005-01.pdf
This document is a declaration filed on June 6, 2023, by attorney Christine M. Mackintosh of Grant & Eisenhofer P.A. seeking admission pro hac vice in the US District Court for the Southern District of New York. The filing is part of a shareholder derivative lawsuit (Case 1:23-cv-03903-JSR) brought by the Operating Engineers Construction Industry and Miscellaneous Pension Fund against JPMorgan Chase executives, including James Dimon and James E. Staley, regarding the bank's oversight.
003.pdf
This document is a 'Related Case Statement' filed on May 9, 2023, in the Southern District of New York. It formally links a new shareholder derivative lawsuit filed by the Operating Engineers Pension Fund against JPMorgan's board of directors (Case 1:23-cv-03903) with two existing cases filed by Jane Doe 1 and the US Virgin Islands against JPMorgan (Cases 22-cv-10019 and 22-cv-10904). The filing argues that all cases share a common factual basis regarding JPMorgan's relationship with Jeffrey Epstein, specifically alleging that the bank facilitated his abuse and that the board failed in its oversight duties.
002.pdf
This document is a Civil Cover Sheet (Form JS 44) and an attached list of defendants filed on May 9, 2023, in the Southern District of New York. The filing initiates a derivative lawsuit by 'Operating Engineers Construction Industry and Miscellaneous Pension Fund' against the board and executives of JPMorgan Chase & Co., including Jamie Dimon and Jes Staley. The cover sheet notes the case is related to existing cases 22-10019 (USVI v. JPM) and 22-10904 (Doe v. JPM) presided over by Judge Jed S. Rakoff, which were high-profile lawsuits concerning JPMorgan's relationship with Jeffrey Epstein.
EFTA00030187.pdf
This document is an email thread from July 2019 between Raymond L. Colon and a redacted individual. Colon congratulates the individual on a 'Job well done' regarding the 'Epstein case,' likely referencing Jeffrey Epstein's arrest which occurred days prior. The recipient replies with thanks.
EFTA00015630.pdf
This document is an email thread from July 8-9, 2019, between attorney Raymond L. Colon and a redacted individual (likely a prosecutor or court official). The discussion centers on scheduling a plea hearing at the Magistrate's Court in room 5A for July 10, 2019, and exchanging a plea agreement. Notably, on July 8, Colon congratulates the recipient on a 'Job well done' regarding 'the Epstein case,' coinciding with Jeffrey Epstein's arrest in July 2019.
DOJ-OGR-00005804.jpg
This legal document is a page from a court filing, specifically Document 397 in case 1:20-cr-00330-PAE, filed on October 29, 2021. The text argues for the admissibility of expert testimony from a Dr. Rocchio, who would explain the psychological dynamics of abusive relationships to help the jury understand why victims might act in counterintuitive ways, such as returning to an abuser. The document cites several other cases to support the argument that such dynamics are beyond the common knowledge of an average juror, while also noting the defendant's objection that this type of testimony is not how Rule 702 is meant to work.
DOJ-OGR-00005797.jpg
This document is a page from a legal filing (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell trial) dated October 29, 2021. The text argues for the admissibility of expert testimony regarding 'grooming' and the psychological relationship between sexual abuse victims and perpetrators, citing numerous appellate court precedents (9th, 8th, 10th, 5th, and 2nd Circuits) to support the validity/relevance of such testimony. The filing notes that the defendant is attempting to rely on a single contrary case from the District of Maine.
DOJ-OGR-00005640.jpg
This legal document, page 16 of a filing from October 29, 2021, argues that the proposed expert testimony and 'grooming opinions' of an individual named Roccio should be deemed inadmissible. The author contends that Roccio's testimony is substantially more prejudicial than probative under Rule 403, fails to meet the Daubert standard for scientific reliability, and oversimplifies complex issues, thereby risking misleading the jury. The argument is supported by citations from several court cases, including United States v. Burns and Gonyer, which criticize similar 'grooming theories'.
DOJ-OGR-00005639.jpg
This document is a legal filing, specifically page 15 of Document 386 in case 1:20-cr-00330-PAE, filed on October 29, 2021. The author argues that the expert testimony of an individual named Rocchio regarding 'grooming' should be deemed inadmissible because it is not based on scientific studies, is too general, and will not help the jury understand the specific facts of the case. The argument relies on legal precedents from cases like Daubert, Raymond, and Gonyer to assert that Rocchio's opinions do not meet the standard for expert testimony.
DOJ-OGR-00005637.jpg
This document is a page from a legal filing (Document 386 in Case 1:20-cr-00330-PAE, filed on October 29, 2021) arguing against the reliability of certain expert testimony. It cites the precedent of *United States v. Raymond*, where the court excluded expert Ken Lanning's testimony on grooming because it lacked objective benchmarks and was deemed unreliable. The filing suggests the current court should follow this precedent and also notes that another individual, Rocchio, while a treatment provider for victims, lacks experience in evaluating perpetrators.
HOUSE_OVERSIGHT_017262.jpg
This document appears to be a page from a manuscript or memoir (likely by Alan Dershowitz, given the context of the 'Tison v. Arizona' case discussed) describing Supreme Court oral arguments. The text details the legal debate regarding the 'felony murder' rule, specifically whether the brothers (Ricky and Raymond) had the specific intent to kill the Lyons family or were merely present. The document bears a House Oversight Bates stamp, indicating it was part of the Congressional investigation into the handling of the Epstein case, likely included to illustrate the author's legal philosophy or history.
RE: Congratulations
Confirming no changes to plea agreement sent on 7/3 and scheduling plea for July 10 at 11:30 a.m. in Courtroom 5A.
Re: Congratulations
Requesting the plea agreement be sent today.
Re: Congratulations
Asking for confirmation on time for 'tomorrow'.
RE: Congratulations
Thank you -- I appreciate it.
Re: Congratulations
'Job well done. Congratulations on the Epstein case.'
Congratulations
Job well done. Congratulations on the Epstein case.
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