The USVI And Their Motion To Exclude JP Morgan's Expert Witnesses (Part 1) (11/2/26)

On August 18, 2023, the government of the United States Virgin Islands filed a memorandum in the Southern District of New York seeking to exclude expert testimony presented by JPMorgan Chase in the civil lawsuit concerning the bank's financial relationship with Jeffrey Epstein. The USVI argued that three experts retained by JPMorgan, Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin, offered opinions that were unreliable, irrelevant, unsupported by sufficient evidence, or outside their professional qualifications. The government was particularly critical of Mehlman-Orozco, who presented herself as a human trafficking expert despite what the filing characterized as limited academic training and practical experience in the field. Her proposed testimony included claims suggesting that some minors could voluntarily participate in commercial sex without being trafficked, a position the USVI argued directly contradicted federal sex trafficking law. Prosecutors also challenged her opinions concerning banking regulations, suspicious activity reports, and JPMorgan's internal compliance practices, noting that she acknowledged lacking expertise in financial regulations. Additionally, the government accused her of introducing an unsupported theory of secondary exploitation that appeared designed to discredit trafficking survivors, their attorneys, and the government's motivations for bringing the lawsuit. The USVI maintained that allowing such testimony would confuse the jury and improperly introduce legal interpretations and speculative allegations under the guise of expert analysis.

The memorandum also challenged the proposed testimony of retired FBI agent Joseph Fonseca, who sought to minimize the importance of financial records and suspicious activity reports in investigations involving sex trafficking. The USVI emphasized that Fonseca admitted during his deposition that he had never used suspicious activity reports during his FBI career and had not even understood what they were before JPMorgan hired him for the litigation. According to the filing, his limited familiarity with banking documentation made him unqualified to speculate about whether financial information supplied by JPMorgan could have assisted investigators pursuing Epstein. The government similarly attacked forensic economist Carlyn Irwin's proposed testimony concerning tax benefits awarded to Epstein's businesses through the Virgin Islands Economic Development Commission. Irwin had critic