Jes Staley's Reply Memo In Support Of The Motion To Dismiss The JP Morgan Claims (Part 1) (9/25/26)

Jes Staley’s lawyers used the May 2023 filing to argue that JPMorgan Chase’s third-party claims against him should be dismissed outright. The bank had sought contribution and indemnification from Staley in the lawsuits brought by a Jane Doe plaintiff and the U.S. Virgin Islands over JPMorgan’s relationship with Jeffrey Epstein, but Staley argued those claims were legally defective. His attorneys said the Trafficking Victims Protection Act did not create a right to contribution or indemnification and that JPMorgan could not use New York state law to manufacture one. They also argued that JPMorgan was being sued for its own alleged conduct, not merely for Staley’s actions, which undercut the bank’s attempt to shift liability onto him. Staley’s side further pointed to JPMorgan’s own pleadings, which said his alleged misconduct fell outside the scope of his employment, and argued that the bank had failed to show that Staley caused the same injuries for which JPMorgan itself was being sued.


Staley also attacked JPMorgan’s separate employment-related claims for breach of fiduciary duty and faithless servant, arguing they were time-barred and inadequately pleaded. His attorneys said JPMorgan had been on notice for years that Staley’s relationship with Epstein warranted scrutiny, particularly after Epstein’s 2019 arrest and after the bank produced more than 1,200 Staley-Epstein emails to U.K. authorities. They argued that JPMorgan could not claim it only recently discovered the alleged misconduct when it possessed decades of records and had ample reason to investigate sooner. The filing also said the bank failed to plead with the required specificity who Staley allegedly deceived, when the deception occurred, or how it caused JPMorgan’s later litigation costs and reputational damage. Staley’s lawyers ultimately asked the court to dismiss all of JPMorgan’s claims against him with prejudice.


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source:

Microsoft Word - MTD Reply - Doe an(11210113.11).docx