This page was last updated on June 11, 2024, please make sure to review the changes to certain deadlines that have been extended by one year and the changes are indicated in red.

In September 2023 JPMorgan Chase (“JPM”) settled a lawsuit by the U.S. Virgin Islands (“GVI”) alleging that JPM facilitated and benefited from the sex trafficking of women by Jeffrey Epstein.  The settlement payment made by JPM to GVI was in the amount of $75 million US dollars (the “Settlement Payment”).  The settlement includes that $10 million US dollars of the Settlement Payment will be used to create a fund (the “USVI Mental Health Fund”) to provide a financial resource for mental health services for survivors of Jeffrey Epstein.

You may qualify to apply to the USVI Mental Health Fund if you fall into one or more of the below categories:

• Participating Claimants of the settlement of Jane Doe 1 v. JP Morgan Chase Bank, N.A. (“JPM Class Action”) ¹
• Participating Claimants of the settlement of Jane Doe 1 v. Deutsche Bank Aktiengesellschaft, et al. (“DB Class Action”) ²
• A Class Member of the JPM Class Action
• A Class Member of the DB Class Action
• A participant in the Epstein Victims' Compensation Fund

The Claims Administrator in both the JPM Class Action and the DB Class Action, Simone Lelchuk, is administering the USVI Mental Health Fund.  The Claims Administrator is accepting applications to the USVI Mental Health Fund during the period January 16, 2024, through July 15, 2025 (11:59 PM EDT). Once an application is approved, the Claims Administrator will be making distributions for approved treatment plans per the below guidelines for three years, or January 15, 2027. You can find the necessary application form here.  A PDF copy of the application is available here to assist you in gathering the required materials for your submission.  

Your submission must include a signed letter from your mental health care provider (the “Provider”) on the Provider’s letter with a proposed treatment plan that includes the following information (a) the treatment period recommended by the Provider; (b) the number of sessions per week or month the Provider recommends; (c) the rate per session the Provider charges; (d) if payment will be made directly to the Provider, wire transfer instructions for the Provider, the Provider’s signed IRS Form W-9 (if US based), and the currency (US Dollars, Euros, Pound Sterling, etc.); and (e) whether there are other treatments a Provider recommends (e.g., inpatient facility, consultation with a psychiatrist, etc.). If yes, please make sure the Provider includes details and back-up information for the Claims Administrator to consider these other treatments. Please note that the Claims Administrator understands that this is an initial treatment plan, and your needs may change over time. Therefore, the treatment plan may be amended subject to the Claims Administrator’s approval. While your treatment plan may recommend services that cover a period longer than two years, the USVI Mental Health Fund will only pay for treatment as approved for two years.

A treatment plan may contemplate multiple modalities.  If you have a Provider who is overseeing all of your treatments, this Provider may submit a treatment plan that covers treatment from your Provider as well as adjacent providers.  However, once a treatment plan is approved, the invoices from these additional providers must be included in any submission for payment.  Similarly, the Claims Administrator will need to receive payment instructions and related tax documents for all providers covered by a treatment plan.  Alternatively, you may submit multiple complementary treatment plans for consideration by the Claims Administrator.

The Claim Administrator understands that engaging with a new provider about direct payment from a Qualified Settlement Fund created to provide mental health benefits for the victim/survivors of Jeffrey Epstein may be awkward and involve more disclosure than you are comfortable with at the beginning of a professional relationship.  To address this issue, the Claims Administrator will reimburse victim/survivors with approved treatment plans directly but would prefer that you work with your Provider once you are more comfortable with the relationship and request that payment be made directly from the USVI Mental Health Fund.  

If you are establishing a new relationship with a Provider, the USVI Mental Health Fund will reimburse you for your initial visit with the Provider once a treatment plan is approved.  The Claims Administrator recognizes that a victim/survivor may not feel that a Provider is a good fit and therefore will consider reimbursement for a second consultation with a new Provider if the facts warrant and this is explained in the submission.

Payments will be made by wire transfer on a monthly basis to the Provider or the victim/survivor in the currency designated. The Claims Administrator expects that requests for payment will be submitted on or after the first of the month for services rendered during the prior month.  As part of the payment verification process you will be asked to confirm that all services were actually received or provided.  Payments will be made on a rolling basis but generally weekly.

The Claims Administrator will be reviewing submissions on a weekly basis and will contact you with an approval, or follow-up questions, per your preferred method of contact given in the submission. 

Information about the USVI Mental Health Fund, including the application form and required documentation to support the application and important submission deadlines, can be found on this website. You may also contact the Claims Administrator, Simone Lelchuk, by email at simone@simonelelchuk.com, or you may contact her counsel, Elise Frejka by email at efrejka@frejka.com or by phone (212) 641-0848.

¹ All capitalized terms used but not defined herein shall have the meanings ascribed to them in the JPM Class Action Stipulation of Settlement.

² All capitalized terms used but not defined herein shall have the meanings ascribed to them in the DB Class Action Stipulation of Settlement.