MEMY-1805 harvest: vision-fixhub (part 28)

vision-fixhub/court-05/8b0137c1ef44ec8406fac5088e1488b5608a4e5fd80880a296200c2bd1fbf992.md

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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 1 of 13
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 2 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+July 07, 2023
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+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+CASE NO. 22-CV-10904
+GOVERNMENT OF THE UNITED STATES V.I.,
+Plaintiff,
+VS.
+JPMORGAN CHASE BANK, N.A.,
+Defendant.
+----X
+***CONFIDENTIAL***
+July 7, 2023
+Confidential Remote Video-Recorded
+30 (b) (6) Deposition of
+GVI BY JEAN-PIERRE ORIOL
+Stenographically Reported By:
+Mark Richman, CSR, CCR, RPR, CM
+Job No. J9913116
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 3 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+July 07, 2023
+11
+page.
+MR. ACKERMAN: Okay.
+A.
+No, nothing privileged.
+Q. Okay. Could you read in that
+half page of notes, just read it aloud,
+please.
+A.
+01:13
+Sure.
+The --
+MR. ACKERMAN:
+Objection. You
+can go ahead.
+A.
+Lieutenant
+-Ann Cannonier,
+she's currently the director of
+investigations for VIPD for the last two
+and a half years. She's been with the
+VIPD for 26 years. If the complaint was
+lodged with VIPD a case number would
+have been developed and generated. VIPD
+asserts that there have been
+• no
+complaints made.
+And then for me, what my
+understanding of this proceeding is, is
+that I'm prepared to answer questions on
+investigations and investigation
+monitoring steps.
+e.
+Is that all the notes?
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+01:13
+01:13
+01:14
+01:14
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 4 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+July 07, 2023
+16
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+related to DPNR duties.
+Q.
+So that's what I was getting at.
+The subject matter of all of the six or
+seven depositions, you were testifying
+in connection with your work for DPNR?
+A.
+Yes.
+Were you testifying in your
+individual capacity or as a corporate
+designee?
+A.
+As an agent for the department.
+e.
+So do you understand today that
+you've been designated as a witness
+pursuant to Rule 30 (b) (6)?
+A.
+Yes.
+e.
+What is your understanding of
+what that means?
+MR. ACKERMAN: Objection.
+A.
+That I am representing the GVI
+and not just DPNR.
+e.
+So in your -- in the prior
+deposition you gave in this case, you
+testified in a personal capacity, but
+here you're testifying as a
+representative of the government,
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+01:19
+01:19
+01:19
+01:19
+01:20
+
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 5 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+A.
+I would say that it's going
+further from my, me personally going out
+to the island having done investigation
+work, but from a natural resource
+perspective. And then if, again
+speaking on behalf of the government,
+that there were questions from VIPD and
+whether or not they did any
+investigations or monitoring.
+Okay. So I'm going to read you
+the topic which is "investigations or
+investigative or monitoring steps
+concerning Epstein or his companies
+undertaken by the Virgin Islands Police
+Department or the DPNR that occurred
+prior to December Ist, 2020."
+Is that what you understand
+you've been designated to testify about
+today?
+A.
+July 07, 2023
+18
+01:21
+01:21
+01:22
+01:22
+Yes.
+So it's really two topics, one is
+about the VIPD's investigations and
+monitoring prior to December 1, 2020 and
+one is about DPNR's, correct?
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+01:22
+
+
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 6 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+July 07, 2023
+19
+A.
+0.
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+Yes, I understand.
+So let's start with the first
+one, VIPD. Are you prepared to testify
+on that topic today?
+A.
+To the best of my ability, yes.
+And what did you do to prepare to
+testify as to investigations or
+investigative monitoring steps
+concerning Epstein or his companies
+undertaken by the VIPD?
+A.
+Met with the Lieutenant
+-Ann Cannonier who is the director
+of investigations for the VIPD, and
+asking if there was any investigations
+into Mr. Epstein I guess prior to 2020.
+e. Do you know how long Lieutenant
+Cannonier was the director of
+investigations?
+A.
+Iwo and a half years.
+e.
+Do you know if the information
+that Lieutenant Cannonier provided to
+you was based only on the two and a half
+years or was it based on the full period
+from December 1, 2020 backwards?
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+01:22
+01:22
+
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 7 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+July 07, 2023
+27
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+A.
+So what I know is that the
+purchase of little St.
+James happened
+around 1999.
+Okay. And then Mr. Epstein died
+in approximately 2019, or in 2019,
+correct?
+A.
+Correct.
+So for approximately 20 years he
+was a resident of the USVI?
+MR. ACKERMAN: Objection, scope,
+asked and answered, speculation.
+A.
+Yeah, I don't know the - I don't
+know when he was actually claiming
+residency here in the territory. I only
+know when he purchased this property.
+e.
+He owned property on USVI for 20
+years, correct?
+A.
+Yes.
+MR. ACKERMAN: Objection, scope.
+e.
+And during that 20-year period,
+how many times did VIPD visit Epstein's
+island?
+A.
+made.
+I don't know that any visits were
+2 ESQUIRE
+DEPOSITION SOLUTIONS
+01:31
+01:31
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 8 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+July 07, 2023
+28
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+And no, during that 20 year span,
+no complaints
+were
+received regarding
+Epstein, correct?
+A.
+That's correct.
+Beyond formal complaints, do you
+know
+if there were any interactions
+between VIPD and Epstein during that
+20-year period?
+MR. ACKERMAN:
+Objection.
+A.
+No --
+MR. ACKERMAN: Hold on,
+Commissioner, let me just get my
+objections in. Objection, scope,
+form. Go ahead.
+A.
+No, I do not.
+e.
+Do you know if VIPD had any
+interaction with Epstein's companies?
+MR. ACKERMAN: Objection, scope,
+form.
+A.
+No, I do not.
+Let's pull up tab 40 and enter it
+as exhibit 1.
+(Exhibit 1, document produced to
+JPMorgan by the USVI titled 2010
+2 ESQUIRE
+DEPOSITION SOLUTIONS
+01:33
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 9 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+July 07, 2023
+51
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+VI-JPM-000079601 was marked for
+identification.)
+A.
+Okay.
+e.
+This is an email chain that
+starts with a July 16, 2019 email from a
+Curt
+of CNN.com and it asks
+certain questions of the VI Police
+Department including "Has US Virgin
+Islands Police Department participated
+in lor been asked to participate in) any
+investigation related to Mr. Jeffrey
+Epstein?"
+Do you see that?
+A.
+Yes.
+e.
+Do you know what the answer to
+that question is?
+A.
+Has the US Virgin Islands Police
+Department received any complaints? So,
+again, from what was reported to me,
+that there were no complaints.
+Sorry, I was focused on the
+second question which is has US Virgin
+Islands police participated in or been
+asked to participate in any
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+02:03
+02:03
+02:03
+02:03
+02:04
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 10 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+July 07, 2023
+53
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+e.
+So this is a response by Glenn
+Dratte to the CNN reporter and he's
+reporting, "I did a complete check with
+the VIPD criminal investigations bureau
+and no complaints has been filed against
+MI.
+Jeffrey Epstein with the Virgin
+Islands Police Department.
+If there's
+anything further I can assist please
+reach out to my office."
+Do you see that?
+A.
+Yes.
+So that is the answer as of July
+18, 2019.
+Do you know if subsequent to that
+date there was any investigation?
+MR. ACKERMAN: Objection, scope,
+form.
+A.
+No, I do not know. Or at least
+what was reported to me was that there
+was no investigation.
+There is no case
+number that has been assigned with
+anything related to Mr. Epstein, so --
+And that's -- that's --
+A.
+So I would say no.
+& ESQUIRE
+DEPOSITION SOLUTIONS
+02:06
+02:06
+02:06
+02:06
+02:07
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 11 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+And that's ever, there's no date
+restriction on that?
+A.
+Well that I -- based on what was
+reported to me as of this year, in them
+looking back, that there is no case
+number.
+July 07, 2023
+54
+02:07
+Okay. Would there be any
+investigation that wouldn't be assigned
+a case number?
+A.
+That I don't know. PD would have
+to assign -- PD would have to indicate
+that directly.
+Did you ask Lieutenant Cannonier
+that question?
+What Lieutenant Cannonier did
+A.
+state is that if there was a complaint
+received of that they were opening an
+investigation, that there would be a
+case number.
+e.
+Okay.
+So no USVI individual ever
+came to VIPD to say they were a victim
+of Jeffrey Epstein, correct?
+A.
+Io my understanding, that's
+correct.
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+02:07
+02:07
+02:07
+02:08
+
+
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 12 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+July 07, 2023
+133
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+e.
+When you are conducting - you or
+other DPNR officials are conducting
+investigations
+for DPNR, are you doing
+that within the confines of DPNR's
+jurisdiction?
+A.
+Correct.
+If you saw suspicious activity
+that was outside DPNR's jurisdiction,
+would you or other DPNR investigators
+have reported that activity to the
+proper authorities?
+A.
+Yes, that's correct.
+And does that include, by the
+way, the visit to Epstein's island where
+you saw Epstein with a woman?
+A.
+Yes.
+e.
+Thank you. And earlier today
+there was a, there was an exhibit with
+Jason Marsh, it was an email and
+attachment. Do you recall that set of
+documents? It's exhibits 4 and 5.
+A.
+I can go back to it. I mean I
+know we saw a number of, a number of
+emails that I think Jason was copied on.
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+04:07
+04:07
+
+
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+Case 1:22-cv-10904-JSR Document 283-3 Filed 08/14/23 Page 13 of 13
+GVI BY JEAN-PIERRE ORIOL 30(b)(6), Confidential
+Gov. U.S. Virgin Islands vs JPMorgan Chase
+July 07, 2023
+134
+JP ORIOL - 7.7.23 - CONFIDENTIAL
+Yes. I'm referring to the one,
+the PDF title is 8 and 8A if you have
+that.
+A.
+Okay, yes.
+l. All right. 8, the part of the
+exhibit that is exhibit 5, the one that
+is titled 8A, how many pages is that PDF
+document?
+A.
+48.
+And do you know whether Mr. Marsh
+was forwarding only one article in the
+Virgin Islands Daily News or whether he
+was forwarding the entire paper?
+A.
+I have no clue.
+MR. O'LAUGHLIN: Objection.
+e.
+Do you know, do you know which
+article in the 48 pages Mr. Marsh was
+forwarding to this email address?
+A.
+No, I have no clue.
+e.
+All right. We can put that
+document aside.
+Commissioner Oriol,
+that's all I have.
+Thank you very much.
+THE WITNESS: Okay.
+MR. O'LAUGHLIN: So we're going
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+04:09
+04:09
+04:09
+04:09
+04:10

vision-fixhub/court-05/8b0137c1ef44ec8406fac5088e1488b5608a4e5fd80880a296200c2bd1fbf992.receipt.json

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vision-fixhub/court-05/8b4700ffcadfd6f379d06c08417fc9970e218e96f6515d3eb5eaa741f7d9509e.md

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+Case 1:22-cv-10904-JSR Document 205 |
+MotleyRice
+LLC
+ATTORNEYS AT LAW
+www.motleyrice.com
+"I will stand for my client's rights.
+I am a trial lawyer."
+-Ron Motley (1944-2013)
+Filed 07/14/23 Page 1 of 6
+401 9* St. NW. Suite 630
+Washington, DC 20004
+o. 202.232.5504 f. 202.232.5513
+Linda
+Lirensed in DC, NY
+direct: 202.386.9626
+Isinger@motleyrice.com
+
+BY ECF
+U.S. District Court, Southern District of New York
+Daniel
+Moynihan United States Courthouse
+500 Pearl Street
+New York, New York 10007-1312
+Re:
+Gov't of the U.S. Virgin Islands v. JPMorgan Chase Bank, N.A., Case No. 1:22-
+cv-10904-JSR (S.D.N.Y.) - Letter Brief Pursuant to July 7, 2023 Order
+Dear Judge Rakoff:
+The Government of the United States Virgin Islands ("USVI"), submits this Letter Brief in
+further support of its Motion to Strike Defendant's Affirmative Defenses 5 Through 8 (Dkt. 138,
+139) and in response to the Court's July 7, 2023 Order (Dkt. 204), requesting further briefing on
+"the interests [USVI] is asserting and the kinds and amounts of damages it is seeking." Id. at 2.
+Pursuant to its claims under the TVPA and CICO, the USVI's initial Complaint sought
+proprietary damages in the form of tax revenue, in addition to traditional parens patriae remedies.
+In light of the Court's decision on the Motion to Dismiss, the USVI dropped its claims for
+proprietary damages for its own losses or harms. Dkt. 200 at 2. Each of the remedies the USVI
+now seeks will vindicate quasi-sovereign interests. Thus, as explained in the initial briefing,
+JPMorgan's affirmative defenses are unavailable.
+The Court previously found that:
+The USVI's asserted interest in "assuring its residents it will act to protect them from the
+harmful effects of criminal sex-trafficking enterprises flourishing in the Islands that are
+their home" is indeed general (as all interests that ground parens patriae standing must be);
+but it directly parallels the interest that Puerto Rico successfully asserted in Snapp which
+was an interest in "assuring its residents that it will act to protect them from ... the harmful
+effects of discrimination." [Alfred L. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592, 609
+(1982)]. Indeed, the similarities between the interest asserted by the USVI here and that
+asserted by Puerto Rico in Snapp are considerable. Dkt. 130 at 18.
+Like the government plaintiff in Snapp, the USVI seeks "declaratory relief with respect to
+the past practices of petitioners and injunctive relief requiring petitioners to conform to the relevant
+MT. PLEASANT, SC | MORGANTOWN, WV | CHARLESTON, WV | PROVIDENCE, RI | WASHINGTON, DC | CHERRY NJ
+PHILADELPHIA, PA | HARTFORD, CT | NEW YORK, NY
+
+
+Case 1:22-cv-10904-JSR Document 205 Filed 07/14/23 Page 2 of 6
+Page 2
+federal statutes and regulations in the future." Snapp, 458 U.S. at 598-99; see FAC 4109 (seeking
+injunctive relief and such other relief as the Court deems appropriate); SAC 9119 (same). The
+USVI seeks an injunction to prevent JPMorgan from participating in sex trafficking ventures in
+the future and to protect and prevent potential future victims of traffickers. FAC 9109; 2AC, M9l
+119, 168 (same). An injunction is widely recognized to be appropriate (even quintessential) relief
+for a state attorney general bringing suit as parens patriae.'
+The injunction the USVI seeks is guided by the opinions of its expert witnesses:
+Professor Robert L.
+, Jr., former Commissioner of the U.S. Securities and Exchange
+Commission ("SEC*"), describes "alternative relief" that he approved and oversaw as
+Copoman in is case i. lier of Seport of Rober SA violation at hat 34. The hilars
+important in this case. Ex. A (excerpt of Report of Robert L. L
+an independent compliance consultant ("ICC") to provide "oversight of reporting-related risk from
+a social point of view" needed to overcome the economic incentives to underreport suspicious
+activity. Id. at 33, 9l 70. The other is a permanent injunction against future violations of the TVPA,
+which facilitates future enforcement through contempt proceedings, "reducing the cost of future
+action and, in turn, increasing the ex ante deterrent effects of the relevant judgment." Id. at 33-34,
+99I 71-72. Finally, Professor
+opines on the need for structural changes at JPMorgan:
+The information financial institutions are required to provide to law enforcement is crucial
+to the prevention of wrongdoing. But because they lack economic incentive to report their
+suspicions about their own clients, separation of banks' business and compliance function
+is necessary to ensure banks report all the information the law requires when the law
+requires it. JPM's internal governance did not achieve that separation, and the tragic events
+that followed have imposed untold costs upon society. Id. at 34, Il 74.
+Professor Jonathan J. Rusch, Director of the U.S. and International Anti-Corruption Law
+Program at American University, Washington College of Law, and former Senior Vice President
+and Head of Anti-Bribery & Corruption Governance at Wells Fargo, opines that in his experience
+as a compliance professional, it would be appropriate to require JPMorgan to: (1) perform a rootcause analysis of the violations evidenced in its handling of Epstein's accounts and activities; and
+(2) develop a remediation plan in consultation with the USVI and subject to the Court's approval
+and oversight. Ex. B (excerpt of Expert Opinion Report of Jonathan J. Rusch) at 191-92.
+' See, e.g., Snapp, supra; Purdue Pharma L. P. v. Kentucky, 704 F.3d 208, 215 (2d Cir. 2013) (State
+Attorney General sought, inter alia, "equitable and injunctive relief based on "quasi-sovereign
+interests' in protecting the health and safety of citizens"); People of the State of New York by Vacco
+v. Mid Hudson Med. Grp., 877 F. Supp. 143, 144 (S.D.N.Y. 1995) (State Attorney General sought,
+inter alia, "to enjoin defendant from such unlawful discrimination"); People by Underwood v.
+LaRose Indus. LLC, 386 F. Supp. 3d 214, 218 (N.D.N.Y. 2019) ("New York argues that, 'when,
+as here, a State sues in its parens patriae capacity to enforce laws that protect its citizens and seeks
+civil penalties and injunctive relief to prevent future violations, the State is the real party in
+interest.' The Court agrees.") (citation omitted).
+
+
+Case 1:22-cv-10904-JSR Document 205 Filed 07/14/23 Page 3 ot 6
+Page 3
+Professor Bridgette Carr is Co-Director of the Human Trafficking Clinic + Lab at the University
+of Michigan Law School and co-creator of the University's Human Trafficking Collaborative.
+Professor Carr recommends that JPMorgan involve trafficking experts and, importantly,
+trafficking victims in a review to "identify missed opportunities to prevent human trafficking, and
+implement changes that could prevent such missed opportunities from occurring in the future;"
+developing "accommodations or banking products and protocols to address the unique needs
+trafficking victims face after being exploited and financially abused;" prohibiting participation of
+employees who have personal relationships with a private banking client in decisions to retain or
+exit that client; and providing "an opportunity for any of Epstein's victims to present information
+... about the harm they experienced and the ways in which the bank could have intervened to
+identify or address their abuse." Ex. C (excerpt of Expert Report of Bridgette Carr) at 75-76.
+These sets of recommendations aim to address the same core problem: JPMorgan's knowledge of
+and failure to report Epstein's trafficking because it lacked the economic incentive and motivation
+to place compliance with the law and prevention of trafficking ahead of its own profits.
+The USVI also seeks civil penalties, disgorgement, restitution, damages, including punitive
+damages, and reasonable attorneys' fees, FAC, I 109; SAC, I 119, as "appropriate relief" under
+18 U.S.C. § 1595(d) to further this provision and the TVPA's remedial, punitive, and deterrent
+objectives. See 164 Cong. Rec. S1849-08, S1865, 2018 WL 1415014 (Mar. 21, 2018) ("Let's
+unleash those [resources] in the States to help us address this growing problem throughout our
+country."). Civil liability already existed in the TVPA, and the Court held that allowing State
+Attorneys General the right to vindicate such existing liabilities under its parens patriae authority
+was permissible. Dkt. 130 at 22-23.
+Civil penalties are an appropriate remedy to further the TVPA's deterrent objective in
+parens patriae actions.? Professor
+presents a quantitative analysis showing that, in the
+past, penalties related to the non-filing of SARs "have provided limited reason for bank executives
+to resist their incentives to report less suspicious activity than the law requires," and thus requiring
+more meaningful levels to deter misconduct. Ex. A (excerpt of
+Rpt.) at 8-13.
+The USVI seeks civil penalties consistent with the duration, egregiousness, and impact of
+JPMorgan's violations. The New York Department of Financial Services ("NYDFS") issued a
+$150 million agreed-to penalty on Deutsche Bank for its "inexcusable fail[ure] to detect or prevent
+millions of dollars of suspicious transactions" related to Epstein, including payments to alleged
+co-conspirators; settlement payments and dozens of payments to law firms for legal expenses of
+Epstein and co-conspirators; payments to Russian models and to numerous women with Eastern
+2 See generally State of New Mexico ex rel. Balderas v. Real Estate Law Ctr., P.C., 430 F. Supp.
+3d 761, 875 (D.N.M. 2019) (State, as parens patriae, seeks "civil penalties against the Defendant"
+to "deter future action like the Defendants' conduct"); LaRose Indus., 386 F. Supp. 3d at 219
+("New York seeks to enjoin Defendant from conduct that is illegal under New York law and to
+impose civil statutory fines to punish Defendant and deter other businesses from similarly harming
+New York consumers."); see also SEC v. Lek Securities Corp., 612 F. Supp. 3d 287, 298 (S.D.N.Y.
+2020) ("Neither of those remedies carries the same deterrent effect as a robust civil penalty.").
+
+
+Case 1:22-cv-10904-JSR Document 205 Filed 07/14/23 Page 4 ot 6
+Page 4
+European surnames; and periodic suspicious cash withdrawals totaling more than $800,000 over
+four years.? The USVI will prove even greater participation by JPMorgan in Epstein's sextrafficking venture over more than a decade, and seeks at least $150 million in civil penalties.
+Disgorgement also appropriately furthers the TVPA's deterrent objectives in parens
+patriae actions.* The USVI will prove that JPMorgan profited significantly from its relationship
+with Epstein. Conservatively, the USVI will prove that Epstein generated more than $20 million
+in fees and revenues for the Bank through 2013 when he was exited. In addition, Epstein referred
+many ultra-high net worth clients to the bank, including Sergey Brin, Bill Gates, Leslie Wexner,
+Glenn
+,, and the USVI will prove, also conservatively, that those clients generated an
+additional $20 million in fees. Thus, the USVI conservatively estimates that until Epstein's exit
+from the Bank at the end of 2013, JPMorgan received at least $40 million from its relationship
+with Epstein. This does not include the difficult to quantify value of Epstein introducing
+JPMorgan to high profile individuals, such as Prince Andrew, Ehud Barack, and Lord Peter
+Mandelson, connecting JPMorgan with the Gates Foundation, or consulting services that Epstein
+provided to the Bank including related to the Highbridge acquisition.
+The USVI further seeks compensatory damages suffered by victims and punitive damages
+in amounts to be proven to redress, punish, and deter the harms and threats to its residents' interests
+in physical health, safety, and well-being posed by JPMorgan's facilitation of Epstein's sextrafficking. Compensatory damages of persons harmed by unlawful conduct affecting quasisovereign interests is an appropriate remedy in parens patriae cases. Punitive damages likewise
+is an appropriate remedy that furthers the TVPA's deterrence and punishment objectives in parens
+3 NYDES Press Release, July 7, 2020 (https://www.dfs.ny.gov/reports_and publications/
+press releases/pr202007071#:~:text=Lacewell%20announced%20today%620that%20Deutsche.(
+%E2%80%9CDFS%E2%80%9D%20or%20the%20%E2%80%9C) (last checked July 14, 2023);
+Consent Judgment, July 6, 2020 (available at https://www.dfs.ny.gov/system/files/documents/
+2020/07/ea20200706_deutsche_bank_consent_order.pdf) (last checked July 14, 2023).
+* See generally Balderas, 430 F. Supp. 3d at 875 (State plaintiff as parens patriae seeks
+disgorgement "to deter future action like the Defendants' conduct"); State of Hawaii ex rel. Louie
+v. HSBC Bank Nevada, N.A., 761 F.3d 1027, 1032-33 (9th Cir. 2014) (disgorgement and other
+remedies sought in actions "brought by the State of Hawaii in its sovereign capacity on behalf of
+the State and its citizens ... and also under the State's parens patriae authority") (internal
+quotation marks and citations omitted).
+See, e.g., State of New York by Abrams v. General Motors Corp., 547 F. Supp. 703, 706-07
+(S.D.N.Y. 1982) ("The State's goal of securing an honest marketplace in which to transact business
+is a quasi-sovereign interest. ... This conclusion is not altered by the State's decision to seek ...
+damages on behalf of those who allegedly have been defrauded by GM."); In re TFT-LCD (Flat
+Panel) Antitrust Litig., 2011 WL 560693, at *5 (N.D. Cal. Feb. 15, 2011) ("The damages that
+California seeks, while on behalf of its consumers, would first be paid to the State and distributed
+on an equitable basis. The fact that private parties may benefit from the States" actions does not
+negate the States' substantial interests in these cases.").
+
+
+Hon. Jed S. Asko 1:22-CV-10904-JSR Document 205 Filed 07/14/23 Page 5 of 6
+Page 5
+patriae actions." The USVI also will seek its attorneys' fees and costs for successful prosecution
+of its TVPA claims against JPMorgan.?
+JPMorgan's potential settlement of individual victims' claims for damages does not—and
+cannot—release or compromise the USVI's claims for damages as parens patriae remedies. The
+USVI alone controls these claims." The individual victims, none of whom have received and some
+of whom will not receive payment through the proposed class action settlement, do not control the
+USVI's claims for this relief, which the USVI will recover and seek to distribute on an equitable
+basis to those victims or else appropriate cy pres beneficiaries.? This relief is important to vindicate
+the USVI's interests under the TVPA by punishing and deterring JPMorgan's violations of law.
+Victims also do not have TVPA claims for disgorgement or civil penalties (or injunctive relief).
+See 18 U.S.C. § 1595(a) (victim remedies). As parens patriae, USVI is the real party in interest
+to and likewise controls its claims for civil penalties and other deterrent relief."
+The remedies the USVI pursues are anchored in, and necessary to discharge, its quasisovereign interest and authority under the TVPA to protect the health and safety of its residents
+and to deter and restrain JPMorgan's conduct in order to rein in sex trafficking and protect those
+who might otherwise become victims in the future. In light of the nature of this relief, and for the
+reasons previously argued, the Motion to Strike should be granted.
+° See, e.g., U.S. v.
+Chems. & Plastics Corp., 749 F.2d 968, 972 (2d Cir. 1984) (State coplaintiff sought, inter alia, "compensatory and punitive damages" as part of parens patriae claim);
+see also Banxcorp v. Costco Wholesale Corp., 723 F. Supp. 2d 596, 621 (S.D.N.Y. 2010) (under
+New York law, "to recover punitive damages there must be a wrong against the public interest")
+(internal quotation marks and citation omitted).
+" Attorneys' fees are an appropriate TVPA remedy, 18 U.S.C. § 1595(a), that incentivize State
+Attorneys General to file enforcement actions as parens patriae. See People of the State of New
+York by Abrams v. 11 Cornwell Co., 718 F.2d 22, 24-25 (2d Cir. 1983) ("Also supportive of an
+award of fees to a state ... is the state's role as parens patriae on behalf of a disadvantaged group
+of its citizens, as distinguished from a state's suing to vindicate its own interests.").
+& See State of Nevada v. Bank of Am. Corp., 672 F.3d 661, 671 (9th Cir. 2012) (*IT]he restitution
+that Nevada seeks, while on behalf of its consumers, would first be paid to the State and distributed
+on an equitable basis. That individual consumers may also benefit from this lawsuit does not
+negate Nevada's substantial interest in this case.") (internal quotation marks and citations omitted);
+General Motors, 547 F. Supp. at 706-07 (conclusion that quasi-sovereign interest makes State a
+real party in interest "is not altered by the State's decision to seek ... damages on behalf of those
+who allegedly have been defrauded").
+° See In re Am. Investors Life Ins. Co. Annuity Mktg. and Sales Practs. Litig., 263 F.R.D. 226, 241
+(E.D. Pa. 2009) ("The attorneys' general law enforcement powers are not claims the [class action]
+plaintiffs have, and as such, the plaintiffs do not release any of these claims.")
+'' See, e.g., LaRose Indus., 386 F. Supp. 3d at 218 ("New York argues that, when, as here, a State
+sues in its parens patriae capacity to enforce laws that protect its citizens, and seeks civil penalties
+and injunctive relief to prevent future violations, the State is the real party in interest. The Court
+agrees.").
+
+
+Hon. Jed S. ase 1: 22-CV-10904-JSR Document 205 Filed 07/14/23 Page 6 of 6
+Page 6
+Respectfully submitted,
+ARIEL |
+, ESQ.
+ATTORNEY GENERAL
+By counsel,
+Is/ Linda
+LINDA
+Admitted Pro Hac Vice
+Motley Rice LLC
+401 9th Street NW, Suite 630
+Washington, DC 20004
+Tel: (202) 232-5504
+Isinger@motleyrice.com

vision-fixhub/court-05/8b4700ffcadfd6f379d06c08417fc9970e218e96f6515d3eb5eaa741f7d9509e.receipt.json

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+  "doc_id": "8b4700ffcadfd6f379d06c08417fc9970e218e96f6515d3eb5eaa741f7d9509e",
+  "engine": "marble-apple-vision",
+  "event_count": 14,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "35e2ae9d1e5d1e1950e1b1785b4f64436538ab943c6ac312a59fe4812af60d69",
+  "output_sha256": "fee1918fa6885a11ae273a6463cced40bff6d73b61168efbe23283d2a87a3c2d",
+  "page_markers": false,
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+}

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@@ -0,0 +1,72 @@
+Case 1:22-cV-10904-JSR Document 240-16 Filed 07/25/23 Page 1 of 3
+
+
+
+Case 1:22-cV-10904-JSR Document 240-16 Filed 07/25/23 Page 2 of 3
+From:
+To:
+CC:
+Sent:
+Subject:
+Dalessio, James <James.Dalessio@jpmorgan.com>
+Morris, Paul V <paul.v.morris@jpmorgan.com>
+Bonnie K<
+1/4/2011 8:36:56 PM
+Re: Rapid Response meeting this Thursday
+
+WIT:
+DATE:
+40
+ADR CRA CSR #13921
+Paul
+Jim
+Thanks I was not aware of the new credit
+From: Morris, Paul V
+To: Dalessio, James
+Cc:
+Bonnie K
+Sent: Tue Jan 04 14:48:21 2011
+Subject: RE: Rapid Response meeting this Thursday
+Jim, I thought we did that in approving a $50 million new line of credit last month? I'm happy to do whatever you
+advise. Best,
+From: Dalessio, James
+Sent: Tuesday, January 04, 2011 2:44 PM
+To: Morris, Paul V
+Cc:
+. Bonnie K
+Subject: Re: Rapid Response meeting this Thursday
+Paul
+william langford requested that we responsor this client in light of the new allegations of human trafficing which the firm has
+been actively assisting law enforcement in uncovering others engaged in this practice
+Regards
+Jim
+From: Morris, Paul V
+To: Dalessio, James
+Sent: Tue Jan 04 14:10:26 2011
+Subject: RE: Rapid Response meeting this Thursday
+Jim, Happy New Year!, can you give me a call to discuss, I thought we decided this was not necessary. Thanks
+From: Dalessio, James
+Sent: Monday, January 03, 2011 3:44 PM
+To: Morris, Paul V
+Cc:
+| Mary C;
+Bonnie K; McCleerey, Kevin
+Subject: Rapid Response meeting this Thursday
+Hi Paul,
+See attached draft document for the Rapid Response meeting this Thursday
+We were asked by the firms AML Compliance Director, William Langford, to re-evaluate our sponsorship of
+Epstein and request re-approval from Steve Cutler if we wanted to retain.
+Pls call me if you would like to discuss.
+Thanks
+
+JPM-SDNYLIT-00011967
+
+
+Case 1:22-cV-10904-JSR Document 240-16 Filed 07/25/23 Page 3 of 3
+Jim
+Private Bank Risk Management
+270 Park Ave., 18th Floor
+New York, NY 10017
+Phone (212) 464-1197, Fax (917) 463-0156
+
+JPM-SDNYLIT-00011968

vision-fixhub/court-05/8b4dcf83dfdd4387c8307a5636c69aadd28aa5472fb0f87e3190b7ea21f9ac54.receipt.json

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+{
+  "byte_delta": -78,
+  "dataset": "marble-joined",
+  "doc_id": "8b4dcf83dfdd4387c8307a5636c69aadd28aa5472fb0f87e3190b7ea21f9ac54",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "7062272b27daadcdbe0b12132d8cfb14125006d0c8d078bc0ef18691c0581edf",
+  "output_sha256": "d009ea3f5622c457a8249fb8bf4a1658f18b0d8ee0b7fd3f981d3f5f6024c059",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

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@@ -0,0 +1,42 @@
+Case 1:22-cv-10904-JSR Document 265-24 Filed 08/07/23
+
+
+FILED UNDER SEAL
+
+
+From:
+To:
+Sent:
+Subject:
+Case 1:22-cv-10904-JSR Document 265-24 Filed 08/07/23 Page 2 of 2
+Jeffrey Epstein <jeevacation@gmail.com>
+Jes Staley sjes.staley@jpmorgan.com
+11/11/2010 5:09:22 PM
+Re: Fw:
+she can sit with Richard Axel when I get back, he won the Nobel prize .. he has guaranteed me.
+On Thu, Nov 11, 2010 at 5:22 PM, Jes Staley <jes.staley@jpmorgan.com> wrote:
+resume.
+She is not giving Columbia her non physics GRE's.
+Jes
+From:
+To: Jes Staley
+Sent: Thu Nov 11 11:19:03 2010
+Subject:
+This email is confidential and subject to important disclaimers and conditions including on offers for the purchase
+or sale of securities, accuracy and completeness of information, viruses, confidentiality, legal privilege, and legal
+entity disclaimers, available at http://www.jpmorgan.com/pages/disclosures/email.
+... ..
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+Jeffrey Epstein
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to jeevacation@gmail.com. and
+destroy this communication and all copies thereof,
+including all attachments.
+
+JPM-SDNYLIT-00010989

vision-fixhub/court-05/8b4ffae3185f17f16fe0d6c1fac903d52f4eb4eb1b28eccaa0fccc4b3db936ea.receipt.json

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+  "doc_id": "8b4ffae3185f17f16fe0d6c1fac903d52f4eb4eb1b28eccaa0fccc4b3db936ea",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "2d8458e3951b4c533442fd697fe032caf5ce1c29140ddfdbfb04a85dfd7fcbbf",
+  "output_sha256": "9cd7db86bce3137efc3fedb3a4b46d5a2dcbe1a624e25adfcf2a99cf15d7f01f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

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@@ -0,0 +1,3 @@
+Case 1:22-cV-10904-JSR Document 158-60 Filed 05/23/23 Page 1 of 1
+
+FILED UNDER SEAL

vision-fixhub/court-05/8b707e3a61f9d4b6fa754dc7127245225beb556e31b2142af99a48b6620055f8.receipt.json

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+{
+  "byte_delta": -22,
+  "dataset": "marble-joined",
+  "doc_id": "8b707e3a61f9d4b6fa754dc7127245225beb556e31b2142af99a48b6620055f8",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "791da7fc0a0ec30130263c09f577f3539cee7c197b68bccf0f746fce9cea684b",
+  "output_sha256": "05b0da326ac42cfac8961639da0d303779c612b90ec6e2366c1f9419dc4c53a0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

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@@ -0,0 +1,3 @@
+Case 1:22-cv-10904-JSR Document 341-7 Filed 09/20/23 Page 1 of 1
+
+Filed Under Seal

vision-fixhub/court-05/8b8add2313e13013f0fa284c97ea706718a53a453aa1023f4316c238920c2de1.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -21,
+  "dataset": "marble-joined",
+  "doc_id": "8b8add2313e13013f0fa284c97ea706718a53a453aa1023f4316c238920c2de1",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "5b30ee2a9f50af2da51bab68fc3c6c4e8ccde38b1772aff754eab6bcfedffaa6",
+  "output_sha256": "ba8bfdcfd443a991643deee3045503d3e7916f060a251d94955b99f3d8724b9c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/8bb51c534347405df3bbd8321fdc3f4bf383249096d89ad8b70b1595f299cc21.md

@@ -0,0 +1,105 @@
+Case 1:22-cv-10904-JSR Document 267-4 Filed 08/07/23 Page 1 of 4
+
+
+
+Case 1:22-cv-10904-JSR Document 267-4 Filed 08/07/23 Page 2 of 4
+From:
+Sent:
+To:
+Subject:
+Dawn Henry [dawn.henry@dpnr.vi.gov]
+12/21/201712:49:35 PM
+jeffrey E. [jeevacation@gmail.com]
+RE: Re:
+Importance:
+High
+It can be. Howabout the publiclibraries.
+From: jeffrey E. [mai|to:jeevacation@gmail.com]
+Sent: Thursday, December 21, 2017 5:41 AM
+To: Dawn Henry <dawn.henry@dpnr.vi.gov>
+Subject: Re: Re:
+education in anyform Imin
+On Thu, Dec 21, 2017 at 7:38 AM, Dawn Henry <dawn.henry@dpnr.vi.govs wrote:
+I may have an idea. Let me check first and get back to you.
+Dawn
+From: jeffreyE. [mailto:jeevacation@gmail.com]
+Sent: Thursday, December 21, 2017 5:36 AM
+To: Dawn Henry <dawn.henry@dpnr.vi.gov>
+Subject: Re: Re:
+we gave the salgave co 25 k to the home for girls in st croix.. any suggestions foranother 25k? - with the
+deductions for low income. and reduced corp rate. VI is goingto needa new source of rev.
+On Thu, Dec 21, 2017 at 7:24 AM, Dawn Henry <dawn.henry@dpnr.vi.gov>wrote:
+That is scary - sepsis. Dealing with the aftermath of a hurricane is always more challenging than the hurricane
+itself. With respect to electricity, the new schedule is to have the territory's electricity restored by January 31, 2018. |
+really don't know forinternet because that responsibility is with private ISPs.
+Dawn
+From: jeffrey E. [mailto:jeevacation@gmail.coml
+Sent: Thursday, December 21, 2017 5:16 AM
+To: Dawn Henry <dawn.henry@dpnr.vi.gov>
+Subject: Re:
+ill check thanks. , re pr person. im told, neardeath. from sepsis...
+- how longdo you think until stt back in
+shape? I was the only private plane at the airport.
+
+ESTATE_JPM015321
+
+
+Case 1:22-cv-10904-JSR Document 267-4 Filed 08/07/23 Page 3 of 4
+On Thu, Dec 21, 2017 at 6:16 AM, Dawn Henry <dawn.henry@dpnr.vi.gov> wrote:
+Hi Jeffrey:
+Sorry to hear progress has been slow on the islands. I have been issuing repair and maintenance request for CZM
+throughout the territory within 2 days of the application being deemed complete. The last I heard, you were working
+on submitting the request. Do you know if the application was submitted.
+Hope your staff that went to PR are doing better.
+Dawn
+From: jeffrey E. [mailto:jeevacation@gmail.com|
+Sent: Wednesday, December 20, 2017 6:16 PM
+To: Dawn Henry <dawn.henry@dpnr.vi.gov>
+Subject:
+came to island just forthe day. WHAT A DISASTER. .! still nointernet, clean water. . some people needed to be
+airlifted to pr.. so many dead things. . havent heard back from you afterlast correspondence. hope all is well. tax
+bill not fun for us
+please note
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute insideinformation, and is intended only for
+the use of the addressee. It is the property of
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to jeevacation@gmail.com, and
+destroy this communication and all copies thereof,
+including all attachments. copyright-all rights reserved
+--
+please note
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute insideinformation, and is intended only for
+the use of the addressee. It is the property of
+JEE
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+
+ESTATE_JPMO15322
+
+
+Case 1:22-cv-10904-JSR Document 267-4 Filed 08/07/23 Page 4 of 4
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail orby e-mail to jeevacation@gmail.com, and
+destroy this communication and all copies thereof,
+including all attachments. copyright -all rights reserved
+please note
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+JEE
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to jeevacation@gmail.com, and
+destroy this communication and all copies thereof,
+including all attachments. copyright-all rights reserved

vision-fixhub/court-05/8bb51c534347405df3bbd8321fdc3f4bf383249096d89ad8b70b1595f299cc21.receipt.json

@@ -0,0 +1,14 @@
+{
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+  "doc_id": "8bb51c534347405df3bbd8321fdc3f4bf383249096d89ad8b70b1595f299cc21",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": false,
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+}

vision-fixhub/court-05/8bb92ea4e085f4d9f447a2a6ab0fdb22d6a63ef851451f34830d7afc2d13578c.md

@@ -0,0 +1,94 @@
+Case 1:22-cv-10904-JSR Document 185 Filed 06/14/23 Page 1 of 2
+June 14, 2023
+Via ECF
+WILMERHALE
++1 617 526 6687 (t
++1 617 526 5000 (f
+felicia.ellsworth@wilmerhale.com
+Hon. Jed S. Rakoff
+United States District Court
+Southern District of New York
+Daniel
+Moynihan United States Courthouse
+500 Pearl St., New York, NY 10007-1312
+Re:
+Gov't of the U.S. Virgin Islands v. JPMorgan Chase Bank, N.A., Case No. 1:22-cv-
+10904-JSR (S.D.N.Y.) - Letter Brief on USVI's Improper Confidentiality Designations
+Dear Judge Rakoff:
+JPMorgan Chase Bank, N.A. ("JPMC"") has repeatedly sought the consent of the
+Government of the United States Virgin Islands ("USVI") to file its May 23 Opposition to USVI's
+Motion to Strike publicly. Yet, although USVI lacks any basis to maintain confidentiality over
+the exhibits cited in that filing, it has (again) refused to withdraw its confidentiality designations,
+thereby requiring this Court's intervention. Specifically, USVI asserts confidentiality over
+See Dkt. 160, Exs. 8, 39-52, & 54-60. As before, US VI has no basis-beyond a desire to
+hide the embarrassing information in these documents from the public—to assert confidentiality.
+The documents USVI seeks to shield are public records, produced in response to JPMC's
+document requests, that show
+See Dkt. 159, pp. 6-7. USVI has not identified any basis to designate these
+materials confidential under the Protective Order. See Dkt. 15, 92 (listing the limited categories
+of information that may be designated Confidential). They do not contain confidential financial
+information,' information reported to law enforcement, materials related to ownership of a nonpublic company, trade secrets, information of an intimate nature, Bank Secrecy Act materials, or
+information designated Confidential Supervisory Information by a financial regulator. Id.
+Instead, USVI asserts that exhibits must be kept confidential under an inapplicable federal
+statute, 26 U.S.C. § 6103, that governs the confidentiality of federal tax returns and the information
+therein. As an initial matter, this statute does not apply to the documents USVI seeks to withhold,
+which were
+It is the law of this
+USVI has not raised this provision and, while these documents may contain "financial
+information" broadly defined, it is not of the type contemplated by the Protective Order. Id. 12(a)
+(listing "profitability reports or estimates, percentage fees, design fees, royalty rates, minimum
+guarantee payments, sales reports and sales margins" as examples of the type of financial
+information that might be kept confidential). It is also not financial information belonging to the
+USVI, and the only person who might plausibly be concerned about keeping this information
+confidential, Jeffrey Epstein, is both unworthy of the concern that USVI shows and long deceased.
+Wilmer Cutler Pickering Hale and Dorr ur, 60 State Street, Boston, Massachusetts 02109
+Beijing
+Berlin Boston Brussels Denver Frankfurt London Los Angeles New York Palo Alto San Francisco Washingtor
+
+
+Case 1:22-cv-10904-JSR Document 185 Filed 06/14/23 Page 2 of 2
+Circuit that, because "Congress's purpose in enacting section 6103 ... 'was to curtail loose
+disclosure practices by the IRS,'" that statute is only concerned with returns "obtained from the
+IRS. " Trump v. Deutsche Bank AG, 943 F.3d 627, 649 (2d Cir. 2019) (quoting Stokwitz v. United
+States, 831 F.2d 893, 894 (9th Cir. 1987)), vacated and remanded on unrelated grounds sub nom.
+Trump v. Mazars USA, LLP, 140 S. Ct. 2019 (2020).? Because these documents were not |
+, but rather
+, they do not fall within the ambit of this statute.
+What is more, JPMC offered, as a concession to USVI's concerns, that it would publicly
+file only the first few pages of each document those reflecting
+that do not include
+Those
+pages
+See, e.g., Dkt. 160, Ex. 56. USVI refused, asserting that those pages could not be disclosed because
+they "contain return information." But the statutory definition of "retur information" requires
+that such information be "received by, recorded by, prepared by, furnished to, or collected by the
+Secretary with respect to a return." 26 U.S.C. § 6103 (emphasis added). This language is limited
+to information flowing through the IRS. Baskin v. United States, 135 F.3d 338, 342 (5th Cir. 1998)
+(The plain language of the statute reveals that "return information' must be information which
+has somehow passed through, is directly from, or generated by the IRS.").? Even if the whole
+statute did not require that the information come from the IRS, this provision assuredly does.
+Finally, JPMC notes that USVI's protestations ring especially hollow in light of the
+disclosures USVI has already made. First, without any mention of the above-referenced statute, it
+has produced the documents in question to all parties in this litigation—JPMC, Jane Doe 1, and
+James Staley. Second, USVI has referenced the information contained in some of these documents
+in public court filings. For instance, the Second Amended Complaint in USVI v. Indyke (which
+USVI incorporated by reference into its Complaint here, Dkt. 119, 9923-33) specifically discussed
+the value of the tax exemptions received from USVI by one of Epstein's companies, Dkt. 119-1,
+19 166-174. USVI cannot now object to the disclosure of information it previously made public.
+JPMC respectfully requests that the Court issue an Order rejecting USVI's confidentiality
+designations and allow JPMC to refile its Opposition in unredacted form, along with exhibits
+redacted only to the extent necessary to prevent the disclosure of personal information regarding
+unrelated individuals.
+Sincerely,
+Is/ Felicia H. Ellsworth
+Felicia H. Ellsworth
+2
+Accord Stokwitz, 831 F.2d at 895-96 ("[T]he statutory definitions of 'return' and 'return
+information' to which the entire statute relates, confine the statute's coverage to information that
+is passed through the IRS.").
+Accord Ryan v. United States, 74 F.3d 1161, 1163 (11th Cir. 1996) ("[T]he statutory
+definition of 'return information' confines it to information that has passed through the IRS");
+Stokwitz, 831 F.2d at 895-96; see also Deutsche Bank, 943 F.3d at 649 (concluding that the
+language "to the Secretary" limited the application of a subsection of this statute to information
+obtained from the IRS).
+2

vision-fixhub/court-05/8bb92ea4e085f4d9f447a2a6ab0fdb22d6a63ef851451f34830d7afc2d13578c.receipt.json

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+  "engine": "marble-apple-vision",
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+  "idempotent": true,
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+}

vision-fixhub/court-05/8bbef23d0bfe9380b70f9615e4ea42f1483fc7d3b5342f34ed8107aaaf9c6af7.md

@@ -0,0 +1,3 @@
+Case 1:22-cV-10904-JSR Document 158-66 Filed 05/23/23 Page 1 of 1
+
+FILED UNDER SEAL

vision-fixhub/court-05/8bbef23d0bfe9380b70f9615e4ea42f1483fc7d3b5342f34ed8107aaaf9c6af7.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -22,
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+  "engine": "marble-apple-vision",
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+  "idempotent": true,
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+  "output_sha256": "542326b7750d946d179f1c39aa4a565cbc73590672d3d2af04bef7075da95c3e",
+  "page_markers": false,
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+}

vision-fixhub/court-05/8bce5977ba93c86d10837375559baf7268e5d257279bc58c052dc7bbca6737d1.md

@@ -0,0 +1,24 @@
+Case 1:22-cv-10904-JSR Document 94-1 Filed 03/23/23 Page 1 of 1
+UNITED STATES DISTRICT COURT FOR THE
+SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS
+PLAINTIFF,
+Case Number: 1:22-cv-10904 JSR
+V.
+JPMORGAN CHASE BANK, N.A.
+DEFENDANT.
+ORDER GRANTING MOTION
+FOR LEAVE TO WITHDRAW
+SARA D. AGUINIGA AS
+COUNSEL OF RECORD
+Plaintiff's Motion for Leave to Withdraw Sara D. Aguiñiga as Counsel of Record filed in
+the above-captioned action is GRANTED.
+IT IS HEREBY ORDERED that the pro hac vice admission granted to and the appearance
+of Sara D. Aguiñiga as Counsel of Record for Plaintiff in the above-captioned action is withdrawn,
+and the Clerk shall promptly remove Sara D. Aguiñiga from the list of attorneys receiving
+electronic notices of filings and proceedings in this action.
+New York, NY
+March
+_. 2023
+JED S. RAKOFF, U.S.D.J.

vision-fixhub/court-05/8bce5977ba93c86d10837375559baf7268e5d257279bc58c052dc7bbca6737d1.receipt.json

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+{
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+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/8bebb3622aaf7ca71b9299760efea82f525b85426f211e7845c4c1a945ad81bd.md

@@ -0,0 +1,3 @@
+Case 1:22-cV-10904-JSR Document 265-52 Filed 08/07/23 Page 1 of 1
+
+FILED UNDER SEAL

vision-fixhub/court-05/8bebb3622aaf7ca71b9299760efea82f525b85426f211e7845c4c1a945ad81bd.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -23,
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+  "doc_id": "8bebb3622aaf7ca71b9299760efea82f525b85426f211e7845c4c1a945ad81bd",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
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+  "output_sha256": "86c3517383068bd0d7f842beb6ded384085e114d41d28928936779937c938040",
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+}

vision-fixhub/court-05/8bfec1716f9089b93b3fd9b282125de2dd7b7833e3c883fc3eecd9c41d870532.md

@@ -0,0 +1,89 @@
+Case 1:22-cV-10904-JSR Document 240-10 Filed 07/25/23 Page 1 of 3
+
+
+
+7/11/23, 5:12 PM
+Case 1:22-cV-10904-JSR Documest 240-48 sElled/25/23 Page 2 of 3
+NEW YORK POST
+LOG IN
+RFK Jr., his
+brilliant
+Harvard...
+Three teens
+accused of
+murder aft...
+Beyonce's
+mother, Tina
+Knowles....
+Homeless
+man found
+living in...
+man found
+dead in...
+US Marine
+taken into
+custody...
+Dangerous
+TikTok
+trends clal...
+NEWS
+SECOND GIRL SUES MOGUL
+By Dareh Gregorian
+February 7, 2008 7:50am
+A teen who says she was sexually assaulted by Jeffrey Epstein has filed a $50 million against the financier, the second girl to file suit
+against the Manhattan multimillionaire in two weeks.
+In papers filed in federal court in Florida, the teen - identified only as "Jane Doe No. 2" - says she was lured to Epstein's Palm Beach
+mansion and then sexually assaulted in his massage room.
+"She was recruited by another girl from her school who told her she could make money giving massages to old people. She thought she
+was going to some kind of center," said her lawyer, Jeffrey Herman.
+Herman is also representing "Jane Doe No. 1," who says she was 14 when she went to Epstein's home to give him a massage and wound
+up getting sexually assaulted by him.
+Epstein's lawyer, Guy
+said, "Both complaints are full of lies."
+He called the new lawsuit "an outrageous, defamatory, copycat of the first."
+https://nypost.com/2008/02/07/second-girl-sues-mogul/
+1/6
+
+
+7/11/23, 5:12 PM
+Case 1:22-cv-10904-JSR Documest240-48 sEiled @7/25/23 Page 3 of 3
+The Doe No. 2 suit, like the first, charges that Epstein "engaged in a plan and scheme in which he gained access to primarily
+disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money.
+"In or about 2004-2005, Jane Doe, then approximately 16 years old, fell into Epstein's trap and become one of his victims."
+The suit also says the teen was "recruited" by another minor to "give Epstein a massage for monetary compensation" - and brought to his
+mansion, where she was taken up to the then-52-year-old's massage room.
+Epstein walked in wearing only a towel, and told the girl to "take off her clothes and give him a massage. Jane kept her panties and bra on
+and complied with Epstein's instructions," the suit says.
+"After a short period of time, Epstein removed the towel and rolled over exposing his penis. Epstein began to masturbate and he sexually
+assaulted Jane," the suit says.
+He then paid her $200, and the "recruiter" $100, the suit alleges.
+Herman said that police had interviewed the girl after finding her name and phone number in Epstein's records, but he's currently only
+facing criminal charges related to Jane Doe No. 1.
+That teen allegedly told Epstein she was 18 at the time of their 2005 encounter, but was actually 14 at the time.
+Epstein is expected to plead guilty to a single count of felony solicitation of prostitution next month in return for an 18-month prison term. He
+would face up to five years behind bars if convicted at trial.
+dareh.gregonan@nypost.com
+READ NEXT
+BRITNEY SPEARS OUT OF PSYCH
+REPORT
+SPONSORED STORIES
+One night after we closed the
+restaurant, Donald Trump came in
+with his then-wife Ivana, their kids,
+and their friends. In total, there were
+about 12 of them. The check was
+about $1,300. Jim said, 'No check'
+and brushed me away.
+When I bussed the table after,
+[gallery] Rising Above: Stories of Encounters Between Customers and Employees
+http://parentinfluence.com/
+[Photos] After Tony Curtis Died,
+Novak Confessed What He Did
+Last Night On
+Dr. Kellyann: "Souping" Is The Secret To
+Slimming Down After 60
+dkawellness.com
+NETFI
+FIJT
+https://nypost.com/2008/02/07/second-girl-sues-mogul/
+2/6

vision-fixhub/court-05/8bfec1716f9089b93b3fd9b282125de2dd7b7833e3c883fc3eecd9c41d870532.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -47,
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+  "doc_id": "8bfec1716f9089b93b3fd9b282125de2dd7b7833e3c883fc3eecd9c41d870532",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "d36320abe313f7925db17d96c6e98f97b9a1b73b826b3ae738f161e4dc12deab",
+  "output_sha256": "fdc35344077f7fa4c01b7bd332205aaf06664cc2a56ac49b2006fab1949d9d63",
+  "page_markers": false,
+  "source_id": "epstein-external",
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+}

vision-fixhub/court-05/8c8f04eff35738d7aa351462c4253ade99d93e1e506416107cdba79b1552370a.md

@@ -0,0 +1,3 @@
+Case 1:22-cv-10904-JSR Document 199-7 Filed 06/22/23 Page 1 of 1
+
+Filed Under Seal

vision-fixhub/court-05/8c8f04eff35738d7aa351462c4253ade99d93e1e506416107cdba79b1552370a.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -21,
+  "dataset": "marble-joined",
+  "doc_id": "8c8f04eff35738d7aa351462c4253ade99d93e1e506416107cdba79b1552370a",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "9b04d364397059e731c2b3376282833cbf9cda6ac44f4c53dd2aa115bdbbc1d6",
+  "output_sha256": "c6a06a27f550806ff0d894615de91198a41bf6bb5ad5e40f9fcc399e9804226d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/8c95826c77498e909f26d80c1c25db6bfc793b87018f43e1f4d195766896e399.md

@@ -0,0 +1,111 @@
+Case 1:22-cv-10904-JSR Document 143 Filed 05/15/23 Page 1 of 4
+UNITED STATES DISTRICT COURT FOR THE
+SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS
+Plaintiff,
+Case Number: 1:22-cv-10904-JSR
+JPMORGAN CHASE BANK, N.A.
+Defendant/Third-Party Plaintiff.
+JPMORGAN CHASE BANK, N.A.
+Third-Party Plaintiff,
+JAMES EDWARD STALEY
+Third-Party Defendant.
+GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS'
+MOTION FOR ORDER AUTHORIZING ALTERNATIVE SERVICE
+OF SUBPOENA FOR THIRD PARTY ELON MUSK
+NOW COMES the Government of the United States Virgin Islands, the Plaintiff in the
+above-captioned action, and moves pursuant to Fed. R. Civ. P. 45 for an Order authorizing the
+Government to arrange alternative service of its Subpoena to Produce Documents upon third party
+Elon Musk. As grounds for this Motion, the Government states the following:
+The Government brought this civil action against Defendant JPMorgan Chase Bank, N.A.
+("Morgan") as part of its ongoing effort to protect public safety and to hold accountable those
+who facilitated or participated in, directly or indirectly, the trafficking enterprise of Jeffrey Epstein
+("Epstein"). The Government's investigation has revealed that JPMorgan knowingly, recklessly,
+1
+
+
+Case 1:22-cv-10904-JSR Document 143 Filed 05/15/23 Page 2 of 4
+and unlawfully provided and pulled the levers through which Epstein's recruiters and victims were
+paid and was indispensable to the operation and concealment of the Epstein trafficking enterprise.
+Financial institutions can connect—or choke-human trafficking networks, and enforcement
+actions filed and injunctive relief obtained by attorneys general are essential to ensure that
+enterprises like Epstein's cannot flourish in the future. The Government's investigation further
+revealed that JPMorgan financially profited from the deposits made by Epstein and Epsteincontrolled entities located in the Virgin Islands and from the business opportunities referred to
+JPMorgan by Epstein and his co-conspirators in exchange for its known facilitation of and implicit
+participation in Epstein's sex trafficking venture.
+Upon information and belief, Elon Musk-the CEO of Tesla, Inc., among other
+companies—is a high-net-worth individual who Epstein may have referred or attempted to refer
+to JPMorgan. The Government issued a subpoena for documents to Mr. Musk on April 28, 2023
+(attached as Exhibit I). The Government made good-faith attempts to obtain an address for Mr.
+Musk, including hiring an investigative firm to search public records databases for possible
+addresses. Declaration of Linda
+('
+Decl."), II 2 (attached as Exhibit 2). One address
+found was that of Mr. Musk's counsel who has waived service on Mr. Musk's behalf in several
+recent federal cases filed within the last year. The Government contacted Mr. Musk's counsel via
+email to ask if he would be authorized to accept service on Mr. Musk's behalf in this matter but
+did not receive a response confirming or denying his authority.
+Decl., 99l 3-4. In addition,
+the Government's process server attempted service at the business address for Tesla, Inc. identified
+by the investigative firm, but was unable to confirm whether or not Mr. Musk was at the location
+and available for service and was directed by security to contact the company's registered agent
+and/or legal department.
+Decl., I 5.
+2
+
+
+Case 1:22-cv-10904-JSR Document 143 Filed 05/15/23 Page 3 of 4
+This Court long has recognized that Rule 45 of the Federal Rules of Civil Procedure permits
+alternative service of a subpoena by certified mail where a party is unable to provide personal
+service "li]n accordance with the interpretive principle that the rules be construed and
+administered to secure the just, speedy, and inexpensive determination of every action."" Cordius
+Trust v. Kummerfeld, 45 Fed. R. Serv. 3d 1151, 2000 WL 10268, at *2 (S.D.N.Y. Jan. 3, 2000)
+(quoting Fed. R. Civ. P. I). The Court has permitted alternative service where a party's repeated
+attempts at personal service have failed, see SEC v. David, No. 19-cv-9013, 2020 WL 703464, at
+*1-2 (S.D.N.Y. Feb. 12, 2020) (Rakoff, J.), or where there is an "approaching close of discovery,"
+In re Petrobras Securities Litig., No. 14-CV-9662, 2016 WL 908644, at *1-2 (S.D.N.Y. March 4,
+2016) (Rakoff, J.) (authorizing alternative service by email and overnight mail 56 days before
+April 29, 2016 discovery end date).
+Both circumstances are present here. The Government has made good-faith efforts to
+obtain an address for Mr. Musk and to serve a subpoena upon him personally. Moreover, the factdiscovery end date is at the end of this month. In these circumstances, the Court should in the
+interest of securing just and expeditious resolution authorize the Government to arrange alternative
+service of its Subpoena to Produce Documents by serving Mr. Musk via service upon Tesla Inc.'s
+registered agent.
+Dated: May 15, 2023
+ARIEL L
+_. ESQ.
+ATTORNEY GENERAL NOMINEE
+By counsel,
+Is/ Linda
+Linda
+(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
+3
+
+
+Case 1:22-cv-10904-JSR Document 143 Filed 05/15/23 Page 4 of 4
+Washington, DC 20004
+Tel: (202) 232-5504
+Fax: (202) 232-5513
+Isinger@motleyrice.com
+mliu@motleyrice.com
+dackerman@motleyrice.com
+pboggs@motleyrice.com
+VENETIA VELAZQUEZ
+Admitted Pro Hac Vice
+Acting Chief, Civil Division
+Virgin Islands Department of Justice
+Office of the Attorney General
+213 Estate La Reine, RR1 Box 6151
+Kingshill, St. Croix
+U.S. Virgin Islands 00850
+Tel.: (340) 773-0295 Ext. 202481
+venetia.velazquez@doj.vi.gov
+Attorneys for Plaintiff Government of the
+United States Virgin Islands
+4

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vision-fixhub/court-05/8cbb13bfe6b37c772805899526b731fc23f594b68fd2590955e11b8f5e151f90.md

@@ -0,0 +1,790 @@
+Case 1:22-cv-10904-JSR Document 301-3 Filed 08/25/23 Page 1 of 15
+
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220y1 0901+9 1Documerstant Filed 09|3 2etRage 2łdêr
+UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS,
+)
+)
+)
+Plaintiff,
+)
+1:22-CV-10904-JSR
+VS.
+JPMORGAN CHASE BANK, N.A.,
+Defendant/Third-
+Party Plaintiff.
+)
+)
+)
+)
+JPMORGAN CHASE BANK, N.A.,
+VS.
+Third-Party
+Plaintiff,
+)
+)
+)
+)
+JAMES EDWARD STALEY,
+)
+)
+Third-Party
+Defendant.
+)
+THURSDAY, JULY 6, 2023
+CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
+- -
+Remote Videotaped Deposition of CARLYN IRWIN,
+taken pursuant to notice and conducted at the location of
+the witness in the State of California, commencing at
+9:01 a.m., Pacific Time, on the above date, before Jennifer
+A. Dunn, Registered Merit Reporter, Certified Realtime
+Reporter, California, Illinois & Texas Certified Shorthand
+Reporter, and Missouri Certified Court Reporter.
+GOLKOW LITIGATION SERVICES
+P: 877.370.3377 | F: 917.591.5672
+deps@golkow.com
+Page 1
+
+
+Case 1:220y1 0901+9 1Documerstant Filgd 09|3 2etRage 3dêr
+1
+• All right. Do you know whether -- was that
+statute provided to you or did you or your team find it
+3 yourself?
+4
+A
+If it's not
+stamped then we would have found
+5
+it ourselves.
+6
+• Okay. Did you review any other Virgin Islands'
+7
+statutes or regulations in forming your opinions?
+8
+A Only the background material about the EDC program
+9 that I cite in my report.
+10
+• Okay. So this Statute 29, Virgin Islands Code,
+11
+Section 1101, is the only statute or regulation that you
+12
+reviewed in forming your opinions for this case, correct?
+13
+Correct.
+14
+MR. ACKERMAN: We can take that down, Gina.
+15
+BY MR. ACKERMAN:
+16
+• In forming your opinions for this case, did you
+17
+speak with any other expert retained by Wilmerhale or
+18
+JPMorgan?
+19
+A NO.
+20
+• In forming your opinions for this case, did you
+21
+speak with anyone other than counsel?
+22
+No. Other than counsel and my team, no.
+23
+• And again, the members of your team that you spoke
+24
+with were Mr. Govarra and Ms. Borg and Mr. Kruskol, correct?
+25
+Correct. Well, and obviously I mentioned I had
+Page 35
+
+
+Case 1:22oYf092h19 1Dacumersllant Filgd bº3&23tRage 47fdêr
+1
+A
+You did.
+2
+okay. In terms of calculating, or did you --
+3
+strike that.
+4
+Did you perform any independent analysis to
+5
+determine the economic benefits that the territory received
+6
+in return for tax benefits granted to Mr. Epstein's
+7
+companies?
+8
+I relied on the data that was produced in this
+9 litigation by the U.S. Virgin Islands. That's the data I
+10
+relied upon.
+11
+The data you relied upon are the cost-benefit
+12
+ratios, correct?
+13
+A
+Correct.
+14
+Okay. Is there any other data that you relied
+15
+upon in calculating the economic benefits that the territory
+16
+received in return for tax benefits granted to Mr. Epstein's
+17
+companies?
+18
+A
+No. It was solely based on the data provided by
+19
+USVI in discovery in this matter.
+20
+• And when you say: "Data provided by USVI, " you're
+21
+referring only to the cost-benefit ratios, correct?
+22
+A
+I'm referring to the Excel spreadsheets that laid
+23
+out various categories of benefits that went to the island
+24
+in terms of employment, expenses, taxes, et cetera.
+25
+Okay. And if you look at your Appendix B, those
+Page 64
+
+
+Case 1:220y1 0901+9 1Dacumersalant Filed 09|3 2etRage 50fdêr
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+A
+I do not.
+2
+Okay.
+Do you know whether it is considered as
+3
+authoritative by the EDC staff or commission members?
+4
+A
+The word "authoritative" is what's hanging me up
+5 there. I know that the statistic itself is something that
+the EDC measures, that it reports to the public in an
+aggregated
+fashion,
+and it is something that the EDC
+discusses when granting benefits or extending benefits.
+And I do know that the commission has, through the
+meeting minutes, I'm aware that the commission has certain
+ratios that they refer to as either acceptable or
+unfavorable.
+• Did you perform any analysis on your own to test
+the cost-benefit ratios that were -- that the EDC provided?
+A
+We -- when we were summarizing certain year --
+summarizing performance
+for certain years, we performed
+those calculations independently.
+And in some cases they differed than what's in the
+table on page 22 of my report.
+So that would be the extent of the analysis that
+we did.
+• I'm sorry, can you -- for certain years you
+performed the calculations on your own and they differed
+from what's on Table 22, or on the table on page 22, is that
+what you're saying?
+Page 69
+
+
+Case 1:220Yf098h+9 1Dacupersllant Filgd 09|3&ZetRage Gdêr
+1
+2
+And the reason for that is in that spreadsheet,
+the EDC, for whatever reason, didn't include certain
+benefits in the denominator.
+• So is that listed in your -- is that identified in
+your report somewhere?
+A
+It is.
+Where? I'm just not seeing that.
+So -- so when we calculated -- if you look at the
+4
+5
+6
+7
+8
+A
+9 footnotes.
+10
+Yeah.
+11
+A We can see the tab that we're looking at. So for
+12
+tab -- for footnote 133, we are identifying the Excel file,
+13
+as well as the tab that we are relying on.
+14
+And so where -- sorry, keep going.
+15
+A
+I'm just trying to see something here.
+16
+And so that showed -- that allows anyone to go
+17
+into the -- the file that we identify and reference the data
+18
+that we're pulling.
+19
+Whereas, in 2013 -- in 2013, there was certain
+20
+components, whether it's procurement or charitable
+21
+contributions, I don't know because -- but it was -- so, for
+22 example, okay, so I can see it.
+23
+In 2013, the .01 that is calculated by the EDC in
+24 the file that they sent to us, if you look at the benefits
+25
+tab, the calculation is -- results in .01, but that only
+Page 73
+
+
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220y1090149 1Documerstant Filed 09|3 2etRage Todar
+1
+term, "without any clear economic basis," that's based on
+2 the cost-benefit ratios that we discussed earlier, correct?
+3
+A
+Correct.
+4
+• Is that
+-- is that based on any other evaluation
+5 that you performed?
+6
+A I think part of it might also be the noncompliance
+with charitable donations. But that's the only other thing
+8 I can think of.
+Okay. And then further down in the paragraph, you
+note -- I'll just read the whole thing.
+So it says:
+"The extending of benefits without
+any clear economic basis and without USVI asking the
+appropriate questions to develop a basis for extending them
+suggests there is some other reason why Mr. Epstein was
+given $300 million in tax incentives by USVI and is
+consistent with the possibility that these benefits were
+granted as part of an improper quid pro quo exchange between
+Mr. Epstein and USVI officials."
+Did I read that correctly?
+A
+You did.
+• Okay. Are you opining that there was an improper
+quid pro quo between the USVI and Mr. Epstein?
+A
+No. As a CFE, a certified fraud examiner, my
+understanding is that would be a legal conclusion and is
+left up to the trier of fact.
+Page 90
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220y1 0901t9ra Filed Filgd p9|3d2etRage &dêr
+Okay. So you were not opining that there was an
+improper quid pro quo between the USVI and Mr. Epstein?
+A Correct. I'm merely saying that it suggests that
+there's a possibility.
+• All right. Are there other possibilities you
+haven't ruled out?
+MR. O'LAUGHLIN: Objection.
+THE WITNESS: I would need to know what other
+possibilities are out there.
+BY MR. ACKERMAN:
+• Well, could it be that the EDC performs a
+different analysis than you're performing?
+I've seen no evidence that they perform a
+different analysis. If it's somewhere in the record, it
+hasn't been produced to me.
+Based -- I'm using the EDC's own standards that
+they articulate, their own formula that they set forth, to
+evaluate the extension of these benefits.
+Q
+What about testimony from
+Are you aware of testimony from
+that
+the cost-benefit ratios are not entirely appropriate when
+dealing with financial services companies?
+MR. O'LAUGHLIN: Objection.
+THE WITNESS: I'm aware of that, but in
+analyzing other financial service company's data that
+Page 91
+
+
+Case 1:220Y1092149 1Dacuperslant Filgd 09323tRage Offdêr
+1
+BY MR. ACKERMAN:
+2
+Then if you go to paragraph G. There's a next one
+3 down.
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+It says: "Assess the work done by IDC, EDC, in
+connection with evaluating, extending benefits to, and
+monitoring of, Mr. Epstein's companies."
+Did I read that correctly?
+A
+You did.
+• And is that part of your assignment in this case?
+A
+Yes.
+Okay. So would you agree that you're basically
+evaluating EDC's work to see if you agreed with their --
+with their -- with their methodology and their decisions?
+MR. O'LAUGHLIN: Objection.
+THE WITNESS: I would say I'm assessing the
+work that they performed relative to their own
+benchmarks and standards.
+So I'm not -- I'm not an expert in their
+jobs. I'm merely comparing and assessing what they did
+relative to their own -- their own goals and their own
+objectives.
+BY MR. ACKERMAN:
+Were you determining whether EDC did anything
+illegal?
+A
+No.
+Page 96
+
+
+Case 1:2₴ 6Yr#992enłSRa Document 30ant Filed Q8125t3c Page 1Bplal5r
+1
+to the
+same person,
+or a company backed by the same person,
+2 the same person's going to be managing it, and the same
+3 person's making the representations that you should put --
+4
+give some context or some consideration to the historical
+5
+poor performance.
+6
+• And is it your opinion that the EDC should not
+have granted Southern Trust's certificate?
+A
+I don't have an opinion about that one way or the
+9 other. I'm just observing what transpired.
+• Is it your opinion that Southern Trust acted
+unreasonably in granting tax benefits. I'm sorry, strike
+that.
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Is it your opinion that the EDC acted unreasonably
+in granting tax benefits to Southern Trust?
+MR. O'LAUGHLIN: Objection.
+THE WITNESS: I don't have an opinion about
+that one way or the other. I'm simply noting that
+there is this track record of very unfavorable, or I
+won't say very, of unfavorable and concerning ratios,
+and they gave the same person a certificate for another
+10 years.
+BY MR. ACKERMAN:
+Part of your assignment was to assess the EDC's
+application process, right?
+A
+I think it's more broad than that. But, yes. Io
+Page 118
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:27 6Yr#992enłSRa Document 3Qant Filed Q8125t3c Page 1bptal5r
+of Southern Trust's application for tax benefits?
+A
+Except the EDC granted the tax benefits in spite
+of Financial Trust's poor performance, and a history of an
+application's projections being not -- being off by a
+magnitude of 10.
+So are you opining that they should not have
+granted the benefits of the application?
+A
+No. I think I said I'm not opining on whether or
+9 not they should have. I'm simply saying as part of my
+review, I'm observing that they did, in spite of these other
+factors that I discussed.
+So you're not opining on whether they should have
+granted the certificate. You're just criticizing their
+decision to do so?
+MR. O'LAUGHLIN: Objection. Misstates
+testimony.
+THE WITNESS: I'm pointing to the decision as
+part of my overall opinion regarding the potential
+other factors that went into the EDC's decision to
+extend benefits. So it's -- it's one -- it's one of
+the supporting observations for my overall conclusion.
+BY MR. ACKERMAN:
+• And your overall conclusion, again, is that there
+is a possibility that other factors went into the EDC's
+decision to extend benefits, right?
+Page 121
+
+
+Case 1:2₴ 6Yr#992enłSRa Document 3Qant Filed Q8125t3c Page 18plal5r
+1
+A
+Correct.
+2
+And you don't know what those other factors were,
+3
+correct?
+4
+A I know that, as I state in my report, I'm aware of
+5
+payments that benefited politicians, that benefited
+6
+officials, and that those could be another factor, but I
+7
+don't know the universe of potential factors.
+8
+• You don't know whether those payments affected the
+9 decision, correct?
+10
+A
+I don't.
+11
+• You stated it might -- it's possible, but you
+12
+don't know one way or the other, right?
+13
+A
+It's possible. A fraud examiner is not allowed to
+14
+testify about intent.
+15
+A fraud examiner simply -- and in this case I
+16
+didn't conduct a fraud investigation, that's not my -
+17
+that's not the role, you really can't do that in litigation,
+18
+but it's -- as I stated, my review of the record has given
+19
+me, you know, I've made several observations that suggest
+20
+there could be other reasons beyond the benefit to the USVI
+21
+as to why these benefits were extended over a 20-year
+22
+period.
+23
+• You said you didn't conduct a fraud investigation.
+24
+What do you mean by that?
+25
+So a fraud investigation, as defined by the
+Page 122
+
+
+Case 1:2₴ 6Yr#992enłSRa Document 30ant Filed Q8125t23c Page 13plalr
+1
+Association of Certified Fraud Examiners, is an entirely
+2 different project. It is someone that a company suspects
+some sort of wrongdoing, whether it's an issue with the
+4
+financial reporting or whether it's a misappropriation of
+5
+assets,
+et cetera.
+6
+And then a fraud examiner would, once
+7
+understanding what the allegations are, what the concerns
+8
+are, would design a work plan to investigate those
+9 allegations, document them, conduct interviews of
+10 stakeholders and people who are involved in that aspect of
+11 the business, and would ultimately, if -- if there was found
+12
+to be financial impact, quantify that to the best of that
+13
+their ability and then issue a report.
+14
+The report would -- typically goes back to, you
+15
+know, the audit committee of the company or the risk
+16
+management arm of the company,
+and then they decide what to
+17
+do with it from there.
+18
+So that's an entirely different exercise.
+19
+Q
+Okay. And then that's not what you did here,
+20
+right?
+21
+No. It's -- in my -- I'm unaware of any
+22
+litigation where a fraud examiner could actually conduct a
+23
+fraud investigation because it would require access, open
+24
+access to underlying financial records.
+25
+It would require open access to witnesses outside
+Page 123
+
+
+Case 1:2₴ 6Yr#992enłSRa Document 3Qant Filed Q8125t3c Page 10ptal5r
+1
+the context of a deposition, that type of thing.
+2
+Okay. Let's go to paragraph 67.
+3
+The first line of that reads: "USVI's EDC did not
+4
+properly evaluate Mr. Epstein's applications for benefits,"
+5 right, and it goes on: "And failed to ask him even the most
+6
+basic questions based on information that was uniquely
+7
+available to it about his companies."
+8
+So is it correct here that you are criticizing the
+EDC's evaluation of Mr. Epstein's applications?
+A
+I'm pointing out that there were inconsistencies
+in the public hearing testimony that were not resolved.
+That basically should have raised some sort of questions and
+follow-up.
+10
+11
+12
+13
+14
+And moreover, when extending the benefits in 2009,
+15
+you know, there was discussion about concerns, dangerous
+16
+precedents, and based on my review of the record, none of
+17
+that was resolved before extending that application. Excuse
+18
+me, extending that certificate.
+19
+Did the same people who expressed those concerns
+20
+vote on the extension of the application?
+21
+A
+Well, it was one month later after expressing
+22
+those concerns. I would presume at least some of the same
+23 people were voting.
+24
+I'm not aware that the EDC's membership or
+25
+committee completely turned over in a month between April
+Page 124
+
+
+Case 1:2₴ 6Yr#992enłSRa Document 3Qant Filed Q8125t23c Page 15ptalr
+1
+At no time in April when they were talking about
+2 this and saying this is a dangerous precedent, et cetera,
+did someone say,
+1, well, we should evaluate them from
+4
+zero. This is like a fresh statement.
+we're going to
+5
+set them from zero.
+6
+So to me that's -- that's conflicting information.
+7
+• So you are critical of the EDC's decision-making
+8
+process; is that -- is that a fair characterization?
+9
+A Again, it's a observation that supports my
+10
+ultimate conclusion, right. It's -- there was historical
+11 poor performance, there was discussion about being
+12
+concerned, and they moved forward anyway.
+13
+I'm not -- they may have a ton of reasons that
+14
+they then talk about on the record, I'm not saying that, but
+15
+it's part of my overall conclusion. It's something that
+16
+supports that.
+17
+okay.
+18
+A
+I don't have an independent opinion that they
+19
+shouldn't have approved this. I'm just observing they
+20
+approved it in spite of all of these other things and
+21
+concerns.
+22
+All right. Let's take that document down.
+23
+You said earlier that there were questions asked
+24
+at the 2012 EDC public hearing, right?
+25
+A
+Correct.
+Page 137

vision-fixhub/court-05/8cbb13bfe6b37c772805899526b731fc23f594b68fd2590955e11b8f5e151f90.receipt.json

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vision-fixhub/court-05/8cf1939a406b7fbbdc61f1f39d7c7940dd899354adc3bb65a3a839b4f2f70acf.md

@@ -0,0 +1,53 @@
+Case 1:22-cv-10904-JSR Document 241-3 Filed 07/25/23 Page 1 of 2
+
+
+
+Case 1:22-cv-10904-JSR Document 241-3 Filed 07/25/23 Page 2 of 2
+From:
+Sent:
+To:
+Subject:
+5/28/2008 1:20:17 AM
+mary.erdoes@jpmorgan.com
+Re: Totally stupid
+Epstein there with miley cyrus?
+...=- Original Message -----
+From: mary.erdoes@jpmorgan.com <mary.erdoes@jpmorgan.com>
+To:
+Sent: Tue May 27 20:28:39 2008
+Subject: Totally stupid
+This has turned into a cheezy broker fest....totally not cool, the only
+cool people are here at glenn's table-same as bat mitzvah!
+Generally, this communication is for informational purposes only
+and it is not intended as an offer or solicitation for the purchase
+or sale of any financial instrument or as an official confirmation
+of any transaction. In the event you are receiving the offering
+materials attached below related to your interest in hedge funds or
+private equity, this communication may be intended as an offer or
+solicitation for the purchase or sale of such fund(s). All market
+prices, data and other information are not warranted as to
+completeness or accuracy and are subject to change without notice.
+Any comments or statements made herein do not necessarily reflect
+those of JPMorgan Chase & Co., its subsidiaries and affiliates.
+This transmission may contain information that is privileged,
+confidential, legally privileged, and/or exempt from disclosure
+under applicable law. If you are not the intended recipient, you
+are hereby notified that any disclosure, copying, distribution, or
+use of the information contained herein (including any reliance
+thereon) is STRICTLY PROHIBITED. Although this transmission and any
+attachments are believed to be free of any virus or other defect
+that might affect any computer system into which it is received and
+opened, it is the responsibility of the recipient to ensure that it
+is virus free and no responsibility is accepted by JPMorgan Chase &
+Co., its subsidiaries and affiliates, as applicable, for any loss
+or damage arising in any way from its use. If you received this
+transmission in error, please immediately contact the sender and
+destroy the material in its entirety, whether in electronic or hard
+copy format. Thank you.
+Please refer to http://www.jpmorgan.com/pages/disclosures for
+disclosures relating to UK legal entities.
+
+Erdues-44
+3/15/23
+
+JPM-SDNYLIT-00134475

vision-fixhub/court-05/8cf1939a406b7fbbdc61f1f39d7c7940dd899354adc3bb65a3a839b4f2f70acf.receipt.json

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+  "engine": "marble-apple-vision",
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+}

vision-fixhub/court-05/8d05ef81ab4913fd7d03e5510706f3b25f69b20ef38392d072b468e608239361.md

@@ -0,0 +1,35 @@
+Case 1:22-cv-10904-JSR Document 18-3 Filed 01/11/23 Page 1 of 2
+IN THE UNITED STATES DISTRICT COURT FOR
+THE SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED STATES
+VIRGIN ISLANDS,
+Plaintiffs,
+Case No. 22-cv-10904-JSR
+[PROPOSED| ORDER FOR
+ADMISSION PRO HAC VICE
+V.
+JPMORGAN CHASE BANK, N.A.,
+Defendant.
+The motion of Ronald Machen for admission to practice pro hac vice in the abovecaptioned action is granted.
+Applicant has declared that he is a member in good standing of the bar of the District of
+Columbia, and that his contact information is as follows:
+WILMER CUTLER PICKERING
+HALE AND DORR LLP
+1875 Pennsylvania Avenue NW
+Washington, DC 20006
+Tel.: (202) 663-6881
+Ronald.Machen@wilmerhale.com
+Applicant having requested admission pro hac vice to appear for all purposes as counsel
+for Defendant JPMorgan Chase Bank, N.A. in the above-captioned action,
+IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the
+above-captioned case in the United States District Court for the Southern District of New York.
+All attorneys appearing before this Court are subject to the Local Rules of this Court,
+including the Rules governing discipline of attorneys.
+
+
+Case 1:22-cv-10904-JSR Document 18-3 Filed 01/11/23 Page 2 of 2
+Dated: January
+New York, NY
+_, 2023
+The Honorable Jed S. Rakoff
+United States District Judge

vision-fixhub/court-05/8d05ef81ab4913fd7d03e5510706f3b25f69b20ef38392d072b468e608239361.receipt.json

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+}

vision-fixhub/court-05/8d188c6289fbd3f2b5e1689ed9176e92c7ae68b3cfaa838980b5761eef589ad6.md

@@ -0,0 +1,3 @@
+Case 1:22-cv-10904-JSR Document 168-6 Filed 05/30/23 Page 1 of 1
+
+(FILED UNDER SEAL)

vision-fixhub/court-05/8d188c6289fbd3f2b5e1689ed9176e92c7ae68b3cfaa838980b5761eef589ad6.receipt.json

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+{
+  "byte_delta": -21,
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+  "doc_id": "8d188c6289fbd3f2b5e1689ed9176e92c7ae68b3cfaa838980b5761eef589ad6",
+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "39301cad6969b7d25c309459ac01e0c8e12be9f7b52b9acc2a0578ec07abf828",
+  "output_sha256": "d0bd5b9d80aba56950e84bd02aa8ce02528fd6060802240dd352e0208125da65",
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+}

vision-fixhub/court-05/8d44a913f6695240ac592fbdd520fb19ff55092c2a5c25597f24260e41520838.md

@@ -0,0 +1,3 @@
+Case 1:22-cV-10904-JSR Document 311-18 Filed 08/25/23 Page 1 of 1
+
+Filed Under Seal

vision-fixhub/court-05/8d44a913f6695240ac592fbdd520fb19ff55092c2a5c25597f24260e41520838.receipt.json

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+{
+  "byte_delta": -22,
+  "dataset": "marble-joined",
+  "doc_id": "8d44a913f6695240ac592fbdd520fb19ff55092c2a5c25597f24260e41520838",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "402d970474b3612c520301b2c6d3ddfdcb27721807c5234cadc19c2d6285e4c4",
+  "output_sha256": "470266447e21e0026d2d8c58fc122c3a2f4d622721914e2ff6a89bcdf2cdf9b6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/8d573e1e8e7d238eac8e5d1a0667758734fee97703ef944221aed8dcb2f11691.md

@@ -0,0 +1,70 @@
+Case 1:22-cV-10904-JSR Document 241-10 Filed 07/25/23 Page 1 of 3
+
+
+
+From:
+To:
+Sent:
+Subject:
+Case 1:22-cV-10904-JSR Document 241-10 Filed 07/25/23 Page 2 of 3
+Jeffrey Epstein <jeevacation@gmail.com
+Jes Staley <jes.staley@jpmorgan.com>
+7/10/2010 3:27:04 PM
+Re:
+EXHIBIT_ 35
+wIt: Strey
+6-1123
+DATE
+, ROR CRA CSR #13921
+well one side is availble
+On Sat, Jul 10, 2010 at 10:17 AM, Jes Staley <jes.staley@jpmorgan.com> wrote:
+Beauty and the Beast.....
+From: Jeffrey Epstein <jeevacation@gmail.com>
+To: Jes Staley
+Sent: Fri Jul 09 21:02:03 2010
+Subject: Re:
+what character would you like next
+On Fri, Jul 9, 2010 at 8:45 PM, Jes Staley <jes.staley@jpmorgan.com> wrote:
+Maybe they're tracking u??
+That was fun. Say hi to Snow
+This email is confidential and subject to important disclaimers and
+conditions including on offers for the purchase or sale of
+securities, accuracy and completeness of information, viruses,
+confidentiality, legal privilege, and legal entity disclaimers,
+available at http://www.jpmorgan.com/pages/disclosures/email
+***************************************
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+Jeffrey Epstein
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to jeevacation@gmail.com, and
+destroy this communication and all copies thereof,
+including all attachments.
+This email is confidential and subject to important disclaimers and conditions including on offers for the purchase
+or sale of securities, accuracy and completeness of information, viruses, confidentiality, legal privilege, and legal
+entity disclaimers, available at http://www.jpmorgan.com/pages/disclosures/email
+
+JPM-SDNYLIT-00008669
+
+
+Case 1:22-cv-10904-JSR Document 241-10 Filed 07/25/23 Page 3 of 3
+************************************************
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+Jeffrey Epstein
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to jeevacation@gmail.com, and
+destroy this communication and all copies thereof,
+including all attachments.
+
+JPM-SDNYLIT-00008670

vision-fixhub/court-05/8d573e1e8e7d238eac8e5d1a0667758734fee97703ef944221aed8dcb2f11691.receipt.json

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+{
+  "byte_delta": -71,
+  "dataset": "marble-joined",
+  "doc_id": "8d573e1e8e7d238eac8e5d1a0667758734fee97703ef944221aed8dcb2f11691",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "fdd86c0a71dd31d108d4fca76e5f270e202d6158a4d3c830b8c2805f25f2a720",
+  "output_sha256": "a90724d125e6943090e7c6b9a401c87303e9a2645f93efcf3a4e2e926872e3fe",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/8d5f2c034b2588e6595f32f622db101f795cc17d8e99adbad161aa293ec9521a.md

@@ -0,0 +1,1377 @@
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 1 of 35
+
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 2 of 35
+FEBRUARY 2007
+JPMorganChase O
+
+JPM-SDNYLIT-00275020
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 3 of 35
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 4 of 35
+INTRODUCTION
+Our integrity and reputation depend on our ability to do the right thing, even when
+it's not the easy thing. The Code of Conduct is a collection of rules and policy
+statements intended to assist employees and directors in making decisions about
+their conduct in relation to the firm's business. The Code is based on our
+fundamental understanding that no one at JPMorgan Chase should ever sacrifice
+integrity -- or give the impression that they have -- even if they think it would
+help the firm's business.
+Each of us is accountable for our actions, and each of us is responsible for
+knowing and abiding by the policies that apply to us. Managers have a special
+responsibility, through example and communication, to ensure that employees
+under their supervision understand and comply with the Code and other relevant
+policies.
+You can look to the Code of Conduct to guide your decisions in a variety of
+circumstances. However, no rulebook can anticipate every situation. Ultimately,
+the personal integrity and honesty of every JPMorgan Chase employee define the
+character of our company. Never underestimate the importance of your own
+ethical conduct to the business and success of JPMorga n Chase.
+
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 5 of 35
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 6 of 35
+TABLE OF CONTENTS
+1. ADMINISTRATION OF THE CODE OF CONDUCT
+1.1. Persons subject to the Code of Conduct..
+1.2. Consultants, agents and temporary workers
+1.3. Consequences of violating the Code ...
+1.4. Questions about the Code ...
+1.5. Obligation to report violations
+1.6. Current version of the Code
+1.7. Affirmation..
+2. DIVERSITY
+3. CONFIDENTIAL INFORMATION.
+3.1. Information about the firm, its customers, its employees, and others
+3.2. Prior employer's confidential information and trade secrets...
+3.3. Special rules regarding customer information and data privacy legislation...
+3.4. Publications, speeches, and other communications relating to JPMorgan Chase's business.
+4. INSIDE INFORMATION AND THE CHINESE WALL POLICY
+4.1. Inside Information...
+4.2. The Chinese Wall policy and other information barriers.
+5. OTHER BUSINESS CONDUCT..
+5.1. Assets of the firm.
+5.2. Intellectual property
+5.3.
+Telephones, e-mail, internet, and other electronic communications devices..
+5.4.
+Internal controls, record-keeping, and reporting
+5.5.
+Limits of your authority
+5.6.
+Business relationships ..
+5.6.1. Fair dealing
+5.6.2.
+• Customer, supplier, and employee relationships
+5.7.
+Money laundering and the USA PATRIOT Act.
+5.8.
+Tying of products
+5.9. Bribery and the Foreign Corrupt Practices Act
+5.10. International boycotts and economic sanctions.
+5.11. Post-employment responsibilities..
+5.12. Other professional obligations of some employees
+OUTSIDE ACTIVITIES, GIFTS, AND OTHER POTENTIAL CONFLICTS OF INTEREST.
+6.1. Personal relationships
+6.2. Personal finances..
+6.3. Outside business and not-for-profit activities; outside employment
+6.3.1. General.
+6.3.2. Required pre-clearance of outside activities.
+6.4. Political Activities.
+6.4.1. Political campaign activities and contributions by employees
+1
+2
+2
+2
+...4
+..6
+.6
+..6
+..6
+6
+...8
+.8
+8
+.9
+.9
+...9
+.10
+.10
+.11
+11
+.11
+. 1]
+11
+..12
+. 12
+.12
+.. 12
+..14
+. 14
+14
+15
+16
+16
+
+JPM-SDNYLIT-00275024
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 7 of 35
+6.4.2. Political contributions and related activities by JPMorgan Chase...
+6.5. Accepting gifts, meals, and entertainment from customers, suppliers, and others doing business
+with JPMorgan Chasc...
+6.5.1. What you may aceept...
+What you may not accept.
+6.5.3. Approval of nonconforming gifts
+Required reporting of gifts...
+6.6. Providing gifts, meals or entertainment.
+6.7. Solicitations at work; charitable contributions by the firm
+..20
+21
+7. PERSONAL SECURITIES AND OTHER FINANCIAL TRANSACTIONS.
+7.1. General investment principles.
+7.2. Persons and accounts subject to policies
+7.3. Trading in JPMorgan Chase securities...
+7.3.1. Policies applicable to all employees.
+7.3.2. Employees subject to the "window" and "Senior-level employees"
+7.4. Trading in securities of clients and suppliers....
+Additional policies for certain groups of employees.
+..21
+..21
+..22
+..22
+..22
+....23
+..23
+23
+Definitions and Examples
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 8 of 35
+1. ADMINISTRATION OF THE CODE OF CONDUCT
+The Code of Conduct (the "Code") sets forth certain minimum expectations that JPMorgan Chase has for
+you. You are expected to conduct the firm's business in full compliance with both the letter and the spirit
+of the law, the Code, and any other policies and procedures that may be applicable to you. The "firm"
+and "JPMorgan Chase" as used throughout the Code mean JPMorgan Chase & Co. and all its direct and
+indirect subsidiaries.
+The Code is intended to provide general guidance regarding your conduct as an employee or director of
+JPMorgan Chase. Note that other policies and procedures are listed at the end of many Code sections,
+with an electronic link on the intranet edition of the Code. These listed items provide more detailed
+information about the relevant subject and may include additional requirements with which you must
+comply. However, these lists are not an exhaustive consideration of all policies and procedures that may
+be applicable to you, and you are responsib le for knowing which policies and procedures (whether or no
+listed here) apply to you, and for understanding and complying with them. You should refer to these
+documents where appropriate. Consult any of the persons listed in Section 1.4 if you have questions.
+At the end of the Code, you will find a section of Definitions and Examples.
+Any waiver of the provisions of this Code for an executive officer or a director must be made by the
+Board of Directors and will be promptly disclosed to JPMorgan Chase & Co. stockholders.
+The Corporate Secretary may provide interpretations of the Code, in consultation with the General
+Counsels where appropriate.
+The Code of Conduct does not create any rights to continued employment and is not an employment
+contract.
+1.1.Persons subject to the Code of Conduct
+The Code applies to employees and directors of JPMorgan Chase & Co. and its direct and indirect
+subsıdiaries. Employees of joint ventures and entitics in which JPMorgan Chase holds venture capıtal
+investments are not subject to the Code except to the extent the Legal and Compliance Department
+determines otherwise. The provisions of the Code described in Section 5.11 also apply to former
+employees.
+If any provision contravenes or is less restrictive than the applicable law of any jurisdiction, the local lav
+/ill apply. Similarly, certain business units have policies that are more restrictive than the Code, an
+lose more restrictive policies will apply to those units. You are responsible for understanding an
+
+JPM-SDNYLIT-00275026
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 9 of 35
+1.2. Consultants, agents and temporary workers
+In general, consultants, agents and temporary workers are expected to comply with the underlying
+principles of the Code. Specific arrangements with such persons will vary depending on their relationship
+to the firm. Consult your Compliance officer or your Code Specialist if you have questions about your
+obligations or those of others.
+1.3. Consequences of violating the Code
+Compliance with the Code and with other policies and procedures applicable to you is a term and
+condition of employment by JPMorgan Chase. Violations of any laws that relate to the operation of our
+business, the Code, or other applicable policies and procedures, or failure to cooperate as directed by the
+firm with an internal or external investigation, may result in corrective action, up to and including
+immediate termination of employment. The firm will take all reasonable actions to enforce the Code. In
+cases where a violation of the Code could cause the firm irreparable harm, it may seck injunctive relief in
+addition to monetary damages.
+1.4. Questions about the Code
+Each line of business and support group has been assigned at least one "Code Specialist," generally a
+Compliance officer, to act as a resource for all employees in the area on Code-related issues. Contact
+information for these officers is included in the Code Contacts List, and employees can contact their Code
+Specialist for assistance with any questions regarding the Code.
+Employees who have questions about the Code or other policies and procedures, or about how a particular
+rule applies in a specific situation, can also contact:
+• their manager
+• their local Compliance officer
+• the Office of the General Counsel
+• their Human Resources Business Partner
+• the Office of the Secretary
+Contact information is included in the Code Contacts List.
+The following lists some of the common situations in which you may have obligations under the Code
+and refers you to the relevant section(s) of the Code. You should not use this list as a substitute for
+familiarity with all provisions of the Code.
+Situation
+Unethical or illegal behavior:
+You observe conduct by another employee, a supplier, a customer, or
+another person doing business with the firm that you believe to b
+unethical, illegal, or contrary to the Code of Conduc
+Discriminatory or harassing conduct:
+You experience or observe conduct that you believe violates the firm's
+policies prohibiting employment discrimination or harassment.
+Confidential information:
+Code Section
+2
+3 and 4
+2
+
+JPM-SDNYLIT-00275027
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 10 of 35
+Situation
+You wish to disclose confidential information about the firm, a
+customer, a fellow employee, or another person or entity doing business
+with the firm
+Publications:
+You wish to write and publish a book, article, or other work relating to
+the business of JPMorgan Chase.
+Speaking engagements and public testimony:
+You wish to give a speech or provide testimony on a subject relating to
+the firm's business.
+Media inquiries:
+You have received an inquiry from a member of the media on a subject
+related to the firm's business, or in a situation in which you might be
+seen as speaking for the firm.
+Endorsements:
+A customer, supplier, or other person or entity doing business with the
+firm has asked you to provide an endorsement or testimonial.
+Post-employment obligations:
+You anticipate leaving JPMorgan Chase, and you are not certain what
+continuing obligations you may have after your employment is ended.
+Potential conflict of interest:
+You are in a situation that presents a potential conflict of interest or
+appearance of a conflict of interest.
+Outside business or other for-profit activities:
+You wish to become involved with an outside business or to accept a
+second job.
+Outside not-for-profit activities:
+You wish to become a director, trustee, or officer of a not-for-profit
+organization.
+Holding political office or other governmental position:
+You wish to run for political office or accept appointment to any
+governmental position.
+Political activities:
+You wish to become involved with a political campaign, lobbying
+effort, or other political activity.
+Gifts or entertainment offered or provided by persons doing
+business with JPMorgan Chase:
+You are offered or receive a gift from a customer, supplier, or other
+party doing business with JPMorgan Chase.
+Code Section
+3.4
+3.4
+3.4
+3.4
+5.11
+6
+6.3
+6.3
+6.3 and 6.4
+6.4
+6.5
+3
+
+JPM-SDNYLIT-00275028
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 11 of 35
+Situation
+Gifts to customers, suppliers, or others doing business with
+JPMorgan Chase:
+You wish to make a gift or extend an invitation to a person doing
+business with JPMorgan Chase.
+Charitable solicitations at work:
+You wish to ask co-workers, customers, or suppliers to contribute to a
+charitable cause with which vou are involved.
+Personal investment activity:
+You, or a member of your family, are making personal investments that
+may be subjcet to the firm's policies and procedures regarding personal
+account trading.
+Code Section
+6.6
+6.7
+7
+1.5.
+Obligation to report violations
+You must promptly report any known or suspected violation of the Code or any applicable law or
+regulation, whether the violation involves you or another person subject to the Code. In addition, you
+should report any illegal conduct, or conduct that violates the underlying principles of the Code, by any of
+our customers, suppliers, contract workers, business partners, or agents. If something doesn't look right,
+say something.
+Report violations as follows:
+Matters involving harassment or discrimination must be reported to your manager, to the
+Employee Relations Unit of Human Resources, or to your HR Business Partner.
+Matters involving fraudulent acts, including acts by third parties against the firm or personal
+dishonesty by an employee, must be reported to the Fraud Prevention and Investigation Unit of
+the Real Estate & Security Department.
+If you believe that an official at a high level of the firm is involved, report to the General Auditor.
+All other matters should be reported to the Legal and Compliance Department.
+If the persons to whom you report a violation are not responsive, or if there is reason to believe that
+reporting to the persons indicated above is inappropriate in a particular case, then you should contact the
+firm's General Counsel, any other Executive Committee member, or the General Auditor.
+To call the Fraud Prevention and Investigation Department, dial:
+from within the U.S., Canada and Latin America (toll free)
+1-800-727-7375
+from EMEA
+all locations (toll call
++44-207-325-9082 or 9261 or 1110
+UK, Belgium, Luxemburg, Spain, Switzerland, Italy, South Africa, Germany, Ireland.
+and Russia (toll free)
+00800 3247 5869 (confidential freephone)
+4
+
+JPM-SDNYLIT-00275029
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 12 of 35
+all other EMEA locations (toll free)
++44 207 325 9082 or 9261 or 1110 (reverse charge calls accepted during normal
+business hours
+from Asia Pacific
+all locations (toll call)
++852 2800 1656 or 8780
+China, Hong Kong, Japan, Malaysia, South Korea, Singapore, Thailand, Taiwan, and
+Australia (toll free)
+800 5784 5784 (confidential international freephone)
+all other Asia Pacific locations (toll free)
++852 2800 1656 or 8780 (reverse charge calls accepted during normal business
+hours)
+You may also contact the Fraud Prevention and Investigation Department either
+by mail:
+from North America
+from all other locations
+1 Chan Manhal, for no, E Yet, 81
+or by e-mail:
+from North America
+fraud.prevention.and.investigation@jpmchase.com.
+from Asia Pacific
+from all other locations
+FPI-ASIAPACIFIC@pmorgan.com
+FPI-EMEA@jpmorgan.com
+If you have a particular concern regarding accounting, internal accounting controls, auditing matters, or
+financial reporting practices that you wish to bring to the attention of the Audit Committee of the Board
+of Directors, you may do so by mail sent to: JPMorgan Chase & Co., Attention: Audit Committee
+Chairman, c/o Fraud Prevention and Investigation Department at one of the addresses listed above, or by
+calling the Fraud Prevention and Investigation Department at any of the telephone numbers listed above.
+You may report your concerns anonymously, if you wish. We will respect the confidentiality of those
+who raise concerns, subject to our obligation to investigate the concern and any obligation to notify third
+parties, such as regulators and other authorities. We strictly prohibit retaliation against employees for
+good faith reporting of any actual or suspected violations of the Code.
+You must immediately report to your Human Resources Business Partner any misdemeanor (other than a
+minor traffic violation), criminal charge, or arrest involving you personally, whether it relates to the
+business of the firm or not. See HR's policy on Criminal Convictions, linked below.
+Employees in France are subject to other reporting provisions, which are included in either the
+Compliance Manual (linked below) or the |
+Code of Conduct (available from Human Resources in
+France).
+5
+
+JPM-SDNYLIT-00275030
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 13 of 35
+1.6. Current version of the Code
+The current edition of the Code is posted on the intranet. It may be amended from time to time, and all
+amendments are effective immediately upon posting. It is your responsibility to review the Code from
+time to time to ensure that you are in compliance.
+1.7. Affirmation
+You are required to affirm, either in writing or electronically, that you have read and understood the Code
+and that you will comply with it. This affirmation is required of new employees when they are hired and
+of new directors when they are elected to office. In addition, periodically all employees will be required
+to re-affirm their understanding of and compliance with the then-current Code.
+2.
+DIVERSITY
+JPMorgan Chase is committed to providing an inclusive and nondiscriminatory working environment in
+which all employees are valued and empowered to succeed. The firm prohibits discrimination or
+harassment on the basis of race, color, national origin, citizenship status, creed, religion, religious
+affiliation, age, sex, marital status, sexual orientation, gender identity, disability, veteran status, and any
+other status protected under any applicable law. Each of us is responsible for ensuring implementation of
+this policy and maintaining a business environment free of harassment and intimidation.
+and spelyou may not unlawfully discriminate in your dealings with current or prospective customers
+The firm's Travel and Entertainment Policies preclude reimbursement from, or payment by, JPMorgan
+Chase for membership in or expenses incurred at organizations with discriminatory practices.
+3. CONFIDENTIAL INFORMATION
+We are all responsible for the safeguarding of confidential information, whether it is information
+entrusted to us by our customers, information regarding JPMorgan Chase's businesses and activities, or
+information about other employees.
+3.1.
+Information about the firm, its customers, its employees, and others
+Cou may have access to confidential information related to the firm's business. Information related to th
+rm's business includes information about the firm, as well as information related to the firm's customer
+counterparties, or advisory clients (all of which the Code refers to as customers), business partners,
+suppliers, and your fellow employees.
+You may not, either during your period of service or thereafter, directly or indirectly use or disclose to
+anyone any such confidential information, except as permitted by the Code and other policies applicable
+to you.
+6
+
+JPM-SDNYLIT-00275031
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 14 of 35
+You should observe the following principles when dealing with information relating to the firm's
+business:
+(a)
+Assume that most information that you have about the firm and its business, or about its
+past, present, or prospective customers, suppliers, and employees, is confidential, unless
+the contrary is clear.
+(b)
+(c)
+Treat all personal information about individuals as confidential.
+Before sharing confidential information with others in the firm, be sure that you are
+permitted to do so. Do not disclose confidential customer information to other employees
+who are not involved with the transaction or service for which the information was
+provided to the firm --- even if you believe the disclosure might be useful in the context
+of other firm business --- unless you are authorized to do so.
+(d)
+Do not disclose confidential information to anyone outside the firm unless you are
+authorized to do so. Where such disclosure is authorized, a confidentiality or privacy
+agreement may be required; check with the Legal Department.
+(e)
+If you are permitted to share confidential information, use your judgment to limit the
+amount of information shared and disclose it only on a need-to-know basis in order to
+provide the services we are engaged to provide. Ensure that the recipient knows the
+information is confidential and has been instructed about restrictions on further use and
+dissemination.
+(f)
+Comment or provide information on matters related to the firm's business only if it is part
+of your job function or you are otherwise authorized to do so.
+(g)
+Protect confidential information when communicating electronically -- for instance, by e-
+(h)
+mail or through the internet.
+Remember that all forms of communication are covered, including written, telephonic,
+and electronic communications such as website chatrooms, e-mail, and instant
+messaging.
+(1)
+Consult your manager or your Compliance officer if you have any question about
+whether information can be shared.
+3.2. Prior employer's confidential information and trade secrets
+Do not disclose to JPMorgan Chase, or use during your employment at JPMorgan Chase, any confidential
+information or trade secret of a prior employer, unless the information or trade secret is then public
+information through no action of your own.
+3.3. Special rules regarding customer information and data privacy legislation
+Each of us has a special responsibility to protect the confidentiality of information related to customers.
+This responsibility may be imposed by law, may arise out of agreements with our customers, or may be
+based on policies or practic es adopted by the firm. Certain jurisdictions have regulations relating
+specifically to the privacy of individuals and/or business and institutional customers. Various business
+units and geographic areas within JPMorgan Chase have internal policies regarding customer privacy.
+You should be familiar with those that apply to you. Customer information should never be disclosed to
+anyone outside the firm except as permitted by law and in the proper conduct of our business, where
+disclosure is required by legal process, or where the Legal and Compliance Department otherwise
+determines it is appropriate.
+7
+
+JPM-SDNYLIT-00275032
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 15 of 35
+3.4. Publications, speeches, and other communications relating to JPMorgan Chase's business
+You should be alert to situations in which you may be perceived as representing or speaking for the firm,
+especially in public communications (including internet chatrooms, bulletin boards, etc.). You should not
+make any statements on behalf of JPMorgan Chase, or regarding JPMorgan Chase, its business, or its
+customers, unless it is part of your job or you are otherwise specifically authorized to do so. Refer all
+media inquiries to the Media Relations Office.
+Public testimony (as an expert witness or otherwise), publications and speaking engagements relating to
+the firm's business are subject to pre-clearance. Subpoenas, requests from law enforcement or regulatory
+authorities, media inquiries, product advisory boards, and requests from customers or suppliers for
+testimonials or endorsements should be handled in accordance with applicable procedures. Before
+engaging in any of these activities, consult your Compliance officer or your Code Specialist and the
+relevant policies and procedures. Procedures for pre-clearance of these activities are included in the
+policy on Communication on Matters Relating to the Company's Business.
+If you will be paid for any of these activities, you will also need pre-clearance under Section 6.3.2
+(outside activities); consult your Code Specialist.
+4. INSIDE INFORMATION AND THE CHINESE WALL POLICY
+Buying or selling securities while in possession of material non-public information is prohibited, as is the
+communication of that information to others.
+4.1. Inside Information
+If you are aware of inside information,
+you may not buy or sell securities (including equity securities, bonds and other debt
+securities, convertible securities, derivatives, options, any
+_index including any such
+security as an element, and any other financial instruments) that may be affected by that
+information, either for your own account or any account over which you exercise control
+alone or with others.
+(b)
+information.
+"Inside information" is material, nonpublic information about the securities, activities, or financial
+condition of a corporation, public entity, or other issuer of securities. Material, nonpublic information
+concerning market developments may also be construed to be inside information.
+Information is "material" if it could have an impact on the market price of securities involved or if it is
+kely that a reasonable investor would consider the information important in deciding whether to
+urchase or sell the securities. Information may be material to one issuer but not to another, or to certai
+securities of an issuer but not to all securities of that issuer.
+8
+
+JPM-SDNYLIT-00275033
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 16 of 35
+Information should be considered "nonpublic " unless it is clearly public. Information is deemed public
+once it has been publicly announced or otherwise disseminated in a manner that makes the information
+available to investors generally.
+Likewise, you may not buy or sell securities if you have knowledge of proposed customer trades, trades
+by JPMorgan Chase, or forthcoming research reports regarding those securities or the issuer of those
+securities, and you may not pass along this information to others in any way.
+These prohibitions are applicable no matter how you acquired the inside information. They are applicable
+to the securities of JPMorgan Chase as well as to those of other companies.
+These prohibitions do not apply to qualified transactions pursuant to certain planned acquisition or selling
+programs, such as so-called 10b5-1 programs. These prohibitions also do not apply to legally permissible
+transactions with the issuer of the securities, or with other persons having the same information you have
+(a circumstance likely to be relevant only in the context of private securities). Before engaging in any
+transactions you believe to be permissible under this paragraph, you must consult with your Compliance
+officer.
+4.2. The Chinese Wall policy and other information barriers
+The firm's Chinese Wall policy refers to a system of information barriers designed to limit the flow of
+prohibits anyone in an insider area from communicating inside information, however obtained, to anyone
+in a public area, subject to limited exceptions approved by the relevant Compliance officer.
+In addition, some business areas within the firm require procedures that address more specifically the
+information flows within those business areas. These are also sometimes referred to as Chinese Walls.
+Employees subject to the firm's Chinese Wall policy, or to other information barriers designed to meet
+specific business needs, are responsible for compliance with the provisions of applicable polic ies.
+5. OTHER BUSINESS CONDUCT
+We are all expected to conduct the firm's business in accordance with the highest ethical standards,
+impeting th, aid coustines, supiers, an epth abusines ounciatie, dealing responsibly with th
+ir's assets, and complying with app
+5.1. Assets of the firm
+You are expected to protect the firm's assets as well as the assets of others that come into your custody.
+The firm's assets include not only financial assets such as cash and scurities and physical assets such as
+furnishings, equipment and supplies, but also customer relationships and intellectual property such as
+information about products, services, customers, systems and people. All property created, obtained, or
+
+JPM-SDNYLIT-00275034
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 17 of 35
+compiled by or on behalf of the firm --- including customer lists, directories, files, reference materials and
+reports, computer software, data processing systems, computer programs, and databases --- belongs to the
+firm.
+The firm's assets should be used only for the conduct of the firm's business, except where limited
+incidental personal use is authorized by the Code or other applicable policies.
+5.2. Intellectual property
+Any invention, discovery, development, concept, idea, process, or work related to the firm's business,
+written or otherwise, whether or not it can be patented or copyrighted, that you develop alone or with
+others during your employment with the firm (all of which are referred to as "Company Inventions")
+belongs to the firm. If a Company Invention is something that can be copyrighted and you create it as a
+part of your job with the firm or because the firm asks you to create it, it is a "work made for hire." The
+firm is not required to acknowledge your role in the creation of any Company Inventions or to have your
+permission to modify, expand, or benefit from it.
+As a condition of your employment, you assign exclusively to the firm all of your right, title and interest
+in Company Inventions. You further agree to assist the firm in obtaining for its own benefit intellectual
+property rights, including any patents and copyrights, in the Company Inventions and agree to deliver any
+documents that may be requested to assure, record or perfect your assignment of the Company Inventions
+to the firm.
+5.3. Telephones, e-mail, internet, and other electronic communications devices
+Telephones, electronic mail (e-mail) systems and other electronic communications devices provided by
+JPMorgan Chase, whether in the workplace or elsewhere, are the property of the firm and should be used
+for business purposes; however, limited incidental personal use is permitted, consistent with the Code and
+all other policies of the firm.
+The use of e-mail, the firm's intranet and the internet must conform to the policies of JPMorgan Chase.
+E-mail and internet systems may be used to transmit or provide access to confidential information only
+when such information is adequately protected and transmitting such information is necessary for
+business purposes.
+Among other things, the following are prohibited in electronic communications:
+statements, which, if made in any other forum, would violate any of our policies,
+including policies against discrimination and harassment; participation in impermissibl
+or illegal activities (such as gambling or the use and sale of controlled substances); and
+the misuse of confidential information.
+(b)
+accessing, downloading, uploading, saving, or sending sexually oriented or other
+offensive materials.
+JPMorgan Chase considers all data and communications transmitted through, received by, or contained in
+using such resources.
+10
+
+JPM-SDNYLIT-00275035
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 18 of 35
+5.4. Internal controls, record-keeping, and reporting
+Internal accounting controls and record-keeping policies have been established in order for JPMorgan
+Chase to meet both legal and business requirements. You are expected to maintain and adhere to these
+controls and policies.
+The falsification of any book, record, or account relating to the business of JPMorgan Chase, its
+customers, or its suppliers, or to the disposition of assets of the firm, its customers, or its suppliers
+(including without limitation the submission of any false personal expense statement, claim for
+reimbursement of a non-business expense or a false employee record or claim under an employee benefit
+plan), is prohibited.
+The firm's record-keeping policies include policies for records and document retention and destruction.
+Notwithstanding any other provision of document retention policis, no document or record may be
+destroyed if you have been advised or otherwise should recognize that it may be relevant to a pending or
+hreatened legal or regulatory proceeding, except in accordance with procedures approved by the head o
+he Litigation Group in the Legal Department or one of his/her direct reports
+ț is of critical importance that JPMorgan Chase's filings with regulatory authorities be accurate an
+imely. Information provided to those involved in preparation of the firm's disclosures to regulators an
+investors should be complete, accurate, and informative.
+5.5. Limits of your authority
+Your authority to act on behalf of JPMorgan Chase is limited by various laws, regulations, corporate
+harters, by-laws, and board resolutions, and by internal policies and procedures. You may not sign an
+locuments, or otherwise represent or exercise authority, on behalf of any JPMorgan Chase entity unles
+you are specifically authorized to do so. Be aware of limits on your authority and do not take any action
+that exceeds those limits.
+Delegation of authority, where permissible under corporate policies and otherwise appropriate, should be
+reasonably limited in scope and subject to appropriate ongoing oversight.
+5.6. Business relationships
+5.6.1. Fair dealing
+You should always endeavor to deal fairly and in good faith with the firm's customers, suppliers,
+ompetitors, business partners, regulators, and employees. It is our policy not to take unfair advantage o
+thers through manipulation, concealment, abuse of privileged information, misrepresentation of materia
+facts, or any other unfair dealing practice.
+Customer, supplier, and employee relationships
+During your employment you may not, directly or indirectly:
+solicit for a competitor, or divert or attempt to divert from doing business with JPMorgan
+"hase, any customer, identified prospective customer, supplier, or other person or entity
+vith whom JPMorgan Chase has or had a business relationship
+
+JPM-SDNYLIT-00275036
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 19 of 35
+(b)
+solicit JPMorgan Chase's employees for employment or engagement elsewhere or solicit
+or induce any employee, consultant, independent contractor, agent, or supplier to leave
+JPMorgan Chase.
+5.7. Money laundering and the USA PATRIOT Act
+JPMorgan Chase has established policies, procedures and internal controls designed to assure compliance
+with international laws and regulations regarding money laundering and terrorist financing, including
+relevant provisions of the Bank Secrecy Act and the USA PATRIOT Act in the United States and similar
+legislation in other countries. You should be familiar with, and comply with, these policies, procedures
+and controls. You should also understand your obligations to:
+(a)
+know your customers and your customers' use of the firm's products and services.
+(b)
+get proper training if you are identified as being in a job that poses a risk of money
+laundering or terrorist financing.
+(C)
+be alert to and report unusual or suspicious activity to the designated persons within your
+line of business or region, including your Compliance officer or Risk Manager
+responsible for anti-money laundering compliance.
+5.8.
+Tying of products
+"Tying" arrangements, under which the availability or price of one product is conditioned on the
+customer's purchase of another product, are illegal under some circumstances. United States Federal laws
+govern tying arrangements involving bank subsidiaries of JPMorgan Chase & Co.
+5.9. Bribery and the Foreign Corrupt Practices Act
+Federal and other laws in the United States and the laws of many other countries prohibit giving, offering,
+or promising, directly or indirectly, anything of value to corruptly influence any government official,
+including any officer of a political party or a candidate for political office, for the purpose of obtaining or
+retaining business or to secure an improper advantage (such as favorable regulatory or judicial action).
+Offering or paying such remuneration to any such person, either directly or through any intermediaries
+such as agents, attorneys or other consultants, is strictly prohibited.
+In addition, you may not accept any such payments in connection with any business decision or
+transaction, even if such payments are customary in the particular country involved.
+5.10. International boycotts and economic sanctions
+The U.S. antiboycott law prohibits certain actions to comply with or support an unsanctioned foreign
+oycott against a country friendly to the United States. The prohibited actions include refusing to d
+usiness in a certain country, furnishing information about a person in response to a boycott-relate
+request, and implementing a letter of credit that contains a condition related to any of the prohibited
+actions.
+The U.S. economic sanctions regulations prohibit U.S. persons, including U.S. financial institutions and
+their foreign branches and non-U.S. affiliates, from exporting financial services to certain forcign
+governments and their specially designated nationals named by the Office of Foreign Assets Control
+(OFAC). These regulations also require that assets of these governments and persons be frozen. All
+12
+
+JPM-SDNYLIT-00275037
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 20 of 35
+JPMorgan Chase branches and subsidiaries are required to establish policies and procedures to ensure that
+their customers (and potential customers) are not on the OFAC list. You should be familiar with the
+policies and procedures that apply to you.
+5.11. Post-employment responsibilities
+As a condition of continued employment with JPMorgan Chase, employees will have certain
+responsibilities after their employment with JPMorgan Chase terminates. These responsibilities include
+an obligation to return all firm assets in their possession, maintain the confidentiality of information,
+refrain from insider trading based on information obtained in the course of employment by JPMorgan
+Chase, and, if requested, assist JPMorgan Chase with investigations, litigation, and the protection of
+intellectual property relating to their employment. Senior-Level Employees have additional obligations
+for one year after they leave JPMorgan Chase, including prohibitions on the solicitation and hiring of
+JPMorgan Chase employees and solicitation of certain customers. Certain employees are subject to other
+post-employment restrictions. You are responsible for knowing which post-employment restrictions and
+requirements apply to you.
+5.12. Other professional obligations of some employees
+Some employees have additional obligations relating to their positions with the firm, including employees
+who are considered to be finance professionals, certain employees acting as attorneys for the firm, and
+certain officers in the Investment Bank. If you are subject to any of these additional requirements, you
+should be familiar with and comply with them.
+6.
+OUTSIDE ACTIVITIES, GIFTS, AND OTHER POTENTIAL CONFLICTS OF
+INTEREST
+Employees must never permit their personal interests to conflict with or to appear to conflict with the
+interests of the firm. When faced with a situation involving a potential conflict, ask yourself whether
+public disclosure of the matter could embarrass JPMorgan Chase or you, or would lead an outside
+observer to believe a conflict exists, whether or not one actually does. You must disclose to the Office of
+the Secretary all potential conflicts of interest, including those in which you may have been placed
+inadvertently due to either business or personal relationships with customers, suppliers, business
+associates, or competitors of JPMorgan Chasc, or with other JPMorgan Chase employees.
+6.1. Personal relationships
+In general, you may not act on behalf of JPMorgan Chase in any transaction or business relationship
+involving yourself, members of your family, or other persons or organizations with which you or you
+amily have any significant personal connection or financial interest. These matters should be handled b
+an authorized unrelated employee.
+You may not engage in self-dealing or otherwise trade upon your position with JPMorgan Chase or accept
+r solicit any personal benefit from a client or supplier not generally available to other persons or mac
+vailable to you due to your position with JPMorgan Chase (except in accordance with our polici
+regarding the occasional acceptance of gifts).
+13
+
+JPM-SDNYLIT-00275038
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 21 of 35
+Negotiating with JPMorgan Chase on behalf of others with whom you or your family have a significant
+connection should be avoided if there is a risk that your involvement would be perceived as self-dealing
+or trading upon your position with the firm.
+Hiring or working with relatives, or someone with whom you have a romantic relationship, is subject to
+specific restrictions. You should be aware of those limitations if they apply to you.
+6.2. Personal finances
+Because of the nature of our business, any improper handling of your personal finances could undermine
+your credibility and that of JPMorgan Chase. Also, a precarious personal financial position might appear
+to influence actions or judgments you make on behalf of JPMorgan Chase.
+You may not borrow money (other than nominal amounts) from or lend money to other employees,
+customers or suppliers, or act as a guarantor, co-signer, or surety or in any other similar capacity for
+customers, suppliers, or other employees. You should borrow only from reputable organizations that
+regularly lend money. If you borrow from any financial institution, the loan must be obtained on nonpreferential terms.
+In general, you may not participate in any other personal financial transactions with fellow employees,
+customers, or suppliers. This prohibition includes shared investments (unless they are either widely held
+or held pursuant to firm sponsored co-investment plans) and investment clubs.
+The foregoing limitations do not apply to:
+(a) borrowing from, or acting as guarantor, co-signer, or surety for, relatives or close
+personal friends.
+(b) borrowing on non-preferential terms from a customer that is in the financial services
+business.
+(c)
+making consumer credit purchases on non-preferential terms from a customer or supplier
+in the normal course of that customer/supplier's business.
+6.3. Outside business and not-for-profit activities; outside employment
+6.3.1. General
+Your outside activities must not reflect adversely on JPMorgan Chase or give rise to a real or apparent
+conflict of interest with your duties to the firm. You must be alert to potential conflicts of interest and be
+aware that you may be asked to discontinue any outside activity if a potential conflict arises. You may
+not, directly or indirectly:
+(a)
+accept a business opportunity from someone doing business or seeking to do business
+with JPMorgan Chase that is made available to you because of your position with the
+firm.
+(b)
+(c)
+take for yourself a business opportunity belonging to the firm
+engage in a business that competes with any of the firm's businesses.
+In general, employees may not work for, or serve as a director or officer of or adviser to, a competitor of
+he firm. Competitors include unrelated financial services companies of any kind, and others engaged i
+ny business JPMC is involved in, such as asset managers, depository institutions, credit unions, lenders
+investment banks, insurers, insurance agencies, and securities brokers, dealers, and underwriters.
+14
+
+JPM-SDNYLIT-00275039
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 22 of 35
+Employees should also not invest in a competitor (other than investments in securities of publicly traded
+companies).
+Outside activities must not interfere with your job pertormance or require such long hours as to affect
+your physical or mental effectiveness. Your job at JPMorgan Chase should always be your first work
+priority.
+You may accept appointments as a personal fiduciary only for family members and close personal friends.
+However, you may not act as a personal fiduciary for a personal friend if the friendship developed in the
+context of a JPMorgan Chase customer relationship.
+6.3.2. Required pre-clearance of outside activities
+Pre-clearance is required for certain outside activities by employees, as described below.
+1. Outside business activities
+Subject to the exclusions listed below, you are required to pre-clear:
+any outside activity for which you will be paid, including a second job.
+whether or not you will be paid, any affiliation with another business as a
+director, officer, advisory board member, general partner, owner, consultant,
+holder of 5% or more of the business' voting equity interests, or in any similar
+position.
+However, you are not required to pre-clear the following activities under this Section (although
+these matters may be subject to clearance or reporting requirements of your business unit or of
+other sections of the Code):
+(a)
+certain types of appointments specifically excluded from Section 6.3.2 by the
+Office of the Secretary because they are undertaken at the request of JPMorgan
+Chase in the normal course of a business in which the firm is routinely engaged.
+(b)
+(C)
+(d)
+any affiliation with a trade association, professional association, or other such
+organization related to your position at JPMorgan Chase (however, if the
+organization is involved in lobbying activities, you should discuss the affiliation
+with the Government Relations Department in advance).
+positions with co-op boards, condominium associations, and similar entities the
+sole business of which is to hold title to and/or manage real property in which
+you can or do reside.
+positions with holding companies, trusts, or other non-operating entities
+Lo bol your or your family real eat rote meters that would ming or
+otherwise require pre-clearance under this Section 6.3.2.
+2. Not-for-profit activities
+Not-for-profit activities generally do not require pre-clearance. However, employees are required
+15
+
+JPM-SDNYLIT-00275040
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 23 of 35
+(b) you have been requested to serve in that capacity by a customer or supplier of
+your business unit.
+your service would otherwise present a conflict of interest or the appearance of a
+conflict of interest.
+As noted above, positions with trade associations, professional associations, or other such
+organizations related to your position at JPMorgan Chase need not be pre-cleared.
+3. Governmental activities
+You are required to pre-clear any government position, including as an elected official and as a
+member, director, officer, or employee of a governmental agency, authority, advisory board, or
+other board (a public school or library board, for example). You must obtain pre-clearance before
+becoming a candidate for elective office.
+Procedures and forms for pre-clearance of these activities are available in the JPMorgan Chase
+Procedures and Forms for Pre-Clearance of Outside Activities. You must seek a new clearance for a
+reviously approved activity whenever there is any material change in relevant circumstances, whethe
+arising from a change in your job with JPMorgan Chase or in your role with respect to that activity of
+organization. You must also notify the Office of the Secretary when any approved outside activity
+Note also that publications and speaking engagements relating to the business of JPMorgan Chase must
+be pre-cleared under Section 3.4 of the Code.
+6.4. Political Activities
+6.4.1. Political campaign activities and contributions by employees
+Volunteering for a political campaign. If you wish to volunteer for a political campaign, you must do sc
+on your own time and as an individual, not as a representative of the firm or any of its affiliates. You may
+not use any JPMorgan Chase staff, facilities, equipment, supplies, or mailing lists.
+Vhen acting as a fundraiser for a candidate or political event, be certain that your activities cannot b
+viewed as connected with your position with JPMorgan Chase, especially when communicating with
+colleagues, customers, or suppliers. Contact the Government Relations Department for further guidance
+on such activity.
+Volunteer political activities in connection with the 2008 Presidential Campaign in the United States are
+covered by the policy linked below, "Volunteer Political Activities for Presidential Candidates".
+(Note that running for public office is covered by Section 6.3.2.)
+Political contributions. You have the right to participate in the political process by making personal
+contributions from personal funds, subject to applicable legal limits. However, you cannot be reimbursed
+or otherwise compensated by JPMorgan Chase for any such contribution.
+16
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+Certain lines of business (for example, Municipal Finance and Asset Management) may have additional
+policies regarding employees' personal contributions; you are responsible for being aware of, and
+complying with, any rules applicable to your business unit.
+Additionally, you must contact the Government Relations Department or your local Compliance Officer
+with respect to a personal political contribution that could violate, or create the appearance of a violation
+of, the Foreign Corrupt Practices Act or local law. (See Section 5.9 for a discussion of the Foreign
+Corrupt Practices Act.) Employees need to be especially sensitive when giving to officials who are part
+of the decision-making process with respect to any matters relating to the firm.
+6.4.2. Political contributions and related activities by JPMorgan Chase
+Political contributions and gifts. It is improper to offer or give anything to a public official, either directly
+or through an intermediary, in an effort to secure an advantage that would not have been granted if the
+offer or gift had not been made. In the U.S., political contributions by corporate entities are strictly
+regulated by laws at the federal, state and local levels. These laws often prohibit or limit direct monetary
+contributions made from corporate funds (such as a contribution check or purchase of fundraising event
+tickets) as well as in-kind contributions (such as the use of corporate facilities or staff, and even the
+granting of loans or other products at preferential rates). Local law in jurisdictions outside the U.S. can
+also impose restrictions. Therefore, both within and outside the U.S.,
+(a)
+all requests for firm support (either through monetary or in-kind contributions) of
+political events, political candidates and their campaigns, political parties, or political
+committees must be pre-approved and processed by the Government Relations
+Department.
+(b)
+political contributions proposed to be made by or on behalf of the firm must be precleared by the Government Relations Department.
+(c)
+all gifts to governmental officials to be made by or on behalf of the firm (including items
+of value, transportation, lodging, meals, entertainment, and services, and including
+invitations to non-profit or other special events for which the firm has paid) must comply
+with rules applicable to the relevant jurisdiction and with JPMorgan Chase's policies.
+Note that many jurisdictions prohibit or restrict such gifts. For information on gifts to
+officials in the United States, see Coverage of Government Entities Compliance
+(COGEC); for information on gifts to officials outside the U.S., see the policy on the
+Foreign Corrupt Practices Act. Contact the local Compliance unit in the relevant
+jurisdiction(s) for further guidance.
+Lobbying by or on behalf of JPMorgan Chase. All lobbying activities, including the retention of outside
+lobbyists, must be pre-cleared through the Government Relations Department. Note that the federal
+government and each state has its own definitions and regulations regarding lobbying of governmenta
+mployees, and what might seem like a simple meeting could trigger a reporting requirement; if in doub
+contact Government Relations.
+Accepting gifts, meals, and entertainment from customers, suppliers, and others doing
+business with JPMorgan Chase
+A gift may take many forms. For the purposes of the Code, the term "gift" includes anything of value for
+which you are not required to pay the retail or usual and customary cost. A gift may include meals or
+17
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+refreshments, goods, services, tickets to entertainment or sporting events, or the use of a residence,
+vacation home, or other accommodations.
+Gifts given by others to members of your family, to those with whom you have a close personal
+relationship, and to charities designated by you, are considered to be gifts to you for purposes of the
+Code.
+You may never, except as provided in the Code:
+(a) solicit, for yourself or for anyone else (other than the firm), or accept anything of value
+from anyone doing business with the firm.
+solicit, for yourself or for anyone else (other than the firm), or accept anything of value
+from anyone in return for any business, service, or confidential information of the firm.
+(c)
+solicit, for yourself or for anyone else, or accept anything of value, directly or indirectly
+(other than bona fide salary, wages, awards, and fees paid by or to the firm), from anyone
+in connection with the business of the firm, either before or after a transaction is
+discussed or consummated.
+Note that the restrictions in this section 6.5 are not intended to apply to gifts based on obvious family
+relationships (such as your parents, children, or spouse) or close personal friendships, where the
+circumstances make it clear that it is the relationship rather than the firm's business that is the motivating
+factor.
+You are responsible for being familiar with any additional restrictions that may be applicable to your
+business unit.
+6.5.1. What you may accept
+Acceptance of gifts of any kind (including entertainment and hospitality) from persons that do business or
+seek to do business with JPMorgan Chase (including identified prospective customers) is generally
+prohibited. However, subject to the prohibitions in Section 6.5.2 and to any more restrictive policies
+your business unit may have, the following gifts may be accepted on infrequent occasions from such a
+person if it is clear that the person is not trying to influence or reward you inappropriately in
+connection with any business decision or transaction and the gift is unsolicited:
+(a)
+(b)
+(c)
+gifts having a retail value not exceeding U.S. S100 (or such lesser amount as is
+established by your local Compliance unit) that are given on an occasion when gifts are
+customary (on a birthday or major holiday, or on the occasion of a promotion or
+retirement, for example; note that gifts given in appreciation for good service, or as
+thanks for our business, are not permitted).
+advertising or promotional material having a retail value not exceeding U.S. S100 (or
+such lesser amount as is established by your local Complia nee unit), such as pens,
+pencils, note pads, key chains, calendars, and similar items.
+discounts and rebates on merchandise or services that are offered to the general public, or
+to all employees under a plan negotiated by JPMorgan Chase.
+(d)
+(e)
+amount as is established by your local Compliance unit).
+18
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+(f)
+(g)
+meals, refreshments, and entertainment in the course of a meeting or other occasion,
+provided:
+(1)
+the purpose is business-related,
+(ii)
+your host is present,
+(ill) your attendance is related to your duties with JPMorgan Chase,
+(iv)
+the level of expense is reasonable and customary in the context of your business
+and the relationship with the host, and
+(V)
+the frequency of such invitations from one host is not excessive.
+If you have questions about whether a specific invitation may be accepted under this item
+-- whether, for example, it is business-related, or reasonable and customary in the
+context of your business with the host --- discuss it with your manager, your Code
+Specialist, or your Compliance officer.
+gifts of food or beverage items that are not easily returned, if they are:
+(i)
+given on an occasion when gifts are customary (on a birthday or major holiday,
+or on the occasion of a promotion or retirement, for example; note that gifts
+given in appreciation for good service, or as thanks for our business, are not
+permitted),
+not extravagant, and
+Where this Section refers to "a retail value not exceeding U.S. $100," the relevant Compliance unit wil
+letermine the approximate equivalent in local currency for use in jurisdictions outside the U.S
+Whenever you receive a gift, or an offer of a gift, that is not specifically permitted by this Section 6.5.1,
+make every effort to refuse or return it. If that isn't possible, notify your Compliance officer or your
+Code Specialist to discuss how to deal with the gift.
+6.5.2. What you may not accept
+Except as approved pursuant to Section 6.5.3, you may not accept the following from any current or
+identified prospective customer, supplier, or other party doing business with JPMorgan Chase:
+(a) gifts of cash or cash equivalents (such as gift certificates, gift checks, or securities), in
+any amount.
+(b)
+discounts not available to the general public or to all employees under a plan negotiated
+by Morgan Chase.
+(c)
+(d)
+(e)
+gifts to be delivered in installments.
+bequests or legacies.
+invitations to parties, sports outings, and similar events solely for groups of more than ten
+JPMorgan Chase employees sponsored by parties that do business with JPMorgan Chase,
+including golf or other sports or similar outings, year-end parties, group dinners, or
+departmental entertainment, unless they have been approved in writing by a member of
+the Executive Committee or an officer who reports directly to an Executive Committee
+member, with a copy to your Code Specialist.
+(f)
+travel or accommodation expenses, unless they have been approved in writing by a
+member of the Executive Committee or an officer who reports directly to an Executive
+19
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+(g)
+Committee member, with a copy to your Code Specialist (travel and accommodations are
+not considered gifts and may be accepted if they are agreed as part of a business
+transaction between the party providing the travelor accommodations and JPMorgan
+Chase).
+tickets for sports competitions, concerts, or other events for your personal use, other than
+as permitted under Section 6.5.1.
+6.5.3. Approval of nonconforming gifts
+An Executive Committee member, your Code Specialist, and the Office of the Secretary together may
+approve, on a case-by-case basis, the acceptance of a gift that is not specifically permitted under Section
+6.5.1, or that is prohibited under Section 6.5.2. Any such approval must be in writing and pursuant to full
+written discsure of all relevant facts, including the name of the donor, the circumstances surrounding
+the offer and acceptance, the nature and approximate value of the gift, and the reason why it cannot or
+should not be returned. (Use the Nonconforming Gift Approva 1 Request and Report Form filed under
+Section 6.5.4, signed by cach of the Executive Committee member, your Compliance officer, and the
+Office of the Secretary, for this purpose.)
+6.5.4. Required reporting of gifts
+You are required to file a Nonconforming Gift Approval Request and Report Form with respect to:
+any gift that is not permitted under Section 6.5.1 or that is listed in Section 6.5.2, if the
+gift has not been refused or returned (even if acceptance has been approved in accordance
+with Section 6.5.3). (Note that you must refuse or return any such gift unless it has been
+specifically approved in writing as specified in Section 6.5.3; the Nonconforming Gift
+Approval and Report Form should be used to evidence that approval.)
+(b)
+the offer or receipt of any gift that is so lavish it could give rise to an inference of
+(c)
+impropriety, whether or not you refuse or return it.
+the offer or receipt of frequent gifts from one source, whether or not you refuse or return
+The Nonconforming Gift Approval and Report form, indicating the disposition of the gift, must be signed
+by an Executive Committee member, your Compliance officer, and the Office of the Secretary. The
+Office of the Secretary will maintain a record of all reported gifts.
+6.6. Providing gifts, meals or entertainment
+Loan lays ore outrue or regulations oftenin ourohit. tor ingle, brinks realers and chase
+managers are generally subject to regulatory restrictions on providing gifts.
+Some lines of business have very restrictive gift-giving policies, and others have prohibited gifts entirely.
+You are responsible for knowing and complying with the policies that apply to you.
+The giving of gifts to governmental officials is in many cases strictly limited by law or regulation. See
+Section 6.4.2 for additional guidance.
+20
+
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+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 28 of 35
+Business-related gifts not prohibited by law or firm policies should be reasonable and customary in the
+context of the relationship with the recipient of the gift, appropriate for the occasion, and in conformity
+with the Code, JPMorgan Chase's Travel & Entertainment Policies & Procedures, and all other applicable
+policies.
+6.7. Solicitations at work; charitable contributions by the firm
+While the firm encourages its employees to become involved with charitable organizations, there are
+restrictions on solicitation of customers, suppliers, and fellow employees for contributions. You should
+become familiar with the relevant policies before engaging in any such activities.
+Occasionally customers or suppliers ask that JPMorgan Chase make a contribution to a charity or not-forprofit organization. If it is necessary for business development purposes to make a contribution, you
+should contact Corporate Philanthropy and Sponsorships to help determine the appropriate level,
+including consideration of whether the firm has already made a contribution to the organization.
+7. PERSONAL SECURITIES AND OTHER FINANCIAL TRANSACTIONS
+Your personal investment activities should always be conducted with the Company's reputation in mind
+and in compliance with all applicable laws and regulations.
+7.1. General investment principles
+Employees are expected to devote their workdays to serving the interests of our clients and JPMorgan
+Chase. Accordingly your personal securities and other financial transactions must be oriented towards a
+philosophy of investment as distinguished from short-term or speculative trading.
+In addition to complying with all other Code provisions and relevant policies and procedures, you should
+bserve the following general investment principles in carrying out personal transactions in securities an
+›ther financial instruments. (All references to securities should be understood to include all financia
+instruments, such as equity securities, bonds and other debt securities, convertible securities, derivatives,
+options, and any
+index.)
+(a)
+While in possession of inside information about the issuer of any securities or the
+securities themselves, never buy, sell, or recommend the purchase or sale of such
+securities for your account or the accounts of others, regardless of whether the inside
+information is gained through the scope of your employment or elsewhere. If in doubt,
+don't trade.
+(b)
+Do not buy or sell securities with knowledge of proposed client trades, trades by
+Your trading and investment and veies must be within your financial means.
+(c)
+(d)
+(e)
+by JPMorgan Chase.
+Limit the risks in your personal account trading. Do not engage in excessive trading
+activities that represent a high degree of financial risk.
+21
+
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+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 29 of 35
+(f) Trading and investment activities should be for investment purposes and not for shortterm trading profits.
+(g) Do not engage in speculative trading, such as trading based on rumors.
+7.2. Persons and accounts subject to policies
+All personal investment policies that apply to you also apply to transactions for the account of your
+spouse, your domestic partner, your minor children, and any other person to whom you provide
+significant financial support, as well as to transactions in any other account over which you or any of
+these persons exercise investment discretion, regardless of beneficial interest. These are referred to as
+"employee-associated accounts."
+7.3. Trading in JPMorgan Chase securities
+7.3.1. Policies applicable to all employees
+Purchases and sales of JPMorgan Chase & Co.'s common
+or other securities are subject to the
+general policies related to personal trading. These policies are applicable to the following transactions (as
+they are to your other investment activities):
+(a)
+direct purchases and sales of JPMorgan Chase securities.
+(b) elections involving the JPMorgan Chase & Co. common
+fund in your 401(k) plan,
+deferred compensation plan, or Employee
+Purchase Plan, including decisions to
+increase or decrease contributions or elections that result in increasing or decreasing
+amounts credited to any common
+(c)
+account under an employee benefit plan.
+sales of JPMorgan Chase securities to meet a margin call, with or without your personal
+involvement.
+(d)
+(e)
+placing, canceling, or amending limit orders with respect to JPMorgan Chase securities.
+entering into, canceling, or amending sales plans, sometimes referred to as 10b-5(1)
+plans, with respect to JPMorgan Chase securities.
+However, these policies do not affect automatic purchases of JPMorgan Chase
+previously made benefits elections and acquisitions of JPMorgan Chase
+in accordance with
+through dividend
+reinvestment.
+Purchases and sales of JPMorgan Chase & Co.'s common
+Lor other securities are also subject to any
+more restrictive personal trading policies applicable to your business unit.
+In addition, the following restrictions apply to transactions in JPMorgan Chase securities:
+You may not engage in short selling of JPMorgan Chase, except for short sales against a
+long position already held by you (sometimes referred to as a short sale against the box).
+(b)
+You may not engage in derivative transactions related to JPMorgan Chase securities
+except as part of JPMorgan Chase's compensation and benefits programs, or when usco
+for bona fide hedging purposes against a long position already held by you, or as
+otherwise approved by the Office of the Secretary.
+(c)
+No transactions in JPMorgan Chase securities, including derivative transactions, may be
+made in fully managed accounts (accounts over which you have no trading discretion),
+except dispositions of shares permissibly transferred to the account. Any transfer of
+securities into a managed account is subject to any restrictions applicable to a sale of such
+securities.
+22
+
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+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 30 of 35
+(d) Subject to any other JPMorgan Chase policies on personal securities trading applicable to
+you, you may enter, cancel, or amend limit orders for the purchase or sale of JPMorgan
+Chase securities.
+(e)
+Your transactions in JPMorgan Chase securities may be halted at any time the Company
+finds it necessary or advisable to halt trading by all employees or certain groups of
+employees.
+7.3.2. Employees subject to the "window" and "Senior-levelemployees"
+Certain employees are restricted from engaging in transactions in JPMorgan Chase securities except
+during quarterly window periods and are subject to certain other requirements with respect to transactions
+in JPMorgan Chase securities. This policy affects only those persons who are specifically notified by
+their management or by the Office of the Secretary that they are subject to it.
+Senior-levelemployees (whether subject to the window restrictions or not) must discuss planned
+transactions in JPMorgan Chase securities with a manager in advance. This requirement applies only to
+those persons who are listed as "Senior-level employees" by Human Resources, whether by title such as
+SVP/MD, or otherwise.
+7.4. Trading in securities of clients and suppliers
+As a general rule, you should not invest in any securities of a client with which you have or recently had
+significant dealings or responsibility on behalf of JPMorgan Chase if such investment could be perceived
+as based on confidential information. You may be subject to broader restrictions imposed by your
+business unit.
+If you have information about or are directly involved in negotiating a contract material to a supplier of
+JPMorgan Chase you may not invest in the securities of such supplier.
+If you own the securities of a company with which we are dealing and you are asked to represent
+JPMorgan Chase in such dealings you must:
+(a)
+disclose this fact to your department head and your Compliance unit; and
+(b) obtain prior approval from your Compliance unit before selling such securities.
+7.5. Additional policies for certain groups of employees
+Any area of JPMorgan Chase may impose more restrictive policies on its employees, and you should
+consult your Compliance officer or your Code Specialist on whether any such policies apply to you.
+Employees of the following areas are subject to the Global Personal Trading Policy and Procedure as well
+as any applicable supple mental policies:
+Investment Bank
+Asset and Wealth Management
+•
+•
+Commercial Banking
+Private Equity
+Audit
+Office of the General Counsel
+23
+
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+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 31 of 35
+•
+Executive Management and the Executive Committee
+Risk Management
+Global Technology Infrastructure, IT Risk Management, and Resiliency Risk
+Management groups of Central Technology
+Corporate Resources and Media Relations Groups of Marketing & Communications
+any other business group specifically notified as being subject to the policy and/or a
+supplemental policy
+These policies establish trading limitations and include requirements for pre-clearance of personal
+securities transactions and, in some jurisdictions (including the U.S.), the use of designated brokers.
+24
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 32 of 35
+Definitions and Examples
+Assets of the Firm: Examples of assets of the firm are:
+• furnishings, equipment, supplies and services, such as telephone, the firms intranet, internet,
+and Bloomberg access
+• JPMorgan Chase inventions
+• any property created, obtained, or compiled by or on behalf of JPMorgan Chase, including
+customer lists, directories, files, reference materials and reports, computer software, data
+processing systems, computer programs and databases
+• trade secrets
+• security and other business practices or processes, policies, procedures, and know-how
+• cost, pricing, or financial information
+• employee compensation, health, or personnel records
+• business or marketing plans
+• research
+• business relationships
+• products and services
+• any other information that the firm considers to be proprietary or confidential information
+Chinese Wall: The term "Chinese Wall" usually refers to the policies that create a system of information
+barriers designed to limit the flow of inside information from areas that routinely have access to such
+information to those areas that trade in or sell securities or provide investment advice regarding securities.
+Certain business areas within JPMorgan Chase require procedures that address more specifically the
+information flows within such business areas. These are sometimes also referred to as Chinese Walls.
+Code of Conduct: The Code of Conduct, also referred to as the Code, includes all other policies referred
+to in the Code, and any supple mental policies and procedures that may be applicable to you.
+Code Specialist: Each line of business and support group has been assigned at least one "Code
+Specialist," generally a Compliance officer, to act as a resource for all employees in the area on Coderelated issues. Contact information for these officers is included in the Code Contacts List, and employees
+can contact their Code Specialist for assistance with any questions regarding the Code.
+Confidential information: Examples of confidential information:
+•
+trade secrets, security and other business practices or processes, policies, procedures, or
+know-how
+• internal and external audit reports
+• nonpublic portions of bank examination reports and other reports or information filed with
+regulators
+• software, data processing programs, databases
+• customer or supplier lists, telephone or other contact lists, and other information about
+customers
+• customer presentations
+• information about employees of customers or suppliers
+• cost, pricing, or financial information
+• employee directories, lists, telephone numbers, or other information about employees
+
+JPM-SDNYLIT-00275050
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+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 33 of 35
+• employee compensation, health, or personnel records
+• business or marketing plans and research
+• information posted on the firm's internal websites
+Examples of other confidential information about customers:
+• the same kind of information that the firm considers confidential about itself
+• information obtained from requests or applications for our products or services or as a result
+of "know your customer" due diligence, such as a personal identification number (for
+example, depending on the location, a passport, social security, or national health number),
+birth date or financial information disclosed in a loan application
+• information about transactions with the firm, such as account balances, mortgage loans, or
+other lending, capital markets, or trading transactions
+• information obtained from consumer reporting agencies (credit bureaus), such as a person's
+credit history
+• information provided in connection with an advisory assignment, such as financial
+projections
+• any assessment by the firm of a customer's creditworthiness
+• the fact that a person is a customer
+• information collected through an information collection device from a web server (such as a
+cookie or a beacon)
+Supplier or other third party information that you should assume to be confidential:
+• the same kind of information that the firm considers confidential about itself
+• information received from others such as financial reports or projections and information
+about its business plans, customers, suppliers, or creditors
+Firm: JPMorgan Chase & Co. and its direct and indirect subsidiaries.
+: Anything of value for which you are not required to pay the retail or usual and customary cost. A
+gift may include meals or refreshments, goods, services, tickets to entertainment or sporting events, or the
+use of a residence, vacation home, or other accommodations.
+Inside information: Confidential information that is material, nonpublic information about the securities,
+activities, or financial condition of a corporation, public entity, or other issuer of securities or financial
+instruments. Material, nonpublic information concerning market developments may also be construed to
+be inside information.
+JPMorgan Chase: JPMorgan Chase & Co. and its direct and indirect subsidiaries.
+Material information: Information is "material" when it could have an impact on the market price of
+that issuer (c.g., to equity, but not to debt). Examples of information that could be material include:
+• securities offerings and repurchases
+• a change in earnings and dividends (or estimates of same)
+• significant new business products, discoveries, and services, or the loss of any of these
+
+JPM-SDNYLIT-00275051
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+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 34 of 35
+• a change in an issuer's credit rating by a rating agency
+• significant shifts in operating or financial circumstances, such as cash-flow reductions, major
+write-offs, changes in accounting methods and strikes at major plants
+• voluntary calls of debt or preferred |
+issues
+• significant litigation or litigation developments
+• governmental developments that could affect securities markets
+• changes in control or management
+• developments regarding customers or suppliers (e.g. loss or acquisition of a contract)
+Need-to-know: Persons with a "need-to-know" information require access to that information in order to
+perform the services we are engaged to provide to the party who provided the information to us --- for
+example, lawyers, accountants and other experts, Compliance officers, credit personnel, and senior
+management personnel. Who "needs to know" any particular information will depend on the specific
+facts and circumstances; if in doubt, consult the Legal and Compliance Department. Justification of
+communicating confidential information does not exist simply because the information is helpful to
+another department in activities that are unrelated to the service or transaction for which the information
+was obtained. In some circumstances, legal counsel may determine that limited disclosure is required by
+law (in response to a subpoena, for example) or is otherwise appropriate. These decisions should be made
+only by the Legal and Compliance Department.
+Nonpublic/Public information: Information should be considered nonpublic unless it is clearly public.
+Information is deemed public once it has been publicly announced or otherwise disseminated in a manner
+that makes the information available to investors generally. For example, limited disclosure over a
+private wire service for institutional investors is not considered full disclosure to the public. Information
+disclosed in a press release distributed through a widely circulated news or wire service would generally
+be considered public.
+Personal fiduciary: A person who has undertaken to act primarily for another's benefit, such as a trustee,
+executor, attorney-in-fact, or guardian, outside the scope of your normal job responsibilities at JPMorgan
+Routine banking services: In general, branch banking services (checking or savings accounts, etc.)
+would be considered routine banking services. Whether any other service is "routine" will be a casespecific determination, based on factors such as the size of the transaction, the extent of the relationship
+with the customer, and whether the service(s) provided are subject to variable pricing for different
+customers. If in doubt about whether a customer relationship with a not-for-profit organization triggers
+the pre-clearance requirements of Section 6.3.2(2)(a), discuss the situation with your Code Specialist.
+Senior-Level Employee: A Senior-Level Employee is any employee whose (a) annual base salary rate is
+US$150,000 (or the local currency equivalent) or higher, OR (b) annual total cash compensation is
+US$250,000 (or the local currency equivalent) or higher. "Annual total cash compensation" means the
+employee's annual base salary rate plus job/shift differentials as of the last preceding August 1, plus cash
+earnings under any incentive plans or programs (e.g., annual bonus, commissions, draws, overrides, and
+special recognition payments or incentives) that are paid to or deferred by the employee during the 12-
+month period ending the last preceding July 31. It does not include overtime pay. (For US employees,
+annual total cash compensation is the same as benefits pay for medical purposes, as shown in the
+employee's last annual benefits enrollment materials.)
+
+JPM-SDNYLIT-00275052
+
+
+Case 1:22-cv-10904-JSR Document 326-51 Filed 09/08/23 Page 35 of 35
+Trade association, professional association, or other such organization: A not-for-profit organization
+the main purpose of which is to make available to its members opportunities for education, exchange of
+ideas and information, networking, ctc., such as a bar association or industry professionals' group. The
+term does not apply to entities that engage in business activities, exchanges, trading platforms, or clearing
+systems, for example.

vision-fixhub/court-05/8d5f2c034b2588e6595f32f622db101f795cc17d8e99adbad161aa293ec9521a.receipt.json

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vision-fixhub/court-05/8d63b5f48992953e7308e6da6ffd3192fc860cb7587179216387f01e2ab51cb2.md

@@ -0,0 +1,44 @@
+Case 1:22-cV-10904-JSR Document 263-65 Filed 08/07/23 Page 1 of 3
+
+
+
+Case 1:22-cV-10904-JSR Document 263-65 Filed 08/07/23 Page 2 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+In the Matter of
+JANE DOE,
+Case No. 1:22-cv-10018 (JSR)
+Plaintiff,
+V.
+DEUTSCHE BANK,
+Defendant.
+1, L
+DECLARATION OF
+P. VISOSKI JR.
+P. Visoski, Jr., declare as follows:
+1. Iam
+P. Visoski, Jr., a non-party in the above-captioned matter.
+2. I was employed as a pilot for Jeffrey Epstein ("Epstein") from July 1991 through
+August 2019.
+3. I recall that, in approximately 2002 or 2003, when I first started flying that Epstein's
+Boeing 727, we used cash to pay for jet fuel.
+4. Specifically, it is my recollection that, during this time period, the fuel refinery at the
+John F. Kennedy International Airport ("JFK") offered a significant discount if cash
+was used to purchase fuel because they were not set up to accept credit card payment.
+Accordingly, we used cash to purchase fuel on approximately six to ten occasions
+during the 2002-2003-time frame. Once the fuel price increased and there was less of
+a discount compared to what other fuel suppliers which accepted credit cards offered,
+we ceased using cash to purchase jet fuel.
+On these occasions, I recall picking up the cash from Epstein's office prior to the
+flight and the manager from the fuel company would collect the money on board the
+plane. It is my recollection that all these transactions were documented.
+NYACTIVE-22730321.1
+
+
+Case 1:22-cV-10904-JSR Document 263-65 Filed 08/07/23 Page 3 of 3
+I do not recall paying for any jet fuel with cash after approximately 2003.
+I declare under penalty of perjury under the laws of the United States that the foregoing is true
+and correct to the best of my knowledge.
+Executed this 26th day of May, 2023.
+2
+NYACTIVE-22730321.1

vision-fixhub/court-05/8d63b5f48992953e7308e6da6ffd3192fc860cb7587179216387f01e2ab51cb2.receipt.json

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+}

vision-fixhub/court-05/8d6a00babdd32471ac83a71192f663a0629e9d63564437515715b2779dd42e49.md

@@ -0,0 +1,4 @@
+Case 1:22-cv-10904-JSR Document 311-62 Filed 08/25/23
+
+
+Filed Under Seal

vision-fixhub/court-05/8d6a00babdd32471ac83a71192f663a0629e9d63564437515715b2779dd42e49.receipt.json

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+}

vision-fixhub/court-05/8d93ce995d9567279dcb8075ec0c8422e00fea2a0e3f873e0fc0a65780726b75.md

@@ -0,0 +1,3 @@
+Case 1:22-cv-10904-JSR Document 158-107 Filed 05/23/23 Page 1 of 1
+
+FILED UNDER SEAL

vision-fixhub/court-05/8d93ce995d9567279dcb8075ec0c8422e00fea2a0e3f873e0fc0a65780726b75.receipt.json

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+  "engine": "marble-apple-vision",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/8d9cfdcb8127df642bdf3adcf81c1d5a7659587a29e55eb7f4019e4cdaf90637.md

@@ -0,0 +1,587 @@
+Case 1:22-cv-10904-JSR Document 301-2 Filed 08/25/23 Page 1 of 11
+
+
+
+Case 1:220y1109011t9r 1Dacumers3lant Filed 09|35l2e tRage Zoefder
+1
+UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF NEW YORK
+2
+3
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS
+4
+Plaintiff,
+5
+vS.
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1:22-cv-10904-JSR
+JPMORGAN CHASE BANK, N.A.,
+Defendant/Third-
+Party Plaintiff.
+JPMORGAN CHASE BANK, N.A.
+Third-Party
+Plaintiff,
+VS.
+JAMES EDWARD STALEY,
+Third-Party
+Defendant.
+THURSDAY, JULY 6, 2023
+CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
+- —
+Videotaped deposition of Special
+Agent
+Fonseca, FBI (Retired), held at
+the offices of WilmerHale, 250 Greenwich
+Street, New York, New York, commencing at
+9:07 a.m. Eastern, on the above date, before
+Carrie A.
+, Registered Diplomate
+Reporter and Certified Realtime Reporter.
+-
+GOLKOW LITIGATION SERVICES
+877.370.3377 ph | 917.591.5672 fax
+deps@golkow.com
+Page 1
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220Y1109011t9r 1Documers3lant Filed 09|35|2e tRage 3oefder
+relates to fraud and anything else
+that's
+: from the Act, I honestly -- I
+can't tell you.
+QUESTIONS BY MR. PENDELL:
+Well, and my question was a
+little bit broader than that, and I apologize
+if I asked a bad question. That may happen
+from time to time.
+I'm notorious for asking
+bad questions.
+But I'm interested generally
+in -- do you think that people and businesses
+have an obligation to comply with the law,
+whatever that law is?
+A.
+I would agree, yes.
+Do you have any opinion as to
+whether JPMorgan |
+A.
+I do not.
+No opinion one way or the
+other?
+A.
+I don't.
+Okay. Mr. Fonseca, what
+subject areas do you consider yourself to be
+an expert in?
+Page 17
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220Y109011t9r 1Dacumers3lant Filed 09|35l23 tRage 4efder
+A.
+Anything relevant to crimes
+against children.
+Okay. You are not a certified
+public accountant; is that correct?
+A.
+That is correct.
+e.
+Okay. During your tenure as an
+FBI special agent, I understand that based on
+your CV, and we're going to talk about it a
+little bit more later, you had some
+supervisory authority for other special
+agents; is that true?
+A.
+That is correct.
+Okay. And during your time
+with that supervisory authority over other
+FBI special agents, did you expect that those
+agents that you supervised were going to
+gather as much evidence as possible for an
+investigation that you were pursuing?
+MR. BOUCHOUX: Objection to the
+form.
+THE WITNESS: I expected them
+to do their job. Collecting evidence
+was part of them doing their job, yes.
+QUESTIONS BY MR. PENDELL:
+Do you ever recall a time when
+Page 18
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220Y109241tSPa 1Dacupens3Part Filgd 08|3&23 tRage 5o9fder
+under the age of 18, and the responsibility
+for investigating that would fall outside of
+crimes against children?
+A.
+That is correct. That would --
+if you're referring back to the human
+trafficking scenario I just provided, if they
+were here and not documented and they were
+underage, the human trafficking squad -- the
+public corruption squad and their agent that
+worked human trafficking there for
+undocumented -- and I'1l say women because
+that is pretty much what we saw, was women --
+they would work that case, correct.
+l.
+And what about -- so if you had
+sex trafficking of people under the age of 18
+that were US citizens, would that fall under
+crimes against children?
+A.
+Correct. Adult or child, yes.
+Q.
+Okay. When you say adult or
+children, if somebody -- if there was a sex
+trafficking operation and everyone involved
+was over the age of 18, would crimes against
+children, would that -- what do you call it,
+a bureau or squad?
+A.
+The squad.
+Page 28
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220Y1 09011t9r 1Dacumers3lant Filed 09135|23 tRage Gder
+Is it fair to say that your
+responsibility was
+in carrying out the
+policies?
+MR. BOUCHOUX: objection to
+form.
+THE WITNESS: I would say my
+obligations were to follow protocols
+and to follow my experience in cases.
+QUESTIONS BY MR. PENDELL:
+e.
+While employed by the FBI, were
+you responsible for providing official
+opinions interpreting FBI investigative
+policy?
+A.
+No, I was not.
+e.
+While employed by the FBI, were
+you responsible for setting any other FBI
+policies?
+A.
+No.
+We talked a little bit about
+your experience with the FBI in the crimes
+against children squad.
+I want to focus a little bit
+more on your work within that department
+specifically investigating sex trafficking.
+How many investigations were
+Page 96
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220Y10924 SPa Documen 53Pant Filgd 08|3523 tRage Toider
+you
+involved in at the FBI that specifically
+involved
+sex trafficking?
+A.
+That's a difficult question to
+answer, specifically because I was involved
+as an investigator and as a coordinator for a
+task force that saw a dozen cases a week. So
+it was -- it could be more than that. so
+it's difficult to answer that question. A
+lot.
+Well, let me ask you this. You
+had talked earlier about an example of a case
+you worked on with -- I don't want to call
+him a gentleman, because I would argue that
+he's not, but a man who lured an underage
+person over the Internet across state lines
+for the purposes of sex.
+Although reprehensible and a
+criminal act, would you agree that that
+particular instance is not sex trafficking?
+MR. BOUCHOUX: Objection to the
+form.
+THE WITNESS: I can't tell you
+what he was -- I can't tell you what
+he was charged with, if we're talking
+about that case with
+and --
+Page 97
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220Y109011t9r 1Dacumers3lant Filed 09|35|23 tRage &efder
+QUESTIONS BY MR. PENDELL:
+Do you think that the case
+against Mr. Epstein was a routine sex
+trafficking case in your opinion?
+MR. BOUCHOUX: Objection to the
+form.
+THE WITNESS: Can you define
+"routine"?
+QUESTIONS BY MR. PENDELL:
+e.
+Well, I'm sort of
+interested in -- let me -- well, let me ask
+it this way.
+You've come here and you've
+testified based on your experience --
+A.
+Uh-huh.
+-- that you've worked on
+several, numerous, many, sex trafficking
+cases, and you've never worked on one that
+involved an individual with Mr. Epstein's
+wealth.
+So would you agree with me that
+the sex trafficking case against Mr. Epstein
+was not routine?
+A.
+e.
+No.
+You would not agree with me?
+Page 105
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:220y109011t9r 1Documers3lant Filed 09|35|2e tRage Gader
+A.
+I would not agree.
+Why not?
+A.
+The supposition that wealth
+matters when you are working a case that has
+to do with paying juveniles small amounts of
+money, which we saw in every case, to
+sexually abuse them is not unusual. Your
+wealth has nothing to do with those points of
+the sexual abuse.
+Well, fair enough.
+But we're not just talking
+about wealth here, right?
+Let me ask you this question.
+How many sex trafficking cases have you been
+involved in where there were over a hundred
+victims?
+MR. BOUCHOUX: Objection to the
+form.
+THE WITNESS: I don't think
+any.
+QUESTIONS BY MR. PENDELL:
+So would you agree with me that
+a sex trafficking case with over a hundred
+victims is not a routine case?
+A.
+From the amount of victim point
+Page 106
+
+
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:2Z 6Yr#992enłSRa Document 39ant Filed Q8125t23c Page 1Bplallr
+of view,
+I would say based on my experience,
+that is
+unusual to see that amount of
+victims.
+The way of investigating the case
+would not be unusual.
+Q.
+A hundred victims is a lot,
+isn't it?
+A.
+A hundred victims is a lot
+compared to just one victim, yes.
+e.
+A hundred is --
+And one victim is bad enough.
+A.
+Absolutely.
+e.
+A.
+-- unfathomable, right?
+Absolutely.
+You said something about
+wealth had nothing to do with making it
+routine or not routine.
+I'm paraphrasing
+here because you said something about small
+amounts of money that were paid.
+Have you looked at how much
+money was involved specifically in this case?
+MR. BOUCHOUX: Objection to the
+form.
+THE WITNESS: From the payments
+that were made to the victims, I have
+reviewed statements from the victims
+Page 107
+
+
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:27 6Yr#992en/SRa Document 39ant Filed Q8125123c Page 1 befalr
+1
+2
+3
+to the term "banking information."
+Vague. Ambiguous.
+THE WITNESS: I know what --
+part of our team would be our
+intelligence analysts, but I never
+used banking information, so I
+don't -- I don't know who I'd assign
+that responsibility to except an
+intelligence analyst, I guess.
+QUESTIONS BY MR. PENDELL:
+And let me ask you another
+question in light of counsel's objection,
+which was fair.
+During your tenure with the FBI
+investigating sex trafficking of children,
+were you ever responsible for reviewing the
+financial information of a suspect?
+A.
+And to be clear, too, sex
+trafficking is not just with children. We
+investigated adults as well.
+But the financial interest?
+Your question about that was?
+e.
+Yes. Did you ever review the
+financial information of a suspect?
+MR. BOUCHOUX: Objection to the
+Page 111

vision-fixhub/court-05/8d9cfdcb8127df642bdf3adcf81c1d5a7659587a29e55eb7f4019e4cdaf90637.receipt.json

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