EFTA02527192

JPMorgan Epstein filing (lifted redactions)

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Plaintiff, v. JP MORGAN CHASE BANK, N.A., Defendant. Case No. 22-cv-10904 (JSR) JPMORGAN CHASE BANK, N.A.’S OPPOSITION TO USVI’S MOTION TO STRIKE AFFIRMATIVE DEFENSES Case 1:22-cv-10904-JSR Document 165 Filed 05/25/23 Page 1 of 30 i TABLE OF CONTENTS PRELIMINARY STATEMENT ...............................................................................................

influence local politicians, and says

influence local politicians, and says deJongh even asked Epstein to suggest changes to the territory's sex offender law "Epstein's primary conduit for spreading money and influence throughout the USVI government was First Lady delongh," who worked as Epsteins local fixer for two decades, including throughout her husband John delongh Jns tenure as V.I. gover- nor from 2007 to 2015, according to the filing. Delongh told Epstein which govern- ment officials to pay off, and devised ways to justify his victims' presence in the territory by enrolling them at the University of the Virgin Islands so they could obtain student visas, according to the filing. In a statement to The Daily News on Thursday, UV[ President David Hall denied all allegations in the bank's filing. Attorneys for the bank say docu- ments obtained during the discovery process, which is still ongoing, show that deJongh asked Epstein -- a registered sex offender — to suggest changes to the territory'

From: Cecile de Jongh.

From: "jeffrey E." <jeevacation®gmail.com>

EFTA02658085

Friday, May 26, 2023

Friday, May 26, 2023 very projects f. . John is currently mitigated with a steel plate. The !king to rehabilitate sections of the road. heard on onal Park ehabilitatc mon Bay of Honey- ;outhwest. House, an t between !aches. nent fail- s threaten suit in a sections construe- aid Kim second area of erosion. The project will involve instal- lation of a mechanically stabilized earth retaining wall at one site, and installation of a rock face trapezoi- dal rockery wall at the second site. In response to questioning from St. John CZM Committee member Rafe Boulon, Campo-Allen said native stone will be used, and the rockery wall's facade was chosen with the viewshed in mind. Campo-Allen said there are known archaeological sites close to, but not at, the two failing sections of road- Friday, May 26, 2023 VIRGIN ISLANDS The Virgin Islands Daily News 3 44 Epstein's primary conduit for spreading money and influence throughout the USVI government was First Lady