JP Morgan's Memorandum In Law In Opposition To Jes Staley's Motion To Dismiss (Part 3) (7/7/24)

Beyond The Horizon

JPMorgan Chase Bank N.A.'s memorandum of law in opposition to James Edward Staley’s motion to dismiss addresses several key points:

1. Responsibility and Knowledge: JPMorgan argues that James Staley, as a senior executive, played a significant role in managing the relationship with Jeffrey Epstein. They assert that Staley was aware, or should have been aware, of Epstein's illegal activities and failed to take appropriate action to address or report these issues.
2. Claims of Misconduct: The memorandum highlights specific allegations that Staley facilitated Epstein's criminal enterprise by maintaining and managing Epstein's accounts, even after red flags were raised. This includes allegations of willful blindness and failure to comply with legal and regulatory obligations.
3. Legal Arguments: JPMorgan contends that Staley's motion to dismiss lacks merit because the claims against him are well-supported by evidence and legal precedent. They argue that the allegations, if proven true, establish a clear basis for Staley's liability in connection with Epstein's activities.
4. Fiduciary Duties: The bank emphasizes that Staley breached his fiduciary duties by prioritizing the bank's financial interests over legal compliance and ethical standards. This breach of duty, JPMorgan argues, justifies the continuation of legal proceedings against him.
5. Impact on the Bank: JPMorgan also addresses the reputational and financial damage caused by Staley's alleged misconduct. They claim that his actions have led to significant legal and regulatory scrutiny, which has harmed the bank’s standing and operations.

The opposition memorandum seeks to ensure that Staley remains a party to the lawsuit, holding him accountable for his alleged role in facilitating Epstein's criminal conduct
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source:
gov.uscourts.nysd.591653.140.0.pdf (courtlistener.com)