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Japan doesn't dominate semiconductor fabrication or lithography machines like it once did. But they still keep a mighty grip on the supply chain, particularly one very special chemical. The photoresist is often ignored, we just kind of offhandedly mention it at the end there. But without question, it is the most important chemical of the lithography process. Literally indispensable. Some 90% of this market is held by Japanese companies like JSR and Tokyo Ohka Kogyo, amongst others. One of those companies is today state-owned. In this video, we examine the many generations of photoresist used by the industry and Japan's low-key monopoly of it.
Japan doesn't dominate semiconductor fabrication or lithography machines like it once did. But they still keep a mighty grip on the supply chain, particularly one very special chemical. The photoresist is often ignored, we just kind of offhandedly mention it at the end there. But without question, it is the most important chemical of the lithography process. Literally indispensable. Some 90% of this market is held by Japanese companies like JSR and Tokyo Ohka Kogyo, amongst others. One of those companies is today state-owned. In this video, we examine the many generations of photoresist used by the industry and Japan's low-key monopoly of it.
Writer, game designer, and friend of the show merritt k joins the panel to discuss GDQ runs, the Radiohead of video games, and skeleton bone boobs. Hosted by Alex Jaffe, with Frank Cifaldi, Ash Parrish, Brandon Sheffield, and merritt k. Edited by Esper Quinn, original music by Kurt Feldman. Watch episodes with full video on YouTube Discuss this episode in the Insert Credit Forums SHOW NOTES: alexjaffe.bsky.social frankcifaldi.bsky.social adashtra.bsky.social brandon.insertcredit.com merrittk.com mastodon.social dril 1: If you had to design and perform a gimmicky GDQ speedrun, what would it be? (05:13) Games Done Quick New Super Mario Bros. Wii While Playing Piano by Wes in 41:20 - Awesome Games Done Quick 2025 Bucephalus Elden Ring Peanut Butter the Dog Gyromite Ken Griffey Jr Presents Major League Baseball Ken Griffey Jr. Presents MLB by Peanut Butter the Dog & JSR_ in 29:48 - Summer Games Done Quick 2024 Elden Ring on Saxophone by Dr. Doot in 29:22 - Awesome Games Done Quick 2025 ALF Sonic & Knuckles Star Control 3 2: What are the popular games within the monsterfucking community? (12:03) Sonic the Hedgehog Sonic the Werehog Wolf Werewolf Knuckles the Echidna Shadow the Hedgehog Sonic the Hedgehog 3 (2024) Baldurs Gate III Undertale Sans Undertale Frank Quitely Thanos Death I Love You Colonel Sanders Lady Dimitrescu Resident Evil: Village 3: What tricks do video games do to convince players that they're much bigger than they actually are? (18:39) Banjo-Kazooie Persona series Demonschool Resident Evil series Final Fantasy VII Ryū ga Gotoku / Like a Dragon / Yakuza universe The Legend of Zelda: Majora's Mask Leisure Suit Larry Goes Looking for Love (In Several Wrong Places) Dwarf Fortress Bashi Bazook: Morphoid Masher 4: The Annual Public Domain Adaptation Game - Popeye (24:57) Popeye, Tintin among works entering U.S. public domain in 2025 Popeye Donkey Kong Popeye Olive Oyl Mickey Mouse Gasoline Alley Steve Urkel Steamboat Willie Sea Power Cat Power Paul Atredies Blondie Dagwood Bumstead Nancy Fritzi Ritz Jaws (1975) Dragon Quest Heroes: Rocket Slime Fleischer Studios Paramount Pictures Superman 5: a small rabite's mom asks, why are there so many deserts in video games? Every time I see you playing one of these things you're in a desert. (31:22) Gulf War Dune II: The Building of a Dynasty 6: What is the Radiohead of video games? (35:26) Radiohead Blue Bottle Coffee Ico Shadow of the Colossus Katamari Damacy Can You Pet the Dog? Tomb Radier Fumito Ueda LIGHTNING ROUND: GameFAQ&As - Draskula (39:31) Credit Report (44:57) Recommendations and Outro (45:30): merritt: Fledgling Manor Frank: Drac's Night Out Brandon: Send recommendations for movies about killin nazis, listen to Malice Mizer if you want to feel like a dracula Ash: Interview with the Vampire, make more games about killing klan members This week's Insert Credit Show is brought to you by patrons like you. Thank you. Subscribe: RSS, YouTube, Apple Podcasts, Spotify, and more!
Writer, game designer, and friend of the show merritt k joins the panel to discuss GDQ runs, the Radiohead of video games, and skeleton bone boobs. Hosted by Alex Jaffe, with Frank Cifaldi, Ash Parrish, Brandon Sheffield, and merritt k. Edited by Esper Quinn, original music by Kurt Feldman. Watch episodes with full video on YouTube Discuss this episode in the Insert Credit Forums SHOW NOTES: alexjaffe.bsky.social frankcifaldi.bsky.social adashtra.bsky.social brandon.insertcredit.com merrittk.com mastodon.social dril 1: If you had to design and perform a gimmicky GDQ speedrun, what would it be? (05:13) Games Done Quick New Super Mario Bros. Wii While Playing Piano by Wes in 41:20 - Awesome Games Done Quick 2025 Bucephalus Elden Ring Peanut Butter the Dog Gyromite Ken Griffey Jr Presents Major League Baseball Ken Griffey Jr. Presents MLB by Peanut Butter the Dog & JSR_ in 29:48 - Summer Games Done Quick 2024 Elden Ring on Saxophone by Dr. Doot in 29:22 - Awesome Games Done Quick 2025 ALF Sonic & Knuckles Star Control 3 2: What are the popular games within the monsterfucking community? (12:03) Sonic the Hedgehog Sonic the Werehog Wolf Werewolf Knuckles the Echidna Shadow the Hedgehog Sonic the Hedgehog 3 (2024) Baldurs Gate III Undertale Sans Undertale Frank Quitely Thanos Death I Love You Colonel Sanders Lady Dimitrescu Resident Evil: Village 3: What tricks do video games do to convince players that they're much bigger than they actually are? (18:39) Banjo-Kazooie Persona series Demonschool Resident Evil series Final Fantasy VII Ryū ga Gotoku / Like a Dragon / Yakuza universe The Legend of Zelda: Majora's Mask Leisure Suit Larry Goes Looking for Love (In Several Wrong Places) Dwarf Fortress Bashi Bazook: Morphoid Masher 4: The Annual Public Domain Adaptation Game - Popeye (24:57) Popeye, Tintin among works entering U.S. public domain in 2025 Popeye Donkey Kong Popeye Olive Oyl Mickey Mouse Gasoline Alley Steve Urkel Steamboat Willie Sea Power Cat Power Paul Atredies Blondie Dagwood Bumstead Nancy Fritzi Ritz Jaws (1975) Dragon Quest Heroes: Rocket Slime Fleischer Studios Paramount Pictures Superman 5: a small rabite's mom asks, why are there so many deserts in video games? Every time I see you playing one of these things you're in a desert. (31:22) Gulf War Dune II: The Building of a Dynasty 6: What is the Radiohead of video games? (35:26) Radiohead Blue Bottle Coffee Ico Shadow of the Colossus Katamari Damacy Can You Pet the Dog? Tomb Radier Fumito Ueda LIGHTNING ROUND: GameFAQ&As - Draskula (39:31) Credit Report (44:57) Recommendations and Outro (45:30): merritt: Fledgling Manor Frank: Drac's Night Out Brandon: Send recommendations for movies about killin nazis, listen to Malice Mizer if you want to feel like a dracula Ash: Interview with the Vampire, make more games about killing klan members This week's Insert Credit Show is brought to you by patrons like you. Thank you. Subscribe: RSS, YouTube, Apple Podcasts, Spotify, and more!
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 7:58)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
Deno (JavaScript runtime) mit der programmier.bar.Im Engineering Kiosk Adventskalender 2024 sprechen befreundete Podcaster⋅innen und wir selbst, Andy und Wolfi, jeden Tag kurz & knackig innerhalb von wenigen Minuten über ein interessantes Tech-Thema.Unsere aktuellen Werbepartner findest du auf https://engineeringkiosk.dev/partnersDas schnelle Feedback zur Episode:
Jerod is joined by Ryan Dahl to discuss his second take on leveling up JavaScript developers all around the world. Jerod asks Ryan why not try to fix or fork Node instead of starting fresh, how Deno (the open source project) can avoid the all too common rug pull (not cool) scenario, what's new in Deno 2 & their pragmatic decision to support npm, they talk JSR, they talk Deno KV & SQLite, they even talk about Ryan's open letter to Oracle in an attempt to free the unused "JavaScript" trademark from the giant's clutches.
Jerod is joined by Ryan Dahl to discuss his second take on leveling up JavaScript developers all around the world. Jerod asks Ryan why not try to fix or fork Node instead of starting fresh, how Deno (the open source project) can avoid the all too common rug pull (not cool) scenario, what's new in Deno 2 & their pragmatic decision to support npm, they talk JSR, they talk Deno KV & SQLite, they even talk about Ryan's open letter to Oracle in an attempt to free the unused "JavaScript" trademark from the giant's clutches.
Jerod is joined by Ryan Dahl to discuss his second take on leveling up JavaScript developers all around the world. Jerod asks Ryan why not try to fix or fork Node instead of starting fresh, how Deno (the open source project) can avoid the all too common rug pull (not cool) scenario, what's new in Deno 2 & their pragmatic decision to support npm, they talk JSR, they talk Deno KV & SQLite, they even talk about Ryan's open letter to Oracle in an attempt to free the unused "JavaScript" trademark from the giant's clutches.
Jerod is joined by Ryan Dahl to discuss his second take on leveling up JavaScript developers all around the world. Jerod asks Ryan why not try to fix or fork Node instead of starting fresh, how Deno (the open source project) can avoid the all too common rug pull (not cool) scenario, what's new in Deno 2 & their pragmatic decision to support npm, they talk JSR, they talk Deno KV & SQLite, they even talk about Ryan's open letter to Oracle in an attempt to free the unused "JavaScript" trademark from the giant's clutches.
Today, Charles, Dan, AJ, and Steve dive into a range of fascinating discussions. Joining this episode is special guest, Ryan Dahl, the visionary creator behind Node.js and Deno.In this episode, they traverse an eclectic mix of topics, from humorous offbeat news and dad jokes to in-depth tech discussions. They explore the complexities and legalities surrounding free speech, offering diverse perspectives on its implications in the modern digital landscape.But the heart of our discussion is Ryan Dahl's exploration of Deno 2, the latest evolution in JavaScript's runtime environment. You'll hear about its distinctive features, including the revolutionary JSR project, and how it aims to simplify and secure modern JavaScript development, addressing challenges and limitations found in Node.js. They also discuss the intricacies of TypeScript support, Deno's security model, and the future potential of JavaScript in data science.Join them for a lively conversation packed with insights, technical deep-dives, and plenty of humor. Whether you're a seasoned developer or just starting your coding journey, this episode is sure to offer valuable takeaways and an entertaining ride through the world of modern web development.Sponsors Wix StudioSocialsLinkedIn: Ryan DahlTwitter: @deno_landDenoPicksAJ - SwiftAJ - DenoCharles - Challengers! | Board GameRyan - GrainBecome a supporter of this podcast: https://www.spreaker.com/podcast/javascript-jabber--6102064/support.
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 8:10)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 9:36)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 8:10)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 9:27)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 9:07)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 7:43)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 8:10)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 9:27)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 7:01)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 9:35)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 7:01)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for ExclusionKimberly Mehlman-Orozco:Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.Joseph Fonseca:Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.Carlyn Irwin:Lack of Expertise: The memorandum questions Irwin's qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.(commercial at 9:07)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
Send us a textIn this episode...--> We're joined by streamer and speedrunner JSR to talk games, collecting, and mostly about Peanut Butter, his shiba inu that gained fame for doing a charity speedrun of Gyromite at AGDQ 2024.--> The head of Amazon Games says bringing artificial intelligence into game development is a good idea because games “don't really have acting" anyways.--> Concord, PlayStation's new 5v5 PVP first person hero shooter that released last week, has launched with under 700 concurrent players on Steam, worse than both Suicide Squad: Kill the Justice League and Redfall. Way worse.--> In its latest bid to save itself from oblivion, GameStop has announced the opening of GameStop Retro stores.--> Also: Top 3 New Releases, doggo saying hello!Want more JSR and PB?- twitch.tv/jsr_- x.com/JSR2gamers - youtube.com/@JSR_We love our sponsors! Please help us support those who support us!- Check out the Retro Game Club Podcast at linktr.ee/retrogameclub- Connect with CafeBTW at linktr.ee/cafebtw- Visit A Gamer Looks At 40 at linktr.ee/agamerlooksat40- Get creative with Pixel Pond production company at pixelpondllc.comHosts: retrogamebrews, wrytersview, JSR2gamersOpening theme: "Gamers Week Theme" by Akseli TakanenPatron theme: "Chiptune Boss" by donniegretroClosing theme: "Gamers Week Full-Length Theme" by Akseli TakanenSupport the Show.
The memorandum of law submitted by JPMorgan Chase Bank, N.A. in Case No. 22-cv-10904 (JSR) seeks partial summary judgment against the Government of the United States Virgin Islands (USVI). Here's a summary of the key arguments and points presented in the memorandum:1. Basis for Partial Summary Judgment:No Direct Evidence of Wrongdoing: JPMorgan argues that there is no direct evidence linking the bank to any alleged wrongdoing regarding Jeffrey Epstein's activities. The bank claims it did not knowingly participate in or benefit from Epstein's criminal conduct.Lack of Proximate Cause: The memorandum asserts that the USVI cannot establish proximate cause between JPMorgan's actions and Epstein's criminal activities. JPMorgan argues that its business relationship with Epstein does not make it liable for his independent illegal acts.2. Legal Standards and Framework:Summary Judgment Standards: The bank outlines the legal standard for summary judgment, emphasizing that such a judgment is appropriate when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.Application to Facts: JPMorgan contends that the facts presented do not meet the threshold required to proceed to trial, thereby warranting a summary judgment in its favor.3. Arguments Against USVI Claims:Vicarious Liability: JPMorgan argues that it cannot be held vicariously liable for Epstein's actions. The bank contends that there is no legal basis to extend liability to the bank for actions taken by Epstein, especially when those actions were criminal in nature.Knowledge and Participation: The bank emphasizes that it had no actual knowledge of Epstein's alleged illegal activities and did not participate in or facilitate them. JPMorgan claims any connection to Epstein was purely a banking relationship and not one of criminal conspiracy or complicity.Lack of Evidence of Financial Gain from Wrongdoing: JPMorgan also argues that there is no evidence showing that the bank financially benefited from Epstein's criminal activities. They assert that standard banking fees and services do not equate to complicity in criminal acts.4. Conclusion and Relief Sought:Request for Summary Judgment: The bank requests that the court grant partial summary judgment in its favor, dismissing the claims brought by the USVI to the extent they seek to hold the bank liable for Epstein's criminal conduct.Limitation of Liability: JPMorgan seeks to limit its liability, arguing that any potential misconduct on its part is too far removed from Epstein's actions to warrant legal culpability.The memorandum thus focuses on challenging the basis of the USVI's claims and emphasizes a lack of direct involvement or knowledge of Epstein's criminal behavior by the bank, seeking a court ruling to dismiss or limit the scope of the claims against it.(commercial at 7:50)to contact me:bobbycapucci@protonmail.comgov.uscourts.nysd.591653.223.0_1.pdf (courtlistener.com)
The memorandum of law submitted by JPMorgan Chase Bank, N.A. in Case No. 22-cv-10904 (JSR) seeks partial summary judgment against the Government of the United States Virgin Islands (USVI). Here's a summary of the key arguments and points presented in the memorandum:1. Basis for Partial Summary Judgment:No Direct Evidence of Wrongdoing: JPMorgan argues that there is no direct evidence linking the bank to any alleged wrongdoing regarding Jeffrey Epstein's activities. The bank claims it did not knowingly participate in or benefit from Epstein's criminal conduct.Lack of Proximate Cause: The memorandum asserts that the USVI cannot establish proximate cause between JPMorgan's actions and Epstein's criminal activities. JPMorgan argues that its business relationship with Epstein does not make it liable for his independent illegal acts.2. Legal Standards and Framework:Summary Judgment Standards: The bank outlines the legal standard for summary judgment, emphasizing that such a judgment is appropriate when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.Application to Facts: JPMorgan contends that the facts presented do not meet the threshold required to proceed to trial, thereby warranting a summary judgment in its favor.3. Arguments Against USVI Claims:Vicarious Liability: JPMorgan argues that it cannot be held vicariously liable for Epstein's actions. The bank contends that there is no legal basis to extend liability to the bank for actions taken by Epstein, especially when those actions were criminal in nature.Knowledge and Participation: The bank emphasizes that it had no actual knowledge of Epstein's alleged illegal activities and did not participate in or facilitate them. JPMorgan claims any connection to Epstein was purely a banking relationship and not one of criminal conspiracy or complicity.Lack of Evidence of Financial Gain from Wrongdoing: JPMorgan also argues that there is no evidence showing that the bank financially benefited from Epstein's criminal activities. They assert that standard banking fees and services do not equate to complicity in criminal acts.4. Conclusion and Relief Sought:Request for Summary Judgment: The bank requests that the court grant partial summary judgment in its favor, dismissing the claims brought by the USVI to the extent they seek to hold the bank liable for Epstein's criminal conduct.Limitation of Liability: JPMorgan seeks to limit its liability, arguing that any potential misconduct on its part is too far removed from Epstein's actions to warrant legal culpability.The memorandum thus focuses on challenging the basis of the USVI's claims and emphasizes a lack of direct involvement or knowledge of Epstein's criminal behavior by the bank, seeking a court ruling to dismiss or limit the scope of the claims against it.(commercial at 8:10)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.223.0_1.pdf (courtlistener.com)
The memorandum of law submitted by JPMorgan Chase Bank, N.A. in Case No. 22-cv-10904 (JSR) seeks partial summary judgment against the Government of the United States Virgin Islands (USVI). Here's a summary of the key arguments and points presented in the memorandum:1. Basis for Partial Summary Judgment:No Direct Evidence of Wrongdoing: JPMorgan argues that there is no direct evidence linking the bank to any alleged wrongdoing regarding Jeffrey Epstein's activities. The bank claims it did not knowingly participate in or benefit from Epstein's criminal conduct.Lack of Proximate Cause: The memorandum asserts that the USVI cannot establish proximate cause between JPMorgan's actions and Epstein's criminal activities. JPMorgan argues that its business relationship with Epstein does not make it liable for his independent illegal acts.2. Legal Standards and Framework:Summary Judgment Standards: The bank outlines the legal standard for summary judgment, emphasizing that such a judgment is appropriate when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.Application to Facts: JPMorgan contends that the facts presented do not meet the threshold required to proceed to trial, thereby warranting a summary judgment in its favor.3. Arguments Against USVI Claims:Vicarious Liability: JPMorgan argues that it cannot be held vicariously liable for Epstein's actions. The bank contends that there is no legal basis to extend liability to the bank for actions taken by Epstein, especially when those actions were criminal in nature.Knowledge and Participation: The bank emphasizes that it had no actual knowledge of Epstein's alleged illegal activities and did not participate in or facilitate them. JPMorgan claims any connection to Epstein was purely a banking relationship and not one of criminal conspiracy or complicity.Lack of Evidence of Financial Gain from Wrongdoing: JPMorgan also argues that there is no evidence showing that the bank financially benefited from Epstein's criminal activities. They assert that standard banking fees and services do not equate to complicity in criminal acts.4. Conclusion and Relief Sought:Request for Summary Judgment: The bank requests that the court grant partial summary judgment in its favor, dismissing the claims brought by the USVI to the extent they seek to hold the bank liable for Epstein's criminal conduct.Limitation of Liability: JPMorgan seeks to limit its liability, arguing that any potential misconduct on its part is too far removed from Epstein's actions to warrant legal culpability.The memorandum thus focuses on challenging the basis of the USVI's claims and emphasizes a lack of direct involvement or knowledge of Epstein's criminal behavior by the bank, seeking a court ruling to dismiss or limit the scope of the claims against it.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.223.0_1.pdf (courtlistener.com)
The memorandum of law submitted by JPMorgan Chase Bank, N.A. in Case No. 22-cv-10904 (JSR) seeks partial summary judgment against the Government of the United States Virgin Islands (USVI). Here's a summary of the key arguments and points presented in the memorandum:1. Basis for Partial Summary Judgment:No Direct Evidence of Wrongdoing: JPMorgan argues that there is no direct evidence linking the bank to any alleged wrongdoing regarding Jeffrey Epstein's activities. The bank claims it did not knowingly participate in or benefit from Epstein's criminal conduct.Lack of Proximate Cause: The memorandum asserts that the USVI cannot establish proximate cause between JPMorgan's actions and Epstein's criminal activities. JPMorgan argues that its business relationship with Epstein does not make it liable for his independent illegal acts.2. Legal Standards and Framework:Summary Judgment Standards: The bank outlines the legal standard for summary judgment, emphasizing that such a judgment is appropriate when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.Application to Facts: JPMorgan contends that the facts presented do not meet the threshold required to proceed to trial, thereby warranting a summary judgment in its favor.3. Arguments Against USVI Claims:Vicarious Liability: JPMorgan argues that it cannot be held vicariously liable for Epstein's actions. The bank contends that there is no legal basis to extend liability to the bank for actions taken by Epstein, especially when those actions were criminal in nature.Knowledge and Participation: The bank emphasizes that it had no actual knowledge of Epstein's alleged illegal activities and did not participate in or facilitate them. JPMorgan claims any connection to Epstein was purely a banking relationship and not one of criminal conspiracy or complicity.Lack of Evidence of Financial Gain from Wrongdoing: JPMorgan also argues that there is no evidence showing that the bank financially benefited from Epstein's criminal activities. They assert that standard banking fees and services do not equate to complicity in criminal acts.4. Conclusion and Relief Sought:Request for Summary Judgment: The bank requests that the court grant partial summary judgment in its favor, dismissing the claims brought by the USVI to the extent they seek to hold the bank liable for Epstein's criminal conduct.Limitation of Liability: JPMorgan seeks to limit its liability, arguing that any potential misconduct on its part is too far removed from Epstein's actions to warrant legal culpability.The memorandum thus focuses on challenging the basis of the USVI's claims and emphasizes a lack of direct involvement or knowledge of Epstein's criminal behavior by the bank, seeking a court ruling to dismiss or limit the scope of the claims against it.(commercial at 10:04)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.223.0_1.pdf (courtlistener.com)
The memorandum of law submitted by JPMorgan Chase Bank, N.A. in Case No. 22-cv-10904 (JSR) seeks partial summary judgment against the Government of the United States Virgin Islands (USVI). Here's a summary of the key arguments and points presented in the memorandum:1. Basis for Partial Summary Judgment:No Direct Evidence of Wrongdoing: JPMorgan argues that there is no direct evidence linking the bank to any alleged wrongdoing regarding Jeffrey Epstein's activities. The bank claims it did not knowingly participate in or benefit from Epstein's criminal conduct.Lack of Proximate Cause: The memorandum asserts that the USVI cannot establish proximate cause between JPMorgan's actions and Epstein's criminal activities. JPMorgan argues that its business relationship with Epstein does not make it liable for his independent illegal acts.2. Legal Standards and Framework:Summary Judgment Standards: The bank outlines the legal standard for summary judgment, emphasizing that such a judgment is appropriate when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.Application to Facts: JPMorgan contends that the facts presented do not meet the threshold required to proceed to trial, thereby warranting a summary judgment in its favor.3. Arguments Against USVI Claims:Vicarious Liability: JPMorgan argues that it cannot be held vicariously liable for Epstein's actions. The bank contends that there is no legal basis to extend liability to the bank for actions taken by Epstein, especially when those actions were criminal in nature.Knowledge and Participation: The bank emphasizes that it had no actual knowledge of Epstein's alleged illegal activities and did not participate in or facilitate them. JPMorgan claims any connection to Epstein was purely a banking relationship and not one of criminal conspiracy or complicity.Lack of Evidence of Financial Gain from Wrongdoing: JPMorgan also argues that there is no evidence showing that the bank financially benefited from Epstein's criminal activities. They assert that standard banking fees and services do not equate to complicity in criminal acts.4. Conclusion and Relief Sought:Request for Summary Judgment: The bank requests that the court grant partial summary judgment in its favor, dismissing the claims brought by the USVI to the extent they seek to hold the bank liable for Epstein's criminal conduct.Limitation of Liability: JPMorgan seeks to limit its liability, arguing that any potential misconduct on its part is too far removed from Epstein's actions to warrant legal culpability.The memorandum thus focuses on challenging the basis of the USVI's claims and emphasizes a lack of direct involvement or knowledge of Epstein's criminal behavior by the bank, seeking a court ruling to dismiss or limit the scope of the claims against it.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.223.0_1.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The memorandum of law submitted by JPMorgan Chase Bank, N.A. in Case No. 22-cv-10904 (JSR) seeks partial summary judgment against the Government of the United States Virgin Islands (USVI). Here's a summary of the key arguments and points presented in the memorandum:1. Basis for Partial Summary Judgment:No Direct Evidence of Wrongdoing: JPMorgan argues that there is no direct evidence linking the bank to any alleged wrongdoing regarding Jeffrey Epstein's activities. The bank claims it did not knowingly participate in or benefit from Epstein's criminal conduct.Lack of Proximate Cause: The memorandum asserts that the USVI cannot establish proximate cause between JPMorgan's actions and Epstein's criminal activities. JPMorgan argues that its business relationship with Epstein does not make it liable for his independent illegal acts.2. Legal Standards and Framework:Summary Judgment Standards: The bank outlines the legal standard for summary judgment, emphasizing that such a judgment is appropriate when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.Application to Facts: JPMorgan contends that the facts presented do not meet the threshold required to proceed to trial, thereby warranting a summary judgment in its favor.3. Arguments Against USVI Claims:Vicarious Liability: JPMorgan argues that it cannot be held vicariously liable for Epstein's actions. The bank contends that there is no legal basis to extend liability to the bank for actions taken by Epstein, especially when those actions were criminal in nature.Knowledge and Participation: The bank emphasizes that it had no actual knowledge of Epstein's alleged illegal activities and did not participate in or facilitate them. JPMorgan claims any connection to Epstein was purely a banking relationship and not one of criminal conspiracy or complicity.Lack of Evidence of Financial Gain from Wrongdoing: JPMorgan also argues that there is no evidence showing that the bank financially benefited from Epstein's criminal activities. They assert that standard banking fees and services do not equate to complicity in criminal acts.4. Conclusion and Relief Sought:Request for Summary Judgment: The bank requests that the court grant partial summary judgment in its favor, dismissing the claims brought by the USVI to the extent they seek to hold the bank liable for Epstein's criminal conduct.Limitation of Liability: JPMorgan seeks to limit its liability, arguing that any potential misconduct on its part is too far removed from Epstein's actions to warrant legal culpability.The memorandum thus focuses on challenging the basis of the USVI's claims and emphasizes a lack of direct involvement or knowledge of Epstein's criminal behavior by the bank, seeking a court ruling to dismiss or limit the scope of the claims against it.(commercial at 8:10)to contact me: bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.223.0_1.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The memorandum of law submitted by JPMorgan Chase Bank, N.A. in Case No. 22-cv-10904 (JSR) seeks partial summary judgment against the Government of the United States Virgin Islands (USVI). Here's a summary of the key arguments and points presented in the memorandum:1. Basis for Partial Summary Judgment:No Direct Evidence of Wrongdoing: JPMorgan argues that there is no direct evidence linking the bank to any alleged wrongdoing regarding Jeffrey Epstein's activities. The bank claims it did not knowingly participate in or benefit from Epstein's criminal conduct.Lack of Proximate Cause: The memorandum asserts that the USVI cannot establish proximate cause between JPMorgan's actions and Epstein's criminal activities. JPMorgan argues that its business relationship with Epstein does not make it liable for his independent illegal acts.2. Legal Standards and Framework:Summary Judgment Standards: The bank outlines the legal standard for summary judgment, emphasizing that such a judgment is appropriate when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.Application to Facts: JPMorgan contends that the facts presented do not meet the threshold required to proceed to trial, thereby warranting a summary judgment in its favor.3. Arguments Against USVI Claims:Vicarious Liability: JPMorgan argues that it cannot be held vicariously liable for Epstein's actions. The bank contends that there is no legal basis to extend liability to the bank for actions taken by Epstein, especially when those actions were criminal in nature.Knowledge and Participation: The bank emphasizes that it had no actual knowledge of Epstein's alleged illegal activities and did not participate in or facilitate them. JPMorgan claims any connection to Epstein was purely a banking relationship and not one of criminal conspiracy or complicity.Lack of Evidence of Financial Gain from Wrongdoing: JPMorgan also argues that there is no evidence showing that the bank financially benefited from Epstein's criminal activities. They assert that standard banking fees and services do not equate to complicity in criminal acts.4. Conclusion and Relief Sought:Request for Summary Judgment: The bank requests that the court grant partial summary judgment in its favor, dismissing the claims brought by the USVI to the extent they seek to hold the bank liable for Epstein's criminal conduct.Limitation of Liability: JPMorgan seeks to limit its liability, arguing that any potential misconduct on its part is too far removed from Epstein's actions to warrant legal culpability.The memorandum thus focuses on challenging the basis of the USVI's claims and emphasizes a lack of direct involvement or knowledge of Epstein's criminal behavior by the bank, seeking a court ruling to dismiss or limit the scope of the claims against it.(commercial at 7:45)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.223.0_1.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 7:27)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 7:27)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 7:45)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 8:06)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 7:58)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 8:51)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 8:55)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 8:51)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 8:51)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 8:42)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 8:51)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary JudgmentBackground and Legal Context:The USVI government argues that JPMorgan Chase had actual knowledge of Epstein's illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.Key Arguments:Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein's illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein's suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.Legal Standards and Precedent:The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.Request for Partial Summary Judgment:The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase's liability for facilitating Epstein's criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.Conclusion:The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.(commercial at 8:13)to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
In the case Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. (No. 22-cv-10904-JSR), JPMorgan Chase Bank filed a reply memorandum in support of its motion to dismiss certain claims brought against it. The motion was partially successful.The court granted JPMorgan's motion to dismiss claims under the Virgin Islands Criminally Influenced and Corrupt Organizations Act and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act (Counts II, III, and IV of the Second Amended Complaint). These claims were dismissed because they were unchanged from previous versions that the court had already ruled on.However, the court denied JPMorgan's motion to dismiss the claims related to the Trafficking Victims Protection Act (TVPA). The court had previously considered JPMorgan's arguments against these claims in an earlier motion and had rejected them. JPMorgan reasserted these arguments mainly to preserve them for appeal.This ruling represents a partial victory for both sides: while some claims were dismissed, others, particularly those related to the TVPA, will proceed in the litigation.(commercial 8:07)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.56.0.pdf (courtlistener.com)
In the case Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. (No. 22-cv-10904-JSR), JPMorgan Chase Bank filed a reply memorandum in support of its motion to dismiss certain claims brought against it. The motion was partially successful.The court granted JPMorgan's motion to dismiss claims under the Virgin Islands Criminally Influenced and Corrupt Organizations Act and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act (Counts II, III, and IV of the Second Amended Complaint). These claims were dismissed because they were unchanged from previous versions that the court had already ruled on.However, the court denied JPMorgan's motion to dismiss the claims related to the Trafficking Victims Protection Act (TVPA). The court had previously considered JPMorgan's arguments against these claims in an earlier motion and had rejected them. JPMorgan reasserted these arguments mainly to preserve them for appeal.This ruling represents a partial victory for both sides: while some claims were dismissed, others, particularly those related to the TVPA, will proceed in the litigation.(commercial 8:09)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.56.0.pdf (courtlistener.com)
In the case Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. (No. 22-cv-10904-JSR), JPMorgan Chase Bank filed a reply memorandum in support of its motion to dismiss certain claims brought against it. The motion was partially successful.The court granted JPMorgan's motion to dismiss claims under the Virgin Islands Criminally Influenced and Corrupt Organizations Act and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act (Counts II, III, and IV of the Second Amended Complaint). These claims were dismissed because they were unchanged from previous versions that the court had already ruled on.However, the court denied JPMorgan's motion to dismiss the claims related to the Trafficking Victims Protection Act (TVPA). The court had previously considered JPMorgan's arguments against these claims in an earlier motion and had rejected them. JPMorgan reasserted these arguments mainly to preserve them for appeal.This ruling represents a partial victory for both sides: while some claims were dismissed, others, particularly those related to the TVPA, will proceed in the litigation.(commercial 8:09)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.56.0.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
In the case Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. (No. 22-cv-10904-JSR), JPMorgan Chase Bank filed a reply memorandum in support of its motion to dismiss certain claims brought against it. The motion was partially successful.The court granted JPMorgan's motion to dismiss claims under the Virgin Islands Criminally Influenced and Corrupt Organizations Act and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act (Counts II, III, and IV of the Second Amended Complaint). These claims were dismissed because they were unchanged from previous versions that the court had already ruled on.However, the court denied JPMorgan's motion to dismiss the claims related to the Trafficking Victims Protection Act (TVPA). The court had previously considered JPMorgan's arguments against these claims in an earlier motion and had rejected them. JPMorgan reasserted these arguments mainly to preserve them for appeal.This ruling represents a partial victory for both sides: while some claims were dismissed, others, particularly those related to the TVPA, will proceed in the litigation.(commercial 8:09)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.591653.56.0.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
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