JPMorgan Chase’s memorandum of law opposed Jes Staley’s effort to dismiss the bank’s third-party claims against him in the Epstein litigation, arguing that Staley’s own conduct was central to why JPMorgan faced massive legal exposure in the first place. The bank portrayed Staley as far more than an executive who happened to know Jeffrey Epstein, alleging that he was Epstein’s principal internal advocate at JPMorgan, maintained an extraordinarily close personal relationship with him and repeatedly supported keeping Epstein as a client despite mounting internal concerns. JPMorgan argued that Staley had access to information about Epstein that he failed to disclose to the bank, while simultaneously using his senior position to reassure colleagues about the relationship. According to the bank, those circumstances supported claims that Staley breached his fiduciary duties, failed to act in JPMorgan’s interests and concealed information that would have been highly relevant to the bank’s decisions about whether to continue doing business with Epstein.
JPMorgan also rejected Staley’s argument that the bank was simply trying to shift responsibility for its own failures onto him. Instead, it maintained that the settlements, litigation costs and reputational damage arising from the Epstein relationship were precisely the kinds of losses for which Staley could potentially be held responsible if the allegations against him were proven. The bank emphasized that its claims rested on Staley’s individual duties as a senior executive and on allegations that his undisclosed personal relationship with Epstein conflicted with those obligations. In practical terms, JPMorgan was telling the court that if Staley knew more about Epstein than he revealed, advocated internally for Epstein while withholding that knowledge and exposed the bank to enormous liability as a result, he should not be allowed to walk away from the litigation at the pleading stage. The filing therefore represented a remarkable reversal in the Epstein story: JPMorgan, which had spent years defending its own relationship with Epstein, was now arguing that one of its most powerful former executives bore significant personal responsibility for keeping Epstein inside the bank.
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