MEMY-1805 harvest: vision-fixhub (part 27)

vision-fixhub/court-05/4eec8f8d7c23bb48f79b23e64acdb2a1e8ce08ac56c2ffbe83aa3f2cf78be9d8.md

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+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 1 of 19
+ECONOMIC DEVELOPMENT COMMISSION
+INDUSTRIAL PARK DEVELOPMENT CORPORATION
+April 17, 2008
+Cecile DeJongh
+Manager
+Financial Trust Company, Inc.
+6100 Red Hook Quarter B-3
+St.
+VI 00802
+Dear Mrs. DeJongh:
+A-compliance review has been completed on Financial Trust Company, Inc.
+Enclosed for your review and commentary is a copy of the compliance report
+whuch covers the period of April 1, 1999 to December 31, 2006.
+Please respond to this compliance report within ten (10) working days from receipt
+of this letter. If you have any questions concerning this matter, do not hesitate to
+contact me at 774-8104, Ext. 236.
+Sincerely,
+Director of Compliance
+Co:
+E. Clouden, Chief Executive Officer
+Jr., Assistant Chief Executive Officer
+Francois Dominique, Director Application & Intake
+Sandra Bess, Compliance Officer
+A DIVISION OF THE ECONOMIC DEVELOPMENT AUTHORITY
+P.O. Box 305038 • ST.
+P. IN 3503 - 57, GRO, US. VIC ADS 008 (90 73-30 (40 73-8006
+TOLL FREE 1-877-432-8784 • www.usvieda.org
+VI-JPM-000022897
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 2 of 19
+• UNITED STATES VIRGIN ISLANDS
+COMPLIANCE REPORT
+Financial Trust Company, Inc.
+As of December 31, 2006
+SUMMARY HIGHLIGHT:
+• Financial Trust Company, Inc. has enjoyed seven (7) years of tax benefits.
+• Financial Trust Company, Inc. met and exceeded the capital investment of
+US $300,000.
+• Capital Expenditures from 1999 to 2006 were $570,067 of which 96%
+($546,447) was procured locally.
+• Goods and Services from 1999 to 2006 were $4,252,064 of which 77% was
+procured locally.
+• Financial Trust Company, Inc. met its employment requirement of 11 fulltime employees.
+• Financial Trust Company, Inc. met its residency requirement.
+• Financial Trust Company, Inc. met the 20% management, technical and
+supervisory requirement.
+• Financial Trust Company, Inc. met the requirements of Special Conditions
+#1, #2, #3 and #5.
+• Financial Trust Company, Inc. did not specifically meet the requirements of
+Special Condition #4.
+• Financial Trust Company, Inc. complied with the requirements of the
+procurement process.
+• Financial Trust Company, Inc. met the reporting requirements.
+VI-JPM-000022898
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 3 of 19
+Hamed,
+Inwestors Dream
+Title 29, Chapter 12 VIC, Section 715(a) states in part "upon proper application or
+reapplication, public hearing and in compliance with all other relevant provisions
+of this chapter pertaining to the grant of initial benefits, as determined and required
+by the Commission, ny recipient, neutral development benefits (sic), may bo
+HISTORY:
+Financial Trust Company, Inc. was granted tax exemption benefits to conduct the
+business of financial and economic consulting, money management, investment
+advisory and fiduciary services for its clients. Such clients will include individuals,
+trusts, foundations and business entities. Benefits were granted for a period of ten
+(10) years commencing and terminating as follows:
+Commencement
+Income Taxes
+Gross Receipt Taxes
+Excise Taxes (Raw Materials)
+Excise Taxes (Equip., Mach.)
+Dividend Withholdings
+Interest Withholdings
+Real Property Tax
+April 1, 1999
+April 1, 1999
+January 1, 2000
+January 1, 2000
+April 1, 1999
+April 1, 1999
+January 1, 2000
+Termination
+March 31, 2009
+March 31, 2009
+December 31, 2009
+December 31, 2009
+March 31, 2009
+March 31, 2009
+December 31, 2009
+On November 6, 1998, the corporation filed Articles of Incorporation with the
+Office of the Lieutenant Governor. A Certificate of Incorporation, authorizing
+them to conduct business in the Virgin Islands was issued on November 30, 1998.
+Upon completing an application to the Economic Development Commission
+(EDC) on February 22, 1999, the Beneficiary tax benefits were approved by the
+Governor of the Virgin Islands on November 26, 1999. The certificate of benefits
+was executed by the Chairman of the EDC Board of Commissioners on March 21,
+2000. Financial Trust Company, Inc. has enjoyed seven (7) years of benefits.
+Financial Trust Company, Inc. is solely owned by Mr. Jeffrey Epstein.
+Page 2
+VI-JPM-000022899
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 4 of 19
+INVESTMENT:
+Commencing no later than one (1) year from April 1, 1999, the Beneficiary shall
+be required to invest no less than U.S. $300,000 excluding inventory, in
+accordance with the EDC Rules and Regulations.
+FINDINGS:
+As of December 31, 1999, Financial Trust Company, Inc. met the investment
+requirement of $300,000. During the period covered by this report the Beneficiary
+made additional investments totaling $270,067. Financial Trust Company, Inc.
+invested a total of $570,067 as of December 31, 2006.
+CAPITAL EXPENDITURE:
+Eligible
+Supplier
+150,539
+572
+YEAR
+1999
+2000
+2001
+2002
+2003
+2004
+2005
+2006
+Grand Total
+1,399
+152,510|
+VI Supplier
+326,226
+23,030
+1,599
+21,860
+12,906
+-
+1,781
+6,535
+393,937
+Non-Vi
+Supplier
+14,220
+880
+505
+6,215
+744
+1,056
+23,620 |
+Total
+326,226
+187,789
+2.479
+22,937
+12,906
+6,215
+2,525
+8,990
+570,067|
+FINDINGS:
+From 1999 to 2006 a total of $570,067 was procured in capital expenditures. Of
+the expenditures categorized; 69% ($393,937) were purchases from Virgin Islands
+Suppliers, 27% ($152,510) were procured from Eligible Virgin Islands Suppliers
+for Leasehold Improvements and Office Equipment and the remaining 4%
+($23,620) from Non-Virgin Islands' suppliers for Office Equipment and Furniture
+and Fixtures.
+Page 3
+VI-JPM-000022900
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 5 of 19
+CAPITAL EXPENDITURES
+1999 - 2006
+4%
+27%
+D Eligible Vi
+Supplier
+• V Supplier
+• Non-Vi
+Supplier
+69%
+GOODS AND SERVICES:
+YEAR
+1999
+2000
+2001
+2002
+2003
+2004
+2005
+2006
+Grand Total
+Eligible VI
+Supplier
+281,142
+47,558
+47,635
+44,621
+78,551
+36,443
+45,799
+581,749|
+Vl Supplier
+30,338
+154,391
+170,589
+453,622
+415,191
+445,240
+435,554
+596.029
+2,700,954
+Non-Vi
+Supplier
+3,615
+52,735
+109,194
+238,419
+299,441
+166,863
+59590
+39,404
+969,361
+Total
+33,953
+488,268
+327,441
+739,676
+759,253
+690,654
+531,587
+681,232
+4,252,064
+FINDINGS:
+The total expended for goods and services from 1999 through 2006 was
+64,252,064. Purchases from Virgin Islands suppliers totaled $2,700,954 (64%):
+5969,361 (23%) was spent with Non-Virgin Islands' suppliers; and the remaining
+$581,749 (14%) was procured from Eligible suppliers.
+Page 4
+VI-JPM-000022901
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 6 of 19
+GOODS & SERVICES
+1999 - 2005
+26%
+15%
+59%
+• Eligible VI
+Supplier
+• Vi Supplier
+Non-Vi
+Supplier
+LOCAL PROCUREMENT:
+In accordance with Division 10 of the Economic Development Commission Rules
+and Regulations, the beneficiary must comply with procurement procedures
+(Section 708-701 to 708-718).
+FINDINGS:
+From 1999-2006, the beneficiary's total expenditures were $4,822,131. 64%
+($3,094,891) of the purchases were made from Virgin Island Suppliers of which
+the majority was spent on leasehold improvements, legal/accounting, and
+charitable contributions. 21% ($992,981) were made from Non-Virgin Islands
+Suppliers and the remaining 15% ($734,259) was purchased from Eligible Virgin
+Islands Suppliers.
+The non local expenditures totaling $992,981 comprised mainly of equipment,
+furniture/fixtures,
+market services and legal/accounting. A total of $767,057
+was procured for legal/accounting and
+market services which are exempt
+procurement in accordance with Section 708-704 (e) of the EDC Rules and
+Regulation; $162,900 included purchases of insurance, travel, dues and
+subscriptions, supplies and repairs and maintenance. The Beneficiary indicated that
+these were aggregate purchases from 2000 to 2006 which included computer
+supplies and CCH Tax guides. The remaining capital expenditure were non-local
+Page 5
+VI-JPM-000022902
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 7 of 19
+purchases for office equipment and furniture and fixture totaling $22,564. Several
+purchases were exempt in accordance with the EDC Rules and Regulations
+(promulgated 1981), section 708-704 (b) and Section 708-705 (a).
+In January 2000, after approval of benefits and prior to receipt of certificate, the
+Beneficiary purchased furniture totaling $3,372 from Crate and Barrel, a non-
+Virgin Islands supplier and in March 2000 a specialized computer in the amount of
+$4,947 was purchased from Micro Computer. In accordance with the EDC Rules
+and Regulations Section 708-707 (Rules promulgated 1981), the Beneficiary was
+required to provide proof that solicited quotes were on a competitive basis. The
+Beneficiary stated that these items were specific brands not available in the Virgin
+Islands.
+Total Procurement
+1999 - 2005
+100%
+80%
+60%
+40%
+20%
+0%
+• Non-local
+• VI
+• Eligible VI
+Suppliers
+Cap Exp
+22,564
+387,402
+151,111
+Goods & Svcs
+929,957
+2,104,925
+535,950
+Page 6
+VI-JPM-000022903
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 8 of 19
+EMPLOYMENT:
+The Beneficiary shall employ no later than one year from September 7, 1999 no
+less than eleven (11) persons on a full-time basis who are residents of the Virgin
+Islands as defined in Title 29, V.I. Code Section 703(e).
+Also, in accordance with Section 710(a) Title 29, Chapter 12, VIC (Amended
+1992), after the third year of operation, a beneficiary shall be required to have at
+least 20% of its management, supervisory, and/or technical positions filled by
+residents of the United States Virgin Islands unless granted a waiver by the
+Commission.
+§708-605 Full-Time Employment ..........
+For the purposes of this division,
+"full-time" employees or employment shall mean employment, on a permanent and
+continuous basis, for thirty-two hours or more per week.
+FINDINGS:
+YEAR
+1999
+2000
+2001
+2002
+2003
+2004
+2005
+2006
+TOTAL
+1
+10
+11
+11
+11
+AVERAGE
+FULL
+TIME
+1
+10
+11
+11
+11
+11
+==
+AVERAGE
+V.L. RES.
+0
+10
+11
+11
+11
+12
+11
+11
+AVERAGE
+AVERAGE
+% V.L. Res.
+0%
+MGMT.
+1/1
+100%
+100%
+6/6
+6/6
+100%
+6/6
+100%
+6/6
+100%
+717
+100%
+777
+100%
+6/6
+20%
+V.I.
+MGMT
+0%
+100%
+100%
+100%
+100%
+100%
+100%
+100%
+From September 6, 2000 to December 31, 2006 the average full-time employment
+ranged from ten (10) to twelve (12) employees. The Beneficiary met the
+requirement of eleven (11) full-time employees, and also met the 80% residency
+requirement and the 20% management requirement for the period covered in this
+report.
+Page 7
+VI-JPM-000022904
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 9 of 19
+In the second quarter of 2004, Tequasi Hendricks a senior at the Eudora Kean High
+School was hired as a part-time clerical employee. The Beneficiary stated Ms.
+Hendricks walked into the office off the street, inquired about a job, filled an
+application and was hired. They stated that Ms. Hendricks exhibited exceptional
+work habits and was therefore hired as a full time Researcher/Bookkeeper after
+graduating from high school in 2005.
+SPECIAL CONDITIONS:
+The following conditions shall apply:
+1. The Beneficiary shall provide all employees with health care insurance,
+funded by the Beneficiary
+• From 2000 to 2001, the Beneficiary provided Health, Vision, Life
+and Dental insurance to all full-time employees. Health and dental
+coverage was also provided to employees' eligible dependents
+through Canada Life Assurance.
+• From 2002 to 2006, the Beneficiary provided Health, Dental and
+The Benefician paid Ur of the in and ranic or any.
+eligible employee except Tequasi Hendricks whom the Beneficiary
+stated preferred to be covered by her mother's insurance. The
+Beneficiary also paid 100% dental and health insurance coverage
+• Canada Life Assurance and United HealthCare Insurance
+Company are both registered with the Lieutenant Governor's
+Office of Banking and Insurance.
+Page 8
+VI-JPM-000022905
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 10 of 19
+2. The applicant shall provide all employees a qualified retirement plan funded
+by the Beneficiary.
+• In 2001, the Beneficiary provided all full-time employees a
+SEP/SRA Plan with Merrill
+as Custodian. From 2002 to
+2006 the Beneficiary established an American Funds Savings
+Incentive Match Plan for Employees ("SIMPLE") incorporated
+with an Individual Retirement Agreement (IRA). The Simple IRA
+is offered to all employees receiving at least $5,000 in
+compensation. The Beneficiary makes a matching contributior
+qual to 100% of elective deferrals up to a limit of 3% per calendal
+year. It is noted that from 2000 to 2005 eight employees, and in
+2006 nine employees, participated in the Simple IRA Plan
+facilitated by the Beneficiary.
+3. The applicant shall provide employee training and tuition reimbursement
+program for eligible employees.
+The Beneficiary provided documentation to show the training
+provided to employees.
+• In 2000 the Beneficiary provided in-house training on Power-point
+to all staff and specialized training in Communication, Typing,
+CPA Review and Finance to the accounting employees.
+• Training in Conversation Power Video was provided in 2001 to all
+staff. Computer classes were provided to the messenger/custodian,
+Front Desk Seminar to the receptionist and CPA reviews and
+books purchased for the accounting and research staff.
+• The entire staff was provided Quick-books training in 2002 and the
+accounting staff with CPE and CPA courses.
+• In 2003 the entire staff attended three (3) different Skill-path
+Seminars and one (1) course in CPE continuing education.
+• In 2004, the Skill-path Seminars were provided to the receptionist,
+accounting and research staff. Tax Seminars and CPA review
+courses were provided.
+Page 9
+VI-JPM-000022906
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 11 of 19
+• CPE Tax Seminars and classes with UVI Cell were offered in 2005
+to the accounting staff.
+• In 2006, the Network Administrator was provided training with
+Skill-path. The Controller attended two (2) courses in CPA
+continuing education. The Bookkeeper registered for a one-day
+course at the University of the Virgin Islands - Intro to Insurance
+and Captive Management. And the Receptionist and Custodian /
+Messenger attended a Conference on the Status of Women.
+Additionally, the Beneficiary provided tuition reimbursement to!
+]in 2002, Tequasi Hendricks in 2003 and Jermaine Ruan in 2005
+for classes taken at UVI.
+4. The applicant shall make annual contributions of $50,000 or one percent
+(1%) of gross receipts tax exemption value, whichever is greater, to be
+distributed annually as follows:
+(a) 50% to educational scholarships
+(b) 25% for charity
+(c) 25% for co-op marketing with EDC
+However, after issuance of its certificate, applicant shall prepay the first five
+(5) years of contribution fixed at $50,000, or the sum of $250,000, to be
+distributed as follows:
+(a) $187,500 to a tax-exempt entity from which annual distributions of
+not less than $25,000 to educational scholarship and $12,500 to
+charity shall be made, and
+(b) $62,500 for co-op marketing with IDC
+Page 10
+VI-JPM-000022907
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 12 of 19
+CERTIFICATE REQUIREMENT:
+Gross
+Year
+Gross
+Receipt
+Receipt
+Exemption
+1% Gross
+Receipt
+Exemption
+Value
+After Certificate issued - five (5) years prepayment
+Contribution
+per EDC
+Certificate
+250,000
+50% to
+Educational
+Scholarships
+125,000
+Tax Exempt Entity
+25%
+Charity
+25% Co-op
+Marketing
+with EDC
+62,500
+B2,500
+-
+2000
+2001
+2002
+2003
+2004
+2005
+2006
+50,000
+50,000
+Total Contribution per EDC Certificate
+350,000
+25,000
+25,000
+175,000
+12,500
+12.500
+87,500
+12,500
+12,500
+87,500
+The Beneficiary provided documentation for the period January 2000 to December
+2006 showing total contributions of $1,762,465; $313,875 from Financial Trust
+Co., Inc. and $1,448,590 from the J. Epstein Foundation; made to charities,
+educational scholarships, educational symposiums (other) and Co-op Marketing to
+the EDC.
+Total
+Contributions
+J. Epstein
+Foundation
+Educational
+Scholarships
+Co-op
+Charity
+Marketing
+with EDC
+Other &
+Educational
+Symposiums
+Ineligible
+Contributions
+Financial Trust
+Co., Inc.
+Certificate
+Requirement
+Variance
+J. Epstein
+Foundation
+Over / Short
+Contributions
+313,875
+350,000
+(36,125)
+1,448,590
+1,412,465
+187,500
+187,500
+21,625
+50,000
+(28,375)
+649,431
+621,056
+11,053
+75,000
+25,000
+87,000
+(13,947)
+(12,500)
+434,497
+420,550
+(12,500).
+4,397
+14,300
+4,397
+357,662
+362,059
+14,300
+7,000
+21,300
+Page 11
+VI-JPM-000022908
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 13 of 19
+In 2005 and 2006, Financial Trust Co. Inc. did not directly contribute total
+requirement in charitable contributions in the area of educational scholarship and
+charity. However, it is noted that additional contributions were made from the J.
+Epstein Foundation. A total of $1,448,590 was reported, of which $1,261,000 was
+over the requirement of $187,500 prepaid by Financial Trust Co., Inc. Mr. J.
+Epstein, sole owner of Financial Trust Company Inc. personally funds the J.
+Epstein Foundation.
+In addition, the Beneficiary was initially notified that a contribution of $12,500
+was not due for the 2006 Co-op Marketing with EDC. However during this audit,
+reconciliation of the Beneficiary's contribution account identified an error in
+recording a duplicate payment. Adjustments were made and the Beneficiary was
+notified of payment due and restitution to be made accordingly.
+Following are actual contributions made by Financial Trust Co., Inc and the J.
+Epstein Foundation:
+ACTUAL CONTRIBUTIONS: FINANCIAL TRUST Co., INC.
+Year
+Total
+Contributions
+1. Epstein
+Educationa
+oundation
+Scholarship
+Charity
+Other -
+1. Epstel
+Co-op
+Marketing
+with EDC
+Ineligible
+2000
+2001
+2002
+2003
+2004
+2005
+2006
+Totals
+189,401
+80,920
+600
+1,313
+13,528
+18,081
+10,032
+313, 875
+187,5001
+1,150
+600
+551
+50
+17,620
+600
+:
+-
+62,500
+187,500
+1,110
+2,295
+21,625
+808
+7,000
+625
+870
+11,053
+5
+3,578
+46
+167
+4,397
+12,500
+75,000
+200
+150
+600
+500
+2,950
+3,800
+6,700
+14,300
+' S187,500 prepaid to the J. Epstein Foundation for 5 years (2000 - 2005)
+Page 12
+VI-JPM-000022909
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 14 of 19
+Inwestors Dream
+In 2000, the Beneficiary set up and made an initial payment of
+$187,500 to a tax exempt entity; the J. Epstein Virgin Islands
+Foundation, Inc. as requested in the EDC benefits certificate. The
+Beneficiary also made an additional charitable contribution of $1,901.
+In 2001, the Beneficiary made a total contribution of $80,920.
+Educational Scholarship totaling $17,620 to the Ruby Rutnik
+Scholarship Fund and Antilles School Inc. Contributions in the
+amount of $600 was made to several charities and a contribution of
+$50 was reported as other for personal contributions by Mr. J. Epstein.
+And a payment of $62,500 was made to the EDC for Co-op
+marketing.
+In 2002, a total of $600 was contributed by the Beneficiary toward
+educational scholarships.
+In 2003, the Beneficiary contributed $808 primarily to educational
+scholarships.
+In 2004, the Beneficiary contributed a total of $13,528; $7,000 was
+given to charities and $3,578 reported as other for personal
+contributions made by J. Epstein.
+In 2005, the Beneficiary contributed a total of $18,081; $1,110 made
+to educational scholarships, a shortage of $23,890, $625 to charities, a
+shortage of $11,875, and a payment of $12,500 to the EDC for Co-op
+marketing.
+In 2006, the Beneficiary contributed a total of $10,032; $2,295 given
+for educational scholarships, a shortage of $22,705, 5870 to charities,
+a shortage of $24,130 and $167 reported as other for personal
+contributions by J. Epstein.
+Page 13
+VI-JPM-000022910
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 15 of 19
+ACTUAL CONTRIBUTIONS: J. EPSTEIN FOUNDATION
+Year
+Total
+Educational
+Contribution Scholarships
+Charity
+Educational
+Ineligible
+Symposium
+Contribution
+2000
+2001
+2002
+2003
+2004
+2005
+2006
+Totals
+38,000
+11,100°
+281.477
+179,886
+263,976
+250,314
+423,837
+1,448,590
+25,000
+500
+120,281
+135,250
+162,610
+90,200
+115,590
+649,431
+13,000
+10,600
+90,100
+43,136
+95,866
+138,019
+43.776
+434,497
+71,096
+5,000
+20,595
+260,971
+357,662
+1,500
+500
+1,500
+3,500
+7,000
+The J. Epstein Foundation is a tax exempt entity established by Financial Trust,
+Company Inc., the Beneficiary, primarily for making charitable contributions to the
+Virgin Islands community.
+In 2000, the J. Epstein Foundation received $187,500 from Financial
+Trust Company, Inc. as required by the Beneficiary's certificate. The
+J. Epstein Foundation made a contribution of $38,000; $25,000 to the
+Community Foundation of the VI for educational scholarships and
+$13,000 to charities such as the American Cancer Society, the St.
+Croix Shriner's Club, Caribbean Light Lodge Scholarship Fund,
+Beacon Schools and the United Way of St.
+/ St. John and St.
+Croix. The charitable contribution was $500 over the certificate's
+commitment.
+In 2001, the J. Epstein Foundation contributed $500 to educational
+scholarships and $10,600 to charities. These charities included:
+Antilles School, Inc., Charlotte Amalie High School PED, Women's
+Business Center, the St.
+Baseball Explorers and the St.
+| Youth Soccer Association. These contributions were $26,400
+" Per benefits certificate: commitment was not made.
+Page 14
+VI-JPM-000022911
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 16 of 19
+short of the certificate's commitment: $24,500 - educational
+scholarships and $1,900 - charities.
+In 2002, All Saints School, UVI/Tom Joyner Foundation, Inc. and
+Antillies School received $120,281 toward educational scholarships.
+A total of $90,100 was given as charitable contributions to: Antilles
+School, Arts Alive, Beacon School, the Safety Zone, Elrod Hendricks
+Little League
+West and Zero Tolerance Inter-Neighborhood
+Basketball. Additionally, a total of $71,096 was contributed to an
+Educational Symposium on Artificial Intelligence. A member of the
+Beneficiary's management staff stated that Mr. Epstein likes to enable
+students of a community to become accessible to the world of science
+and other topics. He therefore invited some famous scientists to the
+Virgin Islands for a symposium. The symposium was advertised via
+all the Virgin Islands newspapers and radio airwaves. An invitation
+was also extended to public and private school students. These
+contributions were $243,977 over the certificate's commitment.
+In 2003, a total of $135,250 was made for educational scholarships to
+All Saints Cathedral School, Antillies School, Ruby Rutnik
+Scholarship Fund, Inc., Senator Carlton Dowe Summer Enrichment
+Program and St. Mary's School. The Boys and Girls Club, Cheetahs
+Track Club, Kidscope, Inc., St.
+/ St. John Sickle Cell Disease
+Association, We From Upstreet Inc., V.I. Montessori School and the
+RLS Hospital Cancer Fund are some organizations which received
+charitable contributions totaling $43,136. A contribution was also
+made to the Auburn University for the Ed
+_, Jr. Symposium.
+is a Virgin Islands resident who has excelled in
+academia. These contributions were $142,386 over the certificate's
+commitment.
+In 2004, the J. Epstein Foundation contributed a total of $162,610 in
+educational scholarships to All Saints Cathedral School, Antilles
+chool, the Community Foundation of the VI Inc. and the Rub
+utnik Scholarship Fund. A total of $95,866 in charitabl
+contributions were made to some charities which included; Dinn Brosay
+Page 15
+VI-JPM-000022912
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 17 of 19
+f/b/o Yankees Pee Wee Team, Humane Society of St.
+_ Ras
+Tafari Improvement Association, Inc., the Virgin Islands Golf
+Federation, Inc. and the Women's Coalition of St. Croix. A
+contribution of $5,000 was made to an Educational Symposium.
+These contributions were $226,476 over the certificate's commitment.
+In 2005 contributions from the J. Epstein Foundation Fund to
+Educational Scholarships totaled $90,200. These were given to All
+Saints Cathedral School, Alpha Kappa Alpha Sorority, Inc., Antilles
+School, Julius E. Sprauve, Miss. Virgin Islands Scholarship Fund and
+the Ruby Rutnik Scholarship Fund, Inc. A total of $138,019 was given
+to charities which included UVI Upward Bound Parent Association,
+Caribbean Chorale,
+Inc., BAPO Softball League and Catholic
+Charities of the Virgin Islands. An additional contribution of $20,595
+was made to an Educational Symposium on Physics.
+In 2006, the J. Epstein Foundation made charitable contributions
+totaling $43,776 to The St.
+Storm Baseball Club, the United
+Way of St.
+-St. John, the Community Foundation of the
+Virgin Islands. Educational scholarships totaling $115,590 was given
+to The Friends of the St.
+Public Library, Miss. Virgin Islands
+Scholarship,
+All Saints Cathedral School, Antilles School and
+Interscholastic Athletic Association. The J. Epstein Foundation hosted
+the CERCA Physics Conference and contributed a total of $260,971.
+It is noted that during the period covered in this report, Financial Trust Company,
+Inc. ($7,000) and the J. Epstein Foundation ($14,300) made contributions totaling
+$21,300 to organizations not qualified to receive tax-deductible contributions in
+accordance with the Internal Revenue Service. These organizations include the St
+-St. John Chamber of Commerce, the 2004 Congressional Campaign
+Committee, People for Progress, the Governor's Special Events Fund and the
+Dejongh Francis 2006 Transition.
+Page 16
+VI-JPM-000022913
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 18 of 19
+5. The applicant shall utilize the services of resident licensed broker dealers
+whenever possible, given market conditions.
+• The Beneficiary provided documentation showing Seslia
+Securities, a FINRA registered broker was utilized as a Broker of
+Record for their Savings Incentive Match Plan.
+REPORTING REQUIREMENTS:
+IDC Annual Report:
+Income Tax Return /
+Audited Financial Statements
+Lt. Governor's Annual Report:
+VIESA Report:
+Affidavit of IDC Beneficiary:
+Publication Notices
+Current
+Current
+Current
+Current
+Current
+Current
+FINANCIAL ANALYSIS REVIEW:
+Cost Benefit Analysis reflects an approximate ratio of 1 to 21 for the years 1999 to
+2006. This means that for every $1 given up in tax benefits $0.21 was spent in the
+local economy which includes employee taxes paid, local wages, local taxes paid,
+local procurement of goods and services and capital expenditures, a loss of $0.79.
+This includes the value of tax exemptions on personal income tax of Mr. Jeffrey
+Epstein, the sole owner of Financial Trust Company, Inc.
+Page 17
+VI-JPM-000022914
+
+
+Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 19 of 19
+CONCLUSION
+1. Met the investment requirement.
+2. Met the full-time employment requirement.
+3. Met the residency and management requirement.
+4. Complied with the procurement requirements.
+5. Complied with Special Condition #1 by providing Health, Life and Dental
+Insurance funded by the Beneficiary.
+6. Complied with Special Condition #2 by providing a qualified retirement
+plan funded by the Beneficiary.
+7. Complied with Special Condition #3 by providing training and tuition
+reimbursement to eligible employees.
+8. Did not specifically comply with Special Condition #4 - annual charitable
+contributions in 2005 and 2006. There was a shortfall of $12,500 for Co-op
+Marketing
+with the EDC and $42,322 to charity and educational
+scholarships. However, contributions made from the J. Epstein Foundation
+for charity and educational scholarships exceeded the overall requirement.
+9. Complied with Special Condition #5 by utilizing resident licensed broker
+dealers.
+10. Complied with the reporting requirements of the EDC.
+Prepared by: Sandra Bess
+Reviewed by: Margarita A. Greenidge |
+April 14, 2008
+Page 18
+VI-JPM-000022915

vision-fixhub/court-05/4eec8f8d7c23bb48f79b23e64acdb2a1e8ce08ac56c2ffbe83aa3f2cf78be9d8.receipt.json

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vision-fixhub/court-05/4f033f76824e1ae6de21ced660565803a9b798b45efc7ff906ef4afd9ecaf8eb.md

@@ -0,0 +1,147 @@
+Case 1:22-cv-10904-JSR Document 113 Filed 04/06/23 Page 1 of 3
+BRENDAN V.
+(202) 434-5800
+bsullivan@/wc.com
+- JR.
+LAW OFFICES
+& CONNOLLY LP.
+680 MAINE AVENUE SW
+WASHINGTON, DC 20024
+(202) 434-5000
+WWW.wC.coM
+April 6, 2023
+EDWARD BENNETT
+1920-1988)
+PAUL R. CONNOLLY (1922-1978)
+Hon. Jed S. Rakoff
+Via ECF
+Re:
+Third-Party Defendant James Staley's Motion to Sever and Reconsider
+Dear Judge Rakoff:
+Third-Party Defendant James Staley became a party to these cases less than a month ago.
+The allegations against him are baseless but serious: Mr. Staley is accused of aiding and abetting
+Jeffrey Epstein, one of the most notorious criminals in recent American history. As to potential
+liability, Third-Party Plaintiff JPMorgan Chase Bank, N.A. seeks to hold Mr. Staley liable for the
+entirety of any judgment entered in not one but two cases. It also seeks to disgorge several years
+of compensation. All that is to say: the stakes could hardly be higher for Mr. Staley. Disproving
+these false and highly-publicized allegations is of paramount importance to him. Yet this Court's
+scheduling rulings have severely prejudiced his ability to do so. Despite the high stakes and the
+massive volume of discovery, the Court entered a schedule that afforded Mr. Staley less than one
+month to serve written discovery and roughly two and a half months to complete fact discovery.
+By contrast, even though JPMorgan seeks to offload all liability onto Mr. Staley, it has been
+afforded six months to complete fact discovery.
+This breakneck pace is unnecessary and prejudicial to Mr. Staley. He therefore respectfully
+requests that the Court grant two, independent forms of relief: first, the Court should sever the
+third-party claims against Mr. Staley from the claims against JPMorgan and order that those sets
+of claims be tried separately; second, the Court should reconsider its prior scheduling order and
+(a) grant Mr. Staley the right to take 7-hour, in-person depositions of all witnesses; (b) set a May
+8, 2023 deadline for Mr. Staley to respond to the third-party complaints; (c) vacate the current fact
+discovery deadlines as to Mr. Staley; (d) set a new trial date in March 2024; and (e) order
+JPMorgan and Mr. Staley to meet and confer on all other deadlines.
+Background: On November 24, 2022, Jane Doe 1, on behalf of a purported class, filed a
+complaint against JPMorgan, alleging that it was "the lifeblood for [Epstein's] sex-trafficking
+venture." Compl. 9| 140. The Doe complaint alleges (without citation to any evidence) that Mr.
+Staley, who was a high-ranking executive at the bank, knew that Mr. Epstein was engaged in sex
+trafficking. The United States Virgin Islands then filed its own complaint, which also included
+allegations about Mr. Staley. Those two cases were consolidated for discovery, and, pursuant to
+the original Case Management Plan, the parties had to complete all fact discovery by April 24,
+2023—a full five months after the Doe complaint was filed. Dkt. 16 (Doe case). The Court set
+trial for September 5, 2023.
+
+
+Case 1:22-cv-10904-JSR Document 113 Filed 04/06/23 Page 2 of 3
+& CONNOLLYu*
+April 6, 2023
+Page 2
+On March 8, 2023, JPMorgan filed two third-party complaints against Mr. Staley. Those
+complaints are largely based upon the plaintiffs' allegations and seek to hold Mr. Staley fully liable
+for any judgment in both cases. The third-party complaints also seek repayment of all
+compensation that JPMorgan paid to Mr. Staley from 2006 to 2013. Although the third-party
+complaints are heavily based on the allegations by Doe and the USVI, JPMorgan does make
+significant additional allegations against Mr. Staley.
+On March 14, 2023, JPMorgan filed a standard waiver of service signed by undersigned
+counsel, which stated that "I understand that I, or the entity I represent, must file and serve an
+answer or a motion under Rule 12 within 60 days from 03/09/2023." Dkt. 64. Two days later, on
+March 16, 2023, this Court held a scheduling conference to address how Mr. Staley's late addition
+as a party would impact the case schedule. At the conference, undersigned counsel requested that
+the Court set trial in March 2024 in light of the magnitude and gravity of the case. The Court
+instead continued the trial for only six weeks, to October 23, 2023. During the conference, the
+Court raised the fact that JPMorgan had filed a waiver of service, which provided Mr. Staley 60
+days to respond under Federal Rules of Civil Procedure 4(d)(3) and 12(a)(1)(A)(ii). The Court
+encouraged JPMorgan to personally serve Mr. Staley, apparently expecting that personal service
+would vitiate the waiver and trigger the 21-day response deadline under Rule 12(a)(1)(A)(i).
+The parties then presented the Court with their positions on all interim deadlines via email.
+As Exhibit A reflects, Mr. Staley proposed a standstill of all depositions until May 31, 2023, and
+that fact discovery close on July 31, 2023. During an off-the-record argument regarding the
+schedule, Mr. Staley's counsel explained, among other things, that Mr. Staley could not adequately
+prepare a defense with any less time and that lead counsel for Mr. Staley has a federal criminal
+trial beginning in late May 2023. The Court's scheduling order nonetheless set a May 30 deadline
+for the close of fact discovery. Dkt. 74. The Court also required that Mr. Staley serve all
+interrogatories and requests for admission by April 7—less than a month after he entered the case
+and before any response to the complaint was due. Id. The Court further ordered that there would
+be no standstill of depositions, ruling instead that Mr. Staley could re-depose any witnesses
+deposed before April 24. The Court stated, however, that Mr. Staley's depositions would be
+limited to two hours and had to be conducted telephonically. Id. Finally, the Court ordered Mr.
+Staley to respond to the complaint by April 26 46 days from when he waived service. Id.
+The discovery in this case—which JPMorgan did not begin sending until March 21—has
+been voluminous. Mr. Staley has, to date, received well over 45,000 documents, spanning 240,000
+pages. We estimate that it would take over 900 hours of attorney time to review that volume
+(assuming a 50 document per hour pace). It appears that JPMorgan and the other parties are
+continuing to make rolling productions, meaning that the volume of documents will only continue
+to grow.
+Argument: As to the scheduling issue, a motion for reconsideration should be granted in
+order to "prevent manifest injustice." Kolel Beth Yechiel Mechil of Tartikov v. YLL Irrevocable
+Tr., 729 F.3d 99, 104 (2d Cir. 2013). As to the
+issue, it is governed by Federal Rules of
+Civil Procedure 14(a)(4) and 42(b) under which this Court has the discretion to sever third-party
+claims and order that they be tried separately "IfJor convenience, to avoid prejudice, or to expedite
+and economize." Fed. R. Civ. P. 42(b). Here, to prevent a manifest injustice and to avoid severely
+
+
+Case 1:22-cv-10904-JSR Document 113 Filed 04/06/23 Page 3 of 3
+& CONNOLLYu*
+April 6, 2023
+Page 3
+prejudicing Mr. Staley's defense, the Court should, for four reasons, grant the independent forms
+relief mentioned above - modification of the schedule and
+First, Mr. Staley is severely prejudiced by the schedule and cannot adequately prepare a
+defense without reasonable time for discovery. His lead counsel has trial in May-meaning that
+the current schedule effectively deprives Mr. Staley of his longtime lawyer and choice of counsel.
+But even absent the trial conflict, the present schedule affords Mr. Staley grossly insufficient time
+to mount a defense. The allegations against him are slanderous, and the potential damages are
+astronomical. Given these stakes, he should, at the very least, be afforded the same rights as any
+other litigant before this Court, including those in this case. This is all the more true given the
+volume of discovery and the late date on which Mr. Staley started to receive it. But, despite
+JPMorgan trying to stick Mr. Staley with all the liability, he has somehow ended up with less time
+than any other party. JPMorgan has no answer to Mr. Staley's prejudice other than to state that he
+received a deposition subpoena when a non-party. This isn't a serious argument: preparing for a
+deposition as a non-party witness bears no relation to defending and trying an entire case. And, if
+anything, it is the other parties who have an advantage due to their prior knowledge and possession
+of documents: the USVI and counsel for Doe have been involved in Epstein-related litigation for
+years, and JPMorgan possesses a library of relevant materials, which it presumably reviewed precomplaint, given that its relationship with Epstein has received such scrutiny.
+Second, the current schedule deprives Mr. Staley of basic procedural rights. By allowing
+Mr. Staley to re-depose witnesses whose depositions occur before April 24, the Court recognized
+that Mr. Staley has a lot of catching up to do, given JPMorgan's several-month (at least) head start.
+But the Court limited those depositions to just two hours and required that they be conducted
+telephonically. Rule 30, however, provides that civil litigants have "1 day of 7 hours" to conduct
+their examinations. Fed. R. Civ. P. 30(d)(1). The Rule also defaults to in-person depositions. Fed.
+R. Civ. P. 30(b)(4). But Rule 30 is not the only Rule that has been modified for Mr. Staley. Both
+Rule 4(d)(3) and Rule 12(a)(1)(A)(ii) provide that any defendant who timely returns a waiver of
+service need not respond to any complaint until 60 days after the request was sent. That is exactly
+what Mr. Staley did. And yet this Court shaved two weeks off Mr. Staley's response deadline.
+Third, Mr. Staley's defenses raise different issues and require broader discovery than
+JPMorgan's defenses. For example, Mr. Staley's defenses will require exploration of his
+relationship with JPMorgan dating back to at least 2000—23 years ago—and extending well
+beyond the time he left. Similarly, JPMorgan seeks damages that exceed what it may owe
+plaintiffs, claiming, for example, losses from "adverse publicity" that would require document
+discovery-even expert discovery—far beyond plaintiffs' case, Dkt. 59 9 64. It is impossible to
+take the necessary discovery on such issues in a matter of 10 weeks.
+Fourth, there would be no prejudice to any other party from severing the third-party claims.
+The plaintiffs support [
+•. And JPMorgan should not be heard to complain given that it
+has the most to gain from the prejudice to Mr. Staley. And even if there were some minor prejudice
+to JPMorgan's witnesses from having to appear at two trials, that prejudice pales in comparison to
+the prejudice that Mr. Staley would suffer if he were not granted additional time for fact discovery.
+Respectfully submitted,
+Is/ Brendan V.L
+1. Jr.

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vision-fixhub/court-05/4f0ca1ecbb6b09def0c117a2ce15b94e519017730badf0bd7bd9b63f306a4432.md

@@ -0,0 +1,271 @@
+Case 1:22-cv-10904-JSR Document 241-22 Filed 07/25/23
+
+FILED UNDER SEAL
+
+
+
+Case 1:22-cv-10904-JSR Document 241-22 Filed 07/25/23 Page 2 of 3
+Category
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+Epstein's JPMorgan account ending in 0663
+BegControl
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+JPM-SDNYLIT-00055170
+JPM-SDNYLIT-00055180
+JPM-SDNYLIT-00055184
+
+
+Case 1:22-cV-10904-JSR Document 241-22 Filed 07/25/23 Page 3 of 3
+Category
+Epstein's JPMorgan account ending in 0663
+Epstein's JPMorgan account ending in 0663
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+BegControl
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+JPM-SDNYLIT-00073568
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+JPM-SDNYLIT-00073658
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+JPM-SDNYLIT-00073878
+JPM-SDNYLIT-00073890
+JPM-SDNYLIT-00073902
+JPM-SDNYLIT-00073914
+EndControl
+JPM-SDNYLIT-00055190
+JPM-SDNYLIT-00055198
+JPM-SDNYLIT-00055206
+JPM-SDNYLIT-00055214
+JPM-SDNYLIT-00055220
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vision-fixhub/court-05/4f0ca1ecbb6b09def0c117a2ce15b94e519017730badf0bd7bd9b63f306a4432.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -58,
+  "dataset": "marble-joined",
+  "doc_id": "4f0ca1ecbb6b09def0c117a2ce15b94e519017730badf0bd7bd9b63f306a4432",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "1b1a8b1629aa391b4e56522654f2c6901035ff793a793f6dd65d6d337073fa07",
+  "output_sha256": "fb9a0679b190dd93951720449f58edd1045d48e0544b395436edc51250ddc8e9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13.md

@@ -0,0 +1,36 @@
+Case 1:22-cV-10904-JSR Document 263-54 Filed 08/07/23 Page 1 of 2
+
+
+
+Case 1:22-cv-10904-JSR Document 263-54 Filed 08/07/23 Page 2 of 2
+From:
+Sent:
+To:
+Viani, Lisa X [/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP
+(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=LISA.VIANI]
+1/13/2011 4:26:12 PM
+1. Магу C |
+]; Morris, Paul V [paul.v.morris@jpmorgan.com]
+Subject:
+Location:
+Start:
+1/14/2011 2:30:00 PM
+End:
+1/14/2011 2:45:00 PM
+Show Time As: Tentative
+William Langford, Jes Staley & Catherine Keating RE: Jeffrey Epstein
+Dial-in: 866-446-5908 / Participant passcode: 51690015
+Required
+Attendees:
+Optional
+Attendees:
+Langford, William D; Staley, Jes;
+Mary C; Morris, Paul V
+Cutler, Stephen M
+When: Friday, January 14, 2011 9:30 AM-9:45 AM (GMT-05:00) Eastern Time (US & Canada).
+Where: Dial-in: 866-446-5908 / Participant passcode:
+
+Note: The GMT offset above does not reflect daylight saving time adjustments.
+***$*~*****
+Mary L
+and Paul Morris will join the call in Catherine's office.

vision-fixhub/court-05/4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -43,
+  "dataset": "marble-joined",
+  "doc_id": "4f4d1e403a5c4e924e33c27dc27145ebc5e13f1138ba2b295c02c018a2f71d13",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "c37b9c5562f54cde5692abbff4e86f37664872671da0d5fe92fee23c1c9a5efd",
+  "output_sha256": "8f1c84ef58a0511e1ec0d64908c52a22ff276ca1d54b177046ed76b210fecf6d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c.md

@@ -0,0 +1,3 @@
+Case 1:22-cV-10904-JSR Document 267-52 Filed 08/07/23 Page 1 of 1
+
+FILED UNDER SEAL

vision-fixhub/court-05/4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -23,
+  "dataset": "marble-joined",
+  "doc_id": "4f57a4ad19fe22148e7d7bf7bdaa40b406b6cf88e2c4263564061fc67d98077c",
+  "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": "01568ec64e949d19ffdea89257b9ef620b04afc9ee0e73c45b99fb56bc61ee18",
+  "output_sha256": "c356633d1ceb924629e53a88a6e0a2ac7fd653bd702add270ccbc03523bc7e34",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21.md

@@ -0,0 +1,4 @@
+Case 1:22-cv-10904-JSR Document 239-13 Filed 07/25/23
+_Page 1 of 1
+FILED UNDER SEAL
+

vision-fixhub/court-05/4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -22,
+  "dataset": "marble-joined",
+  "doc_id": "4f7264d2b59f59e658f84811b95047e42f5a54b836b602184d1d5803873dba21",
+  "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": "6404c439215a047c47a8fd6d90af887e330338d622222591acad2ca26be44551",
+  "output_sha256": "9ee478821b59559a53fd8085fa269aa65d03fbdd708445f84b533837fbe81971",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351.md

@@ -0,0 +1,4 @@
+Case 1:22-cv-10904-JSR Document 311-60 Filed 08/25/23
+
+
+Filed Under Seal

vision-fixhub/court-05/4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -33,
+  "dataset": "marble-joined",
+  "doc_id": "4f7fa2e7458b71e670b972240017d2de42280b583a30ae5dcae73bb444f0e351",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "e4d05a8fa3587512210491a1efb71188fac197ad9bcf1675292f87aaaf77de3f",
+  "output_sha256": "b706961551e7e1e126ee7ca0f0ee8d910193e06b888765c6d730e28ec6f8a7cf",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527.md

@@ -0,0 +1,106 @@
+Case 1:22-cV-10904-JSR Document 243-29 Filed 07/25/23 Page 1 of 4
+TO: Jeffrey Epstein
+FROM: Noah Greenhill
+TEL:
+DATE: 1/3/10
+FACSIMILE COVER SHEET
+FAX NUMBER: 212-517-7779
+FAX NUMBER:
+#PAGES (incl. cover): 5
+100 •d
+
+€t:€I 0łoZ-€0-83J
+ESTATE_JPM010125
+
+
+Case 1:22-CV-10904-JSR Document 243-29 Filed 07/25/23
+
+AFFIDAVIT OF GLENN DUBIN
+)
+) ss.:
+STATE OF NEW YORK
+COUNTY OF NEW YORK
+Glenn 1
+being duly swor, deposes and says:
+1.
+I am over (wenty-one years of age and am competeat to testify to the matters
+stated in this affidavit. I have personal knowledge of the facts and statements herein.
+Each of the facts and statements herein is truc and correct.
+2.
+Starting in 2002, an cntity that I both owned and controlled, currently known as
+& Swieca Asset Management, LLC ("DSAM"), owned interests in the general
+partner and in the investment manager of D.B. Zwirn Special Opportunitics Fund, L.P.
+(thc "Zwim Fund"). The Zwirn Fund was named after Daniel Zwim ("Zwim"). While
+Zwim was responsible for the day-to-day management and opcrations of the Zwim Fund,
+after Zwim spun off his business from DSAM (then known as Highbridge Capital
+Management, LLC), I helped introduce investors to Zwim, invested my personal and
+family foundation assets with Zwim, and my firm allocated assets of Highbridge Capital
+Corporation ("HCC") to an account managed by Zwim's company which was also the
+investment manager of the Zwim Fund.
+One of the early investors that I introduced to Zwim was Jeffrcy Epstein
+("Epstein"). Epstein was both a personal friend of mine and a long-time investor in
+HCC. My understanding is that beginning in 2002 Epstein invested assets in the Zwim
+Fund through an cntity called Financial Trust Company, Inc.
+200'd
+
+EV: ET 0102-60-931
+ESTATE_JPM010126
+
+
+Case 1:22-cv-10904-JSR Document 243-29 Filed 07/25/23
+
+4. In the fall of 2006, Zwirn called me and told me that he was firing the Zwirn
+Fund's Chief Financial Officer. Zwim told me that there had been various irregularities
+at the Zwirn Fund, including that investors" moncy was usc to pay for an airplane that
+would be owned by Zwim's company.
+During October 2006, Zwirn told me that he was making attempts to contact each
+investor in the Zwirn Fund, including Epstein, to explain the inegularities to them.
+6. After speaking with Zwirn, Epstein called me very upsel. Epstein said that Zwirn
+had initially described the irregularities as "nonmaterial", but on a subsequent call,
+Zwira's description of the issues made it clear to Epstein that the problems were in fact
+very material. Epstein told me that when he confronted Zwirn about the earlier
+description of the irregularties, Zwim said that his counsel had told Zwirn to use the word
+"non-material". Epstein felt that Zwin had lied to him. Epstein told me thal he wanted
+to redeems Financial Trust Company, Inc.'s entire capital account in the Zwirn Fund
+immediately and that Epstein had made that demand to Zwin.
+7.
+I subscquently spoke to Zwirn about Epstein's demand. Zwim was concerned
+thal a complete redemption could cause a "run-on-the-bank." Zwim asked me to discuss
+with Epsicia roducing his demand to onc-half of Financial Trust Company, Inc. 's total
+capital accout in the Zwim Fund at the time, and I agreed I would discuss it with
+Epstcin.
+8.
+Subscquently, I participated in a three-way call with both Zwim and Epstein.
+During this call, Epstein demanded from Zwim the withdrawal of all of Financial Trust
+800 d
+
+0: 0102-0220
+ESTATE_JPM010127
+
+
+Case 1:22-cV-10904-JSR Document 243-29 Filed 07/25/23 Page 4 of 4
+Company, Inc.'s capital account in the Zwirn Fund. Epsicin said he wanted to redeem all
+of Financial Trust Company, Inc.'s 140 plus million dollars in that capital account
+immediately. Zwim responded that such a redemption could cause a "run-on-the-bank"
+and asked Epstein lo Icduce his redemption demand to half of that amount. Zwim said
+that if Epstein made only a partial redemption request, Zwirn would honor the request
+quickly. During this discussion with Epstein, Epstein agreed to redcom slightly more
+than half of Financial Trust Company, Inc.'s total capital account and said thal Financial
+Trust Company, Inc. would redcem 80 million dollars, and Zwim agreed to honor that
+request. Zwim did not dispute that Epstein had the right to the total redemption of
+Financial Trust Company, Inc.'s capital account in the Zwim Fund. It is my
+understanding,
+based on subsequent conversations with Epstein, that after this
+conversation, Epstein made a written request for that partial redemption of Financial
+Trust Company, Inc.'s capital account in the Zwirn Fund and that Zwim refused to honor
+this request.
+Swom to before me this J
+day of February, 2010.
+-(Scall:
+Notury Public
+Tinath, Damally
+State & New York
+* New York
+Ma Camillion Capita: 6/8/2013
+
+ESTATE_JPMO10128

vision-fixhub/court-05/4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -118,
+  "dataset": "marble-joined",
+  "doc_id": "4fbd2ba38b55f07e1ef8c82865e9cd4d779da5e5bfe99a405e14a8eca7a36527",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "fa8e5d36f33a605d50c93850b0b25ce050551466f731313379350e03732ea484",
+  "output_sha256": "a604024d99de447a0a3ec028b9a7714fe7cf9b710eaa903bde81aa408c4f9195",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5.md

@@ -0,0 +1,35 @@
+Case 1:22-cV-10904-JSR Document 326-88 Filed 09/08/23 Page 1 of 2
+
+
+
+From:
+To:
+Sent:
+Subject:
+Case 1:22-cv-10904-JSR Document 326-88 Filed 09/08/23 Page 2 of 2
+Staley, Jes <jes.staley@jpmorgan.com>
+"jeevacation@gmail.com sjeevacation@gmail.com>
+1/19/2011 3:00:30 AM
+Fw: Cookie Checking In...
+:)
+From:
+To: Staley, Jes
+Sent: Tue Jan 18 21:51:59 2011
+Subject: Fw: Cookie Checking In...
+Huh?
+From: Cookie Neil
+Date: Tue, 18 Jan 2011 20:33:13 -0500
+To:
+Subject: Cookie Checking In...
+Hi
+Spoke with Jim today and he mentioned that the the GRE score is what it is - not to worry - the score does not seem to be a
+problem according to my sources...
+What's going on with your applications? Have you heard back from anyone? Any thoughts or is Columbia still high on your
+list?
+Look forward to hearing from you!
+Best,
+Cookie
+Cookie Neil | Director for Science Development | Columbia University
+Columbia Alumni Center | 622 West 113th Street, New York, NY 10025
+
+JPM-SDNYLIT-00012289

vision-fixhub/court-05/4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -34,
+  "dataset": "marble-joined",
+  "doc_id": "4ff1e66f27ef01036bdc899bfb0850a41461f4d82add3a8f99e02e7e121474a5",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "35122c3cb4c6a9b8dcb7eea6b53c01efeaf26c2297f9f27dea2ed9773513c1a3",
+  "output_sha256": "55ea534bdc5aae8e014c3f3821d319f145476dd49028efb2e67da61caab5051d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21.md

@@ -0,0 +1,161 @@
+Case 1:19-cr-00830-AT Document 56
+Filed 05/25/20 SDe ageNAof 5
+DOCUMENT
+ELECTRONICALLY FILED
+DOC #:
+DATE FILED:_ 5/25/2021
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+United States of America
+V.
+Deferred Prosecution Agreement
+19 Cr. 830 (AT)
+Michael
+Defendant.
+TO: MICHAEL
+On November 19, 2019, a grand jury sitting in this District returned a six-count indictment
+(the "Indictment"), which charged Michael |
+("'you") with committing offenses against the
+United States, to wit, conspiring to knowingly defraud the United States and to knowingly make
+and use a false writing or document, in violation of 18 U.S.C. § 371, and three counts of knowingly
+making and using a false writing or document, in violation of 18 U.S.C. § 1001. However, after a
+thorough investigation, and based on the facts of this case and your personal circumstances, the
+U.S. Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined
+that the interests of justice will best be served by deferring prosecution in this District. Upon your
+acceptance of responsibility for your behavior and by your signature on this deferred prosecution
+agreement (the "Agreement"), prosecution will be deferred during the term of your behavior and
+satisfactory compliance with the terms of this Agreement for the period of six months from the
+date of this Agreement.
+The terms and conditions constituting your good behavior and satisfactory compliance are
+as follows:
+(1) You shall refrain from violating any federal, state, or local law. You shall immediately
+contact your U.S. Pretrial Services Officer if arrested or questioned by a lawenforcement officer.
+(2) You shall associate only with law-abiding persons.
+(3) You shall work regularly at a lawful occupation, regularly attend school, and/or support
+or care for your legal dependents, if any, to the best of your ability, as approved by your
+J.S. Pretrial Services Officer. You shall notify your supervising U.S. Pretrial Services
+Officer prior to any work or school changes.
+(4)
+You shall not leave the contiguous United States without permission of your
+- 1 -
+
+
+Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 2 of 5
+(5)
+You shall notify your supervising U.S. Pretrial Services Officer immediately of any
+change in your place of residence.
+(6) You shall follow your supervising U.S. Pretrial Services Officer's instructions and
+advice.
+(7) You shall report to your supervising U.S. Pretrial Services Officer as directed.
+As a further condition you hereby consent to disclosure, by any federal, state, or local
+government agency, or by any medical or substance abuse treatment provider, to the U.S. Pretrial
+Services Officer supervising your case, of such medical and treatment records as may be requested
+by the Pretrial Services Officer to evaluate deferral of prosecution in this case. You further agree
+that you will execute any additional consent forms that any such agency or provider may require
+to release such information.
+Special conditions are as follows:
+You shall truthfully and completely disclose all information with respect to the activities
+of yourself and others related to your employment by the Bureau of Prisons ("BOP"), which
+information can be used for any purpose. You shall agree to meet with and be interviewed by the
+USAO-SDNY, the Federal Bureau of Investigation, the Department of Justice, Office of the
+Inspector General ("DOJ-OIG"), and any other law enforcement agency designated by this Office.
+You shall complete 100 documented hours of community service, preferably related to the
+criminal justice system, including working with recently released inmates. The specific type of
+community service to be performed must be approved by your Pretrial Services Officer.
+The USAO-SDNY may at any time revoke or modify any condition of this provisional
+release or change the period of such supervision, which shall in no case exceed six months. The
+USAO-SDNY may discharge you from supervision at any time. The USAO-SDNY may at any
+time proceed with the prosecution for this offense should the USAO-SDNY, in its sole discretion,
+deem such action advisable.
+If upon completion of your supervision a written report from your supervising U.S. Pretrial
+Services Officer is received to the effect that you have complied with all the rules, regulations and
+conditions and special conditions applicable to your deferred prosecution, no further prosecution
+will be instituted in this District for the above offenses.
+Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from
+taking any administrative action against you, including suspension or termination of employment,
+based on the facts alleged in the Indictment, the facts identified in the course of the investigation
+that led to the Indictment, or your own statements to the DOJ-OIG or any other law enforcement
+entity. Nothing in this Agreement shall be interpreted to require the BOP or the DOJ-OIG to delay
+- 2-
+
+
+8969ł2
+Case 1:19-cr-00830-AT |
+Document 56 Filed 05/25/21
+
+any administrative action until after the expiration of the period of deferment contemplated by this
+Agreement. You agree that a copy of this Agreement, including your admission and acceptance
+of responsibility, shall be provided to the BOP.
+If you successfully complete the term of supervision and fulfills all the terms and
+conditions of this Agreement, the Government will move the Court to dismiss the Indictment as to
+the defendant.
+It is further understood that this Agreement and the terms and conditions set forth herein
+are limited to the facts and circumstances of this case and lack precedential value.
+Dated: New York, New York
+May 20, 2021
+AUDREY STRUASS
+United States Attorney for the
+Southern District of New York
+Jessea Lmergan
+Nicolas Roos
+Jessica Lonergan
+Assistant United States Attorneys
+Tel.: 212-637-2421 / 1038
+- 3-
+
+Case 1:19-cr-00830-AT Document 56
+Filed 05/25/21 Page 4 of 5
+The undersigned hereby consents to the foregoing. The undersigned hereby further admits
+that he willfully and knowingly completed materially false count and round slips regarding
+required counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center
+("MCC") on August 9, 2019 and August 10, 2019. The undersigned expressly waives any and all
+rights to a speedy trial pursuant to the Sixth Amendment to the United States Constitution, the
+Speedy Trial Act, §§ 3161 et seq., and any other pertinent provisions, and consents to the
+adjournment of all pending proceedings in this case. The undersigned further waives the
+applicable statute of limitations with respect to any prosecution that is not time-barred on the date
+that this agreement is signed. It is the intent of this provision to toll the applicable statute of
+limitations during the pendency of the deferred prosecution.
+The undersigned understands that pursuant to Title 18, United States Code, Section
+3161(h)(2), this Agreement is subject to approval by the Court. Should the Court refuse to
+approve, and thereby reject, this Agreement, neither party shall be bound to any term of this
+Agreement, and no admissions in this Agreement may be used against the undersigned.
+Finally, the undersigned acknowledges that he has read this Agreement and has carefully
+reviewed each provision with his attorney. The undersigned and his attorney acknowledge that no
+threats, promises, or representations have been made, nor agreements reached, other than those set
+forth in this Agreement. The undersigned further acknowledges that he understands and
+voluntarily accepts each and every term and condition of this Agreement.
+Dated: New York, New York
+May 20_, 2021
+Montell Hagins
+Montell Figgins (May 20, 2021 15:49 EDT)
+Montell Figgins, Esq.
+Attorney for Defendant
+Mchal theme
+(May 20, 2021 16:04 EDT)
+Michael
+Michael
+Defendant
+-4-
+
+
+Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 5 of 5
+Pursuant to 18 U.S.C. §3161(b)(2), exclusion under the Speedy Trial Act of the period of
+time during which the prosecution of the defendant is deferred pursuant to this Agreement is
+hereby approved.
+Dated: New York, New York
+May_25, 2021
+Honorable Analisa Torres
+United States District Judge
+The undersigned hereby consents to the foregoing and will accept supervision of the
+above-named defendant on the conditions set forth herein.
+Dated: New York, New York
+May _
+→ 2021
+Francesca
+Digitally signed by
+Piperato
+Francesca Piperato
+Date: 2021.05.24 10:32:36
+-04:00
+United States Pretrial Services Officer
+- 5 -

vision-fixhub/court-05/4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -61,
+  "dataset": "marble-joined",
+  "doc_id": "4ffcd26735f8c0ee52cfc5f2f686ec87fe573149efc32369c0040d5173635d21",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "94014da1d30c3251345a333880435cabaa86c110983b10d90d668818953c4283",
+  "output_sha256": "fdab514c9c68972100b209c0592b947affea11004c11f194abe83d4e14b49a03",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971.md

@@ -0,0 +1,46 @@
+Case 1:22-cV-10904-JSR Document 240-21 Filed 07/25/23 Page 1 of 3
+
+
+
+Case 1:22-cV-10904-JSR Document 240-21 Filed 07/25/23 Page 2 of 3
+From:
+Sent:
+To:
+Subject:
+Attachments:
+Ryan, Maryanne X [maryanne.x.ryan@jpmchase.com]
+3/12/2013 1:41:47 PM
+DeLuca, Phillip A [phillip.a.deluca@jpmchase.com]
+FW: High Profile
+Rapid Response Team - Jeffrey Espstein 3r Mtg - Jan 2010-doc.zip;
+Here you go. I am working from home as I still feel lousy. Head cold that won't go away.
+From: Ryan, Maryanne X
+Sent: Tuesday, February 19, 2013 4:44 PM
+To: DeLuca, Phillip A
+Subject: High Profile
+Here are the ones that | think should be closed, where the LOB has disagreed and signed off to keep.
+DeLuca Deposition
+
+22
+334640-CAK
+04/19/2023
+PB customer Jeffrey Edward Epstein is an American financier and science and education philanthropist, who is convicted sex offender. On multiple
+occasions this relationship has been escalated and approved to remain, including by Steve Cutler. (Rapid Response Doc attached)
+Redacted - Privileged
+
+JPM-SDNYLIT-00194272
+
+
+Case 1:22-CV-10904-JSR Document 240-21 Filed 07/25/23 Page 3 of 3
+to keep open that I think we would like to exit,
+Redacted - Privileged
+Maryanne Ryan
+Legal and Compliance
+AML Investigations
+VP, Compliance Director
+194
+Ave South
+Iselin, NJ 08830
+Phone 732-452-8071
+
+JPM-SDNYLIT-00194273

vision-fixhub/court-05/500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -78,
+  "dataset": "marble-joined",
+  "doc_id": "500766c8ea89d37eac0e470fffeee5813b9ed2e480a7adf73c85a6336a80d971",
+  "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": "6c771def5f16385090bb57d4c5f3537e396ae629b69e7d21d3ef8e2a3cf2bfec",
+  "output_sha256": "df9ba6383857b28a20eb81e6d4568051399f714f2a3c9ed6d2bcbe1cbaa101f8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c.md

@@ -0,0 +1,21 @@
+Case 1:22-cv-10904-JSR Document 287-3 Filed 08/18/23 Page 1 of 1
+Supreme Court of Maryland
+Annapolis, MD
+CERTIFICATE OF GOOD STANDING
+STATE OF MARYLAND, ss:
+1, Gregory Hilton, Clerk of the Supreme Court of Maryland, do hereby
+certify that on the twenty-second day of March, 2012,
+John Marcus McNichols
+having first taken and subscribed the oath prescribed by the Constitution and Laws
+of this State, was admitted as an attorney of said Court, is now in good standing,
+and as such is entitled to practice law in any of the Courts of said State, subject to
+the Rules of Court. This certificate of good standing is valid through the
+thirteenth day of October, 2023.
+ESPREME COURT
+OF MARYLAND
+In Testimony Whereof, I have hereunto
+set my hand as Clerk, and affixed the Seal
+of the Supreme Court of Maryland, this
+fourteenth day of August, 2023.
+Lages dillon
+Clerk of the Supreme Court of Maryland

vision-fixhub/court-05/5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "5039555b9e74e97155583a2a00701c537665b19d87d36ceb42b4615f71ab4d6c",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fbc7ca790fcb075a7471e4db9399a51f891819644a192ccea6ccab990dc32daa",
+  "output_sha256": "d758efd355d3357387296b9e8833ecffd08a64522cb43d3407a4a2995ba1c51e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279.md

@@ -0,0 +1,311 @@
+Case 1:22-cV-10904-JSR Document 194-21 Filed 06/20/23 Page 1 of 5
+
+
+
+Case 1:22-cv-10904-JSR Document 194-21 Filed 06/20/23
+
+VI-JPM-000007663
+Company Hame: Southern Trust Cempany Ins
+Gross Necessa of Sales
+Other Anoms
+Enterest Income
+Devadeed Incons
+Rental Incons
+Gross Waact Paid in the Vi Conclude sagain, sha car
+Average No of Empleases Fell Time
+Averses No, ef Emplosees, (Part Time Cuber)
+Averane No of Residents, Fell Time
+Antone No ef Readers Per Time Ober
+Asemes No ef Nes Reudess Full Tre
+Attle No. of Non-Reseats, Part Time Other
+Other Empires Cents (Linemployment & health insursess, semen, al
+romance etc.)
+Ernipsee Income Taurs Perd and Wahheld
+TAXES AND DUTIES (Provide dollar Meguet paid
+Gross Recry Taxes Cand
+Grosa Rectipes Encapuen ValuE.
+Real Preserv Tax Pard
+Real Pronetty Tax Exengton Velue.
+ENGIM TeNEs Pand
+Exce Tases Freneunn Value Refund
+Income Tanes Pand
+Encome Tess Esception Value Refund
+Custants Duties Paid
+Custome Dates Enemmon Value/Refund
+Othes
+el escapions for such 1axi
+Hotel room mers rad
+Orber Taxes Fees Pad lo VI Governmens (lou suretiv)
+Shuthedder Dandends
+Vi Degasmens of Late Elabor dusbase feet.
+Butters Lense renewal
+Franchise 1as
+Notary somasson fees
+Comfisals of rood sanding fee
+IDTAL TANES PAID:
+TOTAL VALUE OF ENEMPTIONS AND ON REFUNDS:
+Digible for Tee Benefits
+E41
+Ineligible for Tan Benefts**
+151
+Total
+54.690,266
+558).371)
+52.008,905
+-51.353)
+52.919,000
+soil
+85.452.242
+$4.868 305)
+51.690.366
+S6.065.513
+86.877.310
+-31.253
+$2.919,000
+Tatel
+Saurse Decement Needed
+$001.571 Please submut the form WISS
+10
+10
+5334.367
+5199 314 Pease submit the fare W/355
+Tres
+Health insurance
+Svenle IRA
+FICA FUTA.
+Workman's Come
+(Continum, Education
+J06 TOTAL
+Searce Desumess Neede
+so Farm 720VT er 7208
+Su Form 720V7 or 7208
+Preperty tor stressment
+Froperty ter assessment
+Eroom 721
+Form 721
+$291, 989|Form 1120, 11205, 1065, sv 1040 with sex escularion worksheer
+$47.996 Form 1120, 11/05, 200, er 1040 with ter cekuites worksheet
+Please keep copies of receipis for review dy WEDC Complience Offner
+Prose trep ropies of recripts for review by VEGE Compliance Offices
+Form 722
+{Pinne keen copies of reseipts jor itview by VIEDC Compliance Offure
+NA Note no exemptions claimed
+S:selMote no eremations shamed
+Note no exemptions claimed
+30524 sete = raempren claimed
+Note: no esemptions chimed
+Es Noir no premphony clemed
+EMpie no exemptions claimed
+5295.910
+542.798
+Balance per Tae
+Return
+Dilfarence
+malanation
+501
+$1.500.266
+S6.005.613
+56811,210
+- 31.252
+$2-919,000
+sisisis|als
+Other Implores Cort Brasheem
+Sosun
+Lection on Intones Tan Beturn
+$160 031
+521,239
+Corts include in site 14, 17,12, 19, mapectivel
+561,543
+$1,391
+$34 ME
+
+
+
+Document 194-21 Filed 06/20/23
+Case 1:22-cv-10904-JSR
+EXPENINTURES FOR GOODS, SERVICES, PLANT & 6QUIPMENT
+Row meierials and cormonents purcheses
+Repair Maintenance
+Beet
+Interess
+Other Bank Charnes
+Adventising/Promotion Marketing Experises
+Meals Emerainment
+Travel Expenses.
+Freisto & Postage Cures
+Insurance.
+VIEDC FRIe
+Seanlare
+Culities cel, wuer.clest.stc.)
+Supplies and Office expense
+Other (List Separin)
+Dues and subscriptions
+EDC Fees
+Busiers expenses
+Other espsuch satine, outside serves reuthuaties
+SUBTOTAL, G0005 AND SERVICES
+CAPITAL EXPENCITURES
+Building & leprovements
+Leason imprements
+Machinery guinent.
+FuntureFiatures
+Vehicles
+Dober (Lin Serenirin)
+SUBTOTAL CAITAL EXPENDITU MES
+S6.249
+$17,002
+S18.181
+55618)
+513,000
+563,060)
+MERCE.
+Sapollen
+563.671
+TION FOR VARIANCES IN BETWEEN EDC REPORT AND TAX RETURNS:
+It Supers
+514,579
+5138,393
+51,399
+S2,690
+56,760
+5E.506)
+52,064
+530,064
+5101,379|
+530.246
+5,180
+51,699
+5338.453|
+74,614
+3,820)
+IRTAS
+520.8381
+S0: 5138,003/
+5217)
+S1.ELZ
+58.820
+56,760.
+58.508
+8.3641
+$27.002
+31.535.225 SL545.289
+513.764
+5818.560
+S52,548
+$180
+517.9001
+$13,000
+517,500
+S1.6M
+53.586,726 51,200-245
+MONSOON SHINE
+4,186
+$29.187
+58,820)
+Belaose.e9c.TRs.(E3M
+520.838
+S115.893
+51.616]
+$3,380
+$8.506
+52.054
+517.002
+51.585.289
+5119,560
+557,647
+5180
+513,000
+5175N3
+81.699
+34.384.804
+HEnnett
+53.38050%5 deshuctihle limitain.
+$29.187 Amount caritalized includod in schedule L
+85.829 Amount capitaliand inchaded in schedale L
+531434)
+
+$4.186 538.007
+51.590.512 | 52.075.253)
+$3,391,34E
+ER EDE CERTIFICATE
+Certficane neguiremen
+Percent achieved to date
+5553,248
+5400.0к0)
+135313)
+VI-JPM-000007664
+
+
+Case 1:22-cv-10904-JSR Document 194-21 Filed 06/20/23 Page 4 of 5
+EDC ANNUAL REPORT
+Value of Exemptions of Stockholders/Partners/Members
+BENEFICIARY
+Southern Trust Company, Inc.
+Fiscal Year Ending December 31, 2018
+Stoakholders,
+Partners or Members
+Jeffrey E. Epstein
+Soctal Security
+No.
+Physical
+Address
+Little Saint James
+Island, St
+USVI
+Diatributable
+Shares
+EDC Income
+100
+EDC Annual
+report.
+Business
+Activity
+Balance Tax
+Total Tax Due EDC Credit
+Due
+See page 1 of See page 1 of See page 1
+EDC Annual
+EDC Annual
+report.
+report.
+TOTAL S
+Note: Totals of EDC Credit and Balance Tax Due must be carried forward to the EDC Annual Report and reported under Taxes and Duties (See instructions).
+
+
+Case 1:22-cv-10904-JSR Document 194-21 Filed 06/20/23 Page 5 of 5
+A
+D
+E
+F
+G
+EDC INCOME
+A
+TOTAL GROSS INCOME
+Percent of total income subject to Exemption
+_(A).
+_(B)._
+TOTAL TAX DUE
+Amount of Tax Subject to the Exemption E
+_(D)_
+_(C)
+EXEMPTION PERCENTATE
+F
+EDC EXEPMTION CREDIT
+_(E)
+X
+_(f).
+%=
+G
+$
+$
+$
+Line G included on49d of the 2018 Form 1040 Schedule 5 Line 74
+notation EDC credit
+2,964,750
+16,232,605
+18.26%
+291,989
+53,329
+90%
+47,996
+VI-JPM-000007666

vision-fixhub/court-05/503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -293,
+  "dataset": "marble-joined",
+  "doc_id": "503bcf4b8cdd8ae7d3b46810a913f9adf380521fcd5eed28d6c9d709cf798279",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "dd1354a6376a45e7c3a38476a3ea40265ff4b52c92942ef5cbe027a6182988b9",
+  "output_sha256": "f67a4fd1d9aef76412d94db22d3409bc4716519e27c38b94b3e43f5a689de754",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46.md

@@ -0,0 +1,11 @@
+Case 1:22-cv-10904-JSR Document 53-2 Filed 02/21/23 Page 1 of 1
+The Supreme Court of South Carolina
+Certificate of Good Standing
+I, Patricia A. Howard, Clerk of the Supreme Court of South Carolina, do
+hereby certify that Charlotte Eleanor Loper was duly sworn and admitted as an
+attorney in this state on November 19, 2019, and is currently a Regular Member
+of the South Carolina Bar in good standing.
+Patricia A. Howard
+CLERK
+Columbia, South Carolina
+February 14, 2023

vision-fixhub/court-05/506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "506dd96b6f0c670ca0ffe92ff5bc9c5a5edfd4df642a7b9e1c932d38cee85c46",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ae044b7343f41eda5a17f8f47bed3d9264d5a08683eca3fc0de98e5f9310eb72",
+  "output_sha256": "0547357f4621bdb773e75da89e37a59164df1ff209bb48b4bc368d285ef56bfc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a.md

@@ -0,0 +1,4 @@
+Case 1:22-cv-10904-JSR Document 158-80 Filed 05/23/23
+•Page 1 of 1
+
+FILED UNDER SEAL

vision-fixhub/court-05/508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -22,
+  "dataset": "marble-joined",
+  "doc_id": "508b001a81d652f31a1930ef09821c608674c9cd44b020ed99e1ba3b6767a59a",
+  "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": "a42df724884b62ade863fa24a1fa851203d93fd985aef244f13a05c9e9098643",
+  "output_sha256": "bee50e8242c652f39b9c4423f4edbc040c215b1019447bb6b4e05a42a25d7438",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/50946c12815138d84b877119e15f42c48d979c5ab43eb801bef7070652bcd09b.md

@@ -0,0 +1,69 @@
+Case 1:22-cv-10904-JSR Document 284-42 Filed 08/14/23
+
+
+FILED UNDER SEAL
+
+
+From:
+Sent:
+To:
+Subject:
+Case 1:22-cv-10904-JSR Document 284-42 Filed 08/14/23 Page 2 of 3
+Jeffrey Epstein [jeevacation@gmail.com]
+4/9/2009 1:22:57 PM
+Cecile de Jongh
+Re: confidential
+ok, re germaine, we need the most competent people, he has not really kept up... brice, and curtis have both
+complained. i don't mind replacing himm, and i really don't like the settlement
+issue,, he owed us fill
+disclosure
+On Thu, Apr 9, 2009 at 9:18 AM, Cecile de Jongh I
+wrote:
+Thanks - sending again to John. Vincent is off island and Gov't closed for Easter weekend
+until Tuesday (can you believe it). John will email to Vincent.
+From: Jeffrey Epstein cieevacation@nmail.comz
+To: Cecile de Jongh
+Sent: Thursday, April 9, 2009 9:08:01 AM
+Subject: Re: confidential
+Cecil//+ I will talk to the attorney today.. here is the attachment
+Chris lane is the man in charge of the interstate compact in florida//. The interstate compact dictates
+that Receiving states MUST now take probationers. But it is the sending states discretion on whether or
+not to apply. That is the norm,. As the receiving state is responsible for the cost of supervision, In the
+past states had previously turned down transferees. The interstate compact does not now allow the
+state to turn down transfers. Normally as " community control" has to be a heightened and hence, more
+expensive supervision,i.e. once a week reporting (as opposed to once a month and on weekends and
+holidays.) Florida usually does not askanother state to take on the added expense. As compared to the
+normal probation it costs more, so that in my case the VI has to agree to the same terms and conditions
+as the normal community control provisions that I would be subject to if I stayed.
+I think best that the head of the compact commission for the VI - Ms. Swan should deal with Chris Lane (
+Floridas' interstate compact administrator) .
+, my assistant has spoken to
+him previously and he thought this was accomplished with little fuss. The question that remains is
+where on my side do we start. The probation officer, (Duane
+Neither one knows anything about this yet) or the probation compact person, the person in the office
+that usually handles transfers. I will get his number. //. Someone on this end must fill out the transfer
+request forms. l assume Duane.
+On Thu, Apr 9, 2009 at 8:59 AM, Cecile de Jongh
+Jeffrey,
+wrote:
+I forwarded the document you sent me last week to John and he tried to send it on to
+Vincent. He then tried to open it to print it out and the file is corrupted- Vincent can't open
+either. I tried to reopen and print or to resend and I can't open it either. Can you resend to
+
+ESTATE_JPMO16557
+
+
+Case 1:22-cV-10904-JSR Document 284-42 Filed 08/14/23 Page 3 of 3
+John has one question: Would it not be better to have your attorney write a letter to the AG
+(Vincent) requesting the transfer and then we move from there? He (John) sees nothing
+wrong with taking that approach rather than having just phone calls back and forth especially
+since you are a resident of the VI.
+In either case, can you try to resend the document?
+Cecile
+From: Jeffrey Epstein <jeevacation@gmail.com>
+To: Cecile de Jongh
+Sent: Thursday, April 2, 2009 10:48:06 AM
+Subject: confidential
+call me when you get a chance
+
+ESTATE_JPMO16558

vision-fixhub/court-05/50946c12815138d84b877119e15f42c48d979c5ab43eb801bef7070652bcd09b.receipt.json

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vision-fixhub/court-05/509e7628b81b8b6923d2718a51ceb2fbd47ab4e0c7f2b9b6ae6970c38e9bbf6f.md

@@ -0,0 +1,926 @@
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 1 of 41
+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS,
+Plaintiff,
+V.
+Case No. 22-cv-10904 (JSR)
+JPMORGAN CHASE BANK, N.A..,
+Defendant/Third-Party
+Plaintiff.
+JPMORGAN CHASE BANK, N.A.,
+Third-Party Plaintiff,
+V.
+JAMES EDWARD STALEY,
+Third-Party Defendant.
+DECLARATION OF FELICIA H. ELLSWORTH IN SUPPORT OF JPMORGAN
+CHASE BANK, N.A.'S OPPOSITION TO THE GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS' MOTION FOR PARTIAL SUMMARY JUDGMENT
+Pursuant to 28 U.S.C. § 1746, I, Felicia H. Ellsworth, declare under penalty of perjury as
+follows:
+I am a member in good standing of the bar of the Commonwealth of Massachusetts. I
+am one of the attorneys representing Defendant JPMorgan Chase Bank, N.A. ("JPMC")
+in the above-captioned action and have been admitted to this Court pro hac vice. I am a
+Partner with the law firm of Wilmer Cutler Pickering Hale and Dorr LLP, 60 State
+Street, Boston, Massachusetts 02109. I am familiar with the facts set forth herein, and
+if called as a witness, I could and would competently testify thereto.
+1
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 2 of 41
+2.
+Attached as Exhibit 54 is a true and correct copy of excerpts of the transcript from the
+July 7, 2023 deposition of Bridgette Carr, designated confidential pursuant to the
+3. Attached as Exhibit 55 is a true and correct copy of excerpts of the transcript from the
+May 26, 2023 deposition of James Dimon, designated confidential pursuant to the
+4.
+Attached as Exhibit 56 is a true and correct copy of excerpts of JPMC's Responses and
+Objections to Third-Party Defendant James E. Staley's Requests for Admission.
+5. Attached as Exhibit 57 is a true and correct copy of excerpts of the transcript from the
+March 29, 2023 deposition of Francis Pearn.
+6.
+Attached as Exhibit 58 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00072548, designated confidential pursuant to the
+7.
+Attached as Exhibit 59 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00139994, designated confidential pursuant to the
+8.
+Attached as Exhibit 60 is a true and correct copy of excerpts from the June 23, 2023
+Expert Report of Teresa A. Pesce, designated confidential pursuant to the Protective
+Order in this matter and filed under seal.
+Attached as Exhibit 61 is a true and correct copy of excerpts of the transcript from the
+March 15, 2023 deposition of Mary Erdoes, designated confidential pursuant to the
+2
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 3 of 41
+10. Attached as Exhibit 62 is a true and correct copy of excerpts of JPMC's Responses and
+Objections to USVI's First Requests for Admission.
+11. Attached as Exhibit 63 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00149115.
+12. Attached as Exhibit 64 is a true and correct copy of the Rubenstein, Who We Are page,
+available at https://rubenstein.com/who-we-are/#.
+13. Attached as Exhibit 65 is a true and correct copy of excerpts of the transcript from the
+June 27, 2023 deposition of Jorge Amador, designated confidential pursuant to the
+14. Attached as Exhibit 66 is a true and correct copy of excerpts of the transcript from the
+April 7, 2023 deposition of Mary l
+15. Attached as Exhibit 67 is a true and correct copy of excerpts of the transcript from the
+July 12, 2023 deposition of Marcus Sheridan, designated confidential pursuant to the
+16. Attached as Exhibit 68 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00755535.
+17. Attached as Exhibit 69 is a true and correct copy of excerpts from JPMC's Responses
+and Objections to Doe's First Set of Interrogatories.
+18.
+Attached as Exhibit 70 is a true and correct copy of excerpts of the transcript from the
+June 10, 2023 deposition of James Staley.
+19. Attached as Exhibit 71 is a true and correct copy of excerpts of the transcript from the
+July 18, 2023 deposition of Catherine Keating, designated confidential pursuant to the
+3
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 4 of 41
+20. Attached as Exhibit 72 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00902699, designated confidential pursuant to the
+21. Attached as Exhibit 73 is a true and correct copy of excerpts of Third-Party Defendant
+James E. Staley's May 23, 2023 Responses and Objections to The United States Virgin
+Islands' Requests for Admission.
+22. Attached as Exhibit 74 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00153462.
+23.
+Attached as Exhibit 75 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00136978.
+24. Attached as Exhibit 76 is a true and correct copy of excerpts of the transcript from the
+April 21, 2023 deposition of Justin Nelson, designated confidential pursuant to the
+25. Attached as Exhibit 77 is a true and correct copy of excerpts of the transcript from the
+July 13, 2023 deposition of John Duffy, designated confidential pursuant to the
+26. Attached as Exhibit 78 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00754968, designated confidential pursuant to the
+27. Attached as Exhibit 79 is a true and correct copy of excerpts of the transcript from the
+May 24, 2023 deposition of Stephen Cutler.
+4
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 5 of 41
+28. Attached as Exhibit 80 is a true and correct copy of excerpts of the transcript from the
+July 7, 2023 deposition of Shaun O'Neill, designated confidential pursuant to the
+29. Attached as Exhibit 81 is a true and correct copy of excerpts from the June 23, 2023
+Expert Report of Joe Fonseca, designated confidential pursuant to the Protective Order
+in this matter and filed under seal.
+30. Attached as Exhibit 82 is a true and correct copy of an article titled,
+modeling
+agent Jean-Luc Brunel found dead in prison cell" dated February 21, 2022 available at
+https://www.cnn.com/2022/02/19/europe/jean-luc-brunel-jeffrey-epstein-deathintl/index.html.
+31. Attached as Exhibit 83 is a true and correct copy of an article titled "Billionaire Jeffrey
+Epstein Arrested for Sec Trafficking" dated July 7, 2019, available at
+https://gothamist.com/news/billionaire-jeffrey-epstein-arrested-for-sex-trafficking.
+32. Attached as Exhibit 84 is a true and correct copy of Exhibit 19 to the May 26, 2023
+deposition of Inais Borque.
+33. Attached as Exhibit 85 is a true and correct copy excerpts of produced by Plaintiff the
+Government of the United States Virgin Islands, I
+stamped VI-JPM-000012446_U
+designated confidential pursuant to the Protective Order in this matter and filed under
+34. Attached as Exhibit 86 is a true and correct copy of excerpts of the VIPA Police
+Manual.
+35. Attached as Exhibit 87 is a true and correct copy of excerpts of produced by Plaintiff
+stamped VI-JPM-
+5
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 6 of 41
+000006467, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+36. Attached as Exhibit 88 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000018027, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+37. Attached as Exhibit 89 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands, |
+stamped VI-JPM-
+000018041, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+38. Attached as Exhibit 90 is a true and correct copy of excerpts of the June 23, 2023
+Carlyn Irwin Expert Report, designated confidential pursuant to the Protective Order in
+this matter and filed under seal.
+39. Attached as Exhibit 91 is a true and correct copy of excerpts of the transcript from the
+July 6, 2023 deposition of Carlyn Irwin, designated confidential pursuant to the
+40. Attached as Exhibit 92 is a true and correct copy of excerpts of the transcript from the
+May 10, 2023 deposition of Bonnie
+designated confidential pursuant to the
+41. Attached as Exhibit 93 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00026008, designated confidential pursuant to the
+6
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 7 of 41
+42. Attached as Exhibit 94 is a true and correct copy of excerpts of the transcript from the
+July 13, 2023 deposition of Francis Pearn, designated confidential pursuant to the
+43. Attached as Exhibit 95 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00127953.
+44. Attached as Exhibit 96 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00001893.
+45. Attached as Exhibit 97 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00449994.
+46. Attached as Exhibit 98 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00127944.
+47. Attached as Exhibit 99 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00010814, designated confidential pursuant to the
+48. Attached as Exhibit 100 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00157090.
+49. Attached as Exhibit 101 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00152748_R.
+50. Attached as Exhibit 102 is a true and correct copy of excerpts of the transcript from the
+May 24, 2023 deposition of Maryanne Ryan, designated confidential pursuant to the
+51. Attached as Exhibit 103 is a true and correct copy of excerpts of the transcript from the
+April 28, 2023 deposition of Kevin McCleerey.
+7
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 8 of 41
+52. Attached as Exhibit 104 is a true and correct copy of a document produced by JPMC,
+_ stamped JPM-SDNYLIT-00119630.
+53. Attached as Exhibit 105 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00274774, designated confidential pursuant to the
+54. Attached as Exhibit 106 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00127930, designated confidential pursuant to the
+55. Attached as Exhibit 107 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00452980.
+56. Attached as Exhibit 108 is a true and correct copy of excerpts of the transcript from the
+May 3, 2023 deposition of William Langford, designated confidential pursuant to the
+57. Attached as Exhibit 109 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00127928.
+58. Attached as Exhibit 110 is a true and correct copy of the June 16, 2023 Expert Report
+of Jorge Amador, designated confidential pursuant to the Protective Order in this matter
+and filed under seal.
+59. Attached as Exhibit 111 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00755043.
+60. Attached as Exhibit 112 is a true and correct copy of a document produced by third
+stamped Estate_006622, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+8
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 9 of 41
+61. Attached as Exhibit 113 is a true and correct copy of a document produced by JPMC,
+_stamped JPM-SDNYLIT-00136519, designated confidential pursuant to the
+62. Attached as Exhibit 114 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00231636, designated confidential pursuant to the
+63. Attached as Exhibit 115 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00230825, designated confidential pursuant to the
+64. Attached as Exhibit 116 is a true and correct copy of excerpts of the transcript from the
+May 30, 2023 deposition of Francis Pearn, designated confidential pursuant to the
+65. Attached as Exhibit 117 is a true and correct copy of excerpts of the transcript from the
+May 18, 2023 deposition of Richard Kahn, designated confidential pursuant to the
+66. Attached as Exhibit 118 is a true and correct copy of the May 26, 2023 Declaration of
+P. Visoski, Jane Doe 1 v. Deutsche Bank, Case No. 1:22-cv-10018 (JSR).
+67. Attached as Exhibit 119 is a true and correct copy of excerpts of the transcript from the
+April 20, 2023 deposition of Phillip DeLuca, designated confidential pursuant to the
+68. Attached as Exhibit 120 is a true and correct copy of excerpts of the transcript from the
+June 30, 2023 deposition of Kimberly Mehlman-Orozco, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+9
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 10 of 41
+69. Attached as Exhibit 121 is a true and correct copy of excerpts of the transcript from the
+April 18, 2023 deposition of Paul Morris.
+70. Attached as Exhibit 122 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00036580, designated confidential pursuant to the
+71. Attached as Exhibit 123 is a true and correct copy of a document produced by JPMC,
+_stamped JPM-SDNYLIT-W-00025201, designated confidential pursuant to the
+72. Attached as Exhibit 124 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00152809, designated confidential pursuant to the
+73. Attached as Exhibit 125 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00026008, designated confidential pursuant to the
+74. Attached as Exhibit 126 is a true and correct copy of excerpts of the transcript from the
+July 10, 2023 deposition of Stephen Cutler, designated confidential pursuant to the
+75. Attached as Exhibit 127 is a true and correct copy of excerpts of the transcript from the
+July 12, 2023 deposition of Mary Erdoes, designated confidential pursuant to the
+76. Attached as Exhibit 128 is a true and correct copy of excerpts of the transcript from the
+March 3, 2023 deposition of Jane Doe 1, designated confidential pursuant to the
+10
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 11 of 41
+77. Attached as Exhibit 129 is a true and correct copy of excerpts of the transcripts from
+the June 11, 2023 deposition of James Staley, designated confidential pursuant to the
+78. Attached as Exhibit 130 is a true and correct copy of a document produced by JPMC,
+_stamped JPM-SDNYLIT-00006171.
+79. Attached as Exhibit 131 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM002773,
+designated confidential pursuant to the Protective Order in this matter and filed under
+80. Attached as Exhibit 132 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00006718.
+81. Attached as Exhibit 133 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00006716, designated confidential pursuant to the
+82. Attached as Exhibit 134 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00006791.
+83. Attached as Exhibit 135 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00006792, designated confidential pursuant to the
+84. Attached as Exhibit 136 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00008342.
+85.
+Attached as Exhibit 137 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00008669.
+11
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 12 of 41
+86. Attached as Exhibit 138 is a true and correct copy of' a document produced by JPMC,
+stamped JPM-SDNYLIT-00013210, designated confidential pursuant to the
+87. Attached as Exhibit 139 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00013402.
+88. Attached as Exhibit 140 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00013463, designated confidential pursuant to the
+89. Attached as Exhibit 141 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00013475.
+90.
+Attached as Exhibit 142 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00013669.
+91. Attached as Exhibit 143 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00013762.
+92. Attached as Exhibit 144 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00005845, designated confidential pursuant to the
+93. Attached as Exhibit 145 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00006553, designated confidential pursuant to the
+94. Attached as Exhibit 146 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00006886, designated confidential pursuant to the
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 13 of 41
+95. Attached as Exhibit 147 is a true and correct copy of' a document produced by JPMC,
+stamped JPM-SDNYLIT-00010121, designated confidential pursuant to the
+96. Attached as Exhibit 148 is a true and correct copy of a document produced by JPMC,
+_ stamped JPM-SDNYLIT-00010989, designated confidential pursuant to the
+97. Attached as Exhibit 149 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00012289, designated confidential pursuant to the
+98. Attached as Exhibit 150 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00012466, designated confidential pursuant to the
+99. Attached as Exhibit 151 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00004661.
+100. Attached as Exhibit 152 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM001758,
+designated confidential pursuant to the Protective Order in this matter and filed under
+101. Attached as Exhibit 153 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00006586.
+102. Attached as Exhibit 154 is a true and correct copy of a document produced by JPMC,
+_stamped JPM-SDNYLIT-00006592.
+13
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 14 of 41
+103. Attached as Exhibit 155 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00006874.
+104. Attached as Exhibit 156 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00012494.
+105. Attached as Exhibit 157 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00004394, designated confidential pursuant to the
+106. Attached as Exhibit 158 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00004388, designated confidential pursuant to the
+107. Attached as Exhibit 159 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM002742,
+designated confidential pursuant to the Protective Order in this matter and filed under
+108. Attached as Exhibit 160 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00006704, designated confidential pursuant to the
+109. Attached as Exhibit 161 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00010330, designated confidential pursuant to the
+110. Attached as Exhibit 162 is a true and correct copy of a document produced by JPMC,
+stamped .JPM-SDNYLIT-00010603, designated confidential pursuant to the
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 15 of 41
+111. Attached as Exhibit 163 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00004186, designated confidential pursuant to the
+112. Attached as Exhibit 164 is a true and correct copy of a document produced by JPMC,
+_ stamped JPM-SDNYLIT-00010284, designated confidential pursuant to the
+113. Attached as Exhibit 165 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM003001,
+designated confidential pursuant to the Protective Order in this matter and filed under
+114. Attached as Exhibit 166 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM002019,
+designated confidential pursuant to the Protective Order in this matter and filed under
+115. Attached as Exhibit 167 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00013770.
+116. Attached as Exhibit 168 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00205452.
+117. Attached as Exhibit 169 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00269718, designated confidential pursuant to the
+15
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 16 of 41
+118. Attached as Exhibit 170 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00269719, designated confidential pursuant to the
+119. Attached as Exhibit 171 is a true and correct copy of a document produced by JPMC,
+_ stamped JPM-SDNYLIT-W-00021957, designated confidential pursuant to the
+120. Attached as Exhibit 172 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00033761, designated confidential pursuant to the
+121. Attached as Exhibit 173 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00021997, designated confidential pursuant to the
+122. Attached as Exhibit 174 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00037446, designated confidential pursuant to the
+123. Attached as Exhibit 175 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00037463, designated confidential pursuant to the
+124. Attached as Exhibit 176 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00022528, designated confidential pursuant to the
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 17 of 41
+125. Attached as Exhibit 177 is a true and correct copy of excerpts of a document produced
+by JPMC, I
+stamped JPM-SDNYLIT-W-00017133, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+126. Attached as Exhibit 178 is a true and correct copy of excerpts of a document produced
+by JPMC,
+stamped JPM-SDNYLIT-W-00008055, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+127. Attached as Exhibit 179 is a true and correct copy of excerpts of a document produced
+by JPMC,
+stamped JPM-SDNYLIT-W-00020952, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+128. Attached as Exhibit 180 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00000183, designated confidential pursuant to the
+129. Attached as Exhibit 181 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00000001, designated confidential pursuant to the
+130. Attached as Exhibit 182 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00000211, designated confidential pursuant to the
+131. Attached as Exhibit 183 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00022540, designated confidential pursuant to the
+17
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 18 of 41
+132. Attached as Exhibit 184 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00008100, designated confidential pursuant to the
+133. Attached as Exhibit 185 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00022549, designated confidential pursuant to the
+134. Attached as Exhibit 186 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00008123, designated confidential pursuant to the
+135. Attached as Exhibit 187 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-W-00008144, designated confidential pursuant to the
+136. Attached as Exhibit 188 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00136910, designated confidential pursuant to the
+137. Attached as Exhibit 189 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00136911, designated confidential pursuant to the
+138. Attached as Exhibit 190 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00100966.
+139. Attached as Exhibit 191 is a true and correct copy of a document produced by JPMC,
+_stamped JPM-SDNYLIT-00150176.
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 19 of 41
+140. Attached as Exhibit 192 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00100998, designated confidential pursuant to the
+141. Attached as Exhibit 193 is a true and correct copy of a document produced by JPMC,
+_ stamped JPM-SDNYLIT-00030327, designated confidential pursuant to the
+142. Attached as Exhibit 194 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00016246, designated confidential pursuant to the
+143. Attached as Exhibit 195 is a true and correct copy of excerpts from JPMC's Responses
+and Objections to The United States Virgin Islands First Requests for Admissions.
+144. Attached as Exhibit 196 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00902715, designated confidential pursuant to the
+145. Attached as Exhibit 197 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00373074.
+146. Attached as Exhibit 198 is a true and correct copy of a document produced by JPMC,
+stamped JPM-SDNYLIT-00373254.
+147. Attached as Exhibit 199 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015321.
+148. Attached as Exhibit 200 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015326,
+19
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 20 of 41
+designated confidential pursuant to the Protective Order in this matter and filed under
+149. Attached as Exhibit 201 is a true and correct copy of Exhibit 7 from the July 20, 2023
+deposition of Denise
+150. Attached as Exhibit 202 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016517,
+designated confidential pursuant to the Protective Order in this matter and filed under
+151. Attached as Exhibit 203 is a true and correct copy of excerpts of the transcript from the
+June 6, 2023 deposition of Albert Bryan.
+152. Attached as Exhibit 204 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016246,
+designated confidential pursuant to the Protective Order in this matter and filed under
+153. Attached as Exhibit 205 is a true and correct copy of excerpts of a document produced
+by Plaintiff the Government of the United States Virgin Islands,
+stamped VI-
+JPM-000006066, designated confidential pursuant to the Protective Order in this matter
+and filed under seal.
+154. Attached as Exhibit 206 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM025237,
+designated confidential pursuant to the Protective Order in this matter and filed under
+20
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 21 of 41
+155. Attached as Exhibit 207 is a true and correct copy of excerpts of the transcript from the
+May 29, 2023 deposition of Stacey Plaskett.
+156. Attached as Exhibit 208 is a true and correct copy of excerpts of the transcript from the
+May 29, 2023 deposition of Cecile de Jongh, designated confidential pursuant to the
+157. Attached as Exhibit 209 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015885,
+designated confidential pursuant to the Protective Order in this matter and filed under
+158. Attached as Exhibit 210 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015674,
+designated confidential pursuant to the Protective Order in this matter and filed under
+159. Attached as Exhibit 211 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM059741,
+designated confidential pursuant to the Protective Order in this matter and filed under
+160. Attached as Exhibit 212 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016163,
+designated confidential pursuant to the Protective Order in this matter and filed under
+161. Attached as Exhibit 213 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015950,
+21
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 22 of 41
+designated confidential pursuant to the Protective Order in this matter and filed under
+162. Attached as Exhibit 214 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM022478,
+designated confidential pursuant to the Protective Order in this matter and filed under
+163. Attached as Exhibit 215 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM022479,
+designated confidential pursuant to the Protective Order in this matter and filed under
+164. Attached as Exhibit 216 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016210,
+designated confidential pursuant to the Protective Order in this matter and filed under
+165. Attached as Exhibit 217 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM058471,
+designated confidential pursuant to the Protective Order in this matter and filed under
+166. Attached as Exhibit 218 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM060696,
+designated confidential pursuant to the Protective Order in this matter and filed under
+22
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 23 of 41
+167. Attached as Exhibit 219 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM058976,
+designated confidential pursuant to the Protective Order in this matter and filed under
+168. Attached as Exhibit 220 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM023608,
+designated confidential pursuant to the Protective Order in this matter and filed under
+169. Attached as Exhibit 221 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM012505,
+designated confidential pursuant to the Protective Order in this matter and filed under
+170. Attached as Exhibit 222 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015733,
+designated confidential pursuant to the Protective Order in this matter and filed under
+171. Attached as Exhibit 223 is a true and correct copy of excerpts of the transcript from the
+May 24, 2023 deposition of Kenneth Mapp.
+172. Attached as Exhibit 224 is a true and correct copy of excerpts of the transcript from the
+May 30, 2023 deposition of John de Jongh.
+173. Attached as Exhibit 225 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM066053,
+23
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 24 of 41
+designated confidential pursuant to the Protective Order in this matter and filed under
+174. Attached as Exhibit 226 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016303,
+designated confidential pursuant to the Protective Order in this matter and filed under
+175. Attached as Exhibit 227 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM030178,
+designated confidential pursuant to the Protective Order in this matter and filed under
+176. Attached as Exhibit 228 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM024203,
+designated confidential pursuant to the Protective Order in this matter and filed under
+177. Attached as Exhibit 229 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM021286,
+designated confidential pursuant to the Protective Order in this matter and filed under
+178. Attached as Exhibit 230 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM024371,
+designated confidential pursuant to the Protective Order in this matter and filed under
+24
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 25 of 41
+179. Attached as Exhibit 231 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM024370,
+designated confidential pursuant to the Protective Order in this matter and filed under
+180. Attached as Exhibit 232 is a true and correct copy of a document produced by third
+stamped ESTATE_JPMO11964,
+designated confidential pursuant to the Protective Order in this matter and filed under
+181. Attached as Exhibit 233 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM064333,
+designated confidential pursuant to the Protective Order in this matter and filed under
+182. Attached as Exhibit 234 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM064334,
+designated confidential pursuant to the Protective Order in this matter and filed under
+183. Attached as Exhibit 235 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM024927,
+designated confidential pursuant to the Protective Order in this matter and filed under
+184. Attached as Exhibit 236 is a true and correct copy of a document produced by third
+stamped ESTATE_JPMO22970,
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 26 of 41
+designated confidential pursuant to the Protective Order in this matter and filed under
+185. Attached as Exhibit 237 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM050241,
+designated confidential pursuant to the Protective Order in this matter and filed under
+186. Attached as Exhibit 238 is a true and correct copy of a document produced by third
+stamped ESTATE_JPMO50265,
+designated confidential pursuant to the Protective Order in this matter and filed under
+187. Attached as Exhibit 239 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM060776,
+designated confidential pursuant to the Protective Order in this matter and filed under
+188. Attached as Exhibit 240 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM061002,
+designated confidential pursuant to the Protective Order in this matter and filed under
+189. Attached as Exhibit 241 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM061003,
+designated confidential pursuant to the Protective Order in this matter and filed under
+26
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 27 of 41
+190. Attached as Exhibit 242 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM055381,
+designated confidential pursuant to the Protective Order in this matter and filed under
+191. Attached as Exhibit 243 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM021989,
+designated confidential pursuant to the Protective Order in this matter and filed under
+192. Attached as Exhibit 244 is a true and correct copy of a document produced by third
+stamped ESTATE_JPMO12219,
+designated confidential pursuant to the Protective Order in this matter and filed under
+193. Attached as Exhibit 245 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands, |
+stamped VI-JPM-
+000021920, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+194. Attached as Exhibit 246 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM061123,
+designated confidential pursuant to the Protective Order in this matter and filed under
+195. Attached as Exhibit 247 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM062263,
+27
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 28 of 41
+designated confidential pursuant to the Protective Order in this matter and filed under
+196. Attached as Exhibit 248 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM062254,
+designated confidential pursuant to the Protective Order in this matter and filed under
+197. Attached as Exhibit 249 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM065842,
+designated confidential pursuant to the Protective Order in this matter and filed under
+198. Attached as Exhibit 250 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM060812,
+designated confidential pursuant to the Protective Order in this matter and filed under
+199. Attached as Exhibit 251 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM020484,
+designated confidential pursuant to the Protective Order in this matter and filed under
+200. Attached as Exhibit 252 is a true and correct copy of Exhibit 20 from the May 29, 2023
+deposition of Cecile de Jongh.
+201. Attached as Exhibit 253 is a true and correct copy of excerpts of the transcript from the
+May 26, 2023 deposition of Inais Borque.
+28
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 29 of 41
+202. Attached as Exhibit 254 is a true and correct copy of Exhibit 5 from the May 26, 2023
+deposition of Inais Borque, designated confidential pursuant to the Protective Order in
+this matter and filed under seal.
+203. Attached as Exhibit 255 is a true and correct copy of Exhibit 37 from the March 15,
+2023 deposition of Mary Erdoes.
+204. Attached as Exhibit 256 is a true and correct copy of Exhibit 4 from the July 7, 2023
+deposition of Jean-Pierre Oriol, designated confidential pursuant to the Protective Order
+in this matter and filed under seal.
+205. Attached as Exhibit 257 is a true and correct copy of Exhibit 5 from the July 7, 2023
+deposition of Jean-Pierre Oriol, designated confidential pursuant to the Protective Order
+in this matter and filed under seal.
+206. Attached as Exhibit 258 is a true and correct copy of excerpts of the transcript from the
+July 7, 2023 deposition of Jean-Pierre Oriol, designated confidential pursuant to the
+207. Attached as Exhibit 259 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000061108, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+208. Attached as Exhibit 260 is a true and correct copy of Exhibit 10 from the July 13, 2023
+deposition of Carol
+209. Attached as Exhibit 261 is a true and correct copy of excerpt of the transcript from the
+July 18, 2023 deposition of Shani Pinney, designated confidential pursuant to the
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 30 of 41
+210. Attached as Exhibit 262 is a true and correct copy of excerpts of the transcript from the
+July 20, 2023 deposition of Denise
+, designated confidential pursuant to the
+211. Attached as Exhibit 263 is a true and correct copy of excerpts of the transcript from the
+July 12, 2023 deposition of Carol
+, designated confidential pursuant to
+the Protective Order in this matter and filed under seal.
+212. Attached as Exhibit 264 is a true and correct copy of excerpts of the transcript from the
+July 17, 2023 deposition of Denise
+, designated confidential pursuant to the
+213. Attached as Exhibit 265 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016557,
+designated confidential pursuant to the Protective Order in this matter and filed under
+214. Attached as Exhibit 266 is a true and correct copy of excerpts of the transcript from the
+July 13, 2023 deposition of Vincent Frazer, designated confidential pursuant to the
+215. Attached as Exhibit 267 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM024492,
+designated confidential pursuant to the Protective Order in this matter and filed under
+216. Attached as Exhibit 268 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM024494,
+30
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 31 of 41
+designated confidential pursuant to the Protective Order in this matter and filed under
+217. Attached as Exhibit 269 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM030223,
+designated confidential pursuant to the Protective Order in this matter and filed under
+218. Attached as Exhibit 270 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM030225,
+designated confidential pursuant to the Protective Order in this matter and filed under
+219. Attached as Exhibit 271 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM030228,
+designated confidential pursuant to the Protective Order in this matter and filed under
+220. Attached as Exhibit 272 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM025221,
+designated confidential pursuant to the Protective Order in this matter and filed under
+221. Attached as Exhibit 273 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM030179,
+designated confidential pursuant to the Protective Order in this matter and filed under
+31
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 32 of 41
+222. Attached as Exhibit 274 is a true and correct copy of Exhibit 1 to the July 18, 2023
+deposition of Shani Pinney.
+223. Attached as Exhibit 275 is a true and correct copy of the legacy file copy of the Act No.
+7372, Bill No. 29-0239, Twenty-Ninth Legislature of The Virgin Islands, Regular
+Session, 2012, available at
+https://stthomassource.com/legacy_files/userfiles/file/vetoed%20bills%2071912/Act%2
+0No_%207372%20-%20Bill%20No_%2029-0239.pdf.
+224. Attached as Exhibit 276 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM025227,
+designated confidential pursuant to the Protective Order in this matter and filed under
+225. Attached as Exhibit 277 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015021,
+designated confidential pursuant to the Protective Order in this matter and filed under
+226. Attached as Exhibit 278 is a true and correct copy of Bill 0444, a bill passed in the
+United States Virgin Islands in 2012.
+227. Attached as Exhibit 279 is a true and correct copy of excerpts of a document produced
+by Plaintiff the Government of the United States Virgin Islands,
+stamped VI-
+JPM-000012237, designated confidential pursuant to the Protective Order in this matter
+and filed under seal.
+32
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 33 of 41
+228. Attached as Exhibit 280 is a true and correct copy of excerpts of a document produced
+by Plaintiff the Government of the United States Virgin Islands,
+stamped VI-
+JPM-000012328.
+229. Attached as Exhibit 281 is a true and correct copy of 14 Virgin Islands Code
+§ 1721B(a)(1).
+230. Attached as Exhibit 282 is a true and correct copy of produced by Plaintiff the
+Government of the United States Virgin Islands,
+stamped VI-JPM000012616,
+designated confidential pursuant to the Protective Order in this matter and filed under
+231. Attached as Exhibit 283 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands, |
+stamped VI-JPM-
+000087959, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+232. Attached as Exhibit 284 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016129,
+designated confidential pursuant to the Protective Order in this matter and filed under
+233. Attached as Exhibit 285 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM025693,
+designated confidential pursuant to the Protective Order in this matter and filed under
+234. Attached as Exhibit 286 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM044489,
+33
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 34 of 41
+designated confidential pursuant to the Protective Order in this matter and filed under
+235. Attached as Exhibit 287 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016521,
+designated confidential pursuant to the Protective Order in this matter and filed under
+236. Attached as Exhibit 288 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015782,
+designated confidential pursuant to the Protective Order in this matter and filed under
+237. Attached as Exhibit 289 is a true and correct copy of excerpts of the June 16, 2023
+Expert Report of Bridgette Carr, designated confidential pursuant to the Protective
+Order in this matter and filed under seal.
+238. Attached as Exhibit 290 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM024879,
+designated confidential pursuant to the Protective Order in this matter and filed under
+239. Attached as Exhibit 291 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016458,
+designated confidential pursuant to the Protective Order in this matter and filed under
+240. Attached as Exhibit 292 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016316,
+34
+
+
+Case 1:22-cV-10904-JSR Document 265 Filed 08/07/23 Page 35 of 41
+designated confidential pursuant to the Protective Order in this matter and filed under
+241. Attached as Exhibit 293 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM025196,
+designated confidential pursuant to the Protective Order in this matter and filed under
+242. Attached as Exhibit 294 is a true and correct copy of a document produced by third
+stamped ESTATE _JPM024114,
+designated confidential pursuant to the Protective Order in this matter and filed under
+243. Attached as Exhibit 295 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM024119,
+designated confidential pursuant to the Protective Order in this matter and filed under
+244. Attached as Exhibit 296 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM020206,
+designated confidential pursuant to the Protective Order in this matter and filed under
+245. Attached as Exhibit 297 is a true and correct copy of the travel website of the U.S.
+Department of State regarding student visas, available at
+https://travel.state.gov/content/travel/en/us-visas/study/student-visa.html.
+246. Attached as Exhibit 298 is a true and correct copy of a document produced by third
+stamped ESTATE_JPMO20983,
+35
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 36 of 41
+designated confidential pursuant to the Protective Order in this matter and filed under
+247. Attached as Exhibit 299 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM064398,
+designated confidential pursuant to the Protective Order in this matter and filed under
+248. Attached as Exhibit 300 is a true and correct copy of a document produced by third
+stamped ESTATE_JPMO22289,
+designated confidential pursuant to the Protective Order in this matter and filed under
+249. Attached as Exhibit 301 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM029515,
+designated confidential pursuant to the Protective Order in this matter and filed under
+250. Attached as Exhibit 302 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM055329,
+designated confidential pursuant to the Protective Order in this matter and filed under
+251. Attached as Exhibit 303 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM059347,
+designated confidential pursuant to the Protective Order in this matter and filed under
+36
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 37 of 41
+252. Attached as Exhibit 304 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000087870, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+253. Attached as Exhibit 305 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM023450,
+designated confidential pursuant to the Protective Order in this matter and filed under
+254. Attached as Exhibit 306 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015784,
+designated confidential pursuant to the Protective Order in this matter and filed under
+255. Attached as Exhibit 307 is a true and correct copy of Exhibit 19 from the May 29, 2023
+deposition of Cecile de Jongh, designated confidential pursuant to the Protective Order
+in this matter and filed under seal.
+256. Attached as Exhibit 308 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM021434,
+designated confidential pursuant to the Protective Order in this matter and filed under
+257. Attached as Exhibit 309 is a true and correct copy of a document produced by third
+stamped ESTATE_JPMO15122,
+designated confidential pursuant to the Protective Order in this matter and filed under
+37
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 38 of 41
+258. Attached as Exhibit 310 is a true and correct copy of Plaintiff the Government of the
+United States Virgin Islands' Second Amended Complaint, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+259. Attached as Exhibit 311 is a true and correct copy of excerpts from the transcript of the
+May 26, 2023 deposition of Margarita
+260. Attached as Exhibit 312 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000017983.
+261. Attached as Exhibit 313 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000018005.
+262. Attached as Exhibit 314 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000019063.
+263. Attached as Exhibit 315 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM016245,
+designated confidential pursuant to the Protective Order in this matter and filed under
+264. Attached as Exhibit 316 is a true and correct copy of excerpts of a document produced
+by Plaintiff the Government of the United States Virgin Islands,
+stamped VI-
+JPM-000013479, designated confidential pursuant to the Protective Order in this matter
+and filed under seal.
+38
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 39 of 41
+265. Attached as Exhibit 317 is a true and correct copy of a document produced by Mark
+Paneth,
+stamped MP-00001858, designated confidential pursuant to the
+266. Attached as Exhibit 318 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000023078.
+267. Attached as Exhibit 319 is a true and correct copy of a document produced by Plaintifi
+000023091.
+stamped VI-JPM-
+268. Attached as Exhibit 320 is a true and correct copy of excerpts from the May 17, 2023
+deposition of Sandra Bess.
+269. Attached as Exhibit 321 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM015014,
+designated confidential pursuant to the Protective Order in this matter and filed under
+270. Attached as Exhibit 322 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM018432,
+designated confidential pursuant to the Protective Order in this matter and filed under
+271. Attached as Exhibit 323 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000022897.
+39
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 40 of 41
+272. Attached as Exhibit 324 is a true and correct copy of a document produced by third
+stamped ESTATE_JPM055884,
+designated confidential pursuant to the Protective Order in this matter and filed under
+273. Attached as Exhibit 325 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000016206.
+274. Attached as Exhibit 326 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000018885, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+275. Attached as Exhibit 327 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000016200, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+276. Attached as Exhibit 328 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000018918, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+277. Attached as Exhibit 329 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000018934, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+40
+
+
+Case 1:22-cv-10904-JSR Document 265 Filed 08/07/23 Page 41 of 41
+278. Attached as Exhibit 330 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000018551, designated confidential pursuant to the Protective Order in this matter and
+filed under seal.
+279. Attached as Exhibit 331 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000017233.
+280. Attached as Exhibit 332 is a true and correct copy of Exhibit 37 from the May 26, 2023
+deposition of Margarita
+281. Attached as Exhibit 333 is a true and correct copy of a document produced by Plaintiff
+stamped VI-JPM-
+000016492.
+282. Attached as Exhibit 334 is a true and correct copy of Exhibit 14 from the May 29, 2023
+deposition of Cecile de Jongh.
+283. Attached as Exhibit 335 is a true and correct copy of a document produced by JPMC,
+_stamped JPM-SDNYLIT-W-00008805, designated confidential pursuant to the
+Dated: August 7, 2023
+(s/ Felicia Ellsworth
+Felicia H. Ellsworth
+41

vision-fixhub/court-05/509e7628b81b8b6923d2718a51ceb2fbd47ab4e0c7f2b9b6ae6970c38e9bbf6f.receipt.json

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+  "engine": "marble-apple-vision",
+  "event_count": 43,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "34a89f2dd0ce4d813dbd19ef4d82311a47fa479874ffeed43a61a056d12fac59",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212.md

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+Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 1 of 5
+
+
+
+From:
+To:
+CC:
+Sent:
+Subject:
+Attachments:
+Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 2 of 5
+Bonnie K
+<bonnie.k.perry@jpmorgan.coms
+Paul V Morris <paul.v.morris@jpmorgan.coms
+PiJames Dalessio
+<James.Dalessio@jpmorgan.com>
+6/9/2010 10:16:07 PM
+Jeffrey Epstein
+Epstein Article - dtd. 6-9-2010.pdf; Epstein Article dtd. 5-27-2010.pdf
+Hi Paul -
+I have regressed the DDR back to you for additional information.
+Redacted - Privileged
+DDR Name: Jeffrey Epstein ~
+DDR Link -> Notes://PPUSMC017/85256F64005749BC/6BCDEBE8A049C44485256E6F0063C802
+/5EE4238F2F8C2E1485256D2400745A6D
+Redacted - Privileged
+Please update the Transaction Profile/Expected account activity - specifically, please note monthly cash
+withdrawal activity, ranging $30k to $50k and the purpose of these cash withdrawals.
+Please update the summary to include the client's current personal circumstances, business activities,
+etc. I have attached a couple of articles to assist.
+Further, please update the "Financial Trust Company Inc." DDR - last update 2003. This entity holds the bulk of
+the wealth held for Mr. Epstein within the relationship.
+DDR Name: Financial Trust Company, Inc. ~
+DDR link -> Notes://PPUSMC017/85256F64005749BC/58A38C458E8182CD8525727C0067562D
+(26A36B1774A08A5485256D240076F422
+Since this is a BVI entity, please ensure that you obtain evidence of tax declaration (e.g., a statement from
+the lawyer / accountant and 5 yrs of tax statements).
+3 entities within the relationship do not currently have DDRs. Please create DDRs for the following entities:
+• 116 East 65th St LLC
+• NES, LLC
+• Zorro Trust
+If you have any questions, please feel free to contact either me or Jim Dalessio.
+Thanks,
+Bonnie
+Bonnie K
+, VP, CAMS | Private Bank Risk Ngut & Control
+712 Main, tl Fl, Houston, TX 77002 (TX2-N045)
+Tel: 713.216-5136
+Fax: 713.216-7970
+
+WIT:
+DATE: 4-77
+C. Campbell, ADR CRR CSR #13921
+
+JPM-SDNYLIT-00008237
+
+
+Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 3 of 5
+DOWIONES.
+Local
+ATTORNEYS SETTLE FEE DISPUTE WITH BILLIONAIRE LAW FIRM HAD SOUGHT MONEY FOR
+LEGAL BILLS FROM SEX OFFENDER
+y Jane Musgrave The Palm Beach Post
+314 words
+9 June 2010
+South Florida Sun-Sentinel
+FLSS
+Palm Beach
+3B
+English
+Copyright 2010, South Florida Sun-Sentinel. All Rights Reserved.
+A men Who claimed he Pal leach rese of sexual buse pise is apparenty who represented 15
+in court papers filed late Monday, attorneys representing Miami law firm Podhurst Orseck said a settlemen
+had been reached with Epstein.
+Terms of the agreement weren't spelled out
+Podhurst Orseck filed suit against Epstein last month, claiming his refusal to pay its legal bill constituted a
+violation of an agreement the money manager signed to escape federal charges. As part of the 2007 plea
+deal, Epstein agreed to pay attorneys to negotiate settlements on behalf of the 33 women who told federal
+prosecutors he had paid them for sexually charged massages at his Palm Beach mansion when some were
+as young as 14.
+welve of the women sought the help of Podhurst partner Robert Josefsberg, who was appointed t
+legotiate settlements. He also represented three women in civil lawsuits that were also settled fo
+undisclosed amounts. About a dozen other women hired other attorneys to represent them. Most of those
+lawsuits are still pending.
+Epstein pleaded guilty to two sex-related charges and was released from the Palm Beach County jail in July
+after serving 13 months of an 18-month jail sentence. In return, federal prosecutors agreed not to pursue him
+for crimes that could have sent him to prison for decades.
+Billionaire sex offender Jeffrey Epstein had argued law fir inflated its costs. Photo(s)
+Document FLSS000020100609e6690003z
+
+2010 Factiva, Inc, All rights reserved.
+
+JPM-SDNYLIT-00008238
+
+
+Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 4 of 5
+DOWJONES
+A SECTION
+JUDGE ORDERS N.Y. PAPERI TO GIVE UP EPSTEIN TAPE
+y MICHELE DARGAN Daily News Staff Write
+29 word:
+1 May 2010
+alm Beach Daily New:
+PBDN
+DN1
+1A
+English
+Copyright 2010 The Palm Beach Daily News. All Rights Reserved.
+alm Beach Post File Photo hv LIma Sanghvi Jeffrey Epstein, shown in this 2008 file photo, spoke to 'Nev
+York Dailyi News' reporter
+Rush on tape. Since Epstein has asserted his Fifth Amendment privileg
+in depositions, the taped conversation is the only way! the jury can hear Epstein in his own words, attorneys
+for client Jane Doel say.
+The New York Daily News must turn over a tape-recorded interview between reporter
+Rush and sex
+offender Jeffrey Epstein because the information cannot be obtained anywhere else and outweighs
+reporter's privilege, a federal judge has ruled.
+Attorneys Brad
+and Paul Cassell have been fighting to obtain the tape in representing their client
+Jane Doe, a minor at the time of Epstein's abuse. Since Epsiein has asserted his Fifth Amendment privilege
+in depositions, the taped conversation is the only way the jury can hear Epstein in his own words, the
+attorneys say.
+After listening to the 22-minute recording and reading the transcript, Manhattan U.S. District Judge
+McKenna agreed in his six-page ruling.
+Of particular relevance, McKenna noted "a statement included in the first full paragraph attributed to Mr.
+Epstein at page 15 of the transcript... the court finds that the materials at issue 'are not reasonably
+Portions of the recording can be used related to liability and damages, the ruling says.
+But whether the attorneys will have the tape in time for the start of their July 17 trial is still in question.
+The judge's order says the recording
+and transcript will be held in
+decided or the time to file a notice of appeal has expired.
+or under seal until any appeal is
+Ne're happy that the court agreed with our argument that this important evidence supporting Jane Doe
+ase can be presented to the jury," Cassell said by phone Tuesda
+Laura Handman, attorney for the New York Daily News, said they are appealing the decision.
+non-prosecution agreement.
+- mdargan@pbdailynews.com
+Document PBDN000020100602e65r0000d
+Page 1 of 2 2010 Factiva, Inc. All rights reserved.
+
+JPM-SDNYLIT-00008239
+
+
++
+Case 1:22-cV-10904-JSR Document 238-49 Filed 07/25/23 Page 5 of 5
+
+2010 Factiva, Inc. All rights reserved
+
+JPM-SDNYLIT-00008240

vision-fixhub/court-05/50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212.receipt.json

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+  "byte_delta": -150,
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+  "doc_id": "50c8bd2a5015d5c5ae1ed92b0c4855e830a4978f8e95b044d1c3d865d558b212",
+  "engine": "marble-apple-vision",
+  "event_count": 13,
+  "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": "01b6a21f6e61741f620b8d8d17eb9c3a27ac8954a2bcda0861459be5432d746f",
+  "output_sha256": "ec9f3ea9abab59493a1e098d811b02e4b00cbbcca41887137de16f3a431ed387",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/50de972db3ef067a4576e51fef4a215f512aa90ac42dbc9f7b59149a6f88b1a8.md

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+1
+2
+3
+4
+5
+6
+7
+8
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+11
+12
+13
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+15
+16
+17
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+21
+22
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+24
+25
+Case 1:20-cr-00330-PAE Document 771
+Filed 08/10/22 Page 1 of 7
+LCMCMAXT
+3111
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+-x
+UNITED STATES OF AMERICA,
+V.
+20 CR 330 (AJN)
+GHISLAINE MAXWELL,
+Defendant.
+-x
+Before:
+HON. ALISON J. NATHAN,
+Jury Trial
+New York, N.Y.
+December 22, 2021
+3:41 p.m.
+District Judge
+APPEARANCES
+DAMIAN
+United States Attorney for the
+Southern District of New York
+BY: MAURENE COMEY
+ALISON MOE
+LARA POMERANTZ
+ANDREW ROHRBACH
+Assistant United States Attorneys
+HADDON |
+AND
+Attorneys for Defendant
+BY: JEFFREY S. PAGLIUCA
+LAURA A. MENNINGER
+-and-
+BOBBI C. STERNHEIM
+-and-
+& GRESSER
+BY:
+CHRISTIAN R. EVERDELL
+Also Present: Amanda Young, FBI
+Paul Byrne, NYPD
+
+
+1
+2
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+4
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+13
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+21
+22
+23
+24
+25
+Case 1:20-cr-00330-PAE |
+Document 771 Filed 08/10/22 Page 2 of 7
+LCMCMAXT
+3112
+(Jury not present)
+THE COURT: Good afternoon, everyone. We haven't
+heard anything from the jury, so I think it is time to consider
+putting in a note regarding tomorrow since we don't have a
+response on that. So the note I have drafted, with your input,
+let me know,
+"Hello, jury. If your deliberations are not
+completed today, do you wish to deliberate tomorrow, Thursday,
+December 23rd?" And then I have a box for "yes" and a box for
+"no." "Please check yes or no. If yes, what time would you
+like to deliberate from? Blank a.m. to blank p.m. Judge
+Nathan."
+Any thoughts or requests?
+MS. COMEY: Seems perfect.
+MS. STERNHEIM: Fine. Thank you.
+THE COURT: What I'll do is we'll send that in and I
+think everybody just wait, my assumption is it will come right
+back out and we'll reconvene. I'll see you in a moment.
+(Recess)
+THE COURT: As that went in, a note came out. So I
+don't have a response yet, but I have a note.
+"May we please have the following testimonies in a
+binder." The first one is Jane, Wong, Kate. There is
+something else written next to Jane.
+MS. STERNHEIM: Judge, I'm not reading the note, but
+they got Jane. It wasn't in a binder.
+
+
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+23
+24
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+Case 1:20-cr-00330-PAE|
+LCMCMAXT
+Document 771 Filed 08/10/22 Page 3 of 7 3113
+THE COURT: Well, fair enough. Fair enough. I don't
+know if they're asking for another copy.
+MS. STERNHEIM: Or with holes in it, at least.
+THE COURT: I'll show it to you there. Next to Jane,
+it says --
+. I think maybe, Ms. Sternheim, you've intuited.
+In parentheses, it says, "Being returned," crossed out, and
+then it says, "No."
+MS. STERNHEIM: Judge, of the three testimonies they
+got, Jane was the last and it was Juan in a binder. The other
+two were in binders.
+THE COURT: I see.
+I see. I didn't know that.
+MS. STERNHEIM: It was in the rush of trying to get it
+to them quickly.
+THE COURT: Well, we could dispute that, but -- so I
+guess, because they didn't return it, I guess they are asking
+for another copy, three-hole punched and in a binder, in
+addition, Juan and Kate. My clerk will show you the note if
+you'd like to see it.
+MS. COMEY: That's fine, your Honor. I believe
+Ms. Drescher is going to print out those transcripts right now
+with the agreed-upon redactions and we'll hole punch them and
+put them in binders.
+THE COURT: Okay. I think the response is coming out,
+so we'll just sit tight for a minute.
+(Pause)
+
+
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+Case 1:20-cr-00330-PAE
+Document 771 Filed 08/10/22 Page 4 of 7
+LCMCMAXT
+3114
+The response is, "No, thank you." Asterisk, "Jurors
+have made plans for tomorrow."
+So, we will get them what they've asked for as quickly
+as possible. And then, everyone, please be ready to go at
+4:25.
+We'll bring them out for dismissal.
+I had one quick additional point I wanted to make
+about the request yesterday for the question regarding Annie's
+testimony and the request from the defense was to also put in
+the limiting instruction. I wanted to note that the limiting
+instruction went in on the transcript of Annie's testimony, as
+well. So they did have that.
+All right. Anything to address, Ms. Comey?
+MS. COMEY: No, your Honor.
+THE COURT: Ms. Sternheim?
+MS. STERNHEIM: No, thank you.
+THE COURT: We'll see everyone at 4:25 unless we hear
+anything further. As soon as you have the materials, give them
+to
+• please. Thank you.
+(Recess)
+THE COURT: Any matters to take up before we bring
+them to dismiss them?
+MS. COMEY: No, your Honor.
+MS. STERNHEIM: No, thank you.
+THE COURT: Okay. Bring in the jury, please.
+(Continued on next page)
+
+
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+Case 1:20-cr-00330-PAE
+Document 771 Filed 08/10/22 Page 5 of 7
+LCMCMAXT
+3115
+(Jury present)
+THE COURT: Thank you, members of the jury. I did get
+your note that you declined my invitation to deliberate
+tomorrow.
+We had assumed trial would be proceeding and I
+wanted to give you the option to deliberate tomorrow, but
+understand you have plans.
+We will resume Monday at 9:00 a.m. Same instructions
+as previously indicated. As soon as all 12 of you are there,
+you may deliberate. Before then, please wait until all 12 of
+you are there.
+Please stay safe over the long weekend. Obviously
+we've got the variant and I need all of you here and healthy on
+Monday. So please take good care and take cautions.
+Somewhat related to that, the district is going to
+announce some new protocols on Monday, including specific mask
+requirements. So the district is going to require everybody to
+wear either N95s or KN95s or KF94s to be in the courthouse.
+We'll supply those for you. We'll have supplies on Monday.
+You're also welcome to take some for the long weekend if you'd
+like those to help be cautious.
+It's a long weekend, it's a holiday, it's imperative
+that you continue to follow my orders regarding the rules in
+this case as I know that you have, but I have to repeat it.
+It's critical that you, outside of deliberations, don't discuss
+this case with each other or anyone else. No consumption of
+
+
+1
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+3
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+14
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:20-cr-00330-PAE
+Document 771 Filed 08/10/22 Page 6 of 7
+LCMCMAXT
+any media of any kind through any means about the case and no
+communications through any means about the case.
+Continue to
+keep an open mind until you resume your deliberations on
+Monday, the 12 of you.
+If you have any issues that arise regarding either
+COVID or any issues of concern, you contact
+and
+she'11 communicate to me if there are any issues.
+I wish you a very happy holiday, a restful time with
+your families, and we'll see you on Monday.
+Thank you so much.
+Happy holidays.
+(Continued on next page)
+3116
+
+
+1
+2
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+8
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+11
+12
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+14
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+16
+17
+18
+19
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+21
+22
+23
+24
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+Case 1:20-cr-00330-PAE|
+LCMCMAXT
+Document 771 Filed 08/10/22 Page 7of7
+3117
+(Jury not present)
+THE COURT: Any matters to take up, counsel?
+MS. COMEY: No. Thank you, your Honor.
+MS. STERNHEIM: No. Thank you.
+THE COURT: You heard the announcement that's about to
+be forthcoming regarding the masking rules. So that will be
+true for everyone.
+Come Monday, we'll have supplies if needed.
+And please take my words of caution, as well. I need -- well,
+I don't need all of you, but I need most of you back here on
+Monday. In the meantime, happy holidays. See you Monday.
+(Adjourned to December 27, 2021 at 9:00 a.m.)
+* * *

vision-fixhub/court-05/50de972db3ef067a4576e51fef4a215f512aa90ac42dbc9f7b59149a6f88b1a8.receipt.json

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+  "byte_delta": -428,
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+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/50e1f78247043993240a647ff46598f7d6e3d705822d3028cb7d10088315acd3.md

@@ -0,0 +1,20 @@
+Case 1:22-cV-10904-JSR Document 265-67 Filed 08/07/23 Page 1 of 2
+
+
+
+Case 1:22-cV-10904-JSR Document 265-67 Filed 08/07/23 Page 2 of 2
+Armine, Cynthia[cynthia.armine@jpmchase.com]; Cutler, Stephen
+M[stephen.m.cutler@jpmorgan.com]; Shenker, Nina O[nina.o.shenker@jpmorgan.com]; Dellosso,
+Donna[Donna.Dellosso@jpmorgan.com]
+Duffy, John Rljohn.r.duffy@jpmorgan.com]; Dilorio, Phil[phil.diiorio@jpmorgan.com]
+From: Erdoes, Mary E|/O=CORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP
+(FYDIBOHF23SPDLT/CN=RECIPIENTS/CN=MARY.ERDOES]
+Fri 8/9/20139:14:57 PM (UTC)
+Subject: Privileged and confidential follow up
+Re our client exit, the conversation went well and was very professional. I suspect the call last night
+might have helped.
+It will move in an orderly process.
+John did an excellent job.
+ME
+
+JPM-SDNYLIT-00150176

vision-fixhub/court-05/50e1f78247043993240a647ff46598f7d6e3d705822d3028cb7d10088315acd3.receipt.json

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+  "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\"]",
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+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191.md

@@ -0,0 +1,938 @@
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 1 of 30
+IN THE UNITED STATES DISTRICT COURT FOR THE
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE, individually and on behalf of
+all others similarly situated,
+Plaintiff,
+V.
+JPMORGAN CHASE BANK, N.A.
+Defendant/Third-Party Plaintiff.
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS,
+Plaintiff,
+JPMORGAN CHASE BANK, N.A.
+Defendant/Third-Party Plaintiff.
+JPMORGAN CHASE BANK, N.A.
+Third-Party Plaintiff,
+Case Number: 1:22-cv-10019-JSR
+Case Number: 1:22-cv-10904-JSR
+JAMES EDWARD STALEY
+Third-Party Defendant.
+THIRD-PARTY DEFENDANT JAMES STALEY'S
+MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 2 of 30
+TABLE OF CONTENTS
+PRELIMINARY STATEMENT
+1
+BACKGROUND
+..2
+LEGAL STANDARD
+6
+ARGUMENT..
+...7
+I. The Indemnity and Contribution Claims (Counts I and II) Fail as a Matter of Law
+.. 7
+A.
+JPMorgan's Shotgun Pleading Warrants Dismissal of Counts I and II
+...7
+B.
+There Is No Right To Indemnity or Contribution Under the TVPA
+8
+C. JPMorgan's Indemnification Claim Fails for Additional Reasons.
+11
+i. Mr. Staley's Contractual Indemnity Precludes Common Law Indemnity Here... 12
+ii. JPMorgan Fails To State a Claim for Indemnification Because USVI and Doe
+Seek To Hold JPMorgan Directly, Not Vicariously, Liable
+13
+ili. JPMorgan's Indemnification Claim Fails Because JPMorgan's Alleged
+Misconduct Was Outside the Scope of Mr. Staley's Responsibilities
+D. JPMorgan's Contribution Claim Fails
+14
+15
+16
+E. JPMorgan Cannot Receive Contribution for Punitive Damages
+II. Because the Indemnity and Contribution Claims Fail, the Employment Claims Should Be
+Dismissed For Non-Compliance with Rule 14
+III. The Employment Claims Fail on the Merits
+A. The Employment Claims Are Time-Barred
+B.
+The Employment Claims Are Improperly Pleaded
+i. JPMorgan Fails to State a Claim for Breach of Fiduciary Duty
+18
+18
+. 20
+• 21
+ii. JPMorgan Fails to State a Claim Under the Faithless Servant Doctrine
+... 23
+CONCLUSION
+. 25
+ii
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 3 of 30
+TABLE OF AUTHORITIES
+CASES
+Access 4 All, Inc. v. Trump Int'l Hotel & Tower Condo.,
+2007 WL 633951 (S.D.N.Y. Feb. 26, 2007)
+ALP, Inc. v. Moskowitz, 167 N.Y.S.3d 45 (Ist Dep't 2022)
+V.
+, 397 F.3d 515 (7th Cir. 2005)
+v. Loc. Union No. 3, 751 F.2d 546 (2d Cir. 1984)..
+Aozora Bank Ltd. v. Deutsche Bank Sec., 29 N.Y.S.3d 10 (Ist Dep't 2016).
+Ashcroft v. Iqbal, 556 U.S. 662 (2009)...
+Babbitt v. Koeppel Nissan, Inc., 2020 WL 3183895 (E.D.N.Y. June 15, 2020)
+Barmapov v. Amuial, 986 F.3d 1321 (11th Cir. 2021) ...
+Baron v. Grant, 852 N.Y.S. 374 (2d Dep't 2008)
+Bd. of Managers of the 125 N. 10th Condo. v. 125North10, LLC,
+55 N.Y.S.3d 374(2d Dep't 2017).........
+Bellis v. Tokio Marine & Fire Ins. Co., 2002 WL 193149 (S.D.N.Y. Feb. 7, 2002)
+Cannariato v. Cannariato, 24 N.Y.S.3d 214 (2d Dep't 2016)..
+Cisse v. Annucci, 2022 WL 1183274 (N.D.N.Y. Apr. 21, 2022) ..
+v. S.A.C. Trading Corp., 711 F.3d 353 (2d Cir. 2013).
+Corley v. Country Squire Apartments, Inc., 80 N.Y.S.2d 900 (2d Dep't 2006).
+Don Prods./Kingvision v. I
+1. 950 F. Supp. 286 (E.D. Cal. 1996)
+Ebel v. G/O Media, Inc., 2021 WL 2037867 (S.D.N.Y. May 21, 2021)
+Ellul v. Congregation of Christian Bros., 774 F.3d 791 (2d Cir. 2014)
+Felice v. Delporte, 524 N.Y.S.2d 919 (4th Dep't 1988).
+Feltenstein v. City Sch. Dist. of New Rochelle,
+2015 WL 10097519 (S.D.N.Y. Dec. 18, 2015).
+Genesee/Wyoming YMCA v. Bovis Lend Lease LMB, Inc.,
+951 N.Y.S.2d 768 (4th Dep't 2012).....
+10
+18,19
+8,10
+.. 8
+19
+6
+7,22
+8
+14
+13
+15
+19
+8
+...7
+14
+.. 7
+24,25
+18
+17
+...9
+13
+iii
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 4 of 30
+Grewal v. Cuneo, 2016 WL 308803 (S.D.N.Y. Jan. 25, 2016)
+Herman v. RSR Sec. Servs. Ltd., 172 F.3d 132 (2d Cir. 1999).
+Honeywell, Inc. v. J.P. Maguire Co., 1999 WL 102762 (S.D.N.Y. Feb. 24, 1999)
+In re Bernard L. Madoff Inv. Sec. LLC., 721 F.3d 54 (2d Cir. 2013).
+25
+8,10
+12
+. 8
+Kramer v. Time Warner Inc., 937 F.2d 767 (2d Cir. 1991).
+Lamela v. Verticon, Ltd., 128 N.Y.S.3d 91 (3d Dep't 2020)
+..3
+12,13
+. 23
+Laub v. Faessel, 745 N. Y.S.2d 534 (Ist Dep't 2002).
+Le Metier Beauty Inv. Partners LLC v. Metier Tribeca, LLC,
+2015 WL 7078641 (S.D.N.Y. Nov. 12, 2015)...
+Levy v. Young Adult Inst., Inc., 103 F. Supp. 3d 426 (S.D.N.Y. 2015)
+Litle v. Arab Bank, PLC, 611 F. Supp. 2d 233 (E.D.N.Y. 2009)...
+McCarthy v. Turner Constr., Inc., 953 N.E.2d 794 (N.Y. 2011).
+v. Levi & Korsinsky, LLP, 2021 WL 535599 (S.D.N.Y. Feb. 12, 2021)...
+Nassau Roofing & Sheet Metal Co. v. Facilities Dev. Corp., 523 N.E.2d 803 (N.Y. 1988)
+Neurological Surgery, P.C. v. MLMIC Ins. Co., 175 N. Y.S.3d 266 (2d Dep't 2022)...
+. 17
+19,20,21
+• 10
+13
+..25
+16
+Noble v. Weinstein, 335 F. Supp. 3d 504 (S.D.N.Y. 2018) ..
+.9
+Nw. Airlines, Inc. v. Transp. Workers Union of Am., 451 U.S. 77 (1981).
+9,10,11
+Paulsen v. Stifel, Nicolaus & Co., 2019 WL 2415213 (S.D.N.Y. June 4, 2019).
+3
+Petrosurance, Inc. v. Nat'l Ass'n of Ins. Comm'rs, 888 F. Supp. 2d 491 (S.D.N.Y. 2012).
+Phansalkar v. Andersen Weinroth & Co., L.P.., 344 F.3d 184 (2d Cir. 2003).
+Poller v. BioScrip, Inc., 974 F. Supp. 2d 204 (S.D.N.Y. 2013).
+Rombach v. Chang, 355 F.3d 164 (2d Cir. 2004).
+Rubio v. BSDB Mgmt. Inc., 2021 WL 102651 (S.D.N.Y. Jan. 12, 2021).
+Scalia v. Emp. Sols. Staffing Grp., LLC, 951 F.3d 1097 (9th Cir. 2020)
+Sea Trade Mar. Corp. v. Coutsodontis, 744 F. App'x 721 (2d Cir. 2018)
+..6
+24,25
+22
+.20
+21,24
+11
+23
+Serv. Sign Erectors Co. v. Allied Outdoor Advert., Inc., 573 N. Y.S.2d 513 (Ist Dep't 1991)..... 12
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 5 of 30
+Starr Int'l Co. v. Fed. Rsrv. Bank of N.Y., 906 F. Supp. 2d 202 (S.D.N.Y. 2012)
+State Nat'l Ins. Co. v. Certain Interested Underwriters at Lloyd's London,
+2022 WL 4547444 (S.D.N.Y. Sept. 29, 2022).
+Tex. Indus., Inc. v. Radcliff Materials, Inc., 451 U.S. 630 (1981).
+Tobia v. United Grp. of Cos., Inc., 2016 WL 5417824 (N.D.N.Y. Sept. 22, 2016).
+U.S. Fire Ins. Co. v. Raia, 942 N.Y.S.2d 543 (2d Dep't 2012)
+United States. ex rel. Kester v. Novartis Pharms. Corp.,
+23 F. Supp. 3d 242 (S.D.N.Y. 2014).......
+12
+17
+8,9,11
+. 22
+22
+Yukos Cap. S.A.R.L. v. L
+1, 977 F.3d 216 (2d Cir. 2020).
+Ziglar v. Abbasi, 582 U.S. 120 (2017).
+• 7,22
+21,23,24
+9
+Zino Davidoff S.A. v. Selective Distrib. Int'l Inc.., 2013 WL 1245974 (S.D.N.Y. Mar. 8, 2013)... 7
+Zohar CDO 2003-1, Ltd. v. Patriarch Partners, LLC,
+286 F. Supp. 3d 634 (S.D.N.Y.2017).....
+17,18
+STATUTES
+18 U.S.C. § 1591
+28 U.S.C. § 1367.
+N.Y. C.P.L.R. $ 213.
+N.Y. C.P.L.R. § 1401
+4,9
+17
+19
+15
+RULES
+Federal Rule of Civil Procedure 8
+Federal Rule of Civil Procedure 9(b)
+Federal Rule of Civil Procedure 10(b).
+Federal Rule of Civil Procedure 12(b)(6)
+Federal Rule of Civil Procedure 14
+Federal Rule of Civil Procedure 18
+Federal Rule of Evididence 201(b)(2) .
+7,8
+.. passim
+.. 7,8
+.. 6, 18
+16,17
+... 17
+... 3
+V
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 6 of 30
+PRELIMINARY STATEMENT
+In November 2022, Plaintiff Jane Doe sued JPMorgan Chase Bank, N.A. ("JPMorgan").
+Her complaint asserts that JPMorgan ignored Jeffrey's Epstein's sex-trafficking crimes to retain
+him as a lucrative banking client, which in turn enabled Epstein to victimize Doe and others. The
+Government of the U.S. Virgin Islands ("USVI") filed its own suit alleging that JPMorgan enabled
+Epstein to operate his enterprise out of its territory.
+Confronted with documented failures in its anti-money-laundering compliance (along with
+a history of such failures in other matters), JPMorgan sought to change the narrative and deflect
+blame by pulling Jes Staley, one of its former employees, into the two cases via two third-party
+complaints. The bank claims its fifteen-year-long relationship with Epstein was in fact all Mr.
+Staley's fault and that he must pay the plaintiffs' damages. JPMorgan further seeks to claw back
+years of compensation from Mr. Staley, plus damages for "harm" to its already-sullied reputation.
+But JPMorgan has failed to state any viable claim against Mr. Staley. Indeed, the thirdparty complaints, while creating provocative media fodder, never explain how an employee who
+is not alleged to have had decision-making authority over Epstein's accounts-and who is not
+alleged to have seen any of the suspicious account activity that other JPMorgan employees
+ignored caused the plaintiffs' alleged injuries.
+Each of JPMorgan's four claims is legally deficient. Neither the indemnification claim
+(Count I) nor contribution claim (Count II) is actionable.
+First, the indemnification and
+contribution claims fail because the bank engages in defective, shotgun pleading that improperly
+tries to combine multiple claims (all lacking) into two cursory counts. Second, the indemnification
+and contribution claims fail to the extent that they are based on the plaintiffs' claims under the
+Trafficking Victims Protection Act ("TVPA") because that statute does not permit contribution or
+1
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 7 of 30
+indemnification. Third, the indemnification claim fails because JPMorgan does not (and cannot)
+plausibly allege that its liability is solely attributable to Mr. Staley's conduct. Fourth, JPMorgan's
+contractual indemnification of Mr. Staley as one of its officers bars the bank's indemnification
+claim against him under black-letter New York law. Fifth, JPMorgan fails to identify any distinct
+injury for which it seeks contribution.
+The two additional claims—-alleging that Mr. Staley breached his fiduciary duty to the bank
+during his employment and violated the "faithless servant doctrine" ("Employment Claims" at
+Counts III and IV)— also fail as a matter of law. They do not meet the requirements for impleading
+under Rule 14. And, for various reasons, they are deficient on the merits.
+Whether or not JPMorgan is liable to Doe and the USVI remains to be seen. What is certain
+is that the bank cannot treat Mr. Staley as its publie relations shield by asserting claims that lack
+any legal (or factual) basis.
+BACKGROUND
+Third-Party Defendant James Edward "Jes" Staley is a former JPMorgan executive.' He
+began his career at the company in 1979 and
+up the ranks to the highest levels of management.
+See JPMorgan's Third-Party Compl. ("Complaint" or TPC"') 9| 16.- From 2001 to 2009, Mr. Staley
+was the Chief Executive Officer of the bank's Asset Management group. Starting in 2009, Mr.
+Staley moved to the Corporate and Investment Banking division, where he served as its Chief
+Executive Officer and reported to Jamie Dimon, the bank's President and Chairman. Id. Per its
+" Although he vigorously denies many of the allegations in this case, Mr. Staley treats as true the
+Third-Party Complaint's factual allegations for purposes of this motion.
+2 See 22-cv-10019, ECF No. 59, and 22-cv-10904, ECF No. 70. Although JPMorgan filed two
+third-party complaints, one in each of the cases by USVI and Doe, Mr. Staley addresses them
+together in this memorandum given their overwhelming overlap. Only when content from the
+complaints differ will this filing distinguish between them (e.g., "Doe TPC" or "USVI TPC").
+2
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 8 of 30
+bylaws, JPMorgan agreed to indemnify corporate officers such as Staley "to the fullest extent
+permitted by applicable law." Ex A at 7.3
+Mr. Staley left JPMorgan in January 2013, eventually joining its competitor Barclays as
+Chief Executive Officer. TPC 9|21. Upon departing JPMorgan, Mr. Staley allegedly signed an
+Agreement and Release in which he agreed to be bound by JPMorgan's code of conduct even after
+he left employment at the bank. Id.
+Since November 2022, JPMorgan has been embroiled in lawsuits relating to the bank's
+alleged involvement with Jeffrey Epstein and his sex-trafficking enterprise. These suits began
+when Plaintiff "Jane Doe" sued the bank on November 24, 2022, with the U.S. Virgin Islands
+filing a similar complaint about a month later.
+Doe's Allegations: Doe's class action complaint alleges that JPMorgan supplied the
+"financial lifeblood" of Epstein's sex trafficking enterprise by providing him and his associates
+banking services and access to exorbitant amounts of cash from 1998 through August 2013. First
+Am. Compl., 22-cv-10019 ("Doe FAC"') at 1-2, ECF No. 36. Doe claims that JPMorgan provided
+these services even though it knew that Epstein was engaged in sex trafficking. Id. While Doe
+alleges that JPMorgan's knowledge stemmed in part from what Mr. Staley observed, she alleges a
+plethora of other ways that JPMorgan knew of Epstein's misconduct completely independent of
+Mr. Staley's observations: (1) Epstein's widely reported arrest in 2006 that resulted in his
+incarceration and registering as a sex offender, id. I 42, 79-81, 190-99, 216; (2) Epstein's
+3 This Court can consider matters appropriate for judicial notice when reviewing this motion to
+dismiss. Kramer v. Time Warner Inc., 937 F.2d 767, 773 (2d Cir. 1991). JPMorgan's bylaws
+qualify because they are "not subject to reasonable dispute" and "can be accurately and readily
+determined from sources whose accuracy cannot reasonably be questioned." Fed. R. Evid.
+201(b)(2); see also Paulsen v. Stifel, Nicolaus & Co., 2019 WL 2415213, at *3 (S.D.N.Y. June 4,
+2019) ("Courts in this Circuit have routinely taken notice of public disclosure documents filed
+with the SEC that are proffered as part of [a] motion to dismiss.") (collecting cases).
+3
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 9 of 30
+involvement in civil lawsuits, which resulted in payments that were sent from JPMorgan bank
+accounts, id. 11 83, 200, 207-11; and (3) Epstein's suspicious transaction history that included
+large cash withdrawals, wires to women with Eastern European surnames, and payments to known
+conspirators, id. 11 182, 261-62. Doe alleges that she was trafficked by Epstein and unnamed
+associates. Id. 11| 159, 237.
+Doe also alleges that JPMorgan skirted banking regulations to conceal its involvement with
+the trafficking enterprise. Id. 1| 178. The bank, for example, neglected to file Suspicious Activity
+Reports (SARs) required by anti-money laundering laws and failed to adequately conduct "Know
+Your Customer" due diligence. Id. 11 180-82, 271. Doe alleges that, had the bank followed these
+standard practices, Epstein's conduct would not have flown under the radar for years. Id. 9 272.
+Awareness of Epstein's criminal conduct reached the bank's highest levels, including CEO Jamie
+Dimon, id. 911 216-17, and the CEO of private banking, Mary Erdoes, who nevertheless advocated
+to keep Epstein as a client, id. 19 161, 214. JPMorgan continued to serve Epstein for the financial
+benefits to the bank, such as access to his network of wealthy potential customers. Id. 19 164-71.
+Notably, Doe alleges that JPMorgan's misconduct extended beyond 2013—when Mr.
+Staley left the bank. In particular, JPMorgan refused to file SARs and continued to recommend
+Epstein as a client to others. Id. 4 187.
+Four of Doe's claims survived JPMorgan's motion to dismiss: (1) negligently failing to
+prevent physical harm; (2) negligently failing to exercise reasonable care as a banking institution
+providing non-routine banking; (3) knowingly benefitting from participating in a sex-trafficking
+venture in violation of 18 U.S.C. § 1591(a)(2); and (4) obstructing enforcement of the TVPA in
+violation of 18 U.S.C. § 1591(d). Order on Motion To Dismiss, 22-cv-10019, ECF No. 66.
+4
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 10 of 30
+USVI's Allegations: USVI's complaint makes similar allegations. It claims that JPMorgan
+provided financial services and cash to Epstein even though the bank knew of his sex trafficking
+through various means, including (1) Epstein's suspicious transactions, such as wires to victims,
+withdrawals of large sums of cash, and payments to known recruiters, see USVI First Am. Compl.,
+22-cv-10904 ("USVI FAC") 1142, 66-67, and (2) public reports of Epstein's arrest and
+misconduct, id. 11 36-40, 48. USVI alleges that internal messages at the bank show that JPMorgan
+employees were aware of these facts and that this knowledge reached the highest levels of the
+bank, including CEO Jamie Dimon, id. 11l 44-51, 86. And JPMorgan's failure to follow required
+banking practices permitted the sex trafficking conspiracy to operate. Id. 11 76-78, 82. Following
+the Court's order on JPMorgan's motion to dismiss, the only remaining claim brought by the USVI
+arises under the TVPA. Order on Motion To Dismiss, 22-cv-10904, ECF No. 90.4
+JPMorgan's third-party complaints: JPMorgan filed a third-party complaint in each case.
+Both complaints plead identical claims for common law indemnification, contribution, breach of
+fiduciary duty, and breach of the faithless servant doctrine.
+JPMorgan first brings omnibus claims for contribution and indemnification that seek to
+hold Mr. Staley liable for all of the claims that Doe and the USVI bring against JPMorgan, lumping
+together Doe's common law and federal statutory claims. JPMorgan alleges, despite contrary
+assertions in the plaintiffs' complaints, that the plaintiffs seek to hold the bank liable "based in
+substantial part on the acts or omissions of Staley." TPC 9| 46. Thus, it alleges, if JPMorgan is
+4 Despite the Court's dismissal order, USVI has filed a second amended complaint that repleads
+all the original claims (even those that were dismissed). This motion will address only the claim
+in the USVI's operative complaint that was not dismissed. While reserving all rights, Mr. Staley
+notes that, even if JPMorgan's complaint reached the repleaded claims, the same analysis would
+apply because there is no conflict between New York and Virgin Island law on contribution and
+indemnification.
+5
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 11 of 30
+held liable, then Mr. Staley must pay the bank "for all damages awarded" to the plaintiffs by means
+of indemnification and/or contribution. Id. I 48, 55.
+JPMorgan's claims for breach of fiduciary duty and breach of the faithless servant doctrine
+rely on the duties he owed the bank as an employee and his alleged agreement to abide by the
+bank's Code of Conduct, which he purportedly signed each year between 2006 and 2012, id. 19 18-
+19. JPMorgan alleges that Mr. Staley breached his duties by acting against the interests of the
+bank, "failing to report" or "fraudulently concealing" information about Epstein, "affirmatively
+misrepresent[ing]" facts about his personal interactions with Epstein, and "repeatedly provid[ing]
+misleading information to JPMC when vouching for Epstein's character and conduct." Id. 99| 59-
+61, 74-77. As for the breach-of-fiduciary-duty claim, JPMorgan seeks damages related to (1) the
+"cost of defending," and "adverse publicity from," these lawsuits, and (2) "any amounts in
+damages" that JPMorgan might have to pay out to the plaintiffs. Id. 9 64-65. For the faithless
+servant claim, JPMorgan seeks disgorgement of Mr. Staley's compensation from the amorphous
+"period of his disloyalty." Id. 91 78. The bank also seeks punitive damages. Id. 19 66, 79.
+LEGAL STANDARD
+Under Federal Rule of Civil Procedure 12(b)(6), "a complaint must contain sufficient
+factual matter, accepted as true, to state a claim to relief that is plausible on its face." Ashcroft v.
+Iqbal, 556 U.S. 662, 678 (2009) (internal quotation marks omitted). "A claim has facial
+plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable
+inference that the defendant is liable for the misconduct alleged." Id. While the Court must draw
+all reasonable inferences in the complaint's favor, it need not accept as true "mere conclusions of
+law or unwarranted deductions of fact." Petrosurance, Inc. v. Nat'l Ass'n of Ins. Comm'rs, 888 F.
+Supp. 2d 491, 502 (S.D.N.Y. 2012) (internal quotation marks omitted).
+6
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 12 of 30
+"Claims that sound in fraud are subject to the heightened pleading standards of" Rule 9(b).
+v. S.A.C. Trading Corp., 711 F.3d 353, 359 (2d Cir. 2013). Such allegations must be "stated
+with particularity," meaning that they must "specify the time, place, speaker, and content of [any]
+alleged misrepresentations," "explain how the misrepresentations were fraudulent," and "plead
+those events which give rise to a strong inference that the defendant had an intent to defraud,
+knowledge of the falsity, or a reckless disregard for the truth." Id. (cleaned up). In other words,
+"a plaintiff [must] set forth the who, what, when, where and how of" alleged fraudulent conduct.
+United States. ex rel. Kester v. Novartis Pharms. Corp., 23 F. Supp. 3d 242, 252 (S.D.N.Y. 2014).
+Rule 9(b) applies to fiduciary-duty claims that sound in fraud. Babbitt v. Koeppel Nissan, Inc.,
+2020 WL 3183895, at *5 (E.D.N.Y. June 15, 2020).
+ARGUMENT
+I. The Indemnity and Contribution Claims (Counts I and II) Fail as a Matter of Law.
+A. JPMorgan's Shotgun Pleading Warrants Dismissal of Counts I and II.
+As an initial matter, the claims for indemnification and contribution are procedurally
+improper because they violate Rules 8 and 10(b) by lumping together all of the plaintiffs"
+outstanding claims under singular causes of action for contribution and common law
+indemnification. For each of these claims, JPMorgan seeks relief under two distinct bodies of
+law—federal law for the plaintiffs' TVPA claims, and state law for Doe's common-law claims
+even though these claims require distinct analyses. See Don
+Prods./Kingvision v.
+950 F. Supp. 286, 288-89 (E.D. Cal. 1996) (noting that right to indemnity for claim arising under
+federal law must be treated separately from right relating to state-law claim); Zino Davidoff S.A.
+v. Selective Distrib. Int'l Inc., 2013 WL 1245974, at *4 (S.D.N.Y. Mar. 8, 2013) ("Whether a
+defendant who incurs liability under a federal statute may pursue either contribution or
+indemnification is a question of federal law."). This haphazard style of pleading is "flatly
+7
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 13 of 30
+forbidden by the spirit, if not the letter, of" Rules 8(a)(2) and 10(b), because, among other vices,
+it confuses the parties, courts, and factfinders and hinders cogent analysis of each claim
+independently. Barmapov v. Amuial, 986 F.3d 1321, 1324 (11th Cir. 2021) (citation omitted);
+Cisse v. Annucci, 2022 WL 1183274, at *2 (N.D.N.Y. Apr. 21, 2022) (identifying failure to
+separate "into a different count each cause of action or claim for relief" as "shotgun pleading"
+(citation omitted)). The Court should dismiss the indemnification and contribution claims for this
+reason alone.
+B. There Is No Right To Indemnity or Contribution Under the TVPA.
+JPMorgan's indemnification and contribution claims also fail to the extent that they seek
+to offload liability for the plaintiffs' TVPA damages because the TVPA does not permit claims for
+indemnification or contribution against third parties. When an underlying claim arises under
+federal law, "there is no claim for contribution [or indemnification] unless the operative federal
+statute provides one." In re Bernard L. Madoff Inv. Sec. LLC., 721 F.3d 54, 65 (2d Cir. 2013); see
+Herman v. RSR Sec. Servs. Ltd., 172 F.3d 132, 144 (2d Cir. 1999) (affirming dismissal of New
+York state-law claims for contribution and indemnification for liability under Fair Labor Standards
+Act). Such claims are available only through (1) "the affirmative creation of a right of action by
+Congress, either expressly or by clear implication," or (2) "the power of federal courts to fashion
+a federal common law of contribution [or indemnification]." Tex. Indus., Inc. v. Radcliff Materials,
+Inc., 451 U.S. 630, 638 (1981).S Yet courts have been particularly "reluctant to recognize a right
+of contribution [or indemnification] as a matter either of federal common law or of statute."
+, 397 F.3d 515, 523 (7th Cir. 2005) (collecting cases).
+5 While these cases address contribution, their "rationale •
+• extends to claims for
+indemnification."
+v. Loc. Union No. 3, 751 F.2d 546, 548 (2d Cir. 1984).
+8
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 14 of 30
+The TVPA does not mention contribution or indemnification. To determine whether a
+statute nonetheless contains an implied right, courts have traditionally looked to "the language of
+the statute itself, its legislative history, the underlying purpose and structure of the statutory
+scheme, and the likelihood that Congress intended to supersede or to supplement existing state
+remedies." Nw. Airlines, Inc. v. Transp. Workers Union of Am., 451 U.S. 77, 91 (1981). While
+the sole consideration is Congress's apparent intent, in recent decades the Supreme Court has
+signaled that courts should adopt "a far more cautious course before finding implied causes of
+action." See Ziglar v. Abbasi, 582 U.S. 120, 132 (2017).
+First, as mentioned, the TVPA provisions invoked by the plaintifis are completely silent
+on the issue. See generally 18 U.S.C. § 1591. This omission is "significant" given that Congress
+certainly knows how to unambiguously create such rights. See Nw. Airlines, 451 U.S. at 91-92 &
+n.24 (contrasting § 11(f) of the Securities Act of 1933, where Congress did so); Texas Indus., 451
+U.S. at 640, n.11 (same). And this silence rings loudly given that Congress has routinely amended
+the TVPA since its enactment in 2000 and yet has never included such rights. Simply put, if
+Congress had wanted to include indemnification and contribution, it would have.®
+Second, causes of action for contribution or indemnification would cut against the TVPA's
+mission to protect trafficking victims. Noble v. Weinstein, 335 F. Supp. 3d 504, 515 (S.D.N.Y.
+2018) (explaining that civil remedies portion of TVPA serves "the remedial purpose of *enhancing
+... protections of trafficking victims"') (quoting Trafficking Victims Protection Reauthorization
+" The Supreme Court has also suggested that the lack of an express right to contribution or
+indemnification can be "dispositive" unless "the language of the statutes indicates that they were
+enacted for the special benefit of a class of which petitioner is a member." Nw. Airlines, 451 U.S.
+at 91-92. Here, JPMorgan is not among the class that the TVPA is intended to protect, which
+consists of trafficking victims. Rather, it is the party "whose conduct the statute was intended to
+regulate." Feltenstein v. City Sch. Dist. of New Rochelle, 2015 WL 10097519, at *3 (S.D.N.Y.
+Dec. 18, 2015) (citation omitted) (rejecting indemnity and contribution under the ADA).
+9
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 15 of 30
+Act of 2003, 117 Stat. 2878, § 4 (effective Dec. 19, 2003)). As evident in this litigation, such
+claims serve to only to complicate and add expense to victims' suits. See Litle v. Arab Bank, PLC,
+611 F. Supp. 2d 233, 241 (E.D.N.Y. 2009) (finding right of contribution under Anti-Terrorism Act
+would not further goal of compensating victims of terrorism because it would add expense to
+litigation);
+397 F.3d at 523 ("[A]ll that a right of contribution does is add to the costs
+of litigation, and so unless there is a compelling reason to suppose that the legislature would want
+such a right to be enforced... it will not be." (citation omitted)). And to the extent that the statute
+is intended to deter would-be traffickers, permitting indemnification or contribution claims would
+undermine that purpose. See
+1, 397 F.3d at 523 (reasoning that absence of contribution
+or indemnification to divide damages among coconspirators itself "performs [a] deterrent
+function" for would-be violators who must risk being the unlucky one saddled with liability).
+Third, the TVPA's remedial scheme makes clear that Congress did not intend to include
+rights to contribution or indemnity. Courts have routinely cautioned against creating any federal
+common-law rights of indemnity or contribution in areas where Congress has created
+comprehensive legislative remedies." Access 4 All, Inc. v. Trump Int'l Hotel & Tower Condo.,
+2007 WL 633951, at *7 (S.D.N.Y. Feb. 26, 2007); Nw. Airlines, 451 U.S. at 93-94. The TVPA
+presents such a comprehensive scheme. Along with criminal punishments, it provides for various
+civil causes of action. And the "express provision for private enforcement in certain carefully
+defined circumstances ... strongly counsels against judicially engrafting additional remedies."
+Herman, 172 F.3d at 144. Indeed, it is not the Court's "place simply to alter the balance struck by
+Congress" in determining how damages should be apportioned. Nw. Airlines, 451 U.S. at 98.
+Fourth, the relevant legislative history in the TVPA is silent on indemnity and contribution,
+showing that Congress did not even contemplate, let alone intend, for such rights. Without express
+10
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 16 of 30
+language or even a hint of intent, "the essential predicate for implication of a private remedy simply
+does not exist" here. Id. at 94.
+Further, it would be improper to craft such a remedy from federal common law. The
+situations in which such judicial legislating is welcome are "few and restricted," Texas Indus., 451
+U.S. at 640, and they generally fall into one of two categories: (1) when "a federal rule is necessary
+to protect a uniquely federal interest," or (2) when "Congress has given the court the power to
+develop substantive law." Id. (cleaned up). Neither applies here. A defendant's "right of recovery
+from another [potential] wrongdoer ... does not implicate any [federal] interests." Scalia v. Emp.
+Sols. Staffing Grp., LLC, 951 F.3d 1097, 1105 (9th Cir. 2020). And there is no indication that
+Congress "has given the courts the power to develop substantive law" in the area of sex-trafficking
+enforcement, as it has in admiralty law, for example. Tex. Indus., 451 U.S. at 640.
+Since there is no hint that Congress intended for there to be a right of contribution or
+indemnification under the TVPA, and this issue does not implicate a federal interest or area of law
+expressly left to the courts to develop, the Court should not imply such causes of action here.
+JPMorgan's claims for indemnification and contribution arising under the TVPA—which include
+all of the claims alleged in the USVI FAC-therefore fail.
+C. JPMorgan's Indemnification Claim Fails for Additional Reasons.
+JPMorgan's claim for indemnification fails for three other reasons: (1) JPMorgan's
+contractual indemnity of Mr. Staley precludes any claim for common law indemnification in favor
+of the bank; (2) both Doe's and USVI's complaints allege that JPMorgan was directly, not
+11
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 17 of 30
+vicariously, liable for the misconduct; and (3) JPMorgan fails to allege that the decisions that
+caused plaintiffs' injuries were solely within Mr. Staley's province at the bank.?
+i. Mr. Staley's Contractual Indemnity Precludes Common Law Indemnity
+Here.
+Under black-letter New York law, contractual indemnity between parties flowing only in
+one direction extinguishes common law indemnity flowing in the other direction. Serv. Sign
+Erectors Co. v. Allied Outdoor Advert., Inc., 573 N.Y.S.2d 513, 514 (Ist Dep't 1991) ("With the
+subject of indemnification clearly contemplated and expressly addressed by ….. contract, we hold
+that under these circumstances there could only be a one-way obligation to indemnify by ... the
+indemnitor, and any reciprocal obligation is extinguished."); accord Lamela v. Verticon, Ltd., 128
+N.Y.S.3d 91, 94 (3d Dep't 2020) (collecting cases); Honeywell, Inc. v. J.P. Maguire Co., 1999
+WL 102762, at *6 (S.D.N.Y. Feb. 24, 1999).
+Here, JPMorgan agreed to indemnify Mr. Staley-as an officer and employee to the
+"fullest extent" permitted by law. Ex. A [Section 5.01 of 2004 Bylaws]. These bylaws serve as a
+contract between the company and its officers. But nowhere in the bylaws or otherwise did Mr.
+Staley agree to indemnify JPMorgan. Since the parties agreed that JPMorgan would indemnify
+Mr. Staley without a reciprocal right to indemnification for the bank, the common law
+indemnification claim benefitting JPMorgan is foreclosed.
+" Mr. Staley assumes that if the Court were to imply a cause of action for contribution and
+indemnification under the TVPA, it would find that New York state law supplies the rule of
+decision. See Starr Int'l Co. v. Fed. Rsrv. Bank of N.Y., 906 F. Supp. 2d 202, 233-34 (S.D.N.Y.
+2012). Since Doe's common law claims are likewise analyzed under New York law, the Cour
+an analyze the viability of these claims together
+12
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 18 of 30
+ii. JPMorgan Fails To State a Claim for Indemnification Because USVI and
+Doe Seek To Hold JPMorgan Directly, Not Vicariously, Liable.
+Even if common law indemnification were available, the claim still fails because the
+plaintiffs' complaints seek to hold the bank liable for its own actions, not as Mr. Staley's employer.
+Under New York law, a "party cannot obtain common-law indemnification unless it has been held
+to be vicariously liable without proof of any negligence ... on its own part." McCarthy v. Turner
+Constr., Inc., 953 N.E.2d 794, 801 (N.Y. 2011); see Lamela, 128 N.Y.S. 3d at 94 (common law
+indemnification is available only "in favor of' one who is held responsible solely by operation of
+law because of his [or her] relation to the actual wrongdoer'" (emphasis added) (citations
+omitted)); Bd. of Managers of the 125 N. 10th Condo. v. 125North10, LLC, 55 N.Y.S.3d 374, 376
+(2d Dep't 2017) (affirming dismissal of claim for common-law indemnification where party
+seeking indemnity's liability was not "purely vicarious" (emphasis added) (citation omitted)). In
+other words, indemnification claims are not cognizable where the purported indemnitee's "liability
+... in the [pending] main action" would be based on "its own" failures. Genesee/Wyoming YMCA
+v. Bovis Lend Lease LMB, Inc., 951 N.Y.S.2d 768, 771 (4th Dep't 2012) (citation omitted).
+Here, none of the plaintiffs' claims seeks to hold JPMorgan liable solely because it
+employed Mr. Staley. To the contrary, both Doe and USVI premise liability on JPMorgan's own
+alleged misconduct. Underlying the outstanding common law and federal law claims is the
+allegation that JPMorgan provided financial services to Epstein and his associates in furtherance
+of their trafficking enterprise.
+Doe FAC 11 313, 326, 350, 473-74; USVI FAC 19 6, 94. These
+services included, for example, allowing Epstein to withdraw large sums of cash without question.
+Doe FAC 911 326, 350, 474. Doe also alleges that JPMorgan failed to follow "AML and antistructuring reporting requirements found in the Bank[] Secrecy Act [BSA] and other laws," failed
+to "timely file with the federal government the required SARs that financial institutions must file
+13
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 19 of 30
+with FinCEN whenever there is a suspected case of money laundering or fraud," and "concealed
+from the federal government its numerous cash payments to... co-conspirators." Id. 91 474-79.
+The USVI makes similar allegations. USVI FAC 191 6, 76-77, 82, 87. There is no allegation that
+this conduct by JPMorgan was undertaken solely by (or even known to) Mr. Staley.
+The bank is solely responsible for those acts; nowhere is it alleged—in either the plaintiffs'
+complaints or JPMorgan's third-party complaints that Mr. Staley provided cash or participated
+in decision-making on BSA compliance. In fact, it is not even alleged that Mr. Staley was aware
+of Epstein's cash withdrawals or at all involved in the compliance function's consideration of
+whether the Epstein transactions breached banking laws. And even if he did, Doe's allegations
+regarding the bank's willful failure to follow regulations extends beyond 2013, when Mr. Staley
+was no longer working at the bank. Doe FAC | 187. Nor is it alleged that Mr. Staley had decisionmaking authority for Epstein's accounts such that he helped decide whether to keep Epstein as a
+client. In short, it is clear on the face of these complaints that the bank is not being sued as Mr.
+Staley's employer, but rather because it allegedly provided Epstein with the financial tools and
+cover to maintain his trafficking ring
+iii.
+JPMorgan's Indemnification Claim Fails Because JPMorgan's Alleged
+Misconduct Was Outside the Scope of Mr. Staley's Responsibilities.
+JPMorgan's claim for indemnification also fails because it seeks to hold Mr. Staley
+accountable for actions outside the scope of his responsibilities at the bank. Under New York law,
+indemnification is actionable only where the "injury was due solely to the [proposed indemnitor]'s
+negligent performance or nonperformance of an act solely within [his] province." Corley v.
+Country Squire Apartments, Inc., 80 N.Y.S.2d 900, 900 (2d Dep't 2006) (emphasis added); Baron
+v. Grant, 852 N.Y.S. 374, 374 (2d Dep't 2008) ("The party seeking indemnification must have
+delegated exclusive responsibility for the duties giving rise to the loss to the party from whom
+14
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 20 of 30
+indemnification is sought." (citation omitted)). Here, both USVI and Doe allege that they were
+injured by JPMorgan's decisions to retain Epstein as a client and to continue providing financial
+services that served as the "lifeblood" of his sex-trafficking scheme. Doe FAC 9| 193; USVI FAC
+9 94. They likewise claim that they were injured by JPMorgan's refusal to follow federal banking
+regulations. Doe FAC 11 326-27; USVI FAC 191 6, 76-77, 82, 87. JPMorgan has not pleaded that
+Mr. Staley had decision-making authority over Epstein's accounts or the compliance department,
+let alone that these were "solely within his province" at the bank. JPMorgan concedes this, alleging
+that the conduct it places at issue in the third-party complaints "were not in connection with the
+performance of [Mr. Staley's] duties for JPMC." TPC 9| 42. Thus, JPMorgan has failed to
+adequately plead indemnification.
+D. JPMorgan's Contribution Claim Fails.
+To state a claim for contribution, JPMorgan must plead that (1) Mr. Staley breached a duty
+that he owed to either the plaintiffs or JPMorgan; (2) his breach caused an injury; and (3) the injury
+was the same injury for which JPMorgan is being held liable. Bellis v. Tokio Marine & Fire Ins.
+Co., 2002 WL 193149, at *17 (S.D.N.Y. Feb. 7, 2002); see N.Y. C.P.L.R.§ 1401. JPMorgan fails
+to plead elements (1) and (3).
+First, JPMorgan has failed to properly plead that Mr. Staley breached a duty that he owed
+to either the plaintiffs or to the bank. Nowhere in the complaint does JPMorgan allege that Mr.
+Staley owed a duty to USVI or to Doe. And while Staley may have owed a fiduciary duty to
+JPMorgan through their employee-employer relationship, JPMorgan has failed to adequately plead
+that such a duty was breached, as explained further below. See infra pp. 21-23.
+Second, JPMorgan has not adequately pleaded that Mr. Staley caused the same harm for
+which the bank has been sued. No right of contribution arises where the injuries allegedly caused
+by the party are "separate and distinct." Nassau Roofing & Sheet Metal Co. v. Facilities Dev.
+15
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 21 of 30
+Corp., 523 N.E.2d 803, 805 (N.Y. 1988). Here, JPMorgan has failed to plead the injuries for
+which it is seeking contribution. Instead, JPMorgan merely claims that "i]f Doe is successful on
+her claims ... Staley's actions caused or substantially contributed to any resulting damages." TPC
+153. This terse statement fails to state what harm Mr. Staley is being alleged to have caused.
+Perhaps this is no surprise because whatever injury the bank caused simply could not be the same
+as what Mr. Staley allegedly caused. The crux of the plaintiffs' complaints is that JPMorgan
+provided the "financial lifeblood" of Epstein's sex trafficking ring by providing access to limitless
+cash and helping Epstein evade detection by ignoring banking regulations. Doe FAC 11 313, 326,
+350, 473-74; USVI FAC 11| 6, 94. JPMorgan fails to allege how Mr. Staley, a lone bank employee
+who has no banking license and who is not alleged to have had control over Epstein's accounts or
+a formal compliance role, contributed to injuries that are uniquely caused by a financial institution.
+JPMorgan also alleges that Mr. Staley sexually assaulted Doe. TPC 11 27, 52. Even
+accepting this baseless allegation as true as is required, it does not provide a basis for JPMorgan
+to seek contribution. Doe's claims do not seek damages for battery; instead, she seeks all damages
+arising from JPMorgan's financial support of Epstein's sex trafficking ring.
+Because JPMorgan has failed to adequately plead the requirements for contribution, this
+claim must be dismissed.
+E. JPMorgan Cannot Receive Contribution for Punitive Damages.
+Even if the Court finds that the contribution claim should stand, it should strike JPMorgan's
+attempt to receive contribution for any potential punitive damages awarded to Doe or USVI.
+$ JPMorgan's contribution and indemnification claims against Mr. Staley depend on the plaintiffs"
+pleading valid claims against JPMorgan. But the plaintiffs' claims against JPMorgan are deficient
+for at least the reasons identified by JPMorgan in its motions to dismiss, which Mr. Staley hereby
+incorporates by reference, for purposes of preservation. See Mot. To Dismiss, 22-ev-10019, ECF
+No. 46; Motions To Dismiss, 22-cv-10904, ECF Nos. 40, 123.
+16
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 22 of 30
+JPMorgan seeks "contribution for all damages awarded to Doe [and USVI]," who in turn both seek
+punitive damages. TPC 1 55; Doe FAC 1|1 321, 346, 404; USVI FAC 1| 109. But because punitive
+damages are "in the nature of a penalty," contribution among tortfeasors for these damages "is not
+permissible." Felice v. Delporte, 524 N. Y.S.2d 919, 920 (4th Dep't 1988).
+II. Because the Indemnity and Contribution Claims Fail, the Employment Claims
+Should Be Dismissed For Non-Compliance with Rule 14.
+Count III (breach of fiduciary duty) and Count IV (violation of the Faithless Servant
+doctrine) do not belong in this case. If those two Employment Claims are the only claims
+remaining, the Court should dismiss them without prejudice under Rule 14(a).
+Rule 14(a) permits a party to implead another "who is or may be liable to [the third-party
+plaintiff] for all or part of the [plaintiff's] claim against [the third-party plaintiff]." Fed. R. Civ. P.
+14(a)(1). This "standard is not a mere technicality," as "li]mpleader under Rule 14(a) is narrowly
+construed." Le Metier Beauty Inv. Partners LLC v. Metier Tribeca, LLC, 2015 WL 7078641, at
+*3 (S.D.N.Y. Nov. 12, 2015). A third-party claim satisfies Rule 14(a) only "when the third party's
+liability is somehow dependent on the outcome of the main action or when the third party is
+secondarily liable to the defendant." Zohar CDO 2003-1, Ltd. v. Patriarch Partners, LLC, 286 F.
+Supp. 3d 634, 656 (S.D.N.Y. 2017). Unlike for supplemental jurisdiction under 28 U.S.C.
+§ 1367—or for analyzing a discretionary motion to sever claims "the mere fact that the alleged
+third-party claim arises from the same transaction or set of facts as the original claim is not
+enough." State Nat'l Ins. Co. v. Certain Interested Underwriters at Lloyd's London, 2022 WL
+4547444, at *2 (S.D.N.Y. Sept. 29, 2022). Only if impleader is proper with at least one predicate
+claim-
+-that is, one dependent on the outcome of the main action— can the third-party plaintiff join
+non-dependent claims. See Fed R. Civ. P. 18(a).
+17
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 23 of 30
+Here, the Employment Claims are properly joined under Rule 18(a) only if Mr. Staley first
+is properly impleaded based on a third-party claim that satisfies Rule 14(a). If the Court dismisses
+the contribution and indemnity claims, then impleader of the independent Employment Claims is
+improper. Neither Employment Claim depends on the outcome of the plaintiffs' claims against
+JPMorgan. Zohar, 286 F. Supp. 3d at 656. While JPMorgan relies on Doe's and USVI's
+allegations as the basis for the purported breach of fiduciary duty, that alone is not sufficient. In
+theory, JPMorgan could prevail entirely in the main actions and evade any liability yet still prevail
+against Mr. Staley on the Employment Claims and secure disgorgement of his salary or
+compensatory damages independent of what it could have owed the plaintiffs. See TPC 91 64-65,
+78. Whereas the "crucial characteristic of a Rule 14 claim is" a defendant trying to "transfer to
+the third-party defendant the liability asserted against him by the original plaintiff," the
+Employment Claims here are "the type" that JPMorgan "could have asserted in an independent
+action." Zohar, 286 F. Supp. 3d at 656-57 (citation omitted). Accordingly, if, as argued above,
+the indemnification and contribution claims fail, the Employment Claims cannot stand.
+II. The Employment Claims Fail on the Merits.
+The Employment Claims are also subject to dismissal under Rule 12(b)(6).
+A. The Employment Claims Are Time-Barred.
+"Although the statute of limitations is ordinarily an affirmative defense that must be raised
+in the answer, a statute of limitations defense may be decided on a Rule 12(b)(6) motion if the
+defense appears on the face of the complaint." Ellul v. Congregation of Christian Bros., 774 F.3d
+791, 798 n. 12 (2d Cir. 2014). Such is the case here.
+In New York, the limitations period for breach of fiduciary duty claims generally depends
+on the substantive remedy that the plaintiff seeks. ALP, Inc. v. Moskowitz, 167 N. Y.S.3d 45, 52
+(1st Dep't 2022). There is only a three-year limitations period when, as here, the remedy sought
+18
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 24 of 30
+is "purely monetary." Id.; see TPC at 13-14 (prayer for relief). JPMorgan may argue that a sixyear limitations period applies, claiming that this case should be covered by the longer limitations
+period for actions by a corporation against their directors and officers. N.Y. C.P.L.R. § 213(7);
+see Levy v. Young Adult Inst., Inc., 103 F. Supp. 3d 426, 434-35 (S.D.N.Y. 2015). The claim is
+time barred either way. Mr. Staley left JPMorgan in early 2013, TPC 1 16, which was when his
+fiduciary duty and duty of loyalty to the company ended, and which is thus the most recent date
+the claim could arise. JPMorgan, however, waited over 10 years to file these claims. Its suit falls
+well outside even the six-year statute of limitations, so the Court should dismiss the claims.
+To be sure, for "an action based upon fraud," the discovery-accrual rule extends the
+limitations period to the greater of six years or "two years from the time the plaintiff or the person
+under whom the plaintiff claims discovered the fraud, or could with reasonable diligence have
+discovered it." N.Y. C.P.L.R. § 213(8). Because JPMorgan's Employment Claims sound in fraud,
+see infra pp. 20-21, JPMorgan bears the burden to plead and establish that "the fraud could not
+have been discovered prior to the two-year period before the commencement of the action."
+Cannariato v. Cannariato, 24 N.Y.S.3d 214, 216 (2d Dep't 2016) (noting burden rests with
+plaintiff to raise sufficient factual issue and that the issue can be resolved at pleading stage).
+Despite that burden, JPMorgan has pleaded zero facts as to why it could not have discovered the
+alleged claims before the past two years.
+What is more, there is a duty to inquire; a plaintiff cannot claim ignorance of an alleged
+fraud when the facts call for investigation. Aozora Bank Ltd. v. Deutsche Bank Sec., 29 N.Y.S.3d
+10, 14 (Ist Dep't 2016). In other pleadings in this case, JPMorgan heralds a "bombshell" Miami
+Herald story from November 2018 that blew the lid open and "exposed shocking details" about
+Epstein's decades-long operation. JPMorgan Mot. to Dismiss Doe Compl. at 1-2. And in February
+19
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 25 of 30
+2020 two years after JPMorgan concedes that it learned of Epstein's misconduct through the
+article media outlets reported that Mr. Staley was under investigation by the U.K.'s Financial
+Conduct Authority for his connection to Epstein.? Surely the "bombshell" article, Epstein's
+subsequent arrest in 2019, Doe FAC 121, and the public investigation into Mr. Staley put
+JPMorgan on notice of at least the duty to inquire into its own dealings with Epstein, including
+Mr. Staley's alleged involvement. After all, numerous JPMorgan employees knew that Mr. Staley
+had a relationship with Epstein, and the bank had access to Mr. Staley's communications from his
+tenure that JPMorgan now alleges reflect that relationship. As pleaded, the Complaint provides
+no explanation for why JPMorgan sat on its putative claims. The Court should dismiss the
+Employment Claims, which concern a job Mr. Staley left more than a decade ago, as time barred.
+B. The Employment Claims Are Improperly Pleaded.
+Untimeliness aside, JPMorgan fails to properly plead the Employment Claims. As an
+initial matter, both claims must meet the heightened pleading standard of Rule 9(b). The standard
+applies to not only causes of action stylized as fraud claims, but also those in which the "gravamen"
+of the claim relies on dishonest conduct. Rombach v. Chang, 355 F.3d 164, 171-72 (2d Cir. 2004).
+"Courts have found non-fraud claims to sound in fraud where the underlying conduct alleged has
+been fraud or closely linked with fraudulent behavior, such as ... claims that the other party has
+attempted to induce action through misrepresentations or material omissions. This can include
+claims for breach of fiduciary duty." Levy, 103 F. Supp. 3d at 443 (collecting cases).
+Here, Counts III and IV sound in fraud. Both rely on the same alleged underlying
+conduct-namely, that Mr. Staley supposedly subverted the interests of his employer JPMorgan,
+" See, e.g.,
+Clark, Barclays CEO Under Investigation Over Links to Jeffrey Epstein, Wall
+Street Journal (Feb. 13, 2020), https://www.wsj.com/articles/barclays-ceos-links-to-jetfreyepstein-probed-by-u-k-regulators-11581582115?mod=djemalertNEWS.
+20
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 26 of 30
+to which he owed a duty of good faith and loyalty. TPC 11 56-79. For support, JPMorgan
+practically trips over itself alleging varied deception by Mr. Staley: It alleges that he deceived it
+about a material conflict of interest, "fraudulently conceal[ed]" his misconduct, secretly "act[ed]
+against the interests" of the bank, "repeatedly provided misleading information, "affirmatively
+misrepresented" facts," and "consistently and misleadingly vouched" for Epstein. TPC 11| 59-62.
+These claims, which rely on allegedly fraudulent statements and conduct, are precisely the kind
+that trigger Rule 9(b) scrutiny. E.g., Rubio v. BSDB Mgmt. Inc., 2021 WL 102651, at *4 (S.D.N.Y.
+Jan. 12, 2021) (applying Rule 9(b) to counterclaim for violation of faithless servant doctrine
+because "the gravamen of" the claim was "Plaintiff's alleged fraudulent misrepresentations"); cf.
+Levy, 103 F. Supp. 3d at 447 (finding Rule 9(b) not triggered where breach claim "d[id] not allege
+that Levy tricked the organization into taking action it would not otherwise have taken"). Having
+leveled claims of fraud, JPMorgan must plead with particularity when and how Mr. Staley
+allegedly deceived the bank.
+i. JPMorgan Fails to State a Claim for Breach of Fiduciary Duty.
+JPMorgan fails to meet its burden and plead a viable breach of fiduciary duty claim. Under
+New York law, "a plaintiff must allege: (1) the existence of a fiduciary relationship, (2) misconduct
+by the defendant, and (3) damages directly caused by the defendant's misconduct." Yukos Cap.
+S.A.R.L. v.
+, 977 F.3d 216, 241 (2d Cir. 2020) (cleaned up).
+The Complaint falls far short. First, while sweeping, the actual allegations of misconduct
+are conclusory and fatally vague, especially in the face of Rule 9(b). When, how, and from whom
+did Mr. Staley "fraudulently conceal" facts and observations about Epstein? TPC 9| 60. When,
+how, and to whom did Mr. Staley "affirmatively misrepresent" Epstein's activities or "providel]
+misleading information" on Epstein's character and conduct? TPC 161. The Complaint leaves
+21
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 27 of 30
+the parties and the Court guessing as to the critical "who, what, when, where and how of the alleged
+fraud" underlying this claim. Kester, 23 F. Supp. 3d at 252. Such cursory pleading violates Rule
+9(b) and merits the claim's dismissal. Babbitt, 2020 WL 3183895, at *5. Nor does JPMorgan
+properly plead that Mr. Staley had any duty to report to the bank information about Epstein or their
+alleged relationship. An agent, like Mr. Staley, is obligated to disclose only "information that is
+relevant to the affairs of the agency entrusted to him," not every fact on every topic. Poller v.
+BioScrip, Inc., 974 F. Supp. 2d 204, 227 (S.D.N.Y. 2013); see also Neurological Surgery, P.C. v.
+MLMIC Ins. Co., 175 N. Y.S.3d 266, 269 (2d Dep't 2022) (A "cause of action alleging fraudulent
+omission or concealment of material information requires an allegation that the defendant had a
+duty to disclose that information." (emphasis added)). Since JPMorgan has nowhere alleged that
+Mr. Staley had any official responsibilities regarding the Epstein accounts, Mr. Staley's purported
+failure to disclose information to the bank about Epstein does not give rise to a breach of his
+fiduciary duty.
+Second, the Complaint fails to properly plead damages "directly caused by the defendant's
+misconduct." U.S. Fire Ins. Co. v. Raia, 942 N. Y.S.2d 543, 545 (2d Dep't 2012). For a breach of
+fiduciary duty claim, JPMorgan must plead both that it suffered damages and "that the alleged
+misrepresentations or other misconduct were the direct and proximate cause of the losses claimed,"
+not merely a but-for cause.
+Tobia v. United Grp. of Cos., Inc., 2016 WL 5417824, at *22
+(N.D.N.Y. Sept. 22, 2016) (dismissing breach of fiduciary duty claim for failure to allege
+"damages directly caused by Defendants' conduct"); accord Laub v. Faessel, 745 N. Y.S.2d 534,
+536-37 (Ist Dep't 2002).
+JPMorgan notably does not plead that, as of this date, it has actually lost any money from
+Mr. Staley's alleged deception. Indeed, Doe and USVI assert that JPMorgan "financially benefited
+22
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 28 of 30
+by earning millions of dollars" through its connection to Epstein, including from "interest,
+commissions, fees, and other financial benefits." Doe FAC 11| 267-68; USVI FAC 911 95-98. The
+only damages that JPMorgan points to for Count III are (1) costs in defending, and "adverse
+publicity from," these lawsuits, and (2) "any amounts in damages" that JPMorgan might have to
+pay to the plaintiffs. TPC 111 64-65. But neither form of alleged damages suffices. Mr. Staley did
+not "directly cause" this litigation initiated by independent plaintiffs some ten years after he left
+the company, nor any of the associated publicity. Indeed, many of the allegations in USVI's and
+Doe's complaints are completely unrelated to Mr. Staley's conduct. Similarly, any secondhand
+damages that JPMorgan might have to pay to the plaintiffs are completely remote and speculative
+and thus improperly pleaded. See, e.g., Sea Trade Mar. Corp. v. Coutsodontis, 744 F. App'x 721,
+725-26 (2d Cir. 2018) (noting that in order to succeed on breach of fiduciary duty claim, plaintiff
+must prove "non-speculative damages" and that "the claim is not enforceable until damages are
+sustained"). Given JPMorgan's clear failure to point to any non-speculative damages that it has
+incurred through Mr. Staley's purported disloyalty, it has failed to properly plead a cause of action
+for breach of fiduciary duty, and this claim must be dismissed.
+ii. JPMorgan Fails to State a Claim Under the Faithless Servant Doctrine.
+Count IV's claim that Mr. Staley violated the Faithless Servant doctrine fails for similar
+reasons. "New York courts are far from clear regarding the contours of —and interplay between
+a claim for breach of fiduciary duty and the faithless servant doctrine."
+977 F.3d at 242.
+And some courts treat the cause of action as merely an alternate form of recovery for a breach of
+fiduciary duty claim. Id. But under the doctrine, one who owes a duty of loyalty to an employer
+but is "faithless" in the performance may be liable to forfeit his compensation. Phansalkar v.
+Andersen Weinroth & Co., L.P., 344 F.3d 184, 200 (2d Cir. 2003). Courts apply alternate standards
+23
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 29 of 30
+to decide whether an employee's conduct merits disgorgement. See Rubio, 2021 WL 102651, at
+*4. One standard requires that the "misconduct and unfaithfulness ... substantially violate the
+contract of service," while another requires that an agent "act adversely to his employer in any part
+of a transaction, or omit to disclose any interest which would naturally influence his conduct in
+dealing with the subject of his employment." Id. at *4 (cleaned up). But however the standard is
+stated, "New York courts have applied the faithless servant doctrine only in the limited
+circumstances where the employee has acted directly against the employer's interestsas in
+embezzlement, improperly competing with the current employer, or usurping business
+opportunities." Ebel v. G/O Media, Inc., 2021 WL 2037867, at *7 (S.D.N.Y. May 21, 2021).
+Along with lacking particularity for the same reasons as Count III, ° Count IV does not
+remotely allege such "limited circumstances." Id. The complaint here repeats
+phrases, such
+as that Mr. Staley "acted as a faithless servant," "abandoned the interests of [JPMorgan]," and
+"violated the [JPMorgan's] Code of Conduct in a way that permeated his service," id. 91 70-71,
+74, but it lacks factual allegations that match the claim. There are no allegations that Mr. Staley
+embezzled, competed against JPMorgan, usurped business opportunities, or undertook any other
+activity that would put him at financial odds with the bank. Ebel, 2021 WL 2037867, at *7." The
+1° The drive-by allegations for Count IV are just as conclusory as those relating to the breach of
+fiduciary duty claim. They fail under Rule 9(b), as JPMorgan does not detail when, how, and to
+whom Mr. Staley allegedly "consistently and misleadingly vouched for Epstein's good character,"
+or when and how he subverted purported deliberations over whether the bank should keep Epstein
+as a client. TPC 1| 72. Nor does JPMorgan say to whom Mr. Staley "made misrepresentations"
+when "protecting Epstein" from scrutiny. Id. 9 77. Given the charges of deceit, the bank must
+plead with particularity. And it is especially inadequate to just reference hundreds of pages of the
+plaintiffs" allegations that JPMorgan denies in its answer and even in its third-party complaints.
+Rubio, 2021 WL 102651, at *5 (dismissing faithless-servant counterclaim based on "insufficient
+conclusory statements").
+" That the bank pleaded zero direct damages from Mr. Staley's alleged breach of fiduciary duty—
+instead relying on the speculative and remote costs of this litigation underscores the mismatch.
+24
+
+
+Case 1:22-cv-10904-JSR Document 126 Filed 04/24/23 Page 30 of 30
+closest JPMorgan gets is alleging that Mr. Staley lied to keep Epstein as a lucrative client for the
+bank. But misconduct whose only remuneration is incremental profit from "increasing the amount
+of referred business" to the employer is not actionable under the very narrow faithless servant
+doctrine.
+v. Levi & Korsinsky, LLP, 2021 WL 535599, at *6 (S.D.N.Y. Feb. 12, 2021)
+(dismissing claim against lawyer who "acted unfaithfully to benefit other law firms and a mentor
+of hers" outside her firm when the only financial benefit derived from actions that profited her
+firm as well). While JPMorgan "does allege insubordination and dishonesty, [it] fails to allege
+any element of self-dealing on [Mr. Staley]'s part," so the claim is "not actionable under the
+faithless servant doctrine." Grewal v. Cuneo, 2016 WL 308803, at *8 (S.D.N.Y. Jan. 25, 2016).
+The Court should therefore dismiss Count IV.
+CONCLUSION
+For the foregoing reasons, Mr. Staley respectfully requests that the Court dismiss the
+Complaint.
+Date: April 24, 2023
+Respectfully submitted,
+By: /s/ Brendan V.
+Jr.
+Brendan V.
+_Jr.
+Zachary K. L
+Stephen L. Wohlgemuth
+] & CONNOLLY LLP
+680 Maine Avenue SW
+Washington, DC 20024
+Tel: (202) 434-5252
+Fax: (202) 434-5029
+zwarren@wc.com
+Counsel for Third-Party Defendant
+James Edward Staley

vision-fixhub/court-05/50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191.receipt.json

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+  "doc_id": "50e5cca3e99fb169e8a8a9d4a68ad1cbdb86e703d5210d918f2fa2704dd64191",
+  "engine": "marble-apple-vision",
+  "event_count": 35,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "084d6a27d079fa2f9b1c0642d65e9748cf0b45716a87ff07eed2cbe2c1267753",
+  "output_sha256": "d6f1e7572f3f63619d246fd894ebb9b47e586432d04fa29f1d8e8bdeaaff53ec",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/50ef9433c303df710cdbc4f453eefcce0451391d86aa4d0a135be3cbd9c5184f.md

@@ -0,0 +1,182 @@
+Case 1:22-cV-10904-JSR Document 238-28 Filed 07/25/23 Page 1 of 7
+
+
+
+Case 1.22-cv-10904-JSR Document 238-28 Filed 07125/23 Page 2 oft
+What is Human Trafficking?
+Human trafficking is the recruitment, transportation, provision, or
+obtaining of a person for labor or services, through the use of force
+of coercion for the purpose of subjection to involuntary servitude,
+peonage, debt bondage or slavery. Human trafficking has become
+the second largest criminal enterprise and is currently the fastest
+growing criminal industry in the world.
+The Victims
+Human trafficking does not discriminate. Per the Global Slavery
+Index Report, it is estimated that 45.6 million people are currently
+enslaved worldwide. Victims include men, women, boys, girls, and
+transgender individuals lured by false promises of love or
+opportunity. Statistics from the National Center for Missing and
+Exploited Children estimate about 100,000 children per year, are
+caught up in the web of child prostitution.
+facebook
+Key indicators/Red flags of potential Human Trafficking activity:
+Customer Behavior
+• Excessive number of individual accounts
+abbies
+• No deposits from an employer
+
+8
+• Reports of identity theft
+• Hiring of immigration attorneys or ties to other labor intermediaries to handle visa paperwork
+• Business industries with links to human trafficking (e.g. modeling, travel & transportation)
+
+3/29/2:
+JPM-SDNYLIT-00151917
+
+
+Case 1122 CV-10904 JS Documen 238°28 Filed 07125/23 Page 3 or7
+Key indicators/Red flags of potential Human Trafficking activity (cont'd):
+Source of Funds
+• Round- dollar deposits via wires, ACH or cash
+• Excessive interstate or intrastate cash deposits less than $1,000 (round dollar), using multiple
+branches
+• Cash deposits below the CTR threshold deposited at several branches & ATMs
+• Structured transactions, particularly those conducted via MSBs
+• Incoming wires or personal checks deposited into business accounts with no clear purpose
+Use of Funds
+> High volume of debit card/ credit card transactions with the following types of merchants:
+• Airline and/or rental car companies in multiple cities or states
+• Hotel or casino charges and purchases made at high end merchants (jewelry, accessories,
+apparel)
+• Online advertisement providers (see list of known sites)
+› Excessive payments to property management companies, utility companies, and cell phone
+companies
+• Purchase of money orders to pay bills instead of using personal checks
+• Wire transfers to countries with high migrant populations, following unusual cash deposits
+• Wire activity inconsistent with business, particularly international or round dollar wires (e.g. nail
+salon operating in Queens, NY receives large value wire transfers from South America or Southeast
+Asia, or wires in even thousand-dollar increments.)
+
+JPM-SDNYLIT-00151918
+
+
+case L22-CV-10904 SR Document 238-28 Filed 07/25/23 Page 4 017
+NOTE: As of April 6, 2018, backpage.com and affiliated websites have been seized
+by U.S. enforcement agencies...
+backpage.com
+backpage
+Califor
+backpage.com and affiliated
+websites have been seized
+as part of an enforcement action by the Federal Bureau of Investigation, the
+U.S. Postal Inspection Service, and the Internal Revenue Service Criminal
+Investigation Division, with analytical assistance from the Joint Regional
+intelligence Center,
+Other agencies participating in and supporting the enforcement action
+include the U.S. Attarney's Office for the District of Arizona, the U.S.
+Department of Justice's Child Exploitation and Obscenity Section, the U.S.
+Attorney's Office for the Central District of California, the office of the
+California Attorney General, and the office of the Texas Attorney General.
+Additional information will be provided at around 6:00 pm EST on Friday.
+April 6, by the U.S. Department of Justice, and all media inquiries should be
+directed to the U.S. Department of Justice's Office of Public Affairs at
+202-514-2007 and press@lundoiaoy.
+April 6, 2018
+starburs
+
+JPM-SDNYLIT-00151919
+
+
+Case ILL-cv-10904 05R Document 238-26 Filed 0712523 Page 50f7
+...law enforcement has identified at least 30 sites that have taken its place, including:
+• www.bedpage.com
+• www.thebqe.com
+• www.onebackpase.com
+• www.theeroticreview.com - must turn on VPN and "locate" to another
+country
+• switter.at and listing.switter.at
+• SafeOffice (sex workers only): https://www.safeoffice.com/
+• Discord (sex workers only): https://discord.gg/UJK2TKH/ [Requires
+additional confirmation that you're a sex worker.]
+• Telegram: httos://t.me/joinchat/FMw30xB-bdEM4gi6fw3A6w
+• TER boards: https://www.theeroticreview.com/ [Forums up, not
+accepting ads.]
+• Stripperweb: https://www.stripperweb.com
+• Eroticmonkey: https://www.eroticmonkey.com/ [Down as of 2018-04-
+06]
+• Eros.com: https://www.eros.com/
+• P411: https://preferred411.com/
+• Eccie: https://eccie.net/ (Down as of 2018-04-07]
+• Slixa: https://www.slixa.com/
+• TNA: https://www.tnaboard.com/
+• SA Sex Guide: http://www.usasexguide.info
+* Plenty of Fish: https://www.pof.com/ (Not SW-friendly, but SWers
+have used it]
+• Skipthegames:https://skiptherames.com
+• City of Love:http://www.cityoflove.com/
+• Open Adult Directory: https://openadultdirectory.com/escorts/
+• Mature Sensual: https://maturesensual.com/
+• Escort Ads: https://www.escort-ads.com/
+• Humaniplex: http://www.humaniplex.com
+• Cityxguide: https://www.cityxguide.com
+• The Other Board: https://www.theotherboard.com
+• RentMen: https://rent.men/
+• Onebackpage: https://onebackpage.com
+• Rent.love: https://www.rent.love
+• Doublelist.com: https://www.doublelist.com
+• Hubzilla: https://gerzilla.de/channel/sexworkers
+• Dread (Tor-only): http://dreadecomdopooda.onion/d/sexworkers
+• Minds.com Sex Workers Forum -
+https://www.minds.com/groups/profile/825386597235675136
+• Riot.im: https://riot.im/app/#/room/#sw.matrix.org
+Be on the lookout for any of the above websites during your investigation! It may
+indicate potential human trafficking activity is occurring.
+
+JPM-SDNYLIT-00151920
+
+
+Case 1:22-CV-10904-USR Document 238-28 Filed 07125123 Page b oг7
+AML Investigations promotes cases involving possible Human Trafficking. But first, your
+investigation must support why you believe the activity is related to HT. Below are additional tips to
+assist you in determining whether HT may be present in your investigation.
+Negative Media
+Search an entity or customer name via
+open source or strategic corporate
+tools. Searches may yield negative
+news, arrests for prostitution/ human
+trafficking or other crimes which raise
+risk profile of an alert/ customer.
+Demographic Links to Online Adult
+Advertising and Services
+Searches of phone numbers,
+addresses, and email addresses may
+yield nexus to online advertising.
+Previous AML History
+Previous AML History,
+not
+necessarily HT related, may be
+associated with an investigation
+related to suspicious activity such as
+interstate, excessive or structured cash
+activity.
+Additionally, if a SAR is being filed on activity
+relating to potential human trafficking, don't forget
+to select "Box 38h - Human trafficking" in the
+Suspicious Activity Info section of the SAR form.
+38 Other Suspicious Activities
+h
+• Human trafficking
+What are potential quality
+concerns related to
+Human Trafficking?
+• Are the reasons you suspect the activity is related to human trafficking
+adequately explained in the SAR narrative?
+•
+Is Box 38h appropriately selected?
+Has the SAR been flagged as Significant, with the Significant SAR
+procedures appropriately followed?
+
+JPM-SDNYLIT-00151921
+
+
+Case 1:22-cv-10904-JSR Document 238-28 Filed 07/25/23 Page 7 of 7

vision-fixhub/court-05/50ef9433c303df710cdbc4f453eefcce0451391d86aa4d0a135be3cbd9c5184f.receipt.json

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+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
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+}

vision-fixhub/court-05/511580004a5567e16884a5e6856017b4582dad0742206aaa255abaa73ad38b6a.md

@@ -0,0 +1,195 @@
+Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 1 of 8
+
+
+
+Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 2 of 8
+UNITED STATES DISTRICT COURT FOR THE
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE, individually and on behalf of
+all others similarly situated,
+Plaintiff,
+V.
+JPMORGAN CHASE BANK, N.A.
+Defendant/Third-Party Plaintiff.
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS.
+v.
+Plaintiff,
+JPMORGAN CHASE BANK, N.A.
+Defendant/Third-Party Plaintiff.
+JPMORGAN CHASE BANK, N.A.
+Third-Party Plaintiff,
+Case Number: 1:22-cv-10019-JSR
+Case Number: 1:22-cv-10904-JSR
+v.
+JAMES EDWARD STALEY
+Third-Party Defendant.
+THIRD-PARTY DEFENDANT JAMES E. STALEY'S RESPONSES
+AND OBJECTIONS TO UNITED STATES VIRGIN ISLANDS' FIRST
+SET OF REQUESTS FOR ADMISSIONS
+Pursuant to Rules 26 and 36 of the Federal Rules of Civil Procedure, Third-Party
+Defendant James E. Staley, through undersigned counsel, hereby responds and objects to the
+United States Virgin Island's First Requests for Admissions in the above-captioned matters.
+1
+
+
+Case 1:22-cv-10904-JSR Document 238-23 Filed 07/25/23 Page 3 of 8
+9. Staley objects to each Request to the extent that it improperly "seek[s] information as to
+fundamental disagreement at the heart of the lawsuit." Republic of Turkey v. Christie's,
+Inc., 326 F.R.D. 394, 400 (S.D.N.Y. 2018) (citing
+&
+Fed. Prac. & P. §
+2252; Tamas v. Fam. Video Movie Club, Inc., 301 F.R.D. 346, 347 (N.D. III. 2014)).
+10. Staley objects to each Request to the extent that it amounts to an improper use of Requests
+for Admission as a discovery device. Pasternak v. Dow
+1. 2011 WL 4552389, at *5
+(S.D.N.Y. Sept. 28, 2011) (requests for admission "presuppose|] that the party proceeding
+under [Rule 36] knows the facts" and "merely wishes its opponent to concede their
+genuineness." (citations omitted)); L
+v. De Niro, 2022 WL 101909, at *2
+(S.D.N.Y. Jan. 11, 2022) ("[RJequests for admission are used to establish admission of
+facts about which there is no real dispute," not to obtain new information).
+11. Staley objects to each Request to the extent that it is vague because it uses terms that are
+susceptible to more than one meaning, ambiguous, overly broad, or unduly burdensome.
+Fed. R. Civ. P. 26(b)(1).
+12. Staley objects to each Request to the extent that it requests an admission not "relevant to
+any party's claim or defense" and therefore, not "proportional to the needs of the case."
+Fed. R. Civ. P. 26(b)(1).
+II.
+REQUESTS FOR ADMISSION
+REQUEST FOR ADMISSION NO. 1:
+Admit that You were CEO of JPMorgan Asset Management between 2001-2009.
+RESPONSE TO REQUEST FOR ADMISSION NO. 1:
+Subject to and without waiving the General Objections, and reserving the right to amend or
+supplement his response as further information is discovered, Staley denies this Request. He admits
+4
+
+
+Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 4 of 8
+that he was the CEO of JPMorgan Asset and Wealth Management.
+REQUEST FOR ADMISSION NO. 2:
+Admit that You were CEO of JPMorgan Investment Bank between 2009-2012.
+RESPONSE TO REQUEST FOR ADMISSION NO. 2:
+Subject to and without waiving the General Objections, and reserving the right to amend or
+supplement his response as further information is discovered, Staley admits this Request.
+REQUEST FOR ADMISSION NO. 3:
+Admit that You signed a written affirmation each year between 2006-2012 where You pledged to
+remain in compliance with JPMorgan's Code of Conduct.
+RESPONSE TO REQUEST FOR ADMISSION NO. 3:
+In addition to and specifically incorporating his foregoing General Objections, Staley
+objects to Request No. 3 because it inappropriately incorporates documents by reference.
+Subject to and without waiving the foregoing objections, and reserving the right to amend
+or supplement his response as further information is discovered, Staley admits that he signed
+certifications that speak for themselves. Otherwise the request is denied.
+REQUEST FOR ADMISSION NO. 4:
+Admit that You provided information to JPMorgan regarding Your friendship with Epstein.
+RESPONSE TO REQUEST FOR ADMISSION NO. 4:
+In addition to and specifically incorporating his foregoing General Objections, Staley
+objects to Request No. 4 because the terms "information" and "friendship" are vague because they
+are susceptible to more than one meaning.
+Staley objects to Request No. 4 because it seeks information that is not "relevant to any
+party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P.
+26(b)(1).
+5
+
+
+Case 1:22-cv-10904-JSR Document 238-23 Filed 07/25/23 Page 5 of 8
+Staley objects to Request No. 16 because it seeks information that is not "relevant to any
+party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P.
+26(b)(1).
+Subject to and without waiving the foregoing General Objections, and reserving the right to
+amend or supplement his response as further information is discovered, Staley denies this Request.
+REQUEST FOR ADMISSION NO. 17:
+Admit that Epstein referred or otherwise introduced JPMorgan to other ultra-high net worth
+individuals as clients or for additional activities or funds to JPMorgan Private Bank.
+RESPONSE TO REQUEST FOR ADMISSION NO. 17:
+In addition to and specifically incorporating its foregoing General Objections, Staley
+objects to Request No. 17 because the terms "ultra-high net worth individuals," "clients,"
+"additional activities or funds" are vague because they are susceptible to more than one meaning.
+Staley objects to Request No. 17 because it seeks information that is not "relevant to any
+party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P.
+26(b)(1).
+Staley objects to Request No. 17 to the extent it is directed at JPMC's knowledge or actions
+because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to
+the extent the Request seeks information based on his personal knowledge.
+Subject to and without waiving the foregoing General Objections, and reserving the right to
+amend or supplement his response as further information is discovered, Staley admits this Request.
+REQUEST FOR ADMISSION NO. 18:
+Admit that JPMorgan obtained fees, revenue, and business referrals in connection with JPMorgan's
+banking relationship with Epstein.
+RESPONSE TO REQUEST FOR ADMISSION NO. 18:
+12
+
+
+Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 6 of 8
+"reporting," "allegations," and "human trafficking" are vague because they are susceptible to more
+than one meaning and call for improper legal conclusions. Carver, 2018 WL 4579831, at *2.
+Staley objects to Request No. 110 to the extent that it assumes or implies that Staley knew
+about, had reason to know, or should have known of Epstein's actions and because it seeks a legal
+conclusion and thus seeks admissions outside the scope of the Federal and Local Rules. Id.
+Staley objects to Request No. 110 because it "seek[s] information as to fundamental
+disagreement at the heart of the lawsuit." Republic of Turkey, 326 F.R.D. at 40.
+Staley objects to Request No. 110 because it abuses Requests for Admission as a discovery
+device. See Pasternak, 2011 WL 4552389, at *5; De Niro, 2022 WL 101909, at *2.
+Staley objects to Request No. 110 to the extent that it is improperly compound, conjunctive,
+or disjunctive. Fed. R. Civ. P. 36(a)(2).
+Staley objects to Request No. 110 as improperly incorporating a document or documents by
+reference without an opportunity to test their veracity and authenticity. As such, Staley further
+objects to Request No. 110 to the extent it assumes that a person who read what was "report[ed]" in
+the "newspaper or other media articles" had to assume the report to be a full, true, complete, and
+accurate account of the people, actions, or events it described.
+Subject to and without waiving the foregoing objections, and reserving the right to amend
+or supplement his response as further information is discovered, Staley admits that he received and
+reviewed articles about Epstein. Otherwise the request is denied.
+REQUEST FOR ADMISSION NO. 111:
+Admit that in 2006 Jamie Dimon communicated with You regarding Epstein's arrest on charges of
+procuring a minor for prostitution and solicitation of a prostitute.
+RESPONSE TO REQUEST FOR ADMISSION NO. 111:
+In addition to and specifically incorporating his foregoing General Objections, Staley
+76
+
+
+Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 7 of 8
+objects to Request No. 111 because the terms "communicated," "regarding," "arrest," "charges of
+procuring a minor for prostitution," and "solicitation of a prostitute" are vague because they are
+susceptible to more than one meaning and call for improper legal conclusions. Carver, 2018 WL
+4579831, at *2.
+Staley objects to Request No. 111 to the extent that it assumes or implies that Staley knew
+about, had reason to know, or should have known of Epstein's actions and because it seeks a legal
+conclusion and thus seeks admissions outside the scope of the Federal and Local Rules. Id.
+Staley objects to Request No. 111 because it "seek[s] information as to fundamental
+disagreement at the heart of the lawsuit." Republic of Turkey, 326 F.R.D. at 40.
+Staley objects to Request No. 111 because it abuses Requests for Admission as a discovery
+device. See Pasternak, 2011 WL 4552389, at *5; De Niro, 2022 WL 101909, at *2.
+Subject to and without waiving the foregoing objections, and reserving the right to amend
+or supplement his response as further information is discovered, Staley admits this Request.
+REQUEST FOR ADMISSION NO. 112:
+Admit that in 2006 Mary Erdoes communicated with You regarding Epstein's arrest on charges of
+procuring a minor for prostitution and solicitation of a prostitute.
+RESPONSE TO REQUEST FOR ADMISSION NO. 112:
+In addition to and specifically incorporating his foregoing General Objections, Staley
+objects to Request No. 112 because the terms "communicated," "regarding," "arrest," "charges of
+procuring a minor for prostitution," and "solicitation of a prostitute" are vague because they are
+susceptible to more than one meaning and call for improper legal conclusions. Carver, 2018 WL
+4579831, at *2.
+Staley objects to Request No. 112 to the extent that it assumes or implies that Staley knew
+about, had reason to know, or should have known of Epstein's actions and because it seeks a legal
+77
+
+
+Case 1:22-cV-10904-JSR Document 238-23 Filed 07/25/23 Page 8 of 8
+May 22, 2023
+By: /s/ Brendan V. |
+1. Jr.
+Brendan V. L
+Zachary K.
+Stephen L. Wohlgemuth
+& CONNOLLY LLP
+680 Maine Avenue SW
+Washington, DC 20024
+Tel: (202) 434-5252
+Fax: (202) 434-5029
+zwarren@wc.com
+Counsel for Third-Party Defendant
+James Edward Staley
+5

vision-fixhub/court-05/511580004a5567e16884a5e6856017b4582dad0742206aaa255abaa73ad38b6a.receipt.json

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vision-fixhub/court-05/51219913cc7a1d7f5aebf3f9c2b1379f735d205d01fd81c4191207b99ddb7f5c.md

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+Case 1:22-cv-10904-JSR Document 297-3 Filed 08/18/23 Page 1 of 1
+
+FILED UNDER SEAL

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vision-fixhub/court-05/513bd40db153439b58bebf5dfc633759661aae573907126e3f338e9f3fb78006.md

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+Case 1:22-cV-10904-JSR Document 285-82 Filed 08/15/23 Page 1 of 2
+
+
+
+Case 1:22-cv-10904-JSR Document 285-82 Filed 08/15/23 Page 2 of 2
+From:
+Sent:
+To:
+Subject:
+Lesley Groff
+2/11/2019 2:49:25 PM
+Erdoes, Mary E [mary.erdoes@jpmorgan.com]
+Re: Jeffrey Epstein
+...Mary, Jeffrey just thought that kathy is one of the most powerful women in washington and thought you two
+would bond..
+Sent from my iPhone
+On Feb 11, 2019, at 8:03 AM, Erdoes, Mary E <mary.erdoes@jpmorgan.com> wrote:
+Thanks so much, Lesley.
+I dont handle accounts myself but we will definitley get her in the right hands.
+I will reach out to her.
+Thanks for sharing.
+Mary
+From: Lesley Groff
+Date: Thursday, Feb 07, 2019, 2:08 PM
+To: Erdoes, Mary E <mary.erdoes@jpmorgan.com>
+Subject: Jeffrey Epstein
+Hello Mary. Hope you are well. Jeffrey wanted me to reach out to you re his very good friend and former
+House counsel to Pres. Barak Obama, Kathy Ruemmler. She would like to open an account with JPM. Jeffrey
+requests she deal with you personally. Might this be possible?
+Lesley
+Assistant to Jeffrey Epstein
+This message is confidential and subject to terms at: https://www.jpmorgan.com/emaildisclaimer
+including on confidentiality, legal privilege, viruses and monitoring of electronic messages. If
+you are not the intended recipient, please delete this message and notify the sender immediately.
+Any unauthorized use is strictly prohibited.
+
+JPM-SDNYLIT-00233394
+6898ZH

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