MEMY-1805 marker2-fixhub court-usvi-v-jpmorgan (pepper 16-core): 3678/3678

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812844/EFTA02812844.md

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+## EXHIBIT 70 FILED UNDER SEAL
+
+| 1 | UNITED STATES DISTRICT COURT |  |
+| ---- | --------------------------------------- | --------------------- |
+|  | FOR THE SOUTHERN DISTRICT OF NEW YORK |  |
+| 2 |  |  |
+|  | GOVERNMENT OF THE UNITED | ) |
+| 3 | STATES VIRGIN ISLANDS | ) |
+|  |  | ) |
+| 4 | Plaintiff, | ) |
+|  |  | ) |
+| 5 | vs. | ) 1:22-cv-10904-JSR |
+|  |  | ) |
+| 6 | JPMORGAN CHASE BANK, N.A., | ) |
+|  |  | ) |
+| 7 | Defendant/Third- | ) |
+|  | Party Plaintiff. | ) |
+| 8 |  | ) |
+|  | ----- | ) |
+| 9 | JPMORGAN CHASE BANK, N.A. | ) |
+|  |  | ) |
+|  | Third-Party | ) |
+| 10 | Plaintiff, | ) |
+|  |  | ) |
+| 11 | vs. | ) |
+|  |  | ) |
+| 12 | JAMES EDWARD STALEY, | ) |
+|  |  | ) |
+| 13 | Third-Party | ) |
+|  | Defendant. | ) |
+| 14 |  | ) |
+
+SATURDAY, JUNE 10, 2023
+
+CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
+
+\*\*CONFIDENTIAL BSA PORTIONS UNDER SEPARATE COVER\*\*
+
+- - -
+
+Videotaped deposition of James E. Staley, held at the offices of Boies Schiller Flexner, LLC, 55 Hudson Yards, New York, New York, commencing at 9:13 a.m. Eastern, on the above date, before Carrie A. [REDACTED], Registered Diplomate Reporter and Certified Realtime Reporter.
+
+- - -
+
+|  | GOLKOW LITIGATION SERVICES |
+| -- | ------------------------------------ |
+|  | 877.370.3377 ph   917.591.5672 fax |
+|  | deps@golkow.com |
+
+1 don't know.
+
+Q. Irrespective of your involvement with his accounts, the fact that he had his accounts and the size of his accounts at JPMorgan benefitted JPMorgan.
+
+You would agree, right?
+
+7 A. I think no -- you know, I don't think any single client is that important, but he was a client of the bank.
+
+Q. And he continued to refer clients to JPMorgan before, during and after his incarceration, correct?
+
+13 MR. GAIL: Objection.
+
+THE WITNESS: I don't think he referred clients to the bank. I met 16 clients through him, but I don't think he was making a referral.
+
+QUESTIONS BY MR. •
+
+Q. Do you know who McGraw 
+
+A. No.
+
+Q. Do you remember a Tom McGraw in the tax department of JPMorgan?
+
+A. I don't.

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812844/EFTA02812844.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812847/EFTA02812847.md

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+## EXHIBIT 71 FILED UNDER SEAL

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812847/EFTA02812847.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812848/EFTA02812848.md

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+## EXHIBIT 72 FILED UNDER SEAL

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812848/EFTA02812848.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812849/EFTA02812849.md

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+# EXHIBIT 73
+
+#### UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE, individually and on behalf of all others similarly situated,
+
+Plaintiff, v.
+
+
+Defendant/Third-Party Plaintiff.
+
+GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS,
+
+Plaintiff, v.
+
+
+Defendant/Third-Party Plaintiff.
+
+
+Third-Party Plaintiff, v.
+
+JAMES EDWARD STALEY
+
+Third-Party Defendant.
+
+Case Number: 1:22-cv-10019-JSR
+
+Case Number: 1:22-cv-10904-JSR
+
+#### THIRD-PARTY DEFENDANT JAMES E. STALEY'S RESPONSES AND OBJECTIONS TO UNITED STATES VIRGIN ISLANDS' FIRST SET OF REOUESTS 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.
+
+Staley objects to Request No. 26 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 denies this Request.
+
+## REQUEST FOR ADMISSION NO. 27:
+
+Admit that Epstein referred Pagano, CEO, Chairman, and President of Sentigen Bio Services, as a client or for additional activities or funds to JPMorgan's Private Bank.
+
+# RESPONSE TO REQUEST FOR ADMISSION NO. 27:
+
+In addition to and specifically incorporating its foregoing General Objections, Staley objects to Request No. 27 because the terms "referred," "client," and "additional activities or funds" are vague because they are susceptible to more than one meaning.
+
+Staley objects to Request No. 27 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. 27 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 cannot truthfully admit or deny this request because he lacks sufficient knowledge.
+
+## REOUEST FOR ADMISSION NO. 28:
+
+Admit that Epstein referred Andrew Farkas, founder and CEO of Island Capital Group LLC, as a client or for additional activities or funds to JPMorgan's Private Bank.
+
+#### RESPONSE TO REOUEST FOR ADMISSION NO. 28:
+
+In addition to and specifically incorporating its foregoing General Objections, Staley objects to Request No. 28 because the terms "referred," "client," and "additional activities or funds" are vague because they are susceptible to more than one meaning.
+
+Staley objects to Request No. 28 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. 28 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 denies this Request.
+
+## REQUEST FOR ADMISSION NO. 29.
+
+Admit that Epstein referred Larry Page, co-founder of Google, as a client or for additional activities or funds to JPMorgan's Private Bank.
+
+## RESPONSE TO REQUEST FOR ADMISSION NO. 29:
+
+In addition to and specifically incorporating its foregoing General Objections, Staley objects to Request No. 29 because the terms "referred," "client," and "additional activities or funds" are vague because they are susceptible to more than one meaning.
+
+Staley objects to Request No. 29 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. 29 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
+
+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.
+
+#### REOUEST FOR ADMISSION NO. 36:
+
+Admit that Epstein referred Prince Andrew, of York as a client or for additional activities or funds to JPMorgan's Private Bank.
+
+#### RESPONSE TO REQUEST FOR ADMISSION NO. 36:
+
+In addition to and specifically incorporating his foregoing General Objections, Staley objects to Request No. 36 because the terms "referred," "client," and "additional activities or funds" are vague because they are susceptible to more than one meaning.
+
+Staley objects to Request No. 36 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. 36 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 denies this Request.
+
+## REQUEST FOR ADMISSION NO. 37.
+
+Admit that Epstein introduced You to and/or facilitated meetings with Prince Andrew.
+
+#### RESPONSE TO REQUEST FOR ADMISSION NO. 37:
+
+In addition to and specifically incorporating his foregoing General Objections, Staley objects to Request No. 37 because the terms "introduced," "facilitated," and "meetings" are vague because they are susceptible to more than one meaning.
+
+Staley objects to Request No. 47 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. 47 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 cannot truthfully admit or deny this request because he lacks sufficient knowledge.
+
+## REOUEST FOR ADMISSION NO. 48:
+
+Admit that Epstein referred Stephen Salzman, Manager of Priderock Management, LLC, as a client or for additional activities or funds to JPMorgan's Private Bank.
+
+#### RESPONSE TO REQUEST FOR ADMISSION NO. 48:
+
+In addition to and specifically incorporating his foregoing General Objections, Staley objects to Request No. 48 because the terms "referred," "client," and "additional activities or funds" are vague because they are susceptible to more than one meaning.
+
+Staley objects to Request No. 48 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. 48 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 cannot truthfully
+
+admit or deny this request because he lacks sufficient knowledge.
+
+#### REQUEST FOR ADMISSION NO. 49:
+
+Admit that Epstein referred Pritzker, chairman and CEO of the Pritzker Organization, as a client or for additional activities or funds to JPMorgan's Private Bank.
+
+#### RESPONSE TO REQUEST FOR ADMISSION NO. 49:
+
+In addition to and specifically incorporating his foregoing General Objections, Staley objects to Request No. 49 because the terms "referred," "client," and "additional activities or funds" are vague because they are susceptible to more than one meaning.
+
+Staley objects to Request No. 49 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. 49 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. 50:
+
+Admit that You worked with Epstein to develop a donor advised fund with Bill Gates and The Bill and Melinda Gates Foundation.
+
+# RESPONSE TO REOUEST FOR ADMISSION NO. 50:
+
+In addition to and specifically incorporating his foregoing General Objections, Staley objects to Request No. 50 because the terms "worked with," "develop," and "donor advised fund" are vague because they are susceptible to more than one meaning.
+
+Staley objects to Request No. 50 because it seeks information that is not "relevant to any
+
+May 22, 2023
+
+By: /s/ Brendan V. Jr.
+
+Brendan V. 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

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812849/EFTA02812849.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812857/EFTA02812857.md

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+## EXHIBIT 74
+
+From: Evangelisti, Sent: 11/23/2013 2:44:19 PM To: Dimon, Jamie Bamie.dimon@jpmchase.corn] CC: Scher, Peter L (peter.l.scher@jpmchase.com]; =, Judith B. Subject: FT
+
+Jamie - FYI -- Good context below from Richard Kaye. Joe
+
+Original Message From: Kaye, Richard Sent: Saturday, November 23, 2013 03:17 Am Eastern Standard Time To: Zuccarelli, Jennifer R; Mayhew, David L; Scher, Peter L; Judith B.; Evangelisti, Marchiony, Brian J; Beizer, Emily 5; Kornblau, Mark A Subject: Re: FT- Fine dining for Dimon at the Palace raises concerns of commercialization
+
+Thanks Jenn. 1 think we all expected some sort of article like this, and the surprise is that it has taken them so long.
+
+The fact is that the IIII and Palace officials went into this entirely with their eyes open. our name was deliberately not used in res ect of the event or invitations, and we suggested the involvement of organisations of which the is a Patron. I'd also say that, in speaking with the I UK. on the night, he was very proud of what he ad brought together and what it meant for business in the actually said to me, "is anyone tweeting about this tonight.. they should be." we told him it wasn't a very tweeting sort of crowd but he certainly didn't want to keep the event a secret. The has a long history of fending off criticisms of his engagement with business and is fairly resill.t. i My take on this is that, although we would rather not be in the papers again, it doesn't do us too much harm to be seen still be in favour with the British establishment and top business figures.
+
+original Message From: Zuccarelli, Jennifer R Sent: Friday, November 22, 2013 11:43 PM To: Mayhew, David 1; Kaye, Richard; Scher, Peter L; , Judith B.; Evangelisti, ; Marchiony, Brian J; Beizer, Emily 5; Kornblau, Mark A Subject: Fr- Fine dining for Dimon at the Palace raises concerns of commercialization
+
+Below is the FT story on our Buckingham Palace dinner. The story focuses more on the use of Buckingham Palace, but unfortunately we are the lead of the story with a few MPs commenting on it.
+
+Financial Times Fine dining for Dimon at the Palace raises concerns of commercialization By Jenkins, Helen warrell and Kiran Stacey Novem er 2, 2013
+
+It must have been a welcome spot of light relief for Jamie Dimon. only days after he finally agreed to a 513bn settlement with US mortgage regulators, the boss of )PMorgan - and dozens of his corporate clients - were sitting back amid the splendour of Buckingham Palace, enjoying a fine dinner and performances by the Philharmonic and the English National Ballet.
+
+The event, hosted by Prince Andrew, IIII of York, reflects growing enthusiasm by the Family to use its premises to promote business interests. But it also risks stoking criticism over its apparent commercialisation and its intimacy with business.
+
+One senior participant said the bank paid nothing for the evening but the Palace said the bank paid an undisclosed fee for food, drink and the venue. The bank said it also made charitable donations to the orchestra and ballet company.
+
+According to the Palace, the IIII of York is involved in efforts to support British business, and the event was an opportunity to 'engage" with international chief executives about what Britain has to offer.
+
+Keith vaz, the Labour chairman of the home affairs select committee, said the arrangement threatened to undermine the cachet of the palaces and even the security of the family.
+
+He compared it to controversial plans to open up the House of Commons to businesses, telling the Financial Times: "It could be that a company perhaps is not blue chip but may look it. we could take their money and only afterwards find out it is not an appropriate company to book a room in Buckingham Palace."
+
+He added: "There is also the fact that this should be a special place. This is the home of the Queen. where is it all going to end?"
+
+The JPMorgan event on October 30, had a guestlist that included up to 100 corporate and political heavyweights, ranging from Kofi Annan, the former UN secretary-general, to Indian industrialist Ratan Tata. Also present was Tony Blair, the former prime minister who chairs JPMorgan's 'international council' of senior advisers.
+
+Key to organising the night was David Mayhew, the veteran City dealmaker who agreed a decade ago to sell to JPMorgan the Cazenove brokerage he led for many years. Mr Mayhew, still an adviser to JPMorgan, is a close personal friend of Prince Andrew.
+
+Paul Flynn, a republican Labour MP, said renting out Buckingham Palace to US investment banks should be only the start in making the family less dependent on the taxpayer. "I think they could raise about 1100m a year by renting out rooms to tourists on a timeshare basis - they've got about 600 rooms," he said.
+
+Prince Andrew has a mixed record in promoting British business. He stepped down two years ago as the UK's trade envoy following a string of controversies over his business links, most notably his close friendship with US tycoon Jeffrey Epstein who was jailed for sex offences.
+
+Additional reporting by and Daniel schafer

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812860/EFTA02812860.md

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+## EXHIBIT 75
+
+From: Duffy, John R [john.r.duffy@jpmorgan.comj Sent: 9/20/2013 9:20:48 PM To: Erdoes, Mary E Imary.erdoes@jpmorgan.corn] Subject: JE
+
+Spoke with him. Good conversation. Told JE no on sole trustee or POA, yes for advisory role without discretion. Yes for custody in the client's name.
+
+Tough one he brought up regarding Gates - JE and JPM as co-trustee. while I expect that this would be hard to get through - its like co-branding with him. we should still discuss it - Let's talk. He understood.
+
+John R. Duffy J.P. CEO, IT ilrivate Bank 270 Park Avenue New York, NY 10017 Tel: 212-464-1468 Email: john. r.duffyOjpmorgan.com
+
+J.P. securities LLc

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812862/EFTA02812862.md

@@ -0,0 +1,221 @@
+## EXHIBIT 76 FILED UNDER SEAL
+
+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE 1, individually and on behalf of all others similarly situated,
+
+Plaintiff,
+
+JP CHASE BANK, N.A.
+
+Civil Action No.
+
+-against- 1:22-cv-10019-JSR
+
+Defendants.
+
+x
+
+Highly Confidential-Attorneys Eyes Only
+
+Videotaped oral deposition of JUSTIN NELSON, taken pursuant to subpoena, was held BOIES SCHILLER FLEXNER, 55 Hudson Yards,New York, New York commencing April 21, 2023, 9:42 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York.
+
+MAGNA LEGAL SERVICES
+
+(866) 624-6221
+
+www.MagnaLS.com
+
+![](_page_1_Picture_17.jpeg)
+
+2 discussion within that meeting that led to 09:45:54
+
+3 the conclusion that Jeffrey Epstein was going 09:45:56
+
+4 to be terminated as a client? 09:45:57
+
+5 A. I don't remember specifics. 09:45:59
+
+6 Q. What was your understanding as to 09:46:00
+
+7 the reason or reasons that Jeffrey Epstein 09:46:02
+
+8 was going to be terminated? 09:46:04
+
+9 A. Reputational risk. 09:46:06
+
+10 Q. By reputational risk, what did that 09:46:08
+
+11 mean in this particular context, that being 09:46:14
+
+12 related to Jeffrey Epstein? 09:46:16
+
+13 MR. BUTTS: Objection to form. 09:46:18
+
+14 You can answer. 09:46:20
+
+15 A. I think we are aware of the history 09:46:21
+
+16 of Jeffrey, Mr. Epstein, I think that's what 09:46:26
+
+17 went into that decision. 09:46:31
+
+18 Q. Do you remember there being a 09:46:32
+
+19 discussion about any specific banking 09:46:36
+
+20 activity in which he was engaged at the time, 09:46:39
+
+21 that being 2013 time period, that also 09:46:42
+
+22 contributed to that decision? 09:46:46
+
+23 MR. BUTTS: Objection to form. 09:46:47
+
+24 You may answer. 09:46:50
+
+25 A. I don't remember. 09:46:50
+
+2 Q. After Jeffrey Epstein has been 13:30:03
+
+3 terminated, you get the permission of John 13:30:04
+
+4 Duffy to continue a relationship with Jeffrey 13:30:10
+
+5 Epstein where he will be a potential source 13:30:13
+
+6 of future referrals? 13:30:15
+
+7 MR. BUTTS: Objection to form. 13:30:17
+
+8 You may answer. 13:30:19
+
+9 A. Yes. 13:30:19
+
+10 Q. Do you remember where you were when 13:30:19
+
+11 you had these discussions with Mr. Duffy? 13:30:21
+
+12 A. I do not. 13:30:23
+
+13 Q. Were you given any parameters of 13:30:24
+
+14 what is okay to do and what is not okay to do 13:30:27
+
+15 with respect to the relationship with Jeffrey 13:30:30
+
+16 Epstein? 13:30:33
+
+17 A. Yes. 13:30:33
+
+18 Q. What were they? 13:30:33
+
+19 A. We would not engage in any type of 13:30:35
+
+20 relationship where Mr. Epstein had control of 13:30:40
+
+21 a relationship, where we had to interface 13:30:43
+
+22 with him directly as a decisionmaker of any 13:30:46
+
+23 kind. 13:30:50
+
+24 Q. At some point in time, even if that 13:30:50
+
+25 was the objective from the beginning to make 13:30:54
+
+2 sure you didn't have to interface with him to 13:30:57
+
+3 get to a client, isn't that what happened 13:31:00
+
+4 with respect to Black? 13:31:03
+
+5 MR. BUTTS: Objection, 13:31:05
+
+6 mischaracterizes testimony. 13:31:07
+
+7 Q. You can answer. 13:31:09
+
+8 A. No because I never interfaced. We 13:31:12
+
+9 spoke to Mr. Epstein, but he was never a 13:31:17
+
+10 signer on an account for anyone else that we 13:31:22
+
+11 interacted with, he was not a decisionmaker. 13:31:25
+
+12 Q. Was there ever a point in time 13:31:30
+
+13 where Black was the client, but you and 13:31:33
+
+14 your team could only speak with Mr. Epstein 13:31:37
+
+15 as opposed to Mr. Black about the client 13:31:41
+
+16 relationship? 13:31:45
+
+17 MR. BUTTS: Objection. 13:31:46
+
+18 You may answer. 13:31:48
+
+19 A. We spoke to Mr. Epstein about 13:31:48
+
+20 things related to Black, but anything 13:31:51
+
+21 that -- to actually do anything with 13:31:56
+
+22 Black had to go through Black or his 13:32:00
+
+23 family office. 13:32:02
+
+24 Q. And Mr. Epstein was not able to be 13:32:03
+
+25 a signatory on Mr. Black's accounts, right? 13:32:10
+
+2 A. Correct. 13:32:13
+
+3 Q. Did there come a point in time 13:32:13
+
+4 where there was a signatory, but Jeffrey 13:32:16
+
+5 Epstein was the person that was making the 13:32:20
+
+6 calls for Mr. Black? 13:32:22
+
+7 MR. BUTTS: Objection to form. 13:32:25
+
+8 You may answer if you are able. 13:32:26
+
+9 A. There were times where Mr. Epstein 13:32:27
+
+10 had a recommendation, but I can't remember 13:32:32
+
+11 any of those things getting done, so, no. 13:32:38
+
+12 Q. How many times do you think you 13:32:43
+
+13 visited Mr. Epstein after he was terminated 13:32:48
+
+14 from JPMorgan? 13:32:52
+
+15 A. Several times. 13:32:54
+
+16 Q. By several, ballpark what do you 13:32:55
+
+17 think we are talking about? 13:33:01
+
+18 A. Eight to 10, in that range. 13:33:02
+
+19 Q. When is the last time that you 13:33:04
+
+20 remember visiting Jeffrey Epstein, what year? 13:33:05
+
+21 A. I don't remember. 13:33:08
+
+22 Q. Did you visit Jeffrey Epstein as 13:33:09
+
+23 late as 2017? 13:33:12
+
+24 A. It is possible. 13:33:14
+
+25 Q. Did you ever spend the night at any 13:33:16

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812868/EFTA02812868.md

@@ -0,0 +1,305 @@
+## EXHIBIT 77 FILED UNDER SEAL
+
+1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+2
+
+3 4 GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, CASE NO. 1:22-CV-10904
+
+5 Plaintiff, -JSR
+
+6 V.
+
+7 JPMORGAN CHASE BANK, N.A.,
+
+8 Defendant/Third Party Plaintiff.
+
+9
+
+10 JPMORGAN CHASE BANK, N.A.,
+
+11 Third Party Plaintiff,
+
+12 v.
+
+13 JAMES EDWARD STALEY,
+
+14 Third Party Defendant. :
+
+15 CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
+
+16
+
+17
+
+18 19 20 21 Videotaped deposition of JOHN R. DUFFY, taken pursuant to notice, was held at Wilmer Hale, Seven World Trade Center, New York, New York, beginning at 9:17 a.m., on the above date, before L. Gray, a Registered Professional Reporter, Certified Shorthand Reporter, Certified Realtime Reporter, and Notary Public.
+
+22
+
+23 GOLKOW LITIGATION SERVICES 877.370.3377 ph I 917.591.5672 fax deps@golkow.com
+
+24
+
+July 13, 2023
+
+1 A. Rephrase that, please.
+
+Q. At the end of your
+
+conversation with Mr. Staley, you still thought Mr. Epstein should be exited.
+
+A. I was of the opinion his reputational risk was not worth having him as an account, that's correct.
+
+8 Q. And, nevertheless, you signed the DDR allowing him to remain.
+
+A. I did.
+
+11 Q. And if you had declined to sign that, a widening of the circle would have occurred, at which more people would have discussed what to do with this business, right?
+
+A. The I felt like that had already happened.
+
+Q. Did you involve the CEO of the entire Private Bank in that conversation?
+
+A. I don't recall.
+
+Q. Did you involve Phil Di Iorio in that conversation?
+
+1 AFTERNOON SESSION
+
+2
+
+3 THE VIDEOGRAPHER: The time
+
+4 right now is 12:37 p.m. We're
+
+5 back on the record.
+
+6
+
+7 CONTINUED EXAMINATION
+
+8
+
+9 BY MR. SCHIFFMANN:
+
+10 11 12 13 14 Q. Mr. Duffy, at any point during your time as CEO of the U.S. Private Bank, did you become concerned by Mr. Epstein's use of cash from his JPMorgan accounts?
+
+15 16 17 18 19 A. I wasn't concerned about his use of cash. Large clients use cash in different ways. They are different than, you know, the average person on Main Street.
+
+20 21 22 23 24 But I did speak with Mr. Epstein about his use of cash and what it was for and made suggestions to him as it related to his response, which was for aviation fuel, to use his
+
+1 aviation account.
+
+Q. So your answer is no, you were not concerned about his use of cash?
+
+A. It wasn't -- it wasn't outsized in relation to what clients of Mr. Epstein's net worth or asset base has. And it wasn't unusual, as it related to what was expected in that account, and he was pretty consistent in 10 the use of that
+
+So we are always concerned about people who use cash and might be carrying cash around, because it's a liability for them.
+
+Q. So other than the size of -- well, strike that.
+
+So you've just testified that you weren't concerned about the size of the withdrawals. Did anything else about the cash withdrawals concern you while you were CEO of the U.S. Private Bank?
+
+ MR. : Objection.
+
+1 who take out cash regularly, we look for it to be consistent with what was expected for that account. And the DDR is the mechanism for setting the expectation of activity in an account. And Mr. Epstein's cash 8 withdrawals were consistent with the expectations as set by his DDR.
+
+11 BY MR. SCHIFFMANN:
+
+Q. So to answer my question, you did not -- you were not concerned about any aspect of his cash usage while you were CEO of the U.S. Private Bank?
+
+A. I was curious about it. I asked him about it.
+
+Q. But you were not concerned about it?
+
+A. No. We spoke about it. He gave me an answer, which was it was for jet fuel. I took him at his word and felt like I covered that with him.
+
+1 you believed him?
+
+2 A. I did.
+
+3 4 Q. Did you ever think he was being dishonest with you?
+
+5 A. No, I did not.
+
+6 Q. So did you always take
+
+7 Mr. Epstein at his word?
+
+8 A. We didn't talk that often.
+
+9 10 But on that -- on that matter in particular, yes.
+
+11 12 13 Q. Do you remember ever not taking him at his word during any of your conversations?
+
+14 A. They were limited, so no.
+
+15 16 Q. Did you ever discuss your concerns well, withdrawn.
+
+17 Did you ever discuss
+
+18 19 Mr. Epstein's use of cash with Mary Erdoes?
+
+20 A. Yes.
+
+21 22 23 Q. And what do you remember about -- well, when was that conversation?
+
+1 didn't think that it was appropriate?
+
+A. If I thought there was something inappropriate that Mr. Epstein was doing, then I wouldn't have approved it.
+
+Q. If it was your responsibility to continue the relationship, why did you initially decline to approve the account?
+
+10 A. In this review?
+
+11 Q. Yes.
+
+12 A. More information, from my perspective, since we had -- I had a discussion with Mr. Epstein about his use of cash to pay for fuel out of a Hyperion account. I was looking for consistency.
+
+Q. And if you found out more information that made you think that approving Mr. Epstein's account was inappropriate, you would have declined to approve it, right?
+
+A. If I thought there was anything he was doing that was wrong, a crime, illicit, I would not have approved
+
+1 e-mail, do you remember between -- 2 whether between 6:03 p.m. on March 27th and 6:25 p.m. on March 27th you had a conversation with Mr. Epstein about this particular cash withdrawal?
+
+MR. : Objection.
+
+THE WITNESS: I did not have 8 a conversation with him that I 9 recall on that day.
+
+BY MR. SCHIFFMANN:
+
+11 Q. So it stands to reason that when you wrote, "I previously spoke with Jeffrey Epstein about this activity," what you're referring to is his overall pattern of cash withdrawals, not this particular cash withdrawal?
+
+A. I don't -- I had a conversation with him about his cash withdrawals and aviation fuel. That's what I'm referring to there.
+
+Q. Do you remember ever speaking with him specifically about the August 1st -- sorry, about the one payment that references?
+
+1 A. It was.
+
+Q. And, obviously, it was before this these events transpired, right?
+
+A. It would -- it would have.
+
+Yes.
+
+Q. Did you -- do you remember 8 if it was a long time before or had you 9 just had that conversation?
+
+10 A. I don't recall.
+
+11 Q. What prompted you to speak 12 to Mr. Epstein about his cash usage?
+
+A. Cash is a funny asset. It brings liability to clients when they carry it around. Large clients often take large cash at different times of the year. Sometimes it's for household staff. Sometimes it's for holiday gifts. Sometimes it's for building personnel.
+
+So it's not uncommon to talk to a client about their cash.
+
+And with Mr. Epstein, as I've said to you previously, in gaining a broader picture of his account, I asked
+
+1 2 3 4 5 6 7 him about his cash and its usage, and he mentioned aviation fuel, particularly in parts of the world that can be a little bit more difficult to travel through. And where a U.S. bank card would typically not be accepted for payment, hence the OFAC.
+
+8 9 10 And as I previously mentioned, I took him at his word for that.
+
+11 12 13 14 Q. So after this deep dive by , why did you think you needed to speak to him again about the cash withdrawals?
+
+15 16 A. I don't recall. And I don't think we did. That's my recollection.
+
+17 18 19 20 21 Q. The last long sentence in this e-mail is, "Perhaps the best next step is for us to speak with Harry, who we know, and ask Harry about the cash withdrawals."
+
+22 Do you see that?
+
+23 A. I do.
+
+1 received the cash for fuel explanation -- 2 or you never looked into whether or not that explanation made sense, given that he had spent a considerable number of years in jail and then on house arrest?
+
+MR. Objection.
+
+THE WITNESS: Could you 8 repeat your question, please.
+
+MS. LIU: Can I have that question read back.
+
+(Whereupon, the court reporter read back the requested portions of the transcript.)
+
+THE WITNESS: That explanation, to me, was taken at face value and post the conversation with Mr. Epstein. Many of his cash activities, as recommended to him for his aviation fuel needs, were switched to his aviation account, Hyperion.
+
+BY MS. LIU:
+
+Q. Taken at face value, meaning you didn't do any digging into whether or 1 not that explanation made sense? You just took Mr. Epstein at his word, correct?
+
+4 A. I took Mr. Epstein at his word. And then following that, his cash activity for fuel came out of the Hyperion account, and that made sense.
+
+8 Q. It came out of the Hyperion account at your suggestion, correct?
+
+A. Well, it came -- if he is using money, his money for aviation purposes, it's common sense and good advice to give a client advice to make sure that money comes out of your aviation account so that when you're accounting for your aviation expenses, they are well documented.
+
+Q. But you knew that the money was simply being transferred into the aviation account a few days before it was then taken out of the aviation account, correct, Mr. Duffy? That's what the documents in this case show?
+
+1 trafficking business?
+
+2 MR. : Objection.
+
+3 THE WITNESS: I had no
+
+4 reason to believe that
+
+5 Mr. Epstein -- and at no point in
+
+6 time did I believe Mr. Epstein was
+
+7 committing criminal acts through
+
+8 JPMorgan, such as sex trafficking.
+
+9 BY MS. LIU:
+
+10 11 12 13 14 15 Q. So, therefore, you didn't look or have any of the people working for you at the Private Bank look at his transactions to see if any might have matched up with the allegations of sex trafficking; is that fair?
+
+16 17 18 A. No, that's not fair. Our risk and control teams monitor client cash activity.
+
+U
+
+20 21 Q. All right. So let's pull up Tab 12, please.
+
+22 23 24 THE COURT REPORTER: Is that something you're putting in the chat?
+
+1 about the Epstein link."
+
+Do you see that?
+
+A. I do.
+
+4 Q. What did you understand that to mean in February of 2014 when
+
+Mr. Saghri said to you, "We all remain very concerned about the Epstein link"?
+
+8 MR. : Objection.
+
+THE WITNESS: I do not have a recollection of that.
+
+11 BY MS. LIU:
+
+Q. So if you go up to the first page of the e-mail chain, you'll see at some point you -- second e-mail down on the first page, you sent an e-mail to Marcus Sheridan, Re: , and you say, "Sticky, Jeffrey cannot have POA."
+
+Do you see that?
+
+A. I do.
+
+Q. And I assume POA means power of attorney, correct?
+
+A. Yes, it does.
+
+Q. So at this point you thought it was possible that Jeffrey Epstein
+
+8 9 5 THE WITNESS: No. I just 6 was -- wanted to be clear with a 7 colleague that we would not accept Jeffrey as a power of attorney on another client's account.
+
+10 BY MS LIU:
+
+11 12 13 14 15 Q. Why did you think it was possible, at this time, that Jeffrey Epstein might want to be power of attorney on the account? Black family
+
+16 MR. : Objection.
+
+17 18 19 20 THE WITNESS: I don't know. I just wanted to be clear with a colleague that it wasn't a possibility.
+
+21 22 23 MS. LIU: Thank you for your time, Mr. Duffy. I have no further questions.
+
+1 would want to have power of attorney over 2 this relationship that you were building 3 with Black and his family, correct?
+
+4 MR. Objection.

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812884/EFTA02812884.md

@@ -0,0 +1,164 @@
+## EXHIBIT 78 FILED UNDER SEAL
+
+From: Reda, Christina M VOCORPEXCHANGE/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBONF23SPDLT)/CN=RECIPIENTS/CN=W0679801 Sent: 6/29/2011 1:03:30 PM To: McGraw, Subject: Attachments: Toni 1H2011 1- oc.zip
+
+TOM.
+
+Please find revised version of your mid-year accomplishments attached with this transaction added. Note that there are some yellow highlighted words towards the end of the document which indicate the spelling may be off. Please let me know if you would like any additions/changes.
+
+
+Christina
+
+Christina M. Reda Private Bank at J.P. I Advice Lab 270 Park Avenue, 26thi llog I New York. NY 10017 Telephone: (212) 464-0789 Email: christina.m.reda@jumorgan.com
+
+original messa e From: McGraw, sent: Tuesday, June 28, 2011 4:59 PM To: Reda, Christina M Cc: Racanelli Janine A. Subject:
+
+Christina - i have a number of credit related ex i ri . .le-'k a d hic resent one to m mid- ear as an exam le. It's
+
+
+Tom
+
+\*\* \*\*\*\*\*\* \*\*\* \*\*\*\*\* \*\*\*\*\*\*\*\*\*\*\*\* \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* \* \*\*\*\*\*\*\*\*\*\*\*\*\* \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* \*\*\*\*\*\* \*\*
+
+IRS Circular 230 Disclosure: JPMorgan chase & Co. and its affiliates do not provide tax advice. Accordingly, any discussion of u.s. tax matters contained herein (including any attachments) is not intended or written to be used, and cannot be used, in connection with the promotion, marketing or recommendation by anyone unaffiliated with JPMorgan Chase & Co. of any of the matters addressed herein or for the purpose of avoiding U.S. taxrelated penalties.
+
+Original a e From: McGraw, Sent: Tuesday, M728, 2011 4:S3 PM To: Dumont, Judith 0 Cc: Grimes. hn M. Louis M; Subject: , Eugene T; Mandelbaum, Joshua 14; Zimmermann,
+
+Redacted - Privileged
+
+# Redacted - Privileged
+
+Tom
+
+**IRS Circular 230 Disclosure:**
+
+JPMorgan Chase & Co. and its affiliates do not provide tax advice. Accordingly, any discussion of U.S. tax matters contained herein (including any attachments) is not intended or written to be used, and cannot be used, in connection with the promotion, marketing or recommendation by anyone unaffiliated with JPMorgan Chase & Co. of any of the matters addressed herein or for the purpose of avoiding U.S. tax-related penalties.
+
+
+From: Grimes, John M  
+Sent: Monday, June 27, 2011 1:10 PM  
+To: [REDACTED], Louis M; [REDACTED], Eugene T  
+Cc: Archer, Richard; Dumont, Judith O; Seaborn, Neal A; McGraw, [REDACTED]; Bleicher, Kimberly M; Mandelbaum, Joshua M; Zimmermann, [REDACTED] G  
+
+Lou,
+
+
+
+John
+
+John M. Grimes  
+JPMorgan Chase & Co.  
+1 Chase Manhattan Plaza, Floor 59  
+New York, NY 10005  
+Tel: (212) 552-4789  
+Fax: (212) 552-4902  
+john.m.grimes@jpmchase.com
+
+**IRS Circular 230 Disclosure:**
+
+JPMorgan Chase & Co. and its affiliates do not provide tax advice. Accordingly, any discussion of U.S. tax matters contained herein (including any attachments) is not intended or written to be used, and cannot be used, in connection with the promotion, marketing or recommendation by anyone unaffiliated with JPMorgan Chase & Co. of any of the matters addressed herein or for the purpose of avoiding U.S. tax-related penalties.
+
+----- Original Message -----
+
+From: [REDACTED], Louis M  
+To: Grimes, John M; [REDACTED], Eugene T  
+Cc: Archer, Richard; Dumont, Judith O; [REDACTED], Louis M; Seaborn, Neal A; McGraw, [REDACTED]; Bleicher, Kimberly M; Mandelbaum, Joshua M; Zimmermann, [REDACTED] G; [REDACTED], Eugene T  
+Sent: Mon Jun 27 09:44:55 2011  
+
+John/Gene,
+
+
+Thank you,
+
+Louis M. [REDACTED] CFP®  
+Executive Director  
+270 Park Avenue, Floor 19  
+New York, NY 10017
+
+212-464-0494 (phone)  
+212-464-0403 (fax)
+
+
+From: [REDACTED]  
+Sent: Monday, June 27, 2011 9:40 AM  
+To: [REDACTED], Louis M  
+
+Sent from my Verizon Blackberry
+
+
+IRS Circular 230 Notice: Any tax advice provided herein is not intended or written to be used, and cannot be used for, the purpose of a) avoiding penalties the IRS and others may impose on the taxpayer, or b) promoting, marketing or recommending to another party any tax related matters.
+
+
+----- Original Message -----  
+From: [REDACTED], Louis M < [REDACTED]\_louis@jpmorgan.com>  
+To: [REDACTED]  
+Sent: Mon Jun 27 09:31:01 2011  
+
+
+Regards,  
+Lou
+
+Louis M. [REDACTED] CFP®  
+Executive Director  
+270 Park Avenue, Floor 19  
+New York, NY 10017
+
+212-464-0494 (phone)  
+212-464-0403 (fax)
+
+From: [REDACTED]  
+Sent: Friday, June 24, 2011 11:52 AM  
+To: Romano, Louis M  
+
+
+Regards,
+
+
+
+IRS Circular 230 Notice: Any tax advice provided herein is not intended or written to be used, and cannot be used for, the purpose of a) avoiding penalties the IRS and others may impose on the taxpayer, or b) promoting, marketing or recommending to another party any tax related matters.
+
+
+
+From: [Redacted]  
+Sent: Thursday, June 23, 2011 8:31 PM  
+To: '[Redacted] pmorgan.com'  
+Subject: [Redacted]
+
+Lou,
+
+
+IRS Circular 230 Notice: Any tax advice provided herein is not intended or written to be used, and cannot be used for, the purpose of a) avoiding penalties the IRS and others may impose on the taxpayer, or b) promoting, marketing or recommending to another party any tax related matters.
+
+original message
+
+From:
+
+To:
+
+Sent: Thu Jun 23 20:22:57 2011
+
+subject:
+
+From:
+
+Sent: Thursday, June 23, 2011 11:46 AM
+
+To:
+
+Subject:
+
+
+
+
+
+
+
+
+
+
+IRS Circular 230 Notice: Any tax advice provided herein is not intended or written to be used, and cannot be used for, the purpose of a) avoiding penalties the IRS and others may impose on the taxpayer, or b) promoting, marketing or recommending to another party any tax related matters.
+
+
+This message contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended solely for the use of the addressee(s) named above. Any disclosure, distribution, copying or use of the information by others is strictly prohibited. If you have received this message in error, please notify the sender by immediate reply and delete the original message. Thank you.
+
+This email is confidential and subject to important disclaimers and conditions including on offers for the purchase or sale of securities, accuracy and completeness of information, viruses, confidentiality, legal privilege, and legal entity disclaimers, available at <http://www.jpmorgan.com/pages/disclosures/email>.

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812892/EFTA02812892.md

@@ -0,0 +1,197 @@
+## EXHIBIT 79 FILED UNDER SEAL
+
+UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 2 - - -
+
+GOVERNMENT OF THE UNITED : Case Number: STATES VIRGIN ISLANDS : 1:22-cv-Plaintiff, : 10904-JSR JPMORGAN CHASE BANK, N.A. Defendant/Third-Party Plaintiff.
+
+7 JPMORGAN CHASE BANK, N.A. Third-Party Plaintiff, : 8 JAMES EDWARD STALEY 9 Third-Party Defendant. :
+
+10
+
+11 MAY 24, 2023 HIGHLY CONFIDENTIAL
+
+12
+
+13 Videotaped deposition of
+
+14 STEPHEN CUTLER, taken pursuant to notice,
+
+15 was held at the law offices of Boies
+
+16 Schiller Flexner LLP, 55 Hudson Yards,
+
+17 New York, New York, commencing at
+
+18 9:40 a.m., on the above date, before
+
+19 Amanda Dee Maslynsky- , a Certified
+
+20 Realtime Reporter and Notary Public in
+
+21 and for the State of New York.
+
+22 \_ \_ \_ GOLKOW LITIGATION SERVICES, INC. 23 877.370.3377 phI 917.591.5672 fax deps@golkow.com
+
+24
+
+2
+
+3
+
+4
+
+5
+
+6 BY MS. LIU:
+
+7 8 9 10 11 12 13 14 Q. But you do remember and you reviewed documents that reminded you, or refreshed your recollection, Mr. Cutler, correct, that on multiple occasions, as the top lawyer at the company, you said to business, I do not want this person, Jeffrey Epstein, as a client of the bank, correct?
+
+15 16 A. I know that I said that in 2011. I do.
+
+17 18 Q. But he remained a client of the bank until August of 2013, correct?
+
+19 A. Or thereabouts, yes.
+
+20 Q. Who overruled you?
+
+21 MR. GAIL: Objection.
+
+22 BY MS. LIU:
+
+23 Q. Mr. Cutler --
+
+1 matter of being overruled, but I believe that Mr. Staley and -- and others in the business decided that we should retain Mr. Epstein as a client, notwithstanding my concerns that his continuing to have an account at JPMorgan created a reputational risk for the firm.
+
+Q. And who are the others that you mentioned?
+
+A. Well, I don't think that an account for a private bank customer gets retained unless the private bank wants to retain the account and the head of asset management, to whom the private bank reports, wants to retain that account.
+
+And then I know in this case Mr. Staley remained involved, given that he was a primary relationship with the account.
+
+Q. The head of asset management at the time was Mary Erdoes, correct?
+
+A. Correct. Sorry, in 2011, we're talking about, yeah.
+
+consistent, yes.
+
+BY MS. LIU:
+
+Q. And it's also consistent that JPMorgan retained Jeffrey Epstein as a client to deal with the Bear Stearns litigation that Jeffrey Epstein had, correct?
+
+A. I don't know that.
+
+Q. Because then she writes, I reminded him that we have the other matter outstanding.
+
+Do you see that?
+
+A. I do.
+
+Q. So we had the one, it's been approved, settlement is done. But Steve, from Nina, we've got that other litigation with Jeffrey Epstein.
+
+Do you recall that?
+
+A. I don't.
+
+Q. Do you recall the Zwirn
+
+Highbridge litigation?
+
+A. I've now seen documents that remind me there was -- there was another claim that Epstein had.
+
+1 2 3 Epstein's suggestion, to make this elaborate presentation about the world's largest donor-advised fund, correct?
+
+4 5 6 7 8 9 A. If you're asking me if I think we kept Mr. Epstein as a client because of some dealings with the Gates Foundation, I don't think so. But -- I'm sure we'll get to that, but I don't think SO.
+
+10 11 12 13 Q. So you have no reason to disagree that the other matter outstanding was the Highbridge litigation by Jeffrey Epstein, correct?
+
+14 15 16 A. I just don't know what - what Ms. Shenker was talking about in this e-mail to Ms. Erdoes.
+
+17 18 19 20 Q. And what was the Jeffrey Epstein Highbridge litigation that was still outstanding at this time that you were not off-boarding Jeffrey Epstein?
+
+21 MR. GAIL: Objection.
+
+22 23 24 THE WITNESS: I don't -- I don't remember what the -- that litigation, again, assuming that 1 it was litigation, was about.
+
+2 I also don't know that we
+
+3 were not off-boarding Mr. Epstein
+
+4 because of that litigation or
+
+5 litigation claim.
+
+6 BY MS. LIU:
+
+7 Q. So why were you retaining
+
+8 Jeffrey Epstein at this time?
+
+9 MR. GAIL: Objection.
+
+10 THE WITNESS: Why was
+
+11 JPMorgan? I don't know all the
+
+12 reasons.
+
+13 BY MS. LIU:
+
+14 Q. Do you know any of the
+
+15 reasons, Mr. Cutler?
+
+16 A. Well, I know that at least
+
+17 Mr. Staley felt very strongly that
+
+18 Mr. Epstein had paid his debt to society,
+
+19 had served his time, and was someone that
+
+20 a lot of other people trusted. I think
+
+21 Mr. Staley didn't agree with the notion
+
+22 that we shouldn't have him as a client.
+
+23 Q. But, yet, Nina Shenker is
+
+1 You wrote that, correct?
+
+2 A. Yes.
+
+3 4 5 Q. Why did you write "it's another to be paying him"? What did you mean by that?
+
+6 7 8 9 10 11 A. I'll reiterate what I said before. I think that, essentially, would make Mr. Epstein our business partner, and I didn't think, given the reputational issues, that JPMorgan ought to be business partners with Mr. Epstein.
+
+12 13 14 15 16 17 Q. Do you recall that that Gates Foundation project that Mary Erdoes, Jes Staley and with which you were at least partially involved with Jeffrey Epstein, ultimately didn't go through?
+
+18 19 20 21 A. Again, that's my recollection, that we did not do -- JPMorgan did not do a Gates Foundation project.
+
+22
+
+23 24 (Whereupon, Exhibit Cutler-26, JPM-SDNYLIT-00136260, 1
+
+2 3 4 5 6 Q. And do you recall what he said to you or what you -- what you remember about any conversations that happened between someone at JPMorgan and Ken Starr related to Jeffrey Epstein?
+
+7 8 9 10 11 12 A. My best recollection is we were trying to ascertain whether there was, in fact, an ongoing investigation, that is, an investigation of, you know, current conduct, or call it post-conviction conduct.
+
+13 14 15 16 17 And I don't remember the result of the call with Starr, other than we certainly didn't glean from that communication that he thought there was such an investigation.
+
+18 19 Q. Why was that the question you were asking?
+
+20 21 22 A. I don't know if that was the only question. It may have been a character reference kind of thing.
+
+23 24 But at that time, I think we were looking at the account again. There
+
+1 ongoing human trafficking through Jeffrey Epstein?
+
+A. Here is what I was interested in: If Mr. Epstein was continuing to engage in unlawful activity, we didn't want him as a client.
+
+We understood that he had engaged in unlawful activity in the past. That, itself, raised issues. But we were 10 continuing to serve as his bank and 11 maintain his accounts.
+
+If he was involved in in -- if he continued to be involved in criminal activity, we did not want to maintain those accounts.
+
+Q. And what did you do to determine whether or not Jeffrey Epstein was continuing to be involved in criminal activity, namely human trafficking?
+
+A. Right. I -- again, I would not have personally been involved in that. But we had a compliance department and an anti-money laundering function with well-regarded people. And I trusted

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812892/EFTA02812892.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812902/EFTA02812902.md

@@ -0,0 +1 @@
+## EXHIBIT 80 FILED UNDER SEAL

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812902/EFTA02812902.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812903/EFTA02812903.md

@@ -0,0 +1,59 @@
+## EXHIBIT 81 FILED UNDER SEAL
+
+GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS,
+
+Plaintiff,
+
+v.
+
+JPMORGAN CHASE BANK, N.A.,
+
+Defendant/Third-Party Plaintiff
+
+JPMORGAN CHASE BANK, N.A.,
+
+Third-Party Plaintiff,
+
+v.
+
+JAMES EDWARD STALEY,
+
+Third-Party Defendant.
+
+UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+Case No. 22-cv-I0904-JSR
+
+Expert Report of Special Agent Fonseca, FBI (Retired) on behalf of JPMorgan Chase Bank, N.A.
+
+June 23, 2023
+
+programs designed to identify the transfer of child sexual abuse material, additionally known as child pornography.
+
+- 8. I have investigated cases involving the transport and exploitation of women and children across the U.S. border, state lines, and in other countries. I have had the opportunity to assist in the prosecution of more than 100 sexual exploitation cases, with many culminating in trials.
+- 9. I have trained with numerous foreign law enforcement officers and learned of different trafficking techniques to gain an understanding how certain trafficking crimes and crimes against children can be investigated and prosecuted in the U.S. I have investigated these trafficking and crimes against children cases with the assistance of financial records obtained from businesses (hotels, car rental companies, apartment complexes, etc.), financial institutions, money providers (companies such as Western Union and MoneyGram), and prepaid debit cards (such as GreenDot).
+- 10. In 2021, I finished my FBI career as a Counselor for new agent trainees at the FBI Academy in Quantico, Virginia.
+- 11. I am being compensated for my review, analysis, and time in this case at a rate of \$125.00 per how.
+- 12. My compensation is not contingent upon offering any specific opinions or on the outcome of this matter.
+
+## Summary of Opinions:
+
+- 13. 1 was engaged by Wilmer Cutler Pickering Hale and Dorr LLP (Counsel), counsel for JPMorgan Chase Bank N.A. (JPMC or the Bank) to provide an expert opinion and potentially expert testimony in the matter of Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 22-cv-10904 (JSR) (S.D.N.Y.) (the Epstein Litigation).
+- 14. I have reviewed the Second Amended Complaint filed by the Government of the United States Virgin Islands (USVI) in this case and understand that it alleges that JPMC intentionally obstructed the federal government's enforcement of the Traffickin Victims Protection Act, 18 U.S.C. § 1591, against Jeffrey Epstein and "permitting" Epstein to wit w arge amounts of cash from his accounts.' ounsel requested that I provide an opinion ardin
+- 15. In my opinion, based on my review of the materials identified in Appendix B to this Report and my years of experience investigating crimes against children and sex trafficking cases as a Special Agent for the FBI, one or more additional SARs related to Epstein filed by JPMC would not have resulted in an earlier arrest of Epstein nor would
+
+Second Amended Complaint?' 147-168, Government of the United States Virgin Islands v. JPMorgan Chase Bank. N.A.. No. 22-o,--10904 (JSR) (S.D.N.Y.), Dkt. No. 120.
+
+. My conclusion is informed by the allegations a ut Epstein's co net, particularly the allegations about his use of relatively small amounts of cash to compensate women for sexual experiences, the evidence available to investigators in their investigation into Epstein from 2005-2008, publicly available information about Epstein that law enforcement would have been aware of, including allegations in the media about his conduct
+
+- 16. To begin with, over the course of my career, I have never relied on a SAR while investigating a person on charges of sex trafficking. The simple reason for this is due to the victim-centered approach the FBI utilizes when conducting an investigation into sex trafficking.
+- 17. The victim-centered approach to investigating sex trafficking cases focuses on making sure the victim feels safe, secure, and stable. Once victims are safely recovered and supported, they are then able to provide the most important piece of evidence in a sex trafficking case — their testimony. Victim testimony is essential to describe the manner and method of a victim's trafficking, the relevant details of their exploitation and abuse, and anything of value given to or received by any person for a sex act by the victim. In the typical sex trafficking case, investigators would then work to find the best evidence to corroborate the various aspects of the victim's testimony in order to prove sex trafficking-related charges.
+- 18. Based on my experience as an FBI SA, SARs are not useful in sex trafficking or crimes against children investigations because they are unlikely to directly corroborate a victim's testimony or provide evidence of the sex trafficking of a victim. Without direction from a victim alleging the existence of a trafficking operation and describing the manner and method of payment in a way that reasonably matches the transaction activity that potentially could be flagged in a SAR, law enforcement would be unable to determine whether a cash or wire transaction that may be reported in a SAR was related to any trafficking activi
+- 19. It is also my opinion that investigators have an obligation to affirmatively recover evidence they believe is relevant to their investigation. As such, if the FBI had continued to investigate Epstein's conduct following his Florida state conviction in June 2008, and believed that further evidence of his financial activity was relevant to that investi ation. there was enou information available to law enforcement both an m t e pu reco to a ow investigators to eva uate Epstem's activity an more importantly, to know that they should look to JPMC as a source of additional financial information if they felt it was necessary. Specifically, the FBI would have known at all times after 2008 that it could send a
+
+I have also reviewed. relied upon. and agree with the conclusions in the expert report of Teresa A. Pesce.
+
+**Signature**
+
+I declare, under the penalty of perjury, under the laws of the United States of America, that the foregoing is true and correct. Signed this 23rd day of June, 2023:
+

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812908/EFTA02812908.md

@@ -0,0 +1,33 @@
+## EXHIBIT 82
+
+## modeling agent Jean-Luc Brunel found dead in prison cell
+
+By Goillandeau, CNN
+
+Updated 3:38 AM EST, Mon February 21, 2022
+
+![](_page_1_Picture_5.jpeg)
+
+cl Video Ad Feedback
+
+Longtime Epstein associate found dead in prison cell
+
+01:36 Source caN
+
+(CNN) — modeling agent Jean-Luc Brunel, a longtime associate of disgraced financier Jeffrey Epstein, has been found dead in his prison cell, a spokesperson for the Paris prosecutor's office said.
+
+capital at around 1:30 a.m. local time on Saturday, the prosecutor's office told X CNN. It would not comment on whether Brunel killed himself, adding an investigation into the cause of death has been opened, "as it is systematically done in these cases," entrusted to the judicial police.
+
+Brunel's lawyers told CNN their client's "decision was not guided by guilt, but by a sense of injustice."
+
+"Jean-Luc Brunel has never stopped claiming his innocence. He has multiplied his efforts to prove it. A judge had released him a few months ago, and then he was reincarcerated in undignified conditions," a statement sent to CNN by his lawyers Mathias Chichportich, Marianne Abgrall and Christophe Ingrain read.
+
+Accused of rape by several former top models, which he denied, the 75-year-old was put under formal investigation in France in late June 2021 for "rape of a minor over 15," the prosecutor's office confirmed.
+
+Brunel was arrested at Paris Charles de Gaulle Airport in December 2020 on counts of "rape and sexual assault, rape and sexual assault on a minor under 15, rape and sexual assault on a minor over 15, sexual harassment, criminal associations and human trafficking to the detriment of minor victims for the purposes of sexual exploitation."
+
+He was released under judicial supervision for a few days in November 2021, before being returned to prison by decision of the Paris Court of Appeals. He appealed the decision as the prosecution prepared its case.
+
+Brunel's arrest was part of a probe launched in 2019 by prosecutors, targeting "acts of sexual nature likely to have been committed by Jeffrey Epstein and possible accomplices," based on checks and cross-checks carried out on information provided to the Paris public prosecutor's office and exchanges with US authorities.
+
+Epstein was found dead in his prison cell in the United States on August 10, 2019. He was awaiting trial at the Metropolitan Correctional Center in Manhattan, after pleaded not guilty to federal charges accusing him of operating a sex trafficking ring from 2002 to 2005 at his Manhattan mansion and his Palm Beach estate, and allegedly paying girls as young as 14 for sex.

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812911/EFTA02812911.md

@@ -0,0 +1,95 @@
+## EXHIBIT 83
+
+# Gothamist
+
+Donate
+
+![](_page_1_Picture_27.jpeg)
+
+![](_page_1_Picture_28.jpeg)
+
+NEWS
+
+## Billionaire Jeffrey Epstein Arrested For Sex Trafficking
+
+![](_page_1_Picture_31.jpeg)
+
+AP
+
+![](_page_1_Picture_33.jpeg)
+
+**By Jen Chung**
+
+Published Jul 7, 2019
+
+Modified Jul 7, 2019
+
+[13 comments](#)
+
+Share
+
+![](_page_1_Picture_39.jpeg)
+
+![](_page_1_Picture_40.jpeg)
+
+![](_page_1_Picture_41.jpeg)
+
+![](_page_1_Picture_42.jpeg)
+
+## We rely on your support to make local news available to all
+
+Make your contribution now and help Gothamist thrive in 2023 Donate today
+
+Jeffrey Epstein. the billionaire who has been accused of molesting young girls for decades, has been arrested for sex trafficking.
+
+The 12ajW Beast first reported that he was apprehended for 'allegedly sex trafficking dozens of minors in New York and Florida between 2002 and 2005, and will appear in court in New York on Monday, according to three law enforcement sources. Saturday's arrest by the FBI-NYPD Crimes Against Children Task Force comes about 12 years after the 66-year-old financier essentially got a slap on the wrist for allegedly molesting dozens of underage girls in Florida.'
+
+Jim DeFede • Jul 6, 2019
+
+![](_page_2_Picture_7.jpeg)
+
+@DeFede • Follow
+
+BREAKING: @CBSMiami has learned that Jeffrey Epstein was arrested late this afternoon at Teterboro Airport in New Jersey after his private jet landed there from Paris. He was taken into custody by federal agents.
+
+Jim DeFede
+
+@DeFede • Follow
+
+A source familiar with the case told @CBSMiami , Epstein was arrested under a sealed indictment out of @SDNYnews, charged with one count of sex trafficking and one count of conspiracy to commit sex trafficking. A bond hearing is set for Monday in New York. @CBSMiami
+
+9:43 PM • Jul 6, 2019 0
+
+![](_page_2_Picture_14.jpeg)
+
+After being accused of orchestrating a "sexual pyramid scheme' involving young girls and wealthy men (the girls were allegedly told they could make money giving men massages and encouraged to bring in other girls) in New York and Florida. Epstein managed to cut a plea deal in 2007 with then-U.S. Attorney/ now current U.S. Secretary of Labor Alex Acosta. In 2018. the Miami Herald revealed that the arrangement was "the deal of a lifetime." From g Herald report in May:
+
+The controversial agreement negotiated by Acosta allowed Epstein to escape federal sex trafficking charges, even though evidence showed that Epstein had molested more than three dozen girls at his Palm Beach mansion in the 1990s and early 2000s. The victims were never told about the deal, which Acosta then sealed — thereby making it impossible for anyone, including his victims, to find out what crimes Epstein had committed and whether there were any other victims or accomplices involved.
+
+In February, U.S. District Court Judge Kenneth A. Marra declared that the non-prosecution agreement was illegal because it violated the Crime Victims Rights Act, designed by Congress to prevent crime victims from being ignored in the criminal justice process. In this case, the judge ruled, federal prosecutors deliberately hid the agreement from Epstein's victims in violation of the law
+
+Epstein was a prominent donor to Democrats (who returned the money after he was convicted), and was friendly with Prince Andrew; president Bill Clinton.Man Dershowitz; and future president Donald Trump, who once said of Engel'. "I've known Jeff for fifteen years. Terrific guy. He's a lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it - Jeffrey enjoys his social life."
+
+The Herald also managed to identify dozens of women who said they were abused by Epstein, and spoke to eight on the record. One woman who was abused at age 14 said, "You can't ever stop your thoughts. A word can trigger something. For me, it is the word 'pure' because he called me 'pure' in that room and then I remember what he did to me in that room."
+
+After Epstein served a short prison sentence at a cushy federal prison (the NY Times. "His jail arrangement allowed him to get out of the Palm Beach County Stockade six days a week to work out of his office"), in 2011 he souglit to avoid Level 3 sex offender statusin New York City. However, in spite of the Manhattan Assistant District Attorney Jennifer Gaffney attempted to have him classified as a Level 1 sex offender, &judge refused. According to the Daily News, Judge Ruth Pickholtz of the New York Supreme Cour said that the time, "I have to tell you, I'm a little overwhelmed because I have never seen a prosecutor's office do anything like this. I have done so many [sex offender registration hearings] much less troubling than this one where the [prosecutor] would never make a downward argument like this:
+
+The Manhattan DA's office said last ylar that there was no dealing on behalf of Epstein, noting that the office previously admitted admitted that Gaffney "made a mistake (in open court) by
+
+misreading the Sex Offender Registration Act provision about what you have to include and exclude from the score."
+
+Last week, the 2nd Circuit Court of Appeals ordered that almost 2 OOO pages of documents from Epstein's case be unsealed. It's believed that Epstein's friends may be named as well, leading to the court to warn the media, 'We have long noted that the press plays a vital role in ensuring the public right of access.\_ At the same time, the media does the public a profound disservice when it reports on parties' allegations uncritically"
+
+A doorman who works near Epstein's Upper East Side townhouse told the NY Post "Me and my partner heard a big bang... They broke the door down — FBI, cops... They just went in with bags."
+
+When questioned about being a sex offender by a Post reporter in 2O11, Epstein said, 'I'm not a sexual predator, I'm an 'offender.' It's the difference between a murderer and a person who steals a bagel."
+
+Tagged (ALEX ACOSTA) (FLORIDA) JEFFREY EPSTEIN (SEX TRAFFICKING (U.S. ATTORNEY
+
+![](_page_4_Picture_7.jpeg)
+
+Jen Chung
+
+Jen Chung is a former WNYC and Gothamist editor.
+
+Read more

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812916/EFTA02812916.md

@@ -0,0 +1,127 @@
+# EXHIBIT 84
+
+#### Virgin Islands Code Annotated Currentness
+
+#### Title 14. Crimes
+
+#### Chapter 86. Sexual Offender Registration and Community Protection
+
+14 V.I.C. § 1724
+
+1724 Registration requirements
+
+(a) A sex offender required to register in this territory of the United States Virgin Islands under this chapter shall appear in person, unless otherwise required, in accordance with the policies and procedures of the Department of Justice, to register with the Department of Justice on forms provided by the Attorney General of the United States Virgin Islands and shall do so in the following time frame:
+
+(1) A person required to register and who is under supervision in the community on probation, parole, furlough, work release, or a similar program shall register within three (3) business days of being placed under supervision.
+
+(2) A person convicted by the courts of this territory for a covered sex offense and incarcerated or confined in a correctional or juvenile facility or a psychiatric facility within or outside of this territory must register before being released from incarceration or detention.
+
+(3) A person convicted by the courts of this territory for a covered sex offense but is not incarcerated, under supervision or confined must register within three (3) business days of sentencing.
+
+(4) A person who is convicted in any state, territory or Indian tribe of the United States, any foreign jurisdiction or in any federal or military court of one of the covered offenses or an offense similar to one of the covered offenses who moves to or returns to the United States Virgin Islands from another jurisdiction for the purpose of establishing residency, employment, or becoming a student or who did not intend to but who eventually establishes residency, obtains employment or becomes a student within the jurisdiction of this territory shall register within three (3) business days of moving to or returning to the Territory.
+
+(b) All sex offenders required to register in this jurisdiction shall immediately notify the Department of Justice in writing to report the following changes within the prescribed time period and in accordance with the following:
+
+(I) Except as indicated in 1724(b)(4) below, all sex offenders required to register in this jurisdiction shall appear in person at the Department of Justice within three (3) business days after a change is made to update any changes to their name, residence (including termination of residency), temporary lodging information, vehicle information, intend identifiers, or telephone numbers. In the event of a change in temporary lodging, all sex offenders required to register in this jurisdiction shall within three (3) business days inform the Department of Justice, in person, of any changes to their temporary lodging information and both the sex offender and the Department of Justice shall notify within three (3) business days the jurisdiction in which the sex offender will be temporarily staying.
+
+(2) Any sex offender who is a student in any capacity including, but not limited to, an intern or apprentice within the jurisdiction of the territory of the United States Virgin Islands, regardless of location, that changes their school, or otherwise terminates their schooling, or resumes their schooling shall within three (3) business days appear in person at the Department of Justice to update that information. The Department of Justice shall ensure that each jurisdiction in which the sex offender is required to register, or was required to register prior to the updated information being given, are notified within three (3) business days of the change.
+
+(3) Any sex offender who is employed in the territory of the United States Virgin Islands in any capacity, including, but not limited to the Government of the Virgin Islands or a private employer or is otherwise employed within the territory of the United States Virgin Islands, regardless of location, that changes their employment, or otherwise terminates their employment, shall appear within three (3) business days in person at the Department of Justice to update that information. The Department of Justice shall ensure that each jurisdiction in which the sex offender is required to register prior to the updated information being given, are notified within three (3) business days of the change.
+
+(4) All sex offenders required to register in this jurisdiction shall appear in person at the Department of Justice at least twenty one (21) calendar days prior to any intended travel outside of the United States and provide information about their intended travel as provided in section 1726; however, a sex offender who provides reasonable and reliable proof satisfactory to the Department of Justice, that he travels frequently outside the United States for work or other legitimate purposes, or a sex offender who travels outside the United States for emergency situations, shall notify the Department of Justice prior to departure, by telephone or in writing, of travel outside the United States for periods of 48 hours or less, and shall notify the Department of Justice in writing at least 24 hours before traveling outside of the United States for periods of more than 48 hours, and, in any such case, shall notify the Department of Justice in writing upon the sex offender's return to this jurisdiction; provided, however that the Attorney General may at his discretion reduce this twenty-one (21) day notice requirement if a sex offender requests such a reduction and provides information in support of the request.
+
+(c) Before moving from the United States Virgin Islands to another jurisdiction within the United States, a person required to register shall register his new address, temporary or permanent, with the Department of Justice before he leaves the territory. Upon arriving in the new state, territory or Indian tribe, a person required to register shall report said arrival to the Department of Justice and register with the agency responsible for registering sex offenders in the new state, territory or Indian tribe of residency within three (3) days of his arrival. The registration information of that person will be removed from the Virgin Islands registry when proof is provided showing that he is registered in the new state, territory or Indian tribe. If a person required to register moves to a foreign country, he must register his new address with the Department of Justice before he leaves the territory and register in the foreign country if there is a registration requirement in that country.
+
+(d) A sex offender who is required to register shall, at a minimum, appear in person at the Department of Justice for the purposes of verification and keeping their registration current in accordance with the following time frames:
+
+(I) For 'Tier offenders, once every year for 15 years from the time of release from custody for a sex offender who is incarcerated for the registration offense or from the date of sentencing for a sex offender who is not incarcerated for the registration offense.
+
+(2) For a 'Tier 2` offenders, once every IS0 days for 25 years from the time of release from custody for a sex offender who is incarcerated for the registration offense or from the date of sentencing for a sex offender who is not incarcerated for the registration offense.
+
+(3) For 'Tier 3' offenders, once every 90 days for the rest of their lives.
+
+(4) For sex offenders classified in Tier I, Tier 2 or Tier 3 who are homeless, once every week for the period of years prescribed above based upon his or her tier classification until he or she declares a permanent residence after which the frequency of registration shall be as prescribed above according to his or her tier classification.
+
+(e) A sex offender may have their period of registration reduced as follows:
+
+(I) A 'Tier I' sex offender may have his or her period of registration reduced to 10 years only after he or she has maintained a clean record for 10 consecutive years and the Sex Offender Registry Board has made a favorable detennination regarding the risk of re-offense and the degree of dangerousness the sex offender poses to the community.
+
+(2) A 'Tier 3' sex offender may have his or her period of registration reduced to 25 years only if he or she was adjudicated delinquent of an offense as a juvenile that required Tier 3 registration and he or she has maintained a clean record for 25 consecutive years and the Sex Offender Registry Board has made a favorable determination regarding the risk of re-offense and the degree of dangerousness the sex offender poses to the community.
+
+(f) For the purposes of this chapter, a sex offender has a clean record which would allow for the reduction of his or her period of registration if:
+
+(I) The sex offender has not been convicted of any offense, for which imprisonment for more than 1 year may be imposed;
+
+(2) The sex offender has not been convicted of any sex offense;
+
+(3) The sex offender has successfully completed, without revocation, any period of supervised release, probation, or parole; and
+
+(4) The sex offender has successfully completed an appropriate certified sex offender treatment program.
+
+(g) All in person appearances to register or to keep registration current must be in accordance with the following:
+
+(1) At each in person verification, the sex offender shall permit the Department of Justice to take a photograph of the offender.
+
+(2) At each in person verification, the sex offender shall review existing information maintained by the Department of Justice for accuracy.
+
+(3) If any new information or change in information is obtained at an in person verification, the Department of Justice shall immediately notify all other jurisdictions in which the sex offender is required to register of the information or change in information.
+
+(4) The sex offender shall provide any additional information required by the Attorney General.
+
+(5) If any new information or change in information is obtained at an in person verification, the Department of Justice shall immediately update the public website, if applicable, and update information in NCICJNSOR.
+
+## Credits
+
+-Added Oct. 31, 1997, No. 6182, § I, Sess. L. 1997, p. 95; amended Aug. 17, 1999, No. 6285, § 3(b), Sess. L. 1999, p. 34; July 18, 2012, No. 7372, § 6(1)-(11), Sess. L. 2012, p. 136-140; amended Dec. 14, 2012, No. 7458, § 5(1)-(3), Sess. L. 2012, p. 412-413.
+
+#### HISTORY
+
+#### Revision notes.
+
+'Virgin Islands' was substituted for 'United States Virgin Islands' pursuant to the Revised Organic Act of 1954.
+
+Substituted 'October 31, 1997' for 'the effective date of this Act' wherever it appeared in subsection (a) for purposes of clarity.
+
+# Amendments -2012.
+
+Act 7372, § 6(1), rewrote the introductory language in subsection (a).
+
+Act 7372, § 6(2), rewrote subsection (aX1).
+
+Act 7372. § 6(3). rewrote subsection (aX2).
+
+Act 7372, § 6(4), rewrote subsection (4X3).
+
+Act 7372, § 6(5), rewrote subsection (aX4).
+
+Act 7372, § 6(6). rewrote subsection (b).
+
+Act 7372, § 6(7), rewrote subsection (c).
+
+Act 7372, § 6(8), rewrote subsection (d).
+
+Act 7372, § 6(9), rewrote subsection (e).
+
+Act 7372, § 6(10), rewrote subsection (0.
+
+Act 7372, § 6(11), rewrote subsection (g).
+
+Act 7458, § 5(1), substituted 'notify' for appear in person at' in subsection (b).
+
+Act 7458, § 5(2), inserted 'in writing' following 'Department of Justice' in subsection (b).
+
+Act 7458, § 5(3), substituted 'provided in § 1726; however, .. shall notify the Department of Justice in writing upon the sex offender's return to this jurisdiction' for 'may be required by the Attorney General' in subsection (bg4).
+
+# Annotations
+
+# I. Registration.
+
+It was error for the trial court to tell defendant that he could register as a sex offender within five years of his release, as the statute required him to register before his release. Hightree v. People of the Virgin Islands, 60 V.I. 514, 2014 V.I. Supreme LEXIS I I (VI 2014).SUPREME COURT OF THE VIRGIN ISLANDS
+
+14 V.I.C. § 1724, VI ST T. 14 § 1724
+
+Statutes current through Act 8699 of the 2022 session of the 34th Legislature, including all code changes through March 15,2023
+
+Copyright C 2023 Office of the Code Revisor. Legislature of the Virgin Islands All rights reserved.
+
+End or Document C 2023 Thomson Reuters. No claim to original U.S. Government Works.

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812916/EFTA02812916.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812921/EFTA02812921.md

@@ -0,0 +1 @@
+## EXHIBIT 85 FILED UNDER SEAL

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812921/EFTA02812921.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812922/EFTA02812922.md

@@ -0,0 +1,67 @@
+# EXHIBIT 86
+
+# VIRGIN ISLANDS PORT AUTHORITY POLICE MANUAL
+
+![](_page_1_Picture_2.jpeg)
+
+P.O. Box 301707 St. , VI 00803
+
+Tel: (340) 774-1629 Fax: (340) 714-1494
+
+# 19. PATROL SECTORS
+
+#### 19.1 Purpose
+
+Establish policy and procedures concerning geographically designated patrol responsibilities to ensure appropriate police atrol coverage of the VIPA, designate responsibilities, and to prioritize requirements.
+
+#### 19.2 Patrol Sector Policy
+
+19.2.1 Three sectors are established to provide necessary police patrol coverage for the airport in accordance with requirements and available as follows:
+
+- (a) "Screening Sector" The three passenger areas. This is a foot patrol. Due to a FAA requirement to respond to each screening point within ten (10) minutes, the officer assigned to calls to this area must not compromise that FAA requirement.
+- (b) "Patrol Sector" The Airport Operations Area or AOA. All areas on the AOA and FBO areas. This is a vehicular patrol.
+- (c) "Traffic Sector" The "land side" areas outside the Airport Operations Area (AOA). This is a foot and vehicular patrol area.
+
+These sectors shall be manned in the following priority: Screening, Patrol, Traffic.
+
+## 19.3 Sector Functions and Responsibilities
+
+Officers are responsible for emergency and routine response within all sectors, routine liaison with \IPA Authority and tenant employees in all sectors and other functions as assigned by the Lieutenant. Officers must conduct regular patrols of all sectors maintaining a high visibility posture. Officers are not limited to remaining within a specific sector but are responsible for activity in all sectors. The following functions are responsibilities for specific sectors and are listed in order of priority:
+
+19.3.1 Screening Sector:
+
+- (a) Respond to the passenger screening areas when called by emergency alarm or routine request within the ten (10) minutes in accordance with the flexible response system specified in the Airport Security Program and approved by the FAA.
+
+EXHIBIT #3 continued
+
+#### • Officer Safety
+
+Applies appropriate safety precautions and procedures in performance of duties. Applies such requirement in potentially dangerous and/or hazardous situations. Maintains awareness of own location and location of other officers.
+
+#### • Public Interaction
+
+Provide assistance and information; explains procedures, policy, laws, reviews and/or complaints. Advises violators, mediates disputes, comforts victims and controls crowds.
+
+#### • Reporting
+
+Provides oral and written reports to supervisors, and appropriate agencies. Issues citations and summons, takes statements from victims and/or witnesses, completes general paper work generated by assignment.
+
+#### • Legal Knowledge
+
+Demonstrates working knowledge of codes, laws, regulation and legal procedure (i.e. accurately detects crimes and violations and applies appropriate codes, laws or regulations). Complies with statutory requirements when making arrests, conducting searches and obtaining evidence. Writes reports that include all necessary legal elements.
+
+#### • Knowledge of Agency Policy & Procedure
+
+Demonstrates working knowledge of agency policy, regulation and procedure (i.e. ability to verbalize and apply them appropriately).
+
+#### • Patrol
+
+Through implementation of working knowledge of procedures and techniques gained through training, education and experience; performs patrol of agency property and facilities, monitors security check points and passenger screening procedures, responds to calls for assistance or service on V.I. Port Authority Property and Facilities.
+
+### MINIMUM QUALIFICATIONS:
+
+- Applicant must be a U.S. or Naturalized Citizen;
+- Not less than 20 years or more than 35 years of age;
+- Must pass entry level written exam and physical agility test;
+- Have a High School Diploma or GED equivalency and Transcript;
+- Be in excellent physical and mental condition;

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812922/EFTA02812922.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812926/EFTA02812926.md

@@ -0,0 +1 @@
+## EXHIBIT 87 FILED UNDER SEAL

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812926/EFTA02812926.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812927/EFTA02812927.md

@@ -0,0 +1 @@
+## EXHIBIT 88 FILED UNDER SEAL

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812927/EFTA02812927.receipt.json

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+  "text_format": "markdown"
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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812928/EFTA02812928.md

@@ -0,0 +1 @@
+## EXHIBIT 89 FILED UNDER SEAL

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812928/EFTA02812928.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812929/EFTA02812929.md

@@ -0,0 +1,240 @@
+# EXHIBIT 90 FILED UNDER SEAL
+
+## Government of the United States Virgin Islands
+
+v.
+
+JPMorgan Chase Bank, N.A.;
+
+JPMorgan Chase Bank, N.A.
+
+v.
+
+James Edward Staley
+
+Expert Report of Carlyn Irwin
+
+Carlyn Irwin Senior Advisor Cornerstone Research
+
+June 23, 2023
+
+incomplete and contains information that is contradicted by Southern Trust's 2015 reporting package. For example:
+
+- a. The spreadsheet indicates that Southern Trust had "Gross Sales" of only , compared to reported on the tax return.,52
+- b. The spreadsheet indicates that Southern Trust paid compared to \$4.2 million of reported taxes paid in the reporting package.,53
+
+58. In 2016-2018, Southern Trust continued to receive benefits from the EDC program, but at much lower levels due to a significant decline in Southern Trust's revenues and profitability. See Exhibit 1.
+
+#### III. Sli111111:11'y of Findings and Opinions with Respect to USVI Tax Benefits
+
+59. Between 1999 and 2018, USVI's EDC awarded Financial Trust and Southern Trust more than \$300 million in tax benefits. For those years in which Mr. Epstein's companies reported positive ordinary business income, the cost / benefit ratio of tax benefits to Financial Trust and Southern Trust was far lower than EDC's target ratio, as discussed further below:,54
+
+{sup}`152` VI-JPM-000037452, tab Employment & Taxes; VI-JPM-000007474-533 at 477.
+
+{sup}`153` VI-JPM-000037452, tab Employment & Taxes; VI-JPM-000007474-533 at 474.
+
+{sup}`154` Cost / benefit ratios are onl shown for ars in which Financial Trust or Southern Trust reported positive ordinary business income . In 2016-2018, Southern Trust continued to receive benefits from the EDC program, u a muc ower eves ue o a significant decline in Southern Trust's revenues and profitability. In addition, I noted that the 2015 cost / benefit spreadsheet is incomplete and contains information that is contradicted by Southern Trust's 2015 reporting parka e. In the Se tember 7 1999 Executive Session Mr. Francois Domini ue. a S cial Assistant in the IDC, stated that
+
+See VI-JPM-000018885-917 at 88 , . vemor ryan s in is une eposi ion a a good return on investment from that tax benefits [USVI was] given" was idlefinitely at least one and a half, two, would be good: See Deposition of Governor Albert Bryan. Jr., June 6.2013 ("Bryan Deposition"). 47:9- 20. I present the lower of the target cost / benefit ratios for purposes of this table. Actual cost / benefit ratios for Financial Trust and Southern Trust as listed in the Benefits tab of EOC's cost-benefit analysis spreadsheets. See VI-JPM-000032792; VI-JPM-000032774; VI-JPM-000032775; VI-JPM-000032776: VI-JPM-000032777; VI-JPM-000032778; VI-JPM-000032779; VI-JPM-000032780; VI-JPM-000093347; VI-JPM-000037451; VI-JPM-000037452; VI-JPM-000020120; VI-JPM-000020331; VI-JPM-000093348.
+
+| Year | Target Cost / Benefit Ratio | Cost / Benefit Ratio Reported by EDC |
+| ------ | ----------------------------- | -------------------------------------- |
+| 1999 |  |  |
+| 2000 |  |  |
+| 2001 |  |  |
+| 2002 |  |  |
+| 2003 |  |  |
+| 2004 |  |  |
+| 2005 |  |  |
+| 2006 |  |  |
+| 2013 |  |  |
+| 2014 |  |  |
+| 2015 |  |  |
+| 2016 |  |  |
+| 2017 |  |  |
+| 2018 |  |  |
+
+### A. USVI Gave Mr. Epstein Over \$300 Million in Tax Breaks
+
+60. During the period 1999 through 2018, USVI's IDC/EDC gave Mr. Epstein over \$300 million of tax breaks associated with his 100% ownership of Financial Trust and Southern Trust to incentivize him to conduct business in USVI. Attached as Exhibit 1 is a summary of: (i) the taxes and duties paid by Financial Trust and Southern Trust to USVI; and (ii) the reported value of the tax exemptions awarded to Mr. Epstein. According to the tax returns submitted by Mr. Epstein's companies to the IDC/EDC each year, Mr. Epstein paid on earned by Financial Trust and Southern Trust during the period 1999-2018. This indicates that as a result of the IDC/EDC awards, Mr. Epstein's net effective income tax rate earned by his USVI-based companies was only 155
+
+#### B. Giving Mr. Epstein \$300 Million in Benefits Made No Economic Sense
+
+61. As discussed above, based on the methodology used by the IDC in 1999, it was projected that Financial Trust would generate a cost / benefit ratio of= .156 This indicates that for
+
+ua s mately . See Exhibit 1. 155 (income taxes paid 1999-2018) divided by aq 1% VI-JPM-00001888 at 888—889. (ordinary business income 1999-2018)
+
+every of tax breaks that was to be given to Financial Trust (and Mr. Epstein as he was the sole owner of this pass-through company), USVI expected to receive of economic benefits in the form of increased local employment, local tax receipts, and local investment.
+
+62. However, Financial Trust's actual cost / benefit was significantly below the IDC's projections and its so-called'" of. to .,6? As reflected in Financial Trust's annual reporting packages and the available EDC cost/ benefit spreadsheets produced in discovery, Financial Trust's actual cost / benefit ratios in 1999-2001 were:
+
+- a. 1999 ratio =. to ;me
+- b. 2000 ratio =.1 to ; {sup}`166` and
+- c. 2001 ratio =. to .160
+
+63. Each of these ratios calculated by the EDC were well below: (i) the forecasted ratio of. to that was and (ii) the' " ratio of. to
+
+64. Southern Trust's actual cost / benefit was similarly also significantly below the EDC's projections and its so-called'" of. to . For example, per the EDC's cost / benefit calculations produced in discovery, the actual cost / benefit in 2014 was only. to . 161
+
+65. This ratio was well below: (i) the projected ratio that the EDC discussed when it decided to approve Southern Trust's award; (ii) the to level discussed by the EDC in 1999;s2 and (iii) the level discussed by the EDC in 2013.70
+
+66. Thus, from 1999 to 2018, neither Financial Trust nor Southern Trust came close to generating sufficient benefits to USVI to offset the tax incentives granted to Mr. Epstein and these companies let alone reach the thresholds the EDC considered Based on the record, the EDC was aware of Mr. Epstein's companies' multi-year history of poor cost / benefit performance yet agreed to extend Financial Trust's certificate in 2009 and granted Southern Trust a new certificate in 2013 regardless.
+
+{sup}`1&`quot; VI-JPM-000018885-917 at 889.
+
+VI-JPM-000032792, tab Benefits.
+
+{sup}`1&`quot; %/WPM-000032774, tab Benefits.
+
+{sup}`760` VI-JPM-000032775, tab Benefits.
+
+{sup}`161` VI-JPM-000037451, tab Benefits.
+
+VI-JPM-0000113885-917 at 889.
+
+{sup}`163` VI-JPM-000018918-928 at 920.
+
+#### C. USVI Failed to Ask Questions or Develop an Appropriate Basis to Support Extending the \$300 Million in Benefits
+
+67. USVI's EDC did not properly evaluate Mr. Epstein's applications for benefits and failed to ask him even the most basic questions based on information that was uniquely available to it about his companies.
+
+68. In awarding hundreds of millions of dollars in benefits to Mr. Epstein, USVI failed to perform even perfunctory examination of information that was uniquely available to it and ignored its own calculations that Mr. Epstein's companies were not conferring the promised economic benefits on USVI. In 2009 and 2013, the awards to Mr. Epstein were ultimately approved by Governor de Jongh. He approved these benefits while his wife, First Lady Cecile de Jongh, was the office manager for Mr. Epstein's companies and received a salary, bonuses, and other benefits, including tuition for their children, from Mr. Epstein.1" Based on my review of the record, I have not seen any evidence that USVI or the EDC employed any procedure to manage or investigate the real and/or perceived conflict of interest by Governor de Jongh's approval of tax benefits that directly benefitted his family)" Governor de Jongh testified that no such measures were put in place."
+
+69. Moreover, based on my review of the record, it does not appear that the . In 1999, when testifying in front of the EDC on behalf of Financial Trust Company, Mr. Epstein made exaggerated statements, including that ."1" He also testified " 48 but also stated he would 'lee The EDC did not ask , nor
+
+{sup}`164` Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. Case 1:22-cv-10904-JSR, JPMorgan Chase Bank, N.A.'s Opposition to USVI's Motion to Strike Affirmative Defenses, May 23,2023 ("JPMC Opposition to Motion to Strike"). Exhibit 23, ESTATE\_JPM024371: JPMC Opposition to Motion to Strike. Exhibit 25. ESTATE\_JPM024548; JPMC Opposition to Motion to Strike, Exhibit 26, ESTATE\_JPM024549; Deposition of Governor John de Jongh, May 30.2023 ("John de Jongh Deposition"), 136:19-138:22; Cecile de Jongh Deposition, 10:20-22; 76:3-78:12.
+
+{sup}`186` Bryan Deposition, 133:23-134:2.
+
+{sup}`166` John de Jongh Deposition, 162:19-164:1.
+
+{sup}`167` VI-JPM-000016248-270 at 253.
+
+{sup}`788` VI-JPM-000016248-270 at 264.
+
+{sup}`160` VI-JPM-000016248-270 at 256.
+
+[REDACTED]. In addition, when Financial Trust applied for a renewal of EDC benefits for Financial Trust in February 2009, [REDACTED]
+
+[REDACTED].{sup}`170` Based on my review of the record, the EDC did not ask [REDACTED]
+
+
+[REDACTED].{sup}`171` Moreover, the EDC did not ask [REDACTED]
+
+[REDACTED]. Again, based on my review of the record, I am not aware if [REDACTED]
+
+[REDACTED].
+
+70. USVI also did not conduct checks on Financial Trust during the renewal period. A January 2009 EDC due diligence report states that [REDACTED]
+
+
+
+[REDACTED]. Yet, I am not aware of anything in the record that indicates the EDC [REDACTED]. In July 2011, a researcher with the Daily Beast confirmed that Financial Trust was never registered with any of those entities.{sup}`172`
+
+71. Nor does the record reflect that the EDC did anything to review—or even acknowledge—Mr. Epstein's criminal history during their granting of benefits to him despite it being laid out and included in his application. In fact, the Chairman of the EDC from 2007 to 2014, current USVI Governor Albert Bryan, Jr., testified he was not aware of news in 2011 that Mr. Epstein had settled more than two dozen lawsuits and claims against him by teenagers who say they gave him sexually charged massages and/or sex in exchange for money despite the fact that this information was publicly available at the time the EDC was voting to renew tax benefits for Financial Trust.{sup}`173` Mr. Bryan testified that the EDC was generally *less* concerned about the ethics and integrity of the owner of a business receiving EDC benefits if the business was up for renewal, as Financial Trust was after Mr. Epstein's arrest, because the EDC had a track record of
+
+---
+
+<sup>170</sup> VI-JPM-000016200–205 at 202; Associated Press, "A Timeline of the Jeffrey Epstein, Ghislaine Maxwell Scandal," *U.S. News & World Report*, June 28, 2022, available at <https://www.usnews.com/news/politics/articles/2022-06-28/a-timeline-of-the-jeffrey-epstein-ghislaine-maxwell-scandal>.
+
+{sup}`171` VI-JPM-000016200–205 at 202.
+
+<sup>172</sup> VI-JPM-000033049–063 at 051. Note that the NFA administers registration and examination of intermediaries on behalf of the CFTC. See "Be Smart: Check Registration & Backgrounds Before You Trade," CFTC, <https://www.cftc.gov/check>.
+
+{sup}`173` Bryan Deposition, June 6, 2013, 74:7–25; 75:1–13.
+
+relation to economic development benefits brought to USVI.228 Again, the EDC considered a cost / benefit ratio of to■ **to be' "229** 
+
+**90. Based on my review of the record, the EDC was aware that the cost-benefit ratios for Financial Trust In 1999, for of tax breaks that USVI gave to Financial Trust, USVI received** only■ **in economic benefits.= In 2000, for every. of cost (tax breaks given away to Financial Trust), USVI received only (taxes received, local employment, and local purchases)?' In 2001, for every. of cost (tax breaks given away to Financial Trust), USVI received only of benefits? 32 The EDC Board recognized** 
+
+**'233** 
+
+**91. Moreover, granting EDC benefits to Southern Trust also failed to meaningfully spur investment and growth in USVI. For example, in 2014, Southern Trust's award resulted in an actual cost / benefit ratio of. of cost for every in benefits.= .** 
+
+**92. The EDC's grant of tax benefits to Mr. Epstein's USVI-based companies was contrary to its mission and conferred only paltry benefits to the residents of USVI. The lack of economic sense raises the obvious question of why these benefits continued to be granted to Mr. Epstein's companies over a twenty-year period.** 
+
+**93. I have reviewed the Motion to Strike Opposition filed by JPMC in this case and the supporting exhibits. That filing lays out facts suggesting an improper quid-pro-quo relationship between Mr. Epstein and certain high-placed USVI officials with influence over the benefits. For example, First Lady de Jongh received a salary, bonuses, and tuition payments for her children from Financial Trust and Southern Trust.23s Her husband, the Governor, signed off on** 
+
+**{sup}`228`** United States Virgin Islands Economic Development Authority. FY2012 Annual Report. p. 13.
+
+{sup}`228` VI-JPM-000018885-917 at 889
+
+{sup}`238` VI-JPM-000032792, tab Benefits.
+
+{sup}`231` VI-JPM-000032774, tab Benefits.
+
+{sup}`232` VI-JPM-000032775, tab Benefits.
+
+{sup}`233` VI-JPM-000018918-926 at 920.
+
+{sup}`234` VI-JPM-000037451, tabs Employment & Taxes, Procurement, and Benefits.
+
+{sup}`238` JPMC Opposition to Motion to Strike. Exhibit 23, ESTATE\_JPM024371; JPMC Opposition to Motion to Strike, Exhibit 25, ESTATE\_JPM024548; JPMC Opposition to Motion to Strike, Exhibit 26" ESTATE\_JPM024549; John de Jongh Deposition, 136:19-138:22; Cecile de Jongh Deposition, 10:20-22; 76:3-78:12.
+
+. Without such a benchmark, Mr. Amador's "analysis" lacks context and his opinion is unsupported and speculative.
+
+101. Second, Mr. Amador has not presented any analysis of any He merely points to the fact that . Mr.
+
+Amador does not explain why this fact supports his opinion that , rendering his opinion baseless and speculative.
+
+102. Third, there are potential legitimate reasons why it is not unusual to have separate entities hold title to different aircraft. For example, for liability purposes, it is best practice (and financial institutions and/or insurance companies often recommend) that ownership of significant assets be owned by separate legal entities. This is done not only to protect the value of one aircraft should liabilities be generated from another aircraft, but also to maintain corporate formalities.
+
+103. Mr. Amador has failed to present any analysis to support his opinions. He has also failed to consider the nature and scope of Mr. Epstein's businesses and asset holdings.
+
+Executed on this 23rd day of June 2023
+
+eare.S4d
+
+Carlyn Irwin
+
+**Exhibit 1**  
+**Analysis of Economic Development Commission Credits**
+
+|  | Financial Trust Company, Inc. (1999-2012) |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| ---------------------------------------- | ------------------------------------------- | ------ | ------ | ------ | ------ | ------ | ------ | ------ | ------ | ------ | ------ | ------ | ------ | ------ | ---------- |
+|  | 1999 | 2000 | 2001 | 2002 | 2003 | 2004 | 2005 | 2006 | 2007 | 2008 | 2009 | 2010 | 2011 | 2012 | Subtotal |
+| **Taxes and Duties Paid** |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Gross Receipts |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Real Property Tax |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Excise Taxes |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Income Taxes |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Customs Duties |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Other Taxes |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| **Total Taxes Paid** |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| **Value of Tax Exemptions** |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Gross Receipts |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Real Property Tax |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Excise Taxes |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Income Taxes |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Customs Duties |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| **Total Value of Exemptions** |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| **Federal Tax Return (Form 1120S)** |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Net Sales |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+| Ordinary Business Income |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
+
+**Exhibit 1**  
+**Analysis of Economic Development Commission Credits**
+
+|  | Southern Trust Company, Inc. (2013–2018) |  |  |  |  |  |  |  |
+| ---------------------------------------- | ------------------------------------------ | ------ | ------ | ------ | ------ | ------ | ---------- | ------- |
+|  | 2013 | 2014 | 2015 | 2016 | 2017 | 2018 | Subtotal | Total |
+| **Taxes and Duties Paid** |  |  |  |  |  |  |  |  |
+| Gross Receipts |  |  |  |  |  |  |  |  |
+| Real Property Tax |  |  |  |  |  |  |  |  |
+| Excise Taxes |  |  |  |  |  |  |  |  |
+| Income Taxes |  |  |  |  |  |  |  |  |
+| Customs Duties |  |  |  |  |  |  |  |  |
+| Other Taxes |  |  |  |  |  |  |  |  |
+| **Total Taxes Paid** |  |  |  |  |  |  |  |  |
+| **Value of Tax Exemptions** |  |  |  |  |  |  |  |  |
+| Gross Receipts |  |  |  |  |  |  |  |  |
+| Real Property Tax |  |  |  |  |  |  |  |  |
+| Excise Taxes |  |  |  |  |  |  |  |  |
+| Income Taxes |  |  |  |  |  |  |  |  |
+| Customs Duties |  |  |  |  |  |  |  |  |
+| **Total Value of Exemptions** |  |  |  |  |  |  |  |  |
+| **Federal Tax Return (Form 1120S)** |  |  |  |  |  |  |  |  |
+| Net Sales |  |  |  |  |  |  |  |  |
+| Ordinary Business Income |  |  |  |  |  |  |  |  |
+
+Source: VI-JPM-000012940; VI-JPM-000012922; VI-JPM-000012885; VI-JPM-000012850; VI-JPM-000012816; VI-JPM-000012743; VI-JPM-000012722; VI-JPM-000012889; VI-JPM-000012630; VI-JPM-000013335; VI-JPM-000013219; VI-JPM-000013122; VI-JPM-000013087; VI-JPM-000012996; VI-JPM-000007315; VI-JPM-000007407; VI-JPM-000007474; VI-JPM-000007534; VI-JPM-000007588; VI-JPM-000007663

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812929/EFTA02812929.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812940/EFTA02812940.md

@@ -0,0 +1 @@
+## EXHIBIT 91 FILED UNDER SEAL

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812940/EFTA02812940.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812941/EFTA02812941.md

@@ -0,0 +1,195 @@
+## EXHIBIT 92 FILED UNDER SEAL
+
+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE 1, individually and on behalf of all others similarly situated,
+
+Plaintiff,
+
+-against-
+
+JPMORGAN Chase BANK NA, Defendants.
+
+Case No.
+
+1:22-cv-10019-JSR
+
+CONFI DENTIAL
+
+x
+
+Videotaped oral deposition of BONNIE taken pursuant to notice, was held REMOTELY, commencing May 10, 2023, 9:39 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York.
+
+> MAGNA LEGAL SERVICES (866) 624-6221 www.MagnaLS.com
+
+![](_page_1_Picture_14.jpeg)
+
+1
+
+2
+
+3
+
+4
+
+5
+
+6
+
+7
+
+8
+
+9
+
+10
+
+11 Q. Are you aware of any sex
+
+12 trafficking cases coming out of the private 10:51:33
+
+13 bank during your tenure at JPMorgan? 10:51:35
+
+14 MR. BUTTS: Objection. 10:51:40
+
+15 You may answer. 10:51:42
+
+16 A. No, I don't remember any. 10:51:42
+
+17 Q. I think we spoke about rapid 10:51:45
+
+18 response meetings earlier in your discussion 10:51:49
+
+19 of your responsibilities, is that right? 10:51:52
+
+20 A. That's correct. 10:51:53
+
+21 Q. What is a rapid response meeting? 10:51:54
+
+22 A. So it's an escalation of 10:51:57
+
+23 information that was brought to us, 10:52:01
+
+24 derogatory information, where it seems 10:52:07
+
+25 something that should be escalated up to 10:52:11
+
+10:51:13
+
+10:51:14
+
+10:51:14
+
+10:51:15
+
+10:51:19
+
+10:51:20
+
+10:51:20
+
+10:51:26
+
+10:51:28
+
+10:51:31
+
+1
+
+2 management and they just -- we give them the 10:52:13
+
+3 facts, they review it and make a 10:52:20
+
+4 determination on how they want to proceed. 10:52:22
+
+5 Q. So by us, you mean the Americas 10:52:26
+
+6 control group slash -- 10:52:31
+
+7 A. Americas -- 10:52:42
+
+8 MR. BUTTS; So that's I think a 10:52:42
+
+9 good reminder. We are talking over each 10:52:43
+
+10 other a little bit. 10:52:46
+
+11 So can you, Leslie, read the last 10:52:50
+
+12 piece of her answer or the question and 10:52:54
+
+13 then the answer from what you got so 10:52:56
+
+14 far. 10:53:00
+
+15 (Record read.) 10:53:04
+
+16 MR. BUTTS: Maybe Danny, you can 10:53:19
+
+17 take it from the top on that question 10:53:21
+
+18 and we can then answer. 10:53:22
+
+19 Q. By us, you mean the Americas 10:53:23
+
+20 control group/risk management group, right? 10:53:27
+
+21 MR. BUTTS: Objection to form. 10:53:31
+
+22 You may answer. 10:53:32
+
+23 A. Yes. We received it. If I recall, 10:53:33
+
+24 copies may have gone to the banker and their 10:53:39
+
+25 manager, I don't remember. 10:53:42
+
+1
+
+2 Q. Was it your understanding that 14:35:00
+
+3 Mr. Epstein was using large cash withdrawals 14:35:08
+
+4 to pay for fuel expenses when he travels to 14:35:11
+
+5 foreign countries? 14:35:13
+
+6 MR. BUTTS: Objection and objection 14:35:15
+
+7 to form. 14:35:15
+
+8 You may answer, if you are able. 14:35:19
+
+9 A. It's probably one of the only 14:35:20
+
+10 things I really remember because of -- fuel 14:35:23
+
+11 expenses for an airplane, I wouldn't even -- 14:35:27
+
+12 I have no idea what it costs, but I thought 14:35:30
+
+13 that was interesting. 14:35:33
+
+14 Q. Okay. I appreciate your answer. 14:35:37
+
+15 Can you just expand upon what you 14:35:38
+
+16 mean by interesting? 14:35:43
+
+17 MR. BUTTS: Objection to form. 14:35:45
+
+18 You may answer. 14:35:46
+
+19 A. I never thought about how much it 14:35:46
+
+20 would cost to fuel an airplane and the answer 14:35:47
+
+21 seemed reasonable. 14:35:51
+
+22 Q. Does it seem reasonable today that 14:35:54
+
+23 Jeffrey Epstein was using 20,000 to \$40,000 14:35:56
+
+24 in cash to pay for fuel expenses? 14:35:59
+
+25 MR. BUTTS: Objection and objection 14:36:03

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812941/EFTA02812941.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812946/EFTA02812946.md

@@ -0,0 +1,547 @@
+## EXHIBIT 93 FILED UNDER SEAL
+
+## Document Produced in Native Format
+
+|  |  |  | B | C | D |  | E | F |
+| --- | --------- | ----------------- | -------- | --------------------------------------- | -------------- | -------- | --------- | --------------------------------------------- |
+| 1 | Item tt |  | Client | Reason | Date |  | Outcome | Additional Comments |
+|  |  | Jeffrey Epstein |  | Several newspaper articles were found |  |  |  |  |
+|  |  |  |  |  | 10.'17.'2006 | Retain |  | After internal discussions with Jes Staley. |
+|  |  |  |  |  |  |  |  | and Mary , it was decided that we will |
+
+| 1 7 | A B C D E F Item # Client D Outcome Additional Comments 5 |
+| ----- | ----------------------------------------------------------- |
+| 8 | 6 |
+| 9 | 7 |
+| 10 | 8 |
+| 11 | 9 |
+| 12 | 10 |
+| 13 | 11 |
+| 14 | 12 |
+| 15 | 13 |
+| 16 | 14 |
+| 17 | 15 |
+| 18 | 16 |
+| 19 | 17 |
+| 20 | 18 |
+| 21 | 19 |
+| 22 | 20 |
+| 23 | 21 |
+| 24 | 22 |
+| 25 | 23 |
+| 26 | 24 |
+| 27 | 25 |
+
+| Item # | Client | Reason | Date | Outcome | Additional Comments |
+| -------- | ------------ | ------------ | ------------ | ------------ | --------------------- |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+
+| Item # | Client | Reason | Date | Outcome | Additional Comments |
+| -------- | -------- | -------- | ------ | --------- | --------------------- |
+
+| Item # | Client | Reason | Date | Outcome | Additional Comments |
+| -------- | -------- | -------- | ------ | --------- | --------------------- |
+
+| Item # | Client | Reason | Date | Outcome | Additional Comments |
+| -------- | ------------ | ------------ | ------------ | ------------ | --------------------- |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+|  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+
+| Item # | Client | Reason | Date | Outcome | Additional Comments |
+| -------- | ------------ | ------------ | ------------ | ------------ | --------------------- |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+| ■ | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |
+
+| --- | -------- | -------- | -------- | ------ | --------- | --------------------- |
+| 1 | Item # | Client | Reason | Date | Outcome | Additional Comments |
+| 2 |  |  |  |  |  |  |
+| 3 |  |  |  |  |  |  |
+| 4 |  |  |  |  |  |  |
+| 5 |  |  |  |  |  |  |
+| 6 |  |  |  |  |  |  |
+| 7 |  |  |  |  |  |  |
+
+| ---- | -------- | -------- | -------- | ------ | --------- | --------------------- |
+| 1 | Item # | Client | Reason | Date | Outcome | Additional Comments |
+| 8 |  |  |  |  |  |  |
+| 9 |  |  |  |  |  |  |
+| 10 |  |  |  |  |  |  |
+| 11 |  |  |  |  |  |  |
+| 12 |  |  |  |  |  |  |
+| 13 |  |  |  |  |  |  |
+
+| ---- | -------- | -------- | -------- | ------ | --------- | --------------------- |
+| 1 | Item # | Client | Reason | Date | Outcome | Additional Comments |
+| 14 | █ | █ | █ | █ | █ |  |
+| 15 | █ | █ | █ | █ | █ | █ |
+| 16 | █ | █ | █ | █ | █ |  |
+| 17 | █ | █ | █ | █ | █ | █ |
+| 18 | █ | █ | █ | █ | █ | █ |
+
+| A |  | B | C |  | D | E |  |  | F |
+| --------- | ------------------ | -------- | --- | ------- | ----------- | ------------------------------------------- | --------- | ------ | ---------------- |
+| It li # |  | Client |  |  |  |  | .:. • • | • ii | • ii ii : ii • |
+| 21 | Jeff rey Epstein |  |  | .,,,, |  |  |  |  |  |
+|  |  |  |  |  | 7/15/2008 | Catherine will go back to JES to tell him |  |  |  |
+
+|  | A | B | C | D | E | F |  |  |  |
+| --- | --- | --- | --- | --- | --- | ------------------------------------------------------------------------------------ | ------------ | --------------- | --- |
+| 1 | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ |  |  |  |
+| █ | █ | █ | █ | █ | █ | █ <td style="text-align: right;">11/24/2008</td> <td>Not approved.</td> <td>█</td> | 11/24/2008 | Not approved. | █ |
+
+| 1 35 36 | A 6 C D E It # Client son tcome |
+| --------- | --------------------------------- |
+| 37 | 34 |
+| 38 | 35 |
+| 39 | 36 |
+| 40 | 37 |
+| 41 | 38 |
+| 42 | 39 |
+
+| A | B | C | o | E | F | G | H | I |
+| -------- | ----------------- | -------- | ------ | --------- | --------------------- | ----------- | --- | --- |
+| Item 4 | Client/Prospect | Reason | Date | Outcome | Additional Comments | Follow up |  |  |
+|  |  |  |  |  |  | I | I |  |
+
+Reason | D
+Date | E
+Outcome | F
+Additional Comments | G
+Follow up
+Y/N | H
+Follow up
+Complete
+Y/N | I
+F/U Action, due date |
+| ---- | ------------- | ---------------------- | ------------- | ------------ | -------------- | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- |
+| 1 | 8 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  | [REDACTED] |  |  |
+| 9 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  | [REDACTED] |  |  |
+| 10 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |  |
+| 11 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  | [REDACTED] |
+| 12 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  | [REDACTED] |
+| 13 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  | [REDACTED] |
+| 14 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |  |  |  |
+
+[REDACTED]
+
+[REDACTED]
+
+[REDACTED] M-SDNYLIT-W-00026008
+
+|  | A | B | C | D | E | F | G | H | I |
+| ---- | -------- | ----------------- | -------- | ------ | --------- | --------------------- | ------------------ | ------------------------------ | ---------------------- |
+| | Item # | Client/Prospect | Reason | Date | Outcome | Additional Comments | Follow up
+Y/N | Follow up
+Complete
+Y/N | F/U Action, due date |
+| 1 | █ | █ | █ | █ | █ | █ | █ | █ | █ |
+| 15 | █ | █ | █ | █ | █ | █ | █ | █ | █ |
+| 16 | █ | █ | █ | █ | █ | █ | █ | █ | █ |
+| 17 | █ | █ | █ | █ | █ | █ | █ | █ | █ |
+
+| A | B | C | D | E |  | F | G | H | I | J |
+| -------- | ----------------- | ------------------------ | -------- | ------ | ---- | --------- | --------------------- | ----------- | --- | --- |
+| Item N | Clienl/Prospect | Client/Proved Category | Reason | Date |  | Outcome | Additional Comments | Follow up |  |  |
+| I |  |  |  |  | MI |  |  | I |  |  |
+|  |  |  |  |  |  |  |  | I | a |  |
+|  |  |  |  |  |  |  |  | I | a |  |
+| 11- S |  |  |  |  |  |  |  |  |  |  |
+
+Client/Prospect Category | D
+Reason | E
+Date | F
+Outcome | G
+Additional Comments | H
+Follow up
+Y/N | I
+Follow up
+Complete
+Y/N | J
+F/U Action, due date |
+| ---- | ------------- | ---------------------- | ------------------------------- | ------------- | ----------- | -------------- | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- |
+| 1 |  |  |  |  |  |  |  |  |  |  |
+| 9 |  |  |  |  |  |  |  |  |  |  |
+| 10 |  |  |  |  |  |  |  |  |  |  |
+| 11 |  |  |  |  |  |  |  |  |  |  |
+| 12 |  |  |  |  |  |  |  |  |  |  |
+| 13 |  |  |  |  |  |  |  |  |  |  |
+| 14 |  |  |  |  |  |  |  |  |  |  |
+
+| A | B | C | D | E | F | G | H | I |
+| ------- | ----------------- | ----------------------- | -------- | ------ | --------- | ------------------ | ----------- | --- |
+| Item/ | Client/Prospect | Clieutampect Category | Reason | Date | Outcome | AdMhond Camisole | Fallow up |  |
+| 1 |  |  |  |  |  |  | N |  |
+
+| A | B | C | D |  | E |  | F | G | H | I |  | J |
+| -------- | ----------------- | ------------------------- | -------- | --- | --- | --- | --------- | --------------------- | ----------- | --- | ---- | ----- |
+| Item N | Client/Prospect | ClienURrospect Category | Reason |  |  |  |  |  |  |  |  |  |
+|  |  |  |  | — |  | B |  |  |  |  |  |  |
+|  |  |  |  |  |  |  | Outcome | Additional Comments | Follow up |  |  |  |
+|  |  |  |  |  |  |  |  |  |  |  | Fi | i n |
+
+| A | B | C | 0 | -E | F | C | H | I | I | J |
+| ---- | ----------------- | -------------------------- | -------- | ------ | --------- | ----------------- | ---------- | --- | --- | --- |
+|  | Client/Prospect | ClIenttProepect Category | Reason | Date | Outcome | Again's' COMM*. | reliant, |  |  |  |
+| 23 |  |  |  |  |  |  | I |  |  |  |
+| M |  |  |  |  |  |  | I |  |  |  |
+
+| A | B | G | D | E | F | G | H | I | J |
+| -------- | ----------------- | -------------------------- | -------- | ------ | --------- | --------------------- | ----------- | --- | --------------------- |
+| Rein N | Client/Prospect | Client/Prospect Category | Reason | Date | Outcome | Additional Comments | Follow OP |  |  |
+|  |  |  |  |  |  |  |  | y | FA/ Action due data |
+| I |  |  |  |  |  |  | N |  |  |
+
+| I 31 | A B C D E F G H I J Follow up Outcome Additional Comments Follow UP Client/Prospect Client/Prospect Category Reason Date Item N YIN Complete DO n Fi i |
+| ------ | -------------------------------------------------------------------------------------------------------------------------------------------------------- |
+| 32 | 30 |
+| 33 | 31 |
+| 34 | 32 |
+| 35 | 33 |
+| 36 | 34 |
+| 37 | 35 |
+| 38 | 36 |
+| 39 | 37 |
+| 40 | 38 |
+| 41 | 39 |
+
+Client/Prospect Category | D
+Reason | E
+Date | F
+Outcome | G
+Additional Comments | H
+Follow up
+Y/N | I
+Follow up
+Complete
+Y/N | J
+F/U Action, due date |
+| --- | ------------- | ---------------------- | ------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------ | ------------ | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------- | ----------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
+| 1 | 1 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 2 | 2 | Jeffrey Epstein | Existing Client | The Firm's AML Director (William Langford) has expressed concern over the possibility that Mr. Epstein is under investigation for human trafficking. | 1/7/2011 | Discussions to be held with William and Nina to determine how to approach the issue with Jes Staley, who is friends with Epstein. He needs to understand the potential backlash to the firm given all of the work done to root out clients involved in human trafficking. | AML Ops has conducted extensive research to root out clients involved in human trafficking. William Langford is requiring that if the business decides to proceed, then re-approval by Steve Cutler will be required. | Y | | 1/28/11 - Follow up to see if meeting with Jes has taken place and the LOB's decision for re-approval.
+
+3/15/2011:
+
+Paul Morris spoke with JE. The SBLC will not be renewed. |
+| 3 | 3 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |
+| 4 | 1 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |
+| 5 | 1 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |
+| 6 | 1 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |
+| 7 | 1 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |
+| 8 | 1 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |
+
+| A | B | c | D | E | F | G | H | I |  |
+| --------- | --------------- | -------------------------- | ------ | ------ | ------------ | ---------------------- | ---------- | ---- | ----------------------- |
+| Item al | Chentd1ospect | ClienttPlospect Category | Ream | Date | 011ICOITIO | Additional Canwnents | Follow W |  |  |
+|  |  |  |  |  |  |  |  | ym | FA.I Action, due date |
+| i |  |  |  |  |  |  | I |  |  |
+| M |  |  |  |  |  |  | i |  |  |
+
+Client/Prospect Category | D
+Reason | E
+Date | F
+Outcome | G
+Additional Comments | H
+Follow up
+Y/N | I
+Follow up
+Complete
+Y/N | J
+F/U Action, due date |
+| ---- | ------------- | ---------------------- | ------------------------------- | ------------- | ----------- | -------------- | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- |
+| 1 |  |  |  |  |  |  |  |  |  |  |
+| 17 |  |  |  |  |  |  |  |  |  |  |
+| 18 |  |  |  |  |  |  |  |  |  |  |
+| 19 |  |  |  |  |  |  |  |  |  |  |
+| 20 |  |  |  |  |  |  |  |  |  |  |
+| 21 |  |  |  |  |  |  |  |  |  |  |
+
+Client/Prospect Category | D
+Reason | E
+Date | F
+Outcome | G
+Additional Comments | H
+Follow up
+Y/N | I
+Follow up
+Complete
+Y/N | J
+F/U Action, due date |
+| ---- | ------------- | ---------------------- | --------------------------------- | ------------------------- | ------------ | ------------------------------------------------------------------------------------------ | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- |
+| 1 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |  |  |
+| 22 |  |  |  | [REDACTED] |  |  | [REDACTED] |  |  |  |
+| 23 | 22 | Jeffrey Epstein | Existing Client - 4th follow-up | Review with John Duffy. | 8/4/2011 | Duffy to reach out to Jes Staley and advise that we exit while things are a bit settled. |  |  |  |  |
+| 24 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |  |  |  |
+| 25 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |  |  |
+| 26 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |  |  |  |
+| 27 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |  |  |
+| 28 |  | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |  |  |
+
+|  | A | B | C | D | E | F | G | H | I | J |
+| ---- | ------------ | ----------------- | -------------------------- | ------------ | ------------ | ------------ | --------------------- | --------------- | ------------------------ | ---------------------- |
+| 1 | Item # | Client/Prospect | Client/Prospect Category | Reason | Date | Outcome | Additional Comments | Follow up Y/N | Follow up Complete Y/N | F/U Action, due date |
+| 29 | 28 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 30 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 31 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 32 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 33 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 34 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+
+| 1 V. 36 | A B C D E F G El I J Item e CliemUlitospect CeentiPtospe-ct Category Reason Date Outcome Additional Comments Follow up Follow up WN Conplete 994 Fill Action. due date 1 J. |
+| --------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
+| 37 | 36 |
+| .121 | 3B |
+| 40 | 39 |
+| 41 | 40 |
+
+Client/Prospect
+Category | D
+ECI | E
+Reason | F
+Date | G
+Outcome | H
+Additional Comments | I
+Follow up
+Y/N | J
+Follow up
+Complete
+Y/N | K
+F/U Action, due date | L
+Reputational Risk Cite.
+Minutes Written |
+| --- | ------------- | ---------------------- | ---------------------------------- | ------------ | ------------- | ------------ | -------------- | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- | ------------------------------------------------- |
+| 1 | 1 | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 2 |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 3 |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 4 |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 5 |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | Y |  |  |  |
+| 6 |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+
+Client/Prospect
+Category | D
+ECI | E
+Reason | F
+Date | G
+Outcome | H
+Additional Comments | I
+Follow up
+Y/N | J
+Follow up
+Complete
+Y/N | K
+F/U Action, due date | L
+Reputational Risk Cite.
+Minutes Written |
+| ---- | ------------- | ---------------------- | ---------------------------------- | ------------ | ------------- | ------------ | -------------- | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- | ------------------------------------------------- |
+| 1 | S | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |
+| 10 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 11 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 12 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 13 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |  |
+
+Client/Prospect Category | D
+ECI | E
+Reason | F
+Date | G
+Outcome | H
+Additional Comments | I
+Follow up Y/N | J
+Follow up Complete Y/N | K
+F/U Action, due date | L
+Reputational Risk Cte. Minutes Written |
+| ---- | ------------- | ---------------------- | ------------------------------- | ---------- | ------------- | ----------- | -------------- | -------------------------- | -------------------- | ----------------------------- | --------------------------- | --------------------------------------------- |
+| 14 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 15 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 16 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 17 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 18 |  |  |  |  |  |  |  |  |  |  |  |  |
+
+Client/Prospect
+Category | D
+ECI | E
+Reason | F
+Date | G
+Outcome | H
+Additional Comments | I
+Follow up
+Y/N | J
+Follow up
+Complete
+Y/N | K
+F/U Action, due date | L
+Reputational Risk Cite.
+Minutes Written |
+| ---- | ------------- | ---------------------- | ---------------------------------- | ---------- | ------------- | ------------ | -------------- | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- | ------------------------------------------------- |
+| 1 | 18 | [Redacted] | [Redacted] |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 19 | [Redacted] | [Redacted] | [Redacted] |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 20 | [Redacted] | [Redacted] | [Redacted] |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  | [Redacted] |  |
+| 21 | [Redacted] | [Redacted] | [Redacted] |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  | [Redacted] |  |
+| 22 | [Redacted] | [Redacted] | [Redacted] |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 23 | [Redacted] | [Redacted] | [Redacted] |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 24 | [Redacted] | [Redacted] | [Redacted] |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 25 | [Redacted] | [Redacted] | [Redacted] |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+| 26 | [Redacted] | [Redacted] | [Redacted] |  | [Redacted] | [Redacted] | [Redacted] | [Redacted] |  |  |  |  |
+
+Client/Prospect
+Category | D
+ECI | E
+Reason | F
+Date | G
+Outcome | H
+Additional Comments | I
+Follow up
+Y/N | J
+Follow up
+Complete
+Y/N | K
+F/U Action, due date | L
+Reputational Risk Ctte.
+Minutes Written |
+| ---- | ------------- | ---------------------- | ---------------------------------- | ---------- | ------------- | ----------- | -------------- | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- | ------------------------------------------------- |
+| 1 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 27 | 27 |  |  |  |  |  |  |  |  |  |  |  |
+| 28 | 28 |  |  |  |  |  |  |  |  |  |  |  |
+| 29 | 29 |  |  |  |  |  |  |  |  |  |  |  |
+| 30 | 30 |  |  |  |  |  |  |  |  |  |  |  |
+| 31 | 31 |  |  |  |  |  |  |  |  |  |  |  |
+| 32 | 32 |  |  |  |  |  |  |  |  |  |  |  |
+| 33 | 33 |  |  |  |  |  |  |  |  |  |  |  |
+| 34 | 34 |  |  |  |  |  |  |  |  |  |  |  |
+| 35 | 35 |  |  |  |  |  |  |  |  |  |  |  |
+| 36 | 36 |  |  |  |  |  |  |  |  |  |  |  |
+| 37 | 37 |  |  |  |  |  |  |  |  |  |  |  |
+| 38 | 38 |  |  |  |  |  |  |  |  |  |  |  |
+| 39 | 39 |  |  |  |  |  |  |  |  |  |  |  |
+| 40 | 40 |  |  |  |  |  |  |  |  |  |  |  |
+| 41 | 41 |  |  |  |  |  |  |  |  |  |  |  |
+
+Client/Prospect
+Category | D
+ECI | E
+Reason | F
+Date | G
+Outcome | H
+Additional Comments | I
+Follow up
+Y/N | J
+Follow up
+Complete
+Y/N | K
+F/U Action, due date | L
+Reputational Risk Ctte.
+Minutes Written |
+| --- | ------------- | ---------------------- | ---------------------------------- | ---------- | ------------- | ----------- | -------------- | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- | ------------------------------------------------- |
+| 1 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 2 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 3 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 4 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 5 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 6 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 7 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 8 |  |  |  |  |  |  |  |  |  |  |  |  |
+
+Client/Prospect
+Category | D
+ECI | E
+Reason | F
+Date | G
+Outcome | H
+Additional Comments | I
+Follow up
+Y/N | J
+Follow up
+Complete
+Y/N | K
+F/U Action, due date | L
+Reputational Risk Ctte.
+Minutes Written |
+| ---- | ------------- | ---------------------- | ---------------------------------- | ------------ | ------------- | ------------ | -------------- | -------------------------- | ----------------------- | ----------------------------------- | --------------------------- | ------------------------------------------------- |
+| 1 | 8 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 9 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 10 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 11 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 12 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+| 13 | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] | [REDACTED] |
+
+|  | A | B | C | D | E | F | G | H | I | J | K | L |
+| ---- | -------- | ----------------- | -------------------------- | ----- | -------- | ------ | --------- | --------------------- | --------------- | ------------------------ | ---------------------- | ----------------------------------------- |
+|  | Item # | Client/Prospect | Client/Prospect Category | ECI | Reason | Date | Outcome | Additional Comments | Follow up Y/N | Follow up Complete Y/N | F/U Action, due date | Reputational Risk Ctte. Minutes Written |
+| 1 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 14 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 15 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 16 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 17 |  |  |  |  |  |  |  |  |  |  |  |  |
+| 18 |  |  |  |  |  |  |  |  |  |  |  |  |

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812946/EFTA02812946.receipt.json

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marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812986/EFTA02812986.md

@@ -0,0 +1 @@
+## EXHIBIT 94 FILED UNDER SEAL

marker2-fixhub/court-usvi-v-jpmorgan/EFTA02812986/EFTA02812986.receipt.json

@@ -0,0 +1,14 @@
+{
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+}