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B. 
That the Court award the Government punitive and exemplary damages against JP 
Morgan in an amount to be determined at trial; 
C. 
That the Court order JP Morgan to pay appropriate fines to the Government 
pursuant to 18 U.S.C. § 1591(b) in amounts to be determined at trial; 
D. 
That the Court order JP Morgan to provide restitution of all ill-gotten gains to the 
Government pursuant to 18 U.S.C. § 1593 and 14 V.I.C. § 607(a)(6) and pursuant 
to 14 V.I.C. § 608(c)(4) to protect the rights of victims and innocent persons in the 
interest of justice and consistent with the purposes of the CICO Act, in amounts to 
be determined at trial; 
E. 
That the Court award the Government treble damages against JP Morgan pursuant 
to 14 V.I.C. § 607(c) in an amount to be determined at trial; 
F. 
That the Court order JP Morgan to pay appropriate civil penalties to the 
Government pursuant to 14 V.I.C. § 607(e) and 12A V.I.C. § 328(b) and pursuant 
to 14 V.I.C. § 608(c)(4) to protect the rights of victims and innocent persons in the 
interest of justice and consistent with the purposes of the CICO Act, in amounts to 
be determined at trial; 
G. 
That the Court enter an injunction pursuant to 14 V.I.C. § 607(a)(2) and 12A V.I.C. 
§ 328(a)(2) to prevent further illegal conduct and any concealment of illegal 
conduct; 
H. 
That the Court order JP Morgan to provide disgorgement of all ill-gotten gains to 
the Government pursuant to 14 V.I.C. § 607(a)(6) and pursuant to 14 V.I.C. 
§ 608(c)(4) to protect the rights of victims and innocent persons in the interest of 
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justice and consistent with the purposes of the CICO Act, in amounts to be 
determined at trial; 
I. 
That the Court award the Government attorneys' fees and costs pursuant to 18 
U.S.C. § 1595, 14 V.I.C. § 607(c), and 12A V.I.C. § 332 in amounts to be 
determined after trial; and 
J. 
That the Court award the Government and order JP Morgan to provide all such 
other relief as the Court deems appropriate. 
JURY DEMAND 
The Government demands a jury trial on all issues so triable. 
Dated: April 3, 2023 
CAROL THOMAS-JACOBS, ESQ. 
ACTING ATTORNEY GENERAL 
Isl Linda Singer 
Linda Singer (pro hac vice) 
Mimi Liu (pro hac vice) 
David I. Ackerman 
Paige Boggs (pro hac vice) 
MOTLEY RICE LLC 
401 9th Street NW, Suite 630 
Washington. DC 20004 
Carol Thomas-Jacobs (pro hac vice) 
Acting Attorney General of the 
United States Virgin Islands 
Virgin Islands Department of Justice 
34-38 Kronprindsens Gade 
St. Thomas U.S. Vir in Islands 00802 
Attorneys for Plaintiff Government of the 
United States Virgin Islands 
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